HomeMy WebLinkAboutSt. Lawrence College's Book of Authorities (Probationary Status)
IN THE MATTER OF the Colleges Collective Bargaining Act,
R.S.O. 1990, c. (,15;
AND IN THE MATTER OFa grievance filed by Keith Guitard,
dated June 6, 2007
BETWEEN:
ONTARIO PUBLIC SERVICE EMPLOYEES' UNION
("the Un ion")
- and -
ST. LAWRENCE COLLEGE OF APPLIED ARTS AND TECHNOLOGY.
("the College")
COLLEGE'S BOOK OF AUTHORITIES
(PROBATIONARY STATUS)
Tab Case Name
1. The Civil Service Association of Ontario (Inc.) v. The Ontario Council of Regents for
Colleges of Applied Arts and Technology (18 June 1975, ant. Div. (t.)
2. Ontario Council of Regents Colleges of Applied Arts and Technology and Civil Service
Association of Ontario Inc.) Re (1976),13 LAC. (2d) (Weatherill)
.
3. The Civil Service Association of Ontario (lnc.)v. The Ontario Council of Regents for
Colleges of Applied Arts and Technology, No. 414/76 (7 March 1977, ant. Div. (t.)
4. The Ontario Council of Regents for Colleges of Applied Arts and Technology (St. Clair
College) and The Ontario Public Service Employees Union (Minto), Re (20 February
1979,Brandt)
5. The Ontario Council of Regents for Colleges of Applied Arts and Technology
(Fanshawe College) and Ontario Public Service Employees Union (Safran), Re (21
February 1981, Rayner)
6. Durham College of Applied Arts ~nd Technology and Ontario Public Service
Employees' Union (Mcintyre), Re (6 December 1982, Weatherill)
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Tab Case Name
7. Sheridan College of Applied Arts and Technology and Ontario Public Service
Employees Union (Brackenridge), Re (8 May 1985, Brunner)
8. Seneca College and Ontario Public Service Employees Union (Roy), Re (10 February
1988, Samuels)
9. Loyalist College of Applied Arts and Technology and Ontario Public Service
Employees Union (Chapman), Re (6 September 1988, H. Brown)
10. Fanshawe College and Ontario Public Service Employees' Union (Robson), Re (9
September 1988, P. Picher)
11. St. Lawrence College and Ontario Public Service Employees' Union (Abel), Re (19
January 1989, Swan)
12. St. Clair College and Ontario Public Employees' Union (Chesterton), Re (17 June 1996,
Swan)
13. Algonquin College and OPSEU (Mullins), Re (28 June 1998)
14. Rizzo & Rizzo Shoes Ltd. (Re) [1988] 1 s.C.R. 27
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G?c.,LO
IN THE SUPREME COURT OF ONTARIO
DIVISIONAL COURT
ZUBER, MORDEN and REID, JJ.
AND IN.THE MATTER of The
Judicial Review Procedure Act,
Statutes of Ontario, 1971
20 Elizabeth II, Chapter 48
BET WEE N:
THE CIVIL SERVICE ASSOCIATION
OF ONTARIO (INC.)
Applicant
- an d -
THE ONTARIO COUNCIL OF REGENTS
FOR COLLEGES OF APPLIED ARTS
AND TECHNOLOGY
Respondent
- and -
E.A. BLACK, T.H. TRIMBLE, and
D. HOMUTH
Arbitrators
ZUBER, .J. (Orally)
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) . Heard:
C. G.Paliare
for the Applicant
C. G. Ri~gs
for the espondent
June 6th, 1975
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of Orifarfo~(Inc:)-:"fo~r'-:fudicial review of an award by the
Public Service Grievance Board pursuant to a memorandum of
understanding between The Ontario Council of Regents for
Colleges ,of Applied Arts and Technology and the applicant.
The facts, in general terms, upon which this application
is based are as follows. Mr. Aitchison on August 14, 1972
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was taken on the staff of Fanshawe College at London as
a Master on a probationary basis. On May 24, 1974, Mr.
Aitchison was informed by Fanshawe College that he was to
be released. . He was told in the letter from Fanshawe that
his active duties at the College would cease on June 28th
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but that he would be paid until August 31st of that year.
Payment was based on the fact that Mr. Aitchison had earned
and was entitled to his vacation period which extended until
that time. This is to be distinguished from severance pay
or just a plain money allowance at this time.
In the memorandum of understanding between the Council
of Regents and the Civil Service Association, there are two
terms that are relevant. The first is 8.01 which reads as
follows:
"8.01 An employee will be on probation
until he has completed the probationary
period which shall be of two years duration,
it being understood that a further period
of probation of up to one year may be
established by mutual agreement. During
the probationary period, the employee will
.'.': be 'informed ,of ;his.;;progress. at.'. approximately
-., - six' month'" interval's. .:- Also; , it; is understood
.:;~:~thaffan~eiiip'loyee~may_ be. released during
. . the"first five months following the
commencement date of his employment upon
at least one (1) month's written notice
and during the remainder of his probationary
period upon at least three (3) months
written notice."
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And 8.02 reads:
"8.02 It being understood that the release
of an employee during the probationary period
shall not be the subject of a grievance
under the Grievance Procedure, an employee
who has completed his probationary period
and is discharged for cause may lodge a
grievance in the manner and to the extent
provided in the Grievance Procedure."
On September 9, 1974 Mr. Aitchison launched a grievance
which proceeded to the arbitration board. At the commencement.
of the arbitration process, the Board of Regents took issue
with the jurisdiction of the Board taking the position that
Mr. Aitchison was a probationary employee and pursuant to
section 8.02 the grievance was non-arbitrable.
In our view, the issue as to whether or not Mr. Aitchison
was, in fact, a probationary employee was a preliminary issue
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and was critical to the jurisdiction of the Board to deal with
the matter. In view of the fact that it was a jurisdictional
.'..;~~~~~;:,~~_~~ry~i~::t~~~~;~~~i~~l:~is~~~~~:~n .t.o. deter~:~~ .-
n._. ..,.. ~'" whethe~~or."'.o - e~B~~t?:':~}f~~;ri.g~.t5.or;~n~t,:-_in its' conclusi~n.
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that Mr. Aitchison was a probationary employee and not simply
to determine whether or not they placed upon the term an
interpretation which it might reasonably bear.
Tur~ing to the issue then of whether or not Mr. Aitchison
was a probationary employee, the sequence of dates makes it
obvious that he was notified of his release within the two
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year probationary period and it is further obvious that
the termination date of August 31st fell outside the two
year period. The somewhat narrow and crucial point therefore
to be determined in this matter is simply the meaning of
the term "release" as it is used in sections 8.01 and 8.02
of the agreement.
The position of the Council of Regents is that simple
notification that one will be released or that one's services
will come to an end at a future time is sufficient to constitute
release. The position of the Civil Service Association
the issue in this case is correspondingly determined.
In our view, the term "release" must mean the total
cessation of the"-'relationship. of employer. and - empl-oye-e
and this cessation of the relationship in this case must
occur before the expiration of the two year period. The
....mer.~c?;~_~__~i:~~~t~~l?~~~~,:.
- fut'u.re :~'dt~C"not~Jf,ci tsel f,7ter~e '~ihe'~ietafionship.. . . ,.
In adopting this view, we recognize the fact that this
interpretation of the term "release" will have the effect
of shortening the probationary period to 21 months as it
will then be incumbent upon an employer in circumstances
like this to give the three months' notice at a time sufficiently
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......
distant from the expiration of the probationary period
to allow the three months to run within the two. year period.
I should add as well that, in our view, this interpretation
of the agreement is not only the proper one, but also the
only interpretation that the language of this agreement
could reasonably bear.
This application will, therefore, be allowed. The
order of the Board will be quashed and the matter remitted
to it for further consideration. Costs will be to the
applicants to be taxed.
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ILLs
Released: June 18th, 1975
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IN THE MATTER OF AN ARBITRATION
BETWEEN:
THE ONTARIO COUNCIL OF REGENTS OF
COLLEGES OF APPLIED ARTS AND TECHNOLOGY
AND
THE CIVIL SERVICE ASSOCIATION OF ONTARIO
(INC. )
AND IN THE MATTER OF THE GRIEVANCE OF R. GROT SKY
BOARD OF ARBITRATION:
J.F.W. Weatherill, Chairman
J.K.A. Hayes, Union Nominee
~. Wright, Employer Nominee
A hearing was held in this matter at Toronto on June 25,
1976.
G.A. Richards, for the union
E.T. McDermott, for the employer
AWARD
In this grievance, dated April 22, 19?6, the
grievor protc~ts her dismissal from the teaching staff of
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Seneca College. The college has raised, in timely
fashion, the preliminary objection that the grievance is
....
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not arbitrable, the ground of objection being that the
grievor was dismissed during her probationary period..
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This award deals only with the preliminary objection.
The grievor served as a "sessional" employee
...
(and as such was not a member of the bargaining unit) from
April 29, 1974 until April 29, 1975, when she was hired
as a full-time employee. She became, pursuant to article
....
8.01 (a) of the collective agreement, a probationary employee.
The period of probation there provided for is of two
years' duration. The grievor was, it seeIns, given credit for
her service as a sessional employee, so that her probationary
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period was considered as expiring on.Apri1 29, 1976.
On April 14 I., 1976 r' the grievor was notified
thather~ services with: the College were terminated as of
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that date. The evidence of the Dean was.to the effect
thatr.apparent1y because of certairi matters that bad occurred
since.January, 1976, that the grievor "did not meet the
standards the College required" in a teaching ma~ter.
No notice of termination was given, although the College did
tender payment of three months' salary, apparently in
lieu of notice.
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Article 8.01 (a) of the collective agreement
is as follows:
8.01 (a)
An employee will be on probation until
he has completed the probationary period
which shall be of two years' duration.
During the probationary period the employee
will be informed o~ his progress at six-
month intervals. Also, it is understood
that an employee may be released during the
first five months following the commence-
ment date of his employment upon at least
thirty (30) calendar days' written notice
,and during the remainder of his probationary
period upon at least ninety (90) calendar
days' written notice.
The grievor was, ~e think, "released" within
the meaning of article 8.01 (a). She was released during
"the remainder" of the probationary period, that is after
the first five months but before its expiry. It was open
to the employer to release the grievor during that time,
upon ninety days' written notice. As we have stated, no
such notice preceded the grievor's release during her
, .
probationary period. Whether-the failure to .give such
.notice constituted a violation of the collective agreement
is not, strictly speaking, in issue before us. As has
been noted, a payment said to be in lieu of notice was
tendered.
~.
The term "release", as employed in an earlier
memorandum of understanding between the parties, was said
by the Divisional Court, in an application for judicial
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review of an award by the Public Service Crievance Board
'-
made in the case of one Aitchison (June 6, 1975), a teaching
master at Fanshawe College, to mean "the total cessation of
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the relationship of employer and employee --- before the
....
expiration of the two year period". In that case an
employee had been g~ven three months' notice of termination
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or release, the notice being given during the two-year
period, but the termination being effective after the two-year
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period had expired. The question of the Board's jurisdiction
turned on the question whether t'he grievor had been
"releasedll during his probationary period. Since the grievor
in that case remained in the employ of the College until
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a date after the expiry of the two-year period, his
employment was not in fact terminated within that period, and
the .Court, relying on the. defini~ion of the.' ~1~ ,~,".release"
. . ,
which. we have quoted, .quashed the Board's award ~"which
. had been based.on.a.findin<;r tha.t. the..grievor nhad not achieved
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permanent status when his release. took effect".
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In our view; weare bound to apply the
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definition of the term "releasell enunciated by the Court.
In the.Aitchison case it is clear that on that definition
(with which, with respect, we would agree), the grievor
was not "releasedll until after the expiry of his probationary
)
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period. In the instant case, on the other hand, the
employer took those steps generally associated with the
"total cessation of the relationship of employer and
employee", and it took those steps before the two-year.
period had expired. 'In the instant case the employer
purported to, and took appropriate steps to "release" the
grievor, that is to terminate the employment relationship.
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during the probationary period. That is something which the
collective agreement contemplates the employer may do.
Under article 8.01 (a), however, such release may be effected
on notice. The question which arises in the instant case
is whether or not, since there was no such notice, the
release or termination must be said to be a nullity.
1
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If the release was' indeed e~fective and not
.a nullity, then it is clear that this board has no
jurisdiction to proceed further. Articles 8.02 (a) and
9.06 leave no room for doubt on that score:..
'8.02.(a)
It being understood that the release of
an employee during the probationary period
shall not be the subject of a grievance
under the Grievance Procedure, an employee
who has completed his probationary period
and is discharged for cause may lodge a
grievance in the manner and to the extent
provided in the Grievance Procedure.
9.06 Dismissal
It being understood that the dismissal of an
employee during the probationary period shall
not be the sUbject of a grievance, an employee
who has completed his probationary period
may lodge a grievance in the manner set out
in sections 9.07 and 9.08.
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lri the instant case, we think it is clear that
what the employer sought to do was to "release" the
......
grievor, pursuant to article 8.02 (a). Certainly it may
be said to have "dismissed" her within the meaning of
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article 9.06. The two terms are not quite synonymous:
"dismissal" has, we think, a somewhat broader connotation,
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reference to a termination of employment during a
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probationary period, we think there is no substantial
significance in the difference of terminology as between
article 8.02 (a) and article 9.06. The ~stance__o~ ~~~
~greement is clear: ~~re the employer terminates_~~e
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employment. of an employee during )}L~J:Ob~t-; ona.r.~. ~:){~ri.odL .
that te.rmination 'tshalr not be the subject of a grievance,lI.
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It is not for this board.to consider the wisdom or otherwise
. ....
of the employer.rs. actr- nor,. to conclude .that the. employer
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may have had ample opportunity to assess the employee
even e ore the expiry of the period. Our jurisdiction
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in the matter turns en our finding whether or not the
griever was. IIreleased" or "dismissedll during.her
probationary period. Ne make this determination in the
exercise of our jurisdicti-.9i1 to determine "whether the
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,
matter is arbi t-r;::,~le!'. -pursuant to article 9.04 (a)
of the collective agreement._
In the Aitchison case the Divisional Court,
having defined the term "release" and having found (as is
implicit in the decision) tha~ \~e grievor was no longer
an employee at the time of, his actual termination, quashed
the award of the Board and remitted the case for fu~ther
consideration. In its reasons, the Court stated (and
again, with respect, ~e would agree), that "The mere
notification that such termination will occur in the future
does not of itself terminate the relatirinship." In. the
instant case, of course, the grievor was advised of an
immediate termination of emplo~~nt. In the Aitchison
case, however, the -Court went on to make the follo\'ling
statement:
In adopting this view; we recognize the fact that
this_ interpretation of the term "release" will
have the effect of shortening the probationary
period to 21 months as it will then be incumbent
upon an employer in circumstances like this to
give the three months' notice at a time sufficiently
distant from the expiration of the proba-tionary
period to allow the three months to run within the
. two year period. I should add as well that, in
our view, this interpretation of the agreement is
not only the proper one, but also the only inter-
pretation that the language of this agreement could
reasonably bear. .
With respect, these appear to us to be,
strictly speaking, obiter dicta.
While we consider ourselves
bound to apply the Court's definition of the term "release",
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which would in any event be our own, we do not consider
that it is within our jurisdictio~ to ~~t to r~~~ "-
,the ~robationary ~~d_~ll:L'<!l_~jir.~ i_p~L-b..ve-set- 0_. (;l)
in express terms in article B.Ol (a). Our jurisdiction
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in this respect is limited in any event by the general
law, and is expressly limited by article 9.04 (d)'ofthe
~
collective agreement, which is as follows:
9.04 (d)
The arbitration board shall not be authorized ~
to alter, modify or amend any part of the
terms of this Agreement nor to make any
decision inconsistent therewith not to deal
with any matter that is not a proper matter
for grievance under this agreement.
c...
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collective agreement provides that the employer may release )
In our view, where article B.01 (a) of the
a probationary employee upon notice, it does not make
the giving of such notice a necessary condition precedent
~
to, the release. Failure to give such notice would be a.
violation of the agreement for which an appropriate remedy
'-
{such as. payment inl~eu of notice} could be gra.?ted., It
. .
is our view,_ however,-. that it would. take'. express language
.-
in the collective agreement to establish the giving of
notice as a necessary condition prprpAQP~ ~n th~ release of
~
probationary employees, and to effectively alter the express-
"--"~"
provision of the agreement;.. th~!,_,_!:~~~ob~j:,ioEa~period
. . _......~.
"shall be of..j;Jj..Q~r::-?' d\lrationu. Such language does not
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appear in this collective agreement.
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For these reasons, we conclude that the
College did indeed release or dismiss the grievor during
her probationary period. It is clear from articles 8.02 (a)
and 9.06 that such release or dismissal shall not be the
subject of a grievance. The instant case, therefore,
is not arbitrable under this collective agreement. The
grievance is accordingly dismissed.
DATED at Tqronto, thi s 3 0 ~ day of July,
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C airman . .
union Nominee
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Employer Nominee
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NO, 414/76
, III I
373
G sn( g.
IN THE SUPREME COURT OF ONTARIO
DIVISIONAL COURT
GALLIGAN, SOUTHEY AND MALONEY, JJ.
IN THE ~~TTER OF The Judicial
Review Procedure Act, S.O.1971,
c.48,
AND IN THE ~~TTER OF An Arbitration
Award Dated July 30, 1976,
~ I
BET \'l E E N:
THE CIVIL SERVICE ASSOCIATION OF
ONTARIO CINC.),
Applicant
- and -
'-..-/
THE ONTARIO COUNCIL OF REGENTS FOR
COLLEGES OF APPLIED ARTS AND
TECHNOLOGY,
Respondent
- and -
J.F.W. WEATHERILL, J.K.A. HAYES
and W. WRIGHT,
Arbitrators.
GALLIGAN, J.: (Orally)
)
)
)
)
)
)
)
)
)
) C. G. PALIARE,
) for the applicant
)
) E. T. NcDERNOTT A},'D
) J. R. HASSELL,
) for the respondent
)
)
)
)
)
}
)
}
)
)
)
) Heard: February 28 and
) March 1, 1977.
This is an application for judicial review
brought by the applicant, seeking an order quashing the
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award of the majority of the Board of Arbitration on
July 30, 1976.
The application arises out of a grievance
presented by Rose Grotsky with respect to the termination
of her employment with Seneca College of Applied Arts
and Technology. in Toronto. It is common ground that
Ms. Grotsky was employed by Seneca College, commencing
the first day of May, 1974. It is also common ground
that on April 14, 1976, she received a letter from her
employer, which states as follows:-
, j
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" In confirmation of our conversation of
today's date, this is to notify you that
I am unable to recommend extension of your
faculty appointment beyond the probationary
period, and that your services with Seneca
College are terminated as of now.
~-./
You are advised to contact Personnel
Services, Finch Campus, regarding final
salary and benefits to which you are
entitled."
On April 22, 1976, Ms.. Grotsky filed the
following grievance:-
" I grieve that I was dismissed improperly
and without just cause in that I was a) denied
evaluations and b) denied 90 days notice of
termination.
Settlement Desired:
I request reinstatement to my former
position without loss of pay and other
benefits."
l.O-_-<i
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The parties to this application are bound by
~, ~.
a memorandum of agreement extending from September 1, 1975
'-
to August 31, 1976.
It was strongly contended on behalf
'--
of the respondent that because of the privative section
contained in s.85 of The Colleges Collective Bargaining
Act, 1975, our jurisdiction to review the award was very
narrowly prescribed .to matters of strict jurisdiction.
We have come to the conclusion that it is not
r -:
necessary to decide the extent of the restrictions imposed by
s.85 in this case because weare of the view that even if we
have jurisdiction to review the decision of the Board broadlj,
the decision of the majority was one which is reasonable and
one which can amply be supported reasonably upon the wordin;:;
of the agreement.
The decision of the majority of the Board was that the
grievor was not entitled to the benefit of the grievance procedure
under the agreement because the termination of her employment
took place during the probationary period of two years following
the commencement of her employment:
The applicant strongly suggested that we
were bound by the decision of this court in a case which
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is called the Aitchison case, the correct style of cause
of which is The Civil Service Association of Ontario v.
The Ontario Council of Regents for Colleges of Applied
Arts and Technology, which decision was given by this
court on June 5, 1975, and apparently is not yet reported.
I do not think that it is necessary to review
the Aitchison case in detail, because in our opinion it
is distinguishable on its facts. In this case, th~ total
cessation of the relationship of employer and employee
did in f~ct occur prior to April 30, 1976, that is, it
did occur ....-ithin the probationary period. In the Aitchison
case the court held that the employee was not a probationary
employee at the time of termination.of employment by the
employer. In this case, on its facts, this grievor was
still clearly within the probationary period at the time
the termination occurred.
Article 9.06 contains among other provisions
the following words:-
" the dismissal of an employee during the
probationary period shall not be the subject
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01 a grlevance,.... .
While ....-e have been presented with an attractive argument to
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the contrary, it seems that the Board was acting reasonably
when it concluded that the grievance of this grievor was
not arbitrable under the terms of the contract.
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It is our opinion, therefore, that the Board
was acting within its jurisdiction when it determined that
the particular subject of grievance was not arbitrable and
it appears to us that that decision was one that could
reasonably be arrived at having regard to the provisions
of the collective agreement as a whole.
Accordingly, this application must be dismissed,
with costs,
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Dated: March 7 , 1977.
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'-':;-hi;iffE'~~TTER .OF AN,. ABITRATION
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THE :ONTARIO :COUNCIL OF REGEiHS FOR.
. 'COLLEGES OF'APPLIED.ARTS AND TECHNOLOGY
(St. Clair College)
{,,-. ,
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-THE ONTARIO PUBLIC SERVJCE EHPLOYEES UNION
'Grievalice'.of G~L~ Nfn:to
G.J. Brandt. Chairman
J.H. McGivney. Q.C.. College Nom;nee
C. Trm'/er. Union Nomi nee .
C.F. Murray_ Counsel
John Payne. Oi rector of Personnel.
, J ~ . -Oucha rme. Cha i rman . of Automoti ve
Richard Nab;. Grievance Officer
George L.- Minto. Grievor
;~~Th~-:::h'~aring was heJd in;,London. Ontario on December 14. 1978.
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.'^'\~ARD
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In thi s case the gri evor. Mr. George Hi nto tin t\'l;ch,$!para te' .
grievances, alleges that his E~ployer, St. Clair College~ has violated
the collective agreement in that it failed to giVe;~im'~'pro-;~notice
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of his release from employment and that it failed,;,ui.';9~~~.a
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vacation to \'1hich he is entitled. .t ,tf.,j',IoL..\.l'l
At the hearing into the matter the parties.a~~d.r.that.
save in r~spect of certain of the r€lief r~quested"~by~,~:~r, the
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Board \'/as seised of ~n arbitrable grievance. ~~'~:~.ri"
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The issue in this case concerns the status antf:::I'!.ig-ht"5 of persons
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hired under individual contracts of employment as sessiona~~pl~yees.. "More
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particularly the grievance protesting improper not1ce concer,ns. the extent
of the rights, if any, of a sessional employee to d~anp.",J).ot.iipe of rei'~as~"\~-<-"
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from employment and, assuming such a right .to ex~st an9!;'~Qj;1Lwr~ peen
violated, .the extent of the relief \'1hich may beaffQrde.t~er~Y. .The
grievance respecting the failure to give a vacation,~o."~~t1"e; extent
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to \'lhich sessional employees enjoy .the .same rights"':~S;:I~i';~ees to
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vacation entitlement.
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There is no serious' dispute as to the factS:,.,;..Aso'~~.r;esu)t of.
the loss of a pennanent faculty member on assig~ent for,:a'yea.r and as
a resul t of an undertaking between the Coll ege and. th~:l>.~cial
Government to run a 40 week pilot program in motor ven':J'Cle~;mechanics
it became necessary for the Call ege to e~gage so~eone"w'j~li.:tbe proper
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qual ifications to assist in the carrying out of 'the. progra~. Consequently " ~.
on August 13, 1976, the grievor \'las, by a letterfr~~ ~1.H. Geraedts, the
Dean of the School of Technical Arts and Tr~des, offered a position in the
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Automotive Department-bf the SctlOol of Techni ca 1 Arts and Trades. By letter
dated August 17th, 1976 the grievor accepted this offer of a position. The
offer and the terms of the contract of employment are set out in the letter
of~Aogust 13th which recites as follows:
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"D,ear ~1.r. Mi nto:
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. St. Clair COllege .is pleased to offer you'a sessional
, ." t-!achitig'posi tion in the Automotive Department of the School
of Technical Arts and Trades for the period August 30, 1976
to. June 30, 1977..
,~.:," mt~b~.V0'YoiJ\1ill be required to teach 21 hours per \'/eek for a
' ,'w;eek1y..sa1ary of $322, \'/hich includes a vacation pay allo\'/ance.
...,:~~.~~ft('\'11," also be entitled to some of the fringe benefits the
.,Coll ege offers. These incl ude medi ca 1 coverage, sick 1 eave
~redits, and life insurance. We also require a statement
frQm ,You~ physician that you are in good health.
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If there is a shortfall in enrollment which results in
' ".""'':fOuir.s.erv ices no long er be i ng requ ired, your emp 1 oymen t may
be terminated on two \'leeksI' notice or pay in lieu thereof."
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":,/,On'Jurie 30,1977 the pilot p~ogram vias completed and the grievor's contrac'
of-employinent expired on June 30, 1977 the term fixed in the contract for
explrf~t:,f)tiH,ngthe summer of 1977 negotiations to run a second pil ot
p'r<>gram:Were concl uded and, th~ gri evor was asked if he \'/oul d .1 i ke to come
.::"baokt;.'J'lJ~'i-ndicated that he would and, as a r,esult, a letter dated
, Ju.ly.'.7, 1977 \'/aS sent to him, ,again by Dean Geraedts. That letter
recrtes"as: fo 11 OvlS :
~ :.........~1\. ~F~..-.. : ."
. '<'~1Jear:'f.1r. "linto:
, ~;. :iSt. Clair College is pleased to offer you an extension
of your employment in the Automotive Department of the School
of'T~chnical Arts and Trades. This extension is for the
. ~e~iod August 8, 1977 to April 1, 1978.
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You will ,be required to teach twenty-one hours per week
and you will receive a weekly salary of $348. This rate of
pay includes a vacation pay allo\'lance. Effective October l~
1977 you will have completed on year of the two-year. probation-
aryperiod as outlined in the faculty contract. As a result.
your status will change from sessional to. probationary and 0
you will be required to pay union dues.. You \Olill be eligible
for life insurance, medical coverage and sick leave credits.
If there is a shortfall-in enrollment, or if for any
other reason the College determines that your services are
no longer required, you will be given two weeks' notice or
the equivalent pay in lieu of notice. .
If the above offer is acceptable to you, please sign
belO\'1 and return thi s' 1 etter to my offi ce ''Ii thi n seven days .1.0
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On July 13. '1977 the gri.evor signed the document indi cati ng that he accepted
the terms and conditions of this employment' offer in their entirety.
Although the term of this contract of employment was stated'
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to expire on April 1st, 1978 Mr. Ducharme, the Chairman of the Automotive
Depar~ent in which :the grievor was employed, spoke to him about the
end of March and asked hlm if he would be interested in staying on
through to the end of June. T~e grievor and Mr. Ducharme came ~oa
verbal agreement that his employment \'Iould continue and. on April 4th,
1978 the grievor received a letter from Dean Geraedts stating that
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St. Clair was "pleased to offer you an extension of your present
. employment from April ls.t, 1978 to Jun~ 23rd. 197811 and stating
that "all other terms and condi.tions remain as outlined in your letter.
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of [July 7, 1977]". Thegrievor did not sign any document indicating
his acceptance of this offer although he did continue on, in employment
until June 23~ 1978.
No offer of employment was made to the grievor for the
academic year 1978-79 and his employment relationship with the College
was cffectivelv severed as of June 23~ 1978~.
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It is the position of the Union that . under the provisions
of the collective agreement (to beset out belm'/) the grievor \'laS
entitled to receive 90 days written notice of his release from employment
and that, having not received such notice, certain remedies flow therefrom. .
The College does not deny that, apart from the contract of employment
i tsel f (as set out in the 1 etter of July 7, 1977, as extended by the 1 etter
of April 4, 1978) which contract specifies its own fixed date of
termi~ation, no other written document notifyin~ the grievor of hi~
release from B~ployment was sent. As far as the matter of vacation
entitlement is concerned it is admitted that the grievor \'/as not given
a vacation follO\'l1ng the completion of the services he provided
over the 1977-78 year. However, it is contended that, notwithstanding
that fact, the College has in any event met its obligations to ~he
grievor in respect of the payment of the vacation pay allowance.
We propose now to consider the arguments with respect to
each of these separate,grievances.
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1. Failure to Provide Adequate Notice of Release
.The provi sions of .the coll ective agreBllent .\'lhich are rel evant
to this claim are Appendix III, Sections lea) and l(c) and Articles 8.01 (a),
(c) and Article 8.02(a). These Articles recite as follows:
"Appendix III
l.{a) A sessional employee is defined as a full-time
employee appointed on a sessional basis for up to twelve
(12) full ~onths of continuous or non-continuous
accumulated employment in a twenty-four (24) calendar
month period. Such sessional employee may be released
. upon two (2) weeks' written notice and shall resign
by giving 1\010 (2) \'leek's \'/ritten notice.
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1. (c) If a sessional employee is continued in
employment for more than the period set out in
paragraph (a) above. he shall be considered as
having completed the first year of his two (2)
year probationary period and thereafter covered
'by the other provision of the Agreement. The balance
of such an employee's probationary period shall be .
twelve (12) full months of continous or nonccontinuous
accumulated employment during the immediately follo\'1-
ing b/entY-four .(24) calendar month period.. .
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a.Ol(a) A full-time employee will be on probation.
until he has completed the probationary period which shall
be two years' cOlltinous employment.
8.01 (c) During the probationary period an employee
will be informed in writing of his progress at intervals
. of six '(6) months continous employment or s,ix (6) full
months. of accumulated non-continuous employment and a
copy given to him. Also, it is understood that an .
employee may be released during the first five (5)
months of continuous or non-continuous accumulated.
employment following the commencement dateofh,is
employment upon at least thirty (30) calendar days'
written notice and during the remainder of his
prObationary period upon at least ninety (90)
calendary days' \'1ritten notice.1I
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The argument of the Union is that, commencing OctOber 1. 1977. the
grievor had continued his employmeni for more 'ihan the twelve month period
which is prescribed under Appendix 'Il!. 1. (a) as defining a sessional,
employee and that. by reason of Appendix 'Il!, 1 :(c) he then became..a
probationary empioyee'entitledto certain, rights under the collective
agreement one of which is the right to receive notice of release as
per Article a.Ol(c). In the Union's submission. this effect is
confirmed in ~he 1 etter from Oean Geraedts to the grievor. dated
July 7, 1977, ',hich states that "effective October 1. 1977 ... YOUr
status wi] 1 change from sessional to probationary,....: Having thus
established the right of the grievor to claim the protection of
Article 8.01 (c) the Union then submits that j'n the circumstances of
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thi s case that Articl e.-was not cOinpl i ed wi the In that regard "it submitted
that neither the letter of July 7. 1977 nor the letter of April.4. 1978
can be treated as constituting written notice of release' from employment.
In respect of each of these it was submitted that. although tney did
expressly refer 'to the. termination date of the contract of appointment.
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they,did not provide sufficient explicit notice of release such as
. to satisfy Article 8.01 (c). Rather it 'lIas suggested that in essence
what they were was an exteosion of employment and not a notice of' "
release from e~ployment. In any event. with respect to the letter of
April 4. 1978. if that \'Iere to be treated as the \'/ritten notice it
was not given within 90 days of the date of release~
Finally. .it was submitted that since the notice was deficient
.it coul d not be treated as notice and that consequent]y' the. gri evor .
still "remained in the employment of the College entitled to all ,the
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benefits which would flow from his status as such. In the alternative
it was. submitted that. at the very least. he is ent~tled to be given
"money compensation in the amount of 90 days pay for the defective
noti ce.
The College advanced a number of alternative arguments. First.
it was argued that a sessional ~~ployee on a fixed. term contract need
not be given any notice where the contract comes to its natural conclusion
upon the expiry of the fixed term stated therein. Secondly. it was
argued that. if written notice is required. then the appropriate. provision
governing the giving of that notice is as contained in Appendix III, l.(a)
rather than Article 8.0l(c}. Thirdly. it was argued that. if Article 8.01 (c)
governs then the College has. in any event. complied \.tith the notice
requirements. Finally, it 'lIas a,'gued that to the extent that the Union here
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was seeking reinstatement of the grievor to the status of an employee.
the grievance.was not arbitrable by reason of Article a.02(a).
It is appropriate to set out in detail the substance of
. each of these arguments. The first argument is that irrespective of.
whether or not'Appendix III, l.(a) or Ar~icle a.Ol(c) applies in
neither event is there any obligation to give notice where the'release _
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of an employee on a f.ixed term contra~t comes about by reason of the.
natural' e~piry of the term' of that contract. The kind of contract
under which the. grievor was employed was dis~inguished from the
sort of contractual relationship which obtains between regular"
full-time employees and the College. In the latter instance there
fs no fixed term to the period of the ~mployment w,hich is indefinite
in the duration and,therefore, in order to "bring about an end to
the employment, the College is required to give adequate \'larning
of its intention in the form of ,."ritten notice. However,it ,."as
submitted that.;n the situation of a fixed term contract, such. as
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obta,ined here. it is known, from the beginn~ng \-/hen the contract
of employment will come to ,an end and that as such there is no
necesslty for giving any \-larning where the College does not intend
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to termi.nate that employment prior to the expiry 'of, 'the ,period of
stated in the contract. Instead, the only time that th~ College
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needs to:~rovide notice is where it proposes to bring about,what
Ccun~el for the Cbllege described as the "extraordinary, u~natural,
or p'rernature" termination of the relationship. Thus, in the 'circumstances
of this case, since'"the Employer did not bring about a ,premature end
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to the f"ixed term contract,. there \~laS no need to give notice. In
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this connection the Board \'las referred to principles of the common
lah' of contract under which notice is not required to bring about
the natural end of a contract for a fixed tenm.
The first alternative submission of the College \'las that.
in the event that notice is required>> the particular period of notice is
that prescribed by Appendix III. l.(a) rather than Article S.Ol(c). '
In that regard the College submitted that. af.ter October 1.1977 at \'lhich.
point the grievor was convnencing his thirteenth month. of employment. his.
status did not change from that of sessional employee to pr~bationary
'employee but that instead he remained as a sessionalem"ploye:e entering
the second year of his probationary period. In short he,\'las, from that
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point on, a probationary sessional employee. It was further argued
that, since he remained a sessional employee, his rights fell to be
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determined under Appendix III. l.(a) according to \'/hich he could be
released upon two weeks' written notice.
The basis for the College's submissions in this regard rests
on the concluding sentence of Appendix III, l.(c). It was submitted
that the principal effect of the continuation in ~~p1oyment past the'
twelve month period as prescribed in Appendix III, l.(a) is, not
to convert the employee from a sessional employee to a probationary
employee, but merely to treat his first year of employment as the
first year of his probationary period as a sessional employee. It
was argued that this is confirmed by the concluding sentence of
Appendix III, 1. (c) which merely soes on to indicate the manner by
\'/hich "such an employee", that is, a sessional employee, may qualify
as having served his probationary period. Thus, according to this
submission) the grievor's continuation in employment past the, twelve
mont~ per'iod had no effect other than to permit him to claim that
. .
he had served the first year of his probationary period. The only
significance then of the October 1. 1977 date is that it would mark
the ~omm~ncement of the second twenty-four month calendar period
during which he must complete his remaining twelve full months of
continuous or . non-continuous accumulated employment.
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:On the assumption that. at the time of his release. the
grievor remained a sessional employee. the College submits that.
having sen~ him the letter of April 4. 1978 in which his employment
extended to June 23. 1978) it had given him two weeks' written notice
of his release.
The second alternati,ve submission of the College \'las that)
in the event that the Board should conclude .tn~t the grievo~ wa~
entitled to notice under' the provision of Article 8.0l(c). the
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College had nevertheless complied with that requirement. 'It argued
that his employment during the 1977-78 academic year should not
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~le deal now \'lith the various argLiments raised in respect
of the issue.as to the adequacy of the notice given to the grievor.
It is appropriate to deal first with that argument of the.College
which states that, whether or not one is guided by Appendix III
or by Article 8.0l(c), in either event there is no obligation to
give notice where a fixed term contract is permitted to expire
'by passage of time and is not brought to a IJpremature or unnatural"
end. Hhatever the position may be at common la\" ,-lith respect to
individual contracts of employment the parties to this collective
agreement have specifically made -provision for termination of
contracts of employment, for both sessional employees and full-time
employees on probation. These provisi'ons for te.rminationare
contained in.Appendix III, 1.(a) and Article 8.alec) respecti~ely.
In neither case does the language suggest that the ~otice requirements
according to which release may be effective only apply in the
circumstances of an unnatural end to the contract. As the Board
derives its jurisdiction from the collective agreement it mus~
limit its consideration of the rights and obligations of the.parties
to those provisions set down in .the agreement itself. . He therefore
reject the argument that would introduce, by implication from the
common law, a restriction on such rights to notice as are contained
in the collective agreement.
Thus the principal issue becomes one of determining
whether or not the grievor's rights to notice are governed by
Appendix III, 1.(a) or by Article 8.al(c). He are unable to
accept the arguments advanced by the College in connection with
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'the issue as to which of these two clauses governs the required
notice of release of the grievor. That. if 'accepted. would render,
meaningless the concluding words of the first sentence of Appendix III.
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l.(c). that is, "and 'thereafter covered by the other provisions of
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the Agreement ". Appendi x I II. 1. (c) does make provi sian. for ,ca 1 cul ati ng
the service ~y" a sessional employee of his probationary period of
employment. However. it also provides that certain rights\'liil a.ccrue
to hi'm upon the completion of the first of .his 'bio year 'period. \~e
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are unable to. see how the concluding sentence of Appendix III. J..(c),
. upon.which Counsel for the College relied. which provides only for
the calculation of the balance of the probationary period of a
sessional employee, can be taken as depriving a sessional employee
who is continued in employment beyond the period set out ,in Appendix III,
l.(a) of ~uch rights as "he may ha~e under the other provi.~ions. of the
agreement. It may be added that this construction does not r.ender
meaningless the concluding sentence of Appendix III, l.(a) which".
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remains applicable to the situation of a session employe~who has
not continued in employment past the per~.od prescribed in Appendix III.
,1 . (a) . I n the case. of such employees ,re 1 eas e may be effec ted upon
the giving of two weeks written notice.
. We therefore conclude that the grievot's rights to notic~
are to be determined by reference to Article B.Ol(c). The. issue
now becomes one as to whether or not the College has nevertheless
complied with any requirements imposed on it thereby. In that
respect it may be observed initially that the document iss~ed on
April 1, 197B wherein the grievor's employment was extended to
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June 23. 1978 cannof be treated as a third individual contract of
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employment under which his services were engaged. Unlike the other
two contracts there is nothing to indicate the grievor as having
provided written acceptance of a new offer and it consequently
should be treated as simply an extension of the original contract
entered into on July 13. 1977. What is at issue here fs whether
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'or not Article 8.bl(c) requires. in the context of a sessional
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employee on a contract with a fixed expiry date. express written
notice of re1eas~ over and above that which is. explicitly set out
in his contract of employment at the time that he is hired.
Common sense would appear to di~tate that, in the case of a
sessional employee on a fixed term contract. there is really
not the same need for notice as is the case with someone on
an indefinite contract. A sessional employee is aware of the
insecurity of his tenure from the moment of hire. and the sorts
of considerations which argue for adequate notice of release
from employment without a fixed termination date are not as
persuasive~ Notwithstanding t~ose consi~erations it is the. duty
of this Board to construe the agreement and. even though .the
agreement may require something which is unnecessary or indeed
Silly in its context. those are not reasons for refusing to '
recognize the obligation. In pur opinion Article 8.0l(c):
does requir~ specific written notice of release and we are
unable to conclude that the contracts under which the grievor
\'/as hired. \.,hich contracts admittedly contained a termination
date, can be considered as complying with a requirement that
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adequate notice of release be given. The essence of those contracts
\'/ere that they \'/ere either offers of employment or extensions.,of .
employment and can only be technically considered as also constituting
notice of rele'ase from employment. ~Je therefore conclude that the
grievor was entitled' to specific written notice of release from
employment which notice should have been provided at least 90 calendar
days in advance of.his release. There is no dispute that such obligation
was not met and accordi~gly the College has violated Article 8.0l{c)
of the collective agreement.
The issue now to be considered concerns the appropriate
relief that should be awarded in respect of this violation. In connection -
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with the matter'of reli€f the Union claimed first thats'insofar as
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the notice of release was defectives the griev~r has not yet bee~
properly terminated and continues as an employee o{the College until
such time as his rel ease is properly .brought about. Consequently s
the, argument runs, the grievor 'is ent~tled to be reinstat~d in his
employment and is entitled to receipt of all benefits denied him
~s a result of the v~olation of the agreement. The response of
the College to this claim for relief is that such a:claim is, by
reason of Article 8.02(a), not arbitrable. Article 8.02(a) provides
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"8.02(a) It being underst60d that the release of an
employee during the probationary period shall not be
the subject of a grievance under the Grievance Procedure,
an employee who has completed his probationary period
and is discharged for cause may lodge a grievance in .
the manner and to the extent provided in the Grievance
Procedure."
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The basis for the argument on behalf of the College is that, insofar
as the relief claimed by the Union is that the grievor be reinstated
it is in effect a grievance against the release of the employee .and
as such is not arbitrable. In George'Brown"Co11ege v. OPSEU (Grievance
of Godo et a1) the Soard dealt with an issue involving a grievance
by probationary employees alleging that the notice provisions of
Article 8.0l{~) had not been complied with.. The particular relief
requested in that case did not go as far as the:relief requested in
this case insofar as the Union sought merely a declaration th~t
the nqtice of termination of employment was null and void and a
direction to the Employer to serve proper notice of termination
in keeping with the collective agreement. The arbitrator dealt
with the matter of arbitrability as follows.
.:-.
-
..,
-
';
-.
II I n our vi ew, the gri evors may, purs uant to
Article 9.01, bring a grievance on the question
of whether or not proper notice has been given
under Article 8.0l{c)" TheY\"lOuld not be
entitled. under"this co11ective'agreement, to
grieve their.~r~leaSe":as such; but,the .
question whether there has been a proper
release - that is. whether the proper notice was
given-is a distinct question and one \oJhich
is, in our vi e\'l, arb; trab 1 e. Othenli se the
provisions of Article B.Ol{c) would be unenforce-
able." (Emphasis added). .,.
, .
.] 5:
.~
" '
In the alternative .~he Union claimed 90 days pay a~ the
relief.to which the grievor is entitled for the breach of the notice
provisions of the agreement. In response the College submitted that.
the 1 etter of April 1", 1978 shoul d be treated as cons ti tuti ng the.
wri tten noti ce requi red and that, since that 1 etter \'1as 'recei ved '.some
80 days prior to the date of termination, any liability of the
'College in respect of its failure to provide the full 90 days should
be limited to t~e difference between the notice required ana the
notice actually provided, that is, a period of,lO days. . For the
.reasons set out above we cannot conclude that the letter of April 1st,
1978 constituted the written notice of release contemplated by
Article 8.01(c). As indicated above that letter was in fact an offer
. to extend a' period of employment and \"as not 1n fact a notic~ .of ' .
.~.~
.....:""
. -.
c'.
y.
. \"
. :'~:.
.....
.,
, .re 1 ease from employment nobli thstandi n9 the fact tha tit did c~ntemp 1 ate
.....
. .
a fixed date .for the termination of that employment~ We therefore
conclude that the grievor is entitled to receive.90 days pay'for .
the failure of the College to provide him with adequate notice of
release as required by Article 8.0l{c) of the collective agreement.
'-.
'-
2. Failure to Grant.a.VaCation
'-
This is a claim that the grievor.was not given the benefits
to which he is allegedly entitled under Article 5.01 of the agreement.
-...-
There is no issue bet\'/een the parti es as to 't/hether or not the
grievor is a person who qualifies as one entitled to the benefits
contemplated by Article 5.01. There is however dispute as to what
16.
......
those benefits are) in respect of a sessional employee, and as to
whether or not.the College has complied with its obligations under
Article 5.01. Article 5.01 does not specifically provide for the
payment of vacation pay. All it states is that members of the
,. .
'.{.
...
teaching faculty who have completed one full academic year's service
are entitled to a vacation of two months as scheduled by the College.
However, apparently the practise of the College with respect to
its full-time members is to take their annual salary and divide it
.\
.,
by a factor of 26 and pay the result of that mathematical calculation
on a bi-weekly basis for 52 weeks of the year. Thus full-time members
}
of the faculty continue to receive the appropriate portion of their
salary during that period of time that they are off on vacation.
It is the grievor's claim that) since his contract of employment.
terminated on June 23, 1978, he was not given a vacation and moreover,
unlike full-time members of the faculty, the salary he received,Qver
the period of his employment did not include an amount in respect of
the vaca~ion to which he was allegedly,~ntitled. Specifically his
claim is that, since he did not receive the two month vacation,
he should receive, in lieu thereof, t~o months pay.
We find no support for this claim. Initially it maY,be
. observed that his contract of employment recited that he \'lOuld receive
, .
a weekly salary of $348.00 which included 'Ia vacation pay allm'/ance".
The figure of $348.00 per week was arrived at by taking the grievor's
annual salary, which was $14,975.00, and dividing it by a factor of
43 which reflected the number of weeks actually served. In this respect
the grievor was treated differently than full-time employees whose weekly
. .
~
17.
.salary \"ou1d be determined by dividing their annual salary by 52 weeks,
the full working year. The grievor apparently do~s not allege ~hat
he did not receive an annual salary which was commensurate with. his
skills and qualifications.
,
. ..
We are unable to see in what respect the grievor has been
treated any differently than a full-time employ~e for the purposes
of determining vacation pay. The 'only sense in which a full-time
employee receives a paid vacation is that he or she continues to
receive 1/52 of the annual salary throughout each week of the:.
vacation. No amount over and above the.~nnual salary is paid as
vacation pay. The grievor appears to have been treated identically.
He received an annual salary, the amount of which is not the subject.
matter of any complaint. He received that annual salary in the
form of a weekly payment which was based on the number of weeks'
which.he actually worked. In effect, this grievance if a110\oJed
would entitle the grievor to more than would be obtained by a
J!r
.~;~ '
.~ . ~
i..
\,.
':,"'
...
-
. ......
. ,
, .,
full-time employee \'/ho was being paid the same annual salary as
the grievor. Such an employee \'lOuld have. his annual salary.distribut-
ed over the full 52 week~ of the year. The grievor's claim is that
his annual s~lary may be received over the 43 week period and that, .
in addition to that, he is entitled to a further 1/6 of his annual .
salary. We are unable to see any basis in the collective agreement
for permitting a claim of tHat.kind.
. 'While it may be true that, unlike full-time members of
....
faculty, the grievor does not receive a blo month vacation in the
sense of a break from continuous employment, it'isundeniably ..
'-'
.. .
18.
--.
the case that the grievor did enjoy relief from work both during
the summer of 1977 and the summer of 1978. The only difference
,
between his situation and that of a full-time member. of faculty
was that>> at the time he \'IaS enjoying "rel i ef" from.work he did
~.t1
.....
\
~"
'\
not know whether his employment would resume in the fall. Whether
or not his employment would resume in the fall 'he did, to al! intents
and purposes>> enjoy a "vacation from work" \'ihen hi s contract c;>f
employment te.rrrrinated. ~letherefore conclude that the College has
not violated the collective agreement in having failed to. grant
the grievor a vacation. Even if we are wrong in this conclusion
it is evidently the case that, in the circumstances, to order
the College to give the grievor a vacation is not a remedy having
any practical effect. The only practical relief that the grievor
can receive is an amount of money which would reflect his vacation
entitlement and, for the reasons indicated above, we are satsified
--
...
...,
that the College has complied \'/ith its obligations, under the
collective agreement in that~respect.
For these reasons the gri evance respecti ng Vacation is.
dismissed.
DATED in London, . Ontario this 2-a day..of;;6v..i,'!-j 1979;
I x:aacuoI d i s s-en t .
"..1 .H.t>lcGivney" (dissent attached)
J.H. McGivney, College Nominee
I concur/d~g;~n~x
"c. TrO\.;er" (\d th addendum)
C. T rm'/er, Un ion Nomi nee '
/.
. - :.
..
I
Decision of Arbitration Board Me~ber J. H. McGivney, Q.C..
I wish to record my dissent with respect to the
-,
.....
. findings of the majority of the Board on the grievance
alleging improper notice of release.
....r..
Ir.-=..,'.
').
l
~
In considering this particular grievance, it is
useful to have in-mind the nature of the employment
arrangement which the College offered and which the grievor
accepted. The specific details of the employment arrangement, .
are. contained in letters dated April 17, 1976, July 7,
1977 and April 4, 1978 from the College to the gri~vor.
,
These letters establish .three distinct fixed employment
periods the ess~ntial feature of which is that the ~irst
and last' days of each of the employment periods was. fixed
and known in advance of the starting date of the employment
period.
As a result of the July 7, 1977 letter the
grievor knew that he was. to be employed by the College from
August 8, 1977 to April 1, 1978. Further, the letter dated
April 4, 1978 confirmed what the grievor had been told
before April 1 that he was to be employed from April 1,
1978 to June 23, 1978. In the grievance with which we are
concerned the grievor claims that he was given 'inadequate
notice of his release by the College with respect to his
employment which terminated on June 23, 1978.
.
===:;
2 -
"
...
, In those situations where a notice. requirement
-
arises either by practice or by agreement, "the justification
for such a requirement is founded upon human, humane and
'-
practical considerations; that the person whose status is
being affected, usually prejudicially, has the benefit of
....
bei~g forwarned of the event so that he may adjust to the.ne
....
circumstances. In the employment situation the requirement
of notice of termination exists in Common Law and in the
.....
Employment Standards Act for contracts of indefinite hiri~g
- but it has no application when the employee is employed
under a fixed term contract. The logic of the distinction.
is readily apparent from the fact that the employee covered.
by a contract for a fixed t~rm knows, in advance, ,the last
.....
day of his employment.
I turn nO\v to t.he findings of the majority . The
determination in the majority. award whi~h is particularly
trouble"some is that and I quote from page 10 ,of tl1e a\'~ard, .'
---
"the parties of the collect~ve agreement hav~ specifically
"~
made provision for termination of contracts of employment
..,...
: ~
for both sessional employees and full-time employees on
probation.
0,....-
In neither case does the language suggest" that "
the notice requirements according to which release may'be
-...-'
effective apply o~~y in the circumstances of an unnatural
end of the contract." Refer to Appendix III, 1 (a) and
Article 8.01 (e). What this means with respect to a
.
::...'-----=> .
- 3 -
-
sessional employee with less than 12 months employment,
is that the College is required to give him two-weeks
-,
written notice of release from employment in order to have
-
the employment contract terminate at the time both parties
have previously agreed that the contract would terminate.
.-'"-
.r"..
I
'11:
I submit with respect that the Arbitration Board
should endeavour to ascertain the intention of the parties,
and the words in the agreement are of great assistance in
that pursuit, but where the words lead to a ludicrous
result, the Board should favour the possibility which leads
to a sensible result providing it doe~ no manifest disservice
to the language of the agreement.. Assume a sessional
employe~ covered by Appendix III, lea) is hired for ~he
period.June 1 to 15. With the arrival of June 15, the
employee would know that, in the absence of some other
arrangement, June 15 would be 'his last, day of employm~nt.
l,am unable to accept that the parties of the collective
agreement intended to negotiate a-provision which would
.
have required that written notice of release be given to
a sessional employee in order to have the fixed term contract
terminate on its last day of the term.
\vhile the interpretation of Appendix III, 1 (a)' does
not bear on the disposition of this grievance, it does
permit the majority to suggest that since the parties
agreed that written notice of release was required in
~~---=
, - 4-
these circumstances'under Appendix III, lea) so too was
,it required in the same circumstances for sessional
"
...
I should observe that the majority award recogniz~:
that to construe the agreement in the manner indicated ~
"may require something which is unnecessary or indeed
. .
silly in its context." And yet the majority express the
view that it is. constrai~ed by the language to interpret
the agreement in this way. With respect, I do not agree
. that the Board is required to so interpret the agr~ement. '-
tn my opinion it is open to the Board to determine.that
the notice provisions in Appendix III, lea) ~elated 'to
'-
premature,.termination of a fixed term, .that the notice
provisions in Article 8.01 ec) relate only to full-time
--
.term agreement whic~ expires on the last day of the term
~ and this view would be consistent with the Common Law,
---
statute law, the reasonable needs of the parties and the
contract of emplayment..
l"1hile the argument was not raised at the hearing ;-.
the point should be made that the collective agreement
applicable to this grievance expressly recognizes and
~ :'
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L-
sanctions the employment of sessional employees. The
.,
Arbitration Board should endeavour to give effect to the
pro~isions of an individual agreement between the College
'';&
.. ~
and a sessional employee. In this case the intention of
.1,-
'"~-
both the College and the grievor was that the fixed term
contract would terminate or expire on the last day of its
---,',
"'
term without any further fqrmality or notice. The
...
Arbitration Board should not frustrate the clear intent
of the parties.
There is one other aspect of the individual contract
...
of employment between the grievor and the College and this
involves the principle of estoppel. The effect of that
co.ntract vias that the grievor in effect said to the. College
II I will \'lork for the College for the period from August. 8,
1977 to June 23, 1978.11 The grievor in effect is.saying:
II.X agree that my last day of employment is June 23, 1978. II
It is clear that the grievor.made a representation which
the Co~lege relied -on. Had the assurance not been given by
the. grlevor, the College might well have enhanced its.
.position vis a vis the termination by pursuing other steps.
In my view of the principle of estoppel the grievor should
not be permitted to deny the representation.
In the majority a\\Tard there are several findings on
the unacceptability of the letters of July 7, 1977 and
April 1, 1978 as valid written notices of release. The
following statement is taken from the award (page 13).
E~
-[ :;
"
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"TIle essence of those t t th t h
con rac s were a t eywere either
offe~s of employment or extensions of employment"and can
only be technically considered as also constituting notice ~
of release from employment." The requirements for a valid
notice of termination are that the notice be specific as. to~
date of termination and that it be clear and unequivocal.
..
The letters referred to would seem to meet the requir~ments
for'a valid notice. The letter of July 7, 1977 would have ~
been proper notice of termination of the fixed term which
expired on April 1, 1978 and I do not accept that the
..
validity of that letter as notice was destroyed by the
extension of employment to June 2~, 1978. In addition the
College refers to the letter of April 4, 1978 and submits
that it meets the requirements of a notice and 'if
~
.inadequate it is . only to the extent that it "Tas given to
the grievor less than 90 days before his release date.
Assuming that' the notice is valid as to. form and substance ",
does the failure to give the notice, 90 days or more in
advance of the termination date vitiate the total notice?'
We might be guided by the practice in the civil courts
where a determination is made that insufficient notice of
~
termination has been given. In that situation the courts
would make an award which added to the actual notice given;
and adjudged to be inadequate, would represent the amount
of notice which the court deemed appropriate.- In this
'......J
~
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case, the letter of April 4, 1978 was given to the grievor
80 days before June' 23, 1978. The grievor has had 80 days
actual notice and an award of an additional ten days would
have brought him in line with the requirement of Article
.,~~
~:
:.......
.'
.~
-
8.0J., (c).
""'
I am somewhat mystified by the references in- the
':.."?-- .
majority award (page 13) to the e~fedt that the letters
~
referred to "were either offers of employment or extension
of employment and can only be technically considered as
also constituting notice of release from employment."
If the letters meet the generally recognized requirements
for a notice of release, and whether they do or do not
meet the requirements is a technical question; if they do .
meet the standard, even technically, as the majority award
suggests, the College is enti~led to the benefit of that
notice. In view of this statement I am at a loss to
understand on what basis the majority are able to avoid
. giving effect to the letters as meeting the requirements
of Article 8.01 (c).
In summary, I would have come to the conclusions
which follow:
1. There is no requirement in the collective
agreement for written notice of release
from employement for -a sessional employee
ina fixed term contract which has run its
full term.
- 8 -
, *
:
2. In the alternative, that if the 90-day
written notice requirement was'applicable,-
that the letters from the College constituted
valid written notice.
3 i In the ~lternative, that if- the.extens.i6n
. !
ofemp1oyrnent referred to in. the April 4,' .1978'
letter vitiated theearl{er notice of release ~
that then the April 4, 1978 l~tter was a valid
notice except with respect to length. To cure
that d~ficiency, I would award the grievor 10 ~
,days pay i~ lieu of notice which when added
. -
to the 80 days actual notice would have
provided the grievor with the full 90 days
'-
written notice.
'-
-
.,.....
.....
Dated at Windsor this 31st day of January, 1979
1~}1v1--
"
I
v.
. /2 {
!/. 4.... '" ..i/j
I
J. H. McGivney, Q.C.
'.
\..--
-;;..
....,
.
. .
,
Re:
s~. Clair College and Ontario
Public Service Employees Union
(OPSEU) - Grievance of G.L. Minto
In my opinion it is open to a board of arbitration
.
to find that where the notice required by article BOlC of
the Collective Agreement in this matter has been improperly
given or: in any way given in a defective manner, that such
notice is no notice at all and that therefore it has 'no
.
effect on the employees status as an employee. . I find the
provisi6ns of article BOle with respect to notice to be .
mandatory,accordingly a failure by the college to comp~y
~Tith those provisions renders the release of the employee
nugato!"y .
I cannot agree that article 802A of the Collective
Agreement in any way detracts from the~andatory effect, of
article BOIC. In its O\oTn terms article 802A provides that
an employee who is released during his probationary period
cannot grieve that release. Nothing in the Collective
Agreement restricts the right of the probationary employee
to grieve th~ inadequacy of the notice given of his release.
Consequently in my vie\." if the college does not terminate an
employee during his probationary period as they have a right
to do .and if such an employee is given no effective notice
that he is to be released then he continues in the status
of employee and \,'ould in my opinion have the right to
Grieve claiming whatever benefits accrue to an employee.
. .
~.
- 2 -
,-
,
That argument was made by the union on behalf
of the.grievor in the instant case. I would have Supported
that argument. Nevertheless I have agreed with the
,
I
, .
chairmans disposition of this grievance in the circumstances
of this case, but I do not wish my concurence ~o.be seen as .
an agreement that ,in no circumstances can a board of
arbitration find that a defective release has had the effect
of maintaining the grievors status as an employee therefore
entitling him to reinstatement and full compensation. .
In the instant case as I read the evidence the grievor
accepted the fact of his release. He did not, for example,
present himself for work at the beginning af the next"
. academic term as though he were still an employee. The
'11
thrust of his case in these particular circumstances seems
to be that he was entitled to compensation in the form of
damages. Since the award has given him that I am prepared
to concur in it but my concurence goes no further" than that.
All of which is respectfully submitted.
--
Christopher Trower
'Union Nominee
--
~
CT: j 9
I i
. I
IN THE MATTER OF AN ARBITRATION BET WEE N:
THE ONTARIO COUNCIL OF
REGENTS FOR
COLLEGES OF APPLIED ARTS &
TECHNOLOGY
(FANSHAWE COLLEGE)
(hereinafter called the
"Employer"
- and -
ONTARIO PUBLIC SERVICE
EMPLOYEES
UNION
(hereinafter called the
"Union" )
GRIEVANCE OF
S. SAFRAN
(hereinafter called the
BOARD OF ARBITRATION:
W. B. Rayner, Chairman
J. H. McGivney, Q.C., College
Nominee
R. Cochrane, Union Nominee
APPEARING FOR THE UNION:
R. Nabi
"
G
r
i
e
v
o
r
~
~
APPEARING FOR THE COLLEGE:
C. Murray
HEARINGS IN RELATION TO THIS MATTER WERE HELD IN LONDON,
ONTARIO I ON 1 MAY AND 12 NOVEMBER, 1980
A WARD
This grievance arises from the release of thegrievor on October the
5th, 1979. The grievor claims that she was a full time probationary
employee at the time of her release and that she was not given the
proper notice as required by Artic.le 8.01(c) of the Collecti
Agreement. That article provides for at least 90 calendar days written
notice when a probationary full time employee is released after the
first five months of continuous or non-continuous accumulate
employment. The grievor claims that since she was not given proper
notice she has not been properly released and still remains an employee
of the College. She therefore seeks back pay from the time of October
the 5th, 1979 as well as a declaration to the effect that
she still continues asan employee. 4
The College maintains that the grievor was not a full--time
probationary employee at the time that she was released. The grievor
was given two weeks notice and the College takes the position that that
was the appropriate notice given to the grievor because of her status
at. the time that the notice was given.
There are really no facts in dispute.
Both parties agree that the grievance is properly filed and is properly
before the board. They both agree that the Board has jurisdiction to
hear the grievance.
3
The grievor commenced employment at Fanshawe College on December 19th,
1977. She worked occasionally for the college. In 1978, in July, the
grievor was offered and accepted three weeks of sessional employment.
In September of 1978 the grievor received certain instructions from her
c~ordinator, Mr. McGowan. In the first week of September the grievor
taught . two days as a substitute teacher. Mr. McGowan then asked her to
share a class because the class was too large. Hence, in the next week in
September the grievor worked four days, The following week, the week of September
25th her part of the shared group became her class. Mr. McGowan gave her
. this class and thereafter the grievor taught for three or four days a
week with a substitute teacher taking the fifth day.
This arrangement was unsatisfactory and McGowan asked the grievor to take the
classon all possible days after that. The grievor worked a substantial
number of weeks from October 1978 to October 1979 wherein her total
days work were five and her hours worked were fifteen. These figures
become important because of the provisions of the collective agreement.
The parties filed a list of hours and days worked for each week by
the grievor. The Board attaches that as an appendix
to this award,
4
On or about December the 1st, 1978 the grievor entered into a verbal
agreement with the Employer to teach three hours per day, twelve hours per week
until March 31, 1979. In actual fact, for many of the weeks in that period, the
grievor exceeded twelve hours per week.
The parties agree that the period between December 1977 and September 11, 1978 is
not in issue.
At all material times the grievor was paid as a teaching master teaching in the adult
education, division, Level II in English and Mathematics. The grievor did not
however receive benefits under the Collective Agreement.
After her termination, the grievor advised the Employer she did not consider herself
discharged and requested placement in two vacant positions for which she was
qualified.
In response to this, the Employer indicated by a letter from the president of the
College, Mr. Rawson, that the grievor was properly terminated. That letter is
important with respect to the College's position and it reads as follows:
"I have reviewed the facts surrounding your grievance dated 1979 10
17, and it is clear that ona number of occasions you worked in excess
of the range of hours per week for partial-load teachers as outlined
in the Academic Memorandum of Agreement. We therefore have
addressed ourselves to what your status would have been if we had
reviewed ahead of time the various teaching assignments you have
actually conducted during the whole of your period of employment
with the College.
5
It is our view that during the 6 months of July and
November, 1978, and February, March, June and July, 1979,
your employment would have been considered "full-time
sessional" since during those months you taught in excess
of the partial load limit for a period of more than 15 days
in each of the months mentioned. We believe that "full-time
sessional" is a reasonable classification for those 6
months in the light of Article 8.01 of the Collective
Agreement, which indicates how an employee may accrue
seniority when employed on a full~time, but non-continuous
basis.
During the remainder of your period of employment, you
would have been classified as a.partial-load teacher.
Since the College's normal practise is to pay full-time
sessional teachers based on an annual salary rather than
hourly rates/we will ensure the necessary financial
adjustments are made to reflect the above conclusions. In
addition, we will reimburse you at an hourly rate for those
hours about which there is some discussion as to whether or
not the work was properly authorized.
The college considers the two week notice period
appropriate in view of the fact that you would have been
considered either as a sessional or partial-load employee."
The parties agree that during the period when the Employer considered
the grievor as a sessional employee, she was compensated as ifshe was a
teaching master, a step on the salary grid except that she did not receive any of the
benefits provided by the Collective Agreement.
The griever, on cross'-examination, was questioned by the lo-:er's counsel
. with respect to those weeks wnerein she worked less
;h-n five days, The griever had several different reasons why she did : - : t ;.: ork five
days for most of those weeks. In some instances the r.~son was because a
statutory holiday fell within the week. In
instances the griever did not work because of illness or death -he family. In one
instance she did not work because it was a
6
professional development day at the college. In other instances the
grievor took time off for personal reasons including both extension of
vacation and religious holiday.
The grievor testified that she had no difficulty in getting time off when
requested. However, during the month of September, 1979, the grievor was told by
her co-ordinator that her hours were too high and that she was supposed
to take off one day a week. Hence for the weeks in September of 1979
the grievor worked only 4. days per week.
It should be remembered that the co-ordinator is a member of the
bargaining unit. The grievor testified that she was paid monthly and
that on occasion she had trouble rationalizing her pay with the hours worked.
She indicated that her pay cheques
were wrong at least twice and perhaps four times. However she said the
normal pay cheque matched her work.
Finally, the grievor indicated that her class was her responsibility.
She did however indicate that she would teach one hour English and two
hours Math to her class and then a second person would teach two hours
English and one hour Math to the same class. Nevertheless, she was
responsible for the progress and records of her students. She also
planned her own curriculum,
The Union argues that since October of 1978 the grievor employed as a
full time teaching
7
, ,
Mr. Nabi indicated that there were six types of .employees who worked iri
teaching capacities at the college.
The first type of employee he classified as a part-time employee and
that was an employee who worked six hours or less per week. That employee
is excluded from the operation of the collective agreement by article
101 of the agreement, the recognition clause.
The second type of employee according to -1r; Nabi I s breakdown was a
sessional employee. That employee is also excluded under the
recognition clause of the collective agreement. A sessional employee is
defined in appendix three of the collective agreement, section l(a) as
"a full-time employee appointed on a sessional basis for up to twelve
full months of continuous or non- continuous accumulated employment in
a 24 calendar month period."
The third type of employee is a sessional probationary employee. Under
the appendix just quoted a sessional employee who stays on for more
than the 12 full months goes into the probationary stream. That result
is set out in section l(c) of the appendix.
The fourth class of employee is a full time probationary employee.
Under the provisions of section 8.01 (a)a full time em-loyee is on
probation until he has completed 2 years continuous er-ployment.
Article 8,Ol(b) sets out the method of calculating that
8
period. It reads:
"ARTICLE 8 -SENIORITY
~
8.01 (b) Effective September I, 1976, the
probationary period shall also consist of twenty-four
(24)
full months of non-continuous employment (in periods
- of at least one (l) full month each) in a forth- eight (48)
calendar month period. For this purpose, only the
period after September I, 1975 shall be taken into
account or credited. However, an employee' continuous
service acquired in accordance with the provisions of
the previous agreement dated the 17th day of
September 1975, as at August 31, 1976 for the period
~
back to September 1, 1975 shall count as continuous
employment or months of non-continuous accumulated
employment for the purpose of this Section.
For the purpose of this paragraph, effective
September 1, 1976, a calendar month in which the
employee completes fifteen (15) or more days worked
shall be considered a "full month"
The. fifth category of employee is a full-time employee described in
section 3.03 (a) of the collective agreement.. That Article reads:
"ARTICLE 3 -SALARIES
3.03 (a) Persons who teach thirteen hours or more
will be salaried, the salary r.ange to be determined
according to the proportion that the individual's
part-time teaching load is to the average full-time
teaching 10- of the department of the particular
College concerned (This pro-rating of salary does not
apply to any full- time teacher who for whatever
reason may at some time have a reduced teaching duty
of less than thirteen hours per week.)
Effective September 1, 1977 pro-rata salary pay ment
under this article will be discontinued and the
salary scales as set out in Appendix I wi.ll aTpply to
persons teaching fourteen (14) hours or more on a
regular basis. Persons teaching over six {6) and u;
to and including thirteen (13) hours on a regular
bas:
will be covered by paragraph (b) hereof and Appendix
Mr. Nabi pointed out that under that provision it is possible for
a full-time employee to work less than fourteen hours per week.
;: .::;
The last type of employee is a partial load employee. That type of
employee is described in Article 3.03 (b) of the Agreement. That
Article reads:
"3.03 (b). Persons who teach over six (6) and up to
and including thirteen (13) hours per week on a
regular basis shall be referred to as "partial-load"
employees and shall not receive salary, vacations,
holidays or fringe benefits (except for coverage of
9
Workmen's Compensation and liability insurance} under
this Memorandum and Appendix I but shall be paid for
the performance of each teaching hour at an hourly
rate within the range of hourly rates set out in
Appendix II and in accordance with the other provisions
of Appendix II."
The Union argues that the grievor is not a part-time enployee as she
clearly worked more than six hours per week. There is no doubt that
this is the case and indeed the College does not even suggest that the
grievor was a part-time employee.
The Union also argues that the grievor was not a sessional employee as
her only appointment as a sessional teacher was for July of 1978. Mr. Nabi argued-
that a sessional employee must be appointed by the College as a sessional
er-ployee and that that was not done. Hence, the grievor could not be a sessional
employee. Ho also argues that the Employer could r.c't a-oint the griever as a
sessional employee retroactively as Mr. Ra-'son attempted to do in his
letter. Although Mr. Nabi recognized the need for sessional employees, and
recognized the fact that sessional employees could
1
o
be appointed for more than one session, he denies any right of the 1
college to make that appointment retroactively. At this point it should
be pointed out that schedule I of the College's Collective Bargaining
Act 5.0. 1975, c. 74 section {viii} contemplates an appointment for
more than one session.
Mr. Nabi referred the Board to Article 12.02 of the Collective
Agreement which provides in part that "if requested by the local Union,
the rationale for a sessional appointment by the College shall be the
subject of discussion." Obviously, the Union has some concern in
protecting the integrity of the bargainin unit. This section indicates
that concern. Mr. Nabi argues that if the college can make sessional
appointments retroactively, 4 Article 12.02 would be rendered meaningless.
Mr. Nabi argues that since the grievor is not a sessional employee she clearly is not
a probationary sessional employee.
He argues as well that the grievor cannot be considered a partial load
employee, He indicates that for a considerable pen' of time the grievor worked
weeks where her hours exceeded thi rteen. Indeed, according to his figures for
the majority of the timethe grievor worked fifteen hours per week.
This then, according to the Union's position, means that the grievorcan
only be considered a full-tine cnployec. Mr. Nabi says that the grievor
should be considet-d a full-time probationary
1
1
~ l
employee as she had, at the time of release, not yet completed the
period of time set out in Article 8.01 for probation,
The second major point raised by the Union is that the grievor, being a
probationary full-time employee, was entitled to 90 days notice under
Article 8.01 (c)., . Since she did not receive this notice she was still
an employee. In other words, the giving of notice was a mandatory .
condition precedent to a valid release. In support of that proposition,
Mr. Nabi relies on Re CIP Containers 2 L.A.C. (2d) 308 (Brown). In that
case the learned arbitrator referred to Re Valade and Eberlee,(1972) 1
O.R. 682. We will refer to this decision in more detail later.
Finally, the Union contends that since the grievor was not properly
released and still remains an employee, she is entitled to compensation from
the time that the invalid release was made.
Not unnaturally, the Employer disputes the Union position.
Mrs. Murray argues that the Union's argument is based on a false premise, She says
that there are no air-tight compartments in the Collective Agreement.
She says that there are various '-:ays people can be employed and a
person can enjoy a hybrid status.
. In essence, this argument requires the Board to find that for the
period 0- time when the grievor worked in excess of thirteen hours, per
week, she was a sessional employee and for the period of time
1
2
~
When she worked thirteen hours or less per week she was a partial load
employee.
In support of this position, Mrs. Murray breaks the period of
employment down into three separate components. She says that from
September 11th to December 30th the grievor wa- a r-,-rtial l6a-
teacher. During that period of time sheworked six weeks over thirteen
hours per week and six weeks under thirteen hours per week.
The second period of time is between December 4th and Marc1- 31st,
1979. Again, the teacher was a partial load teacher accord ing to Mrs,
Murray. By agreement, the grievor agreed to provide twelve hours per
week. During that period of time the grievor in actual fact worked
seven weeks under thirteen hours and ten weeks over thirteen hours.
- ,
The final period of time occurs after March 31st. There Mrs. Murray
says that a day-to-day arrangement was in effect.
Mrs. Murray indicates that there can be more than one sessionfor a
sessional teacher. This is contemplated by the provisions of the Act
referred to earlier.
Alternatively, the Employer says that if it is necessary to label the
irievor, she is best labelled as a partial load teachc -rs. Murray says
that the griever, on a regular basis, worked
1
3
between six and thirteen hours. In essence, the Employer says that the
grievor did not work sufficiently over thirteen hours per week, to say
that on a regular basis, she was working more than as a partial load
teacher. According to Mrs. Murray's figures, the grievor worked
somewhere between 56 and 57 percent of her time at fifteen hours per
week or more. Using the test enunciated by the Labour Relations Board
in Re Sydenham Hospital, the grievor failed to establish that' she
worked the 5/7th ratio in the category as set out in that decision.
Mrs. Murray also indicates that all other indcia of the relationship
indicate a partial load employee. The grievor did not receive benefits
of the full-time employees. The Collective Agreement prevents partial
load employees from receivinq those benefits. The grievor had a very
flexible relationship with respect to time off and vacations.
Finally, the Employer argues that even if the Union is correct in all
its submissions, the proper remedy to be given to the grievor is
damages for failure to give the.90 days notice. She is not, however, to
be reinstated. In essence, the College is saying that Article 8.01 (c)
of the Collective Agreement isnot a true mandatory condition precedent
to a proper release. If
it has been breached, the proper remedy lies in datmages in lieu 0-
notice.
tho College says tnat if the tffiion is correct in all of its
submissions, including the invalidity of the release
the Board should not award damages until argument and evidence be led
on the quantum of damage, as there will be some difficulty in _
calculating damages and seniority. Indeed, both parties asked the Board
to remain seized of this issue if the need arises and, accordingly, we
propose to say no more about it at this stage of the award,
We are of the view that the grievor cannot be considered to be a
partial load employee within the meaning of Article 3;03 (b) as she did
not usually teach between six and thirteen hours .per week, The
evidence is that the grievor on a regular basis worked more than
thirteen hour per week.
We are also of the view that the grievor is n?t a sessional employee as
set for in the appendix to the Collective Agreement, We do not feel
that the College can retroactively appoint a person to the sessional status,
in view of the particula provisions of the Collective Agreement relied
upon by the Union, i.e., Article 12. Moreover, the Board is not
convinced that an employee should move from one category to another on
a weekly basis as suggested by Mrs. Murray. Rather, we are satisfied
that the grievor was a full-tIa- probationa-' employee within the
meaning of the Collective Agreement. It is also clear that the grievor
wa a full-time probationary employee as suggested by the Union, under
the provisions of Article 8.01 (a).
The issue that now remains before the Board is whether the grievor
1
4
1
5
retains that status because of the improper notification given to her
by the College.
The Union takes the position that the grievor remains an employee
because the proper notification period as set out in Article 8.01(c)
has not been given. The-Union says this is a true condition precedent
to the grievor's termination, and since this condition precedent has
not been met, the termination is ineffective.
The Union relies on on Re CIP Containers 2 L.A.C. (2d) 308 (Brown). In
that case the collective agreement required the company to state in
writing the reason for the discharge. That requirement was not met and
the Board concluded that that require ment was a mandatory requirement,
and failure to meet it rendered the discharge nugatory. In so doing,
the Board relied on Re Valade and Eberlee, [1972] 1 O.R. 682. Again, in
that case, the court concluded that failure to give reasons for the
discharge as re quired. by statute, rendered the discharge invalid.
In our view, both of those cases are easily distinguishable zrom the
present case. The purpose of giving the reason for tWe discharge is to
permit the employee to determine whether and how be or sh-- should
contest the discharge. In this particular case, what is compl-ircd
about is the lcngth of notice. The purpose 0: any notice provision with
rospoct to tho termination of
1
6
employment is to provide the employee with some time in order to
(
locate alternaLe employment. If the notice period is not given,
the normal course of events in any civil action is to award damages.
Similarly, in the present case, an award of damages would make the
grievor whole. The breach of the Collective Agreement is that the
Employer did not give the proper period of notice and can result only
in an award of damages. That award adequately ccmpensates the grievor.
Mr. Nabi also- referred the Board to another decision between the
parties where the question was raised at least tangential:
However, we are not of the opinion that that case requires a
conclusion that failure to give notice under ;-rticle 8.01 (c)
renders the discharge invalid. 4
The Union also relied on section 65 of the College's Collective
Bargaining Act, 1975. That section provides in part that "for the
purposes of.this Act, no person shall be deemed to have ceased to be an
employee ... or by reason only of his being dismissed by his employer
contrary to this Act or to a collective agreement". The-Union says that
the grievor was dismissed contrary to the provisions of Article 8.01
(c) and hence, because of sectior 65 of the Act, still remains an
employee. Hc--:ever, that argu-ent overlooks the opening words of the
section) "for the purposes of this Act." If an employee is improperly
dismissed, the employee still remains an. employee under Section 65 for
the purposes of the Act. It is interesting to note that the Act
contains several
1
7
provisions which amount to unfair labour practices under the Ontario
Labour Relations Act. It is obvious that the intention of Section 65 is
to maintain the employer/employee relationship in order that the
employee can maintain his rights under the Act. However, the section
does not require that relationship be maintained in order that the
employee maintain any rights under the collective agreement. This
section is limited in its operation by its opening words "for the
purposes of this Act."
Since we are of the view that the employer did not give proper notice
under Article 8.01 (c), but since we are of the view that that giving
of notice is not a mandatory condition precedent to the termination of
the grievor, we are of the view that the Union is not entitled to a
declaration that the grievor be rein stated in her job and be paid for
the entire period from the date of termination. Rather, what the
grievor is entitled to is ninety days pay in lieu of notice less the
adjustment for the two-week written notice previously provided to her
by the College. This award places the grievor in the same position she
would have been in if the Employer had, in fact, complied with the
notice provisions of the Collective Agreement. In that regard, the
award fulfills the functions of the Collective Agreement and the most
important function of any award ,that is, to place thc injured party -n
the same position that that party would have been in if the Agreement
had been properly carried out.
1
8
As requested by the College particularly, and the Union in general, the
Board will remain seized of the matter in case the parties have any
difficulty in working out the precise amount of money owing to the
grievor.
DATED at London, Ontario, this
I concur/~-5eee~.
I concur/&&-e..
LI day of-4. . t7- .AA.o. * .A-
II
J~ ~f ~ , ,3'
(
], H. McGivney, Q,C" College Nominee
"
R. Cochrane, Union Nominee
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IN THE MATTER OF AN ARBITRATION
BETWEEN: DURHAM COLLEGE OF APPLIED ARTS AND TECHNOLOGY
AND ONTARIO PUBLIC SERVICE EMPLOYEES' UNION AND IN THE MATTER OF THE GRIEVANCE OF
R. McINTYRE
BOARD OF ARBITRATION: JF.W. Weatherill, Chairman
T. Traves, Union Nominee
W. Shuttleworth, Employer Nominee
A hearing in this matter was held at Toronto on October 6, 1982,
R.J. Mazar for the grievor
R.R. Dunsmore for the employer
AWARD
In this grievance, dated June 18, 1982, the grievor protests her dismissal from
employment with the College, The employer raised two objections to the
arbitrability of this matter, and these were fully heard and argued at the hearing,
The matter was then adjourned, and we now make our determination on the preliminary
questions.
The more substantial objection raised by the employer is that the matter is not
arbitrable because the grievor's employment was terminated while she was still a
probationary employee anq that, under the terms of the collective agreement, a
grievance on the merits of such termination is not arbitrable,
It is acknowledged that the grievor was, at the time she was advised of the
termination of her employment, a probationary employee. Having previously been
employed by the college on a sessional basis she was advised, by letter dated June
15, 1981, of her appointment as a full time Teaching Master. She was given one
year's credit toward the probationary period which, under article 8.01(a) (i) of
the collective agreement, is of two years' duration. In the grievor's case, it is
agreed that she would have become a regular full-time employee with full seniority
rights on August 24, 1982, had her employment not been terminated.
-2~ In article 8.01(c) of the collective agreement
it is provided that, in cases of orobationary employees having more than five
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months' accumulated employment, such employees may be released upon at least ninety
calendar days' written notice. The written notice given the grievor fell short of
that, by a few days, While the grievor might have a valid claim for payment in
respect of the required period of notice (and such claim would be arbitrable), the
giving of notice is not, in our view, a condition of the validity of the discharge
itself, provided, of course, that the notice be given during the probationary
period, as was the case here.
In the instant case, the grievor's employment with the College did in fact come to
an end in July, 1982, while she was still a probationary employee. Following the
notice she was given, she had no newly assigned duties, although she may have been
completing some of the year's work, and completing arrangements relating to the end
of her employment, Her last day at work appears from the evidence to have been June
25, and about mid-July she turned in her keys and received a cheque in final
payment of salary and other benefits, apparently for the period ending August 31,
1982. The fact that the grievor may have received payment, or would be entitled to
payment in lieu or partially in lieu of notice for a period ending
-3-
a few days after the date when her probation would have
ended dges not alter the fact, as we find it to be in this case, of the termination
of the grievor's employment within the probationary period, and when the employer
was entitled to release her, As we have indicated, any grievance relating to the
sufficiency of such payment would be arbitrable,
Article 8.01(c) of the collective agreement provides, as we have noted, that an
employee in the grievor's position
"n1ay be released" during the probationary period. The
employer did release the grievor during her probationary period, as we have found.
Employees so released do not, under this collective agreement, have a right of
grievance, nor a right to proceed to arbitration. That proposition expresses what
is set out clearly in the following articles of the agreement:
8.02(a) It being understood that the release of an employee during the
probationary period shall not be the subject of a grievance under the
Grievance Procedure, an employee who has completed his probationary
period and is discharged for cause may lodge a grievance in the manner
and to the extent provided in the Grievance Procedure.
11.06 Dismissal
It being understood that the dismissal of an employee during the
probationary period shall not be the subject of a grievance, an employee
who has completed his probationary period may lodge a grievance in the
manner set out in Sections 11.07 and 11.08.
-4-
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11,07 An employee who claims he has been dismissed without cause shall,
within twenty (20) days of the date he is advised in writing of his
dismissal, present his grievance in writing to the President commencing
at Step No. 2 and the President shall convene a meeting and give the
grievor and the Union steward his decision in accordance with the
provisions of step 1-0. 2 of Section 11,03,
11.~3 (in part) In the event any difference arising from the
interpretation, application, administration or alleged contravention of
the Agreement has not been satisfactorily settled under the foregoing
Grievance Procedure, the matter shall then, by notice in writii-g given
to the other party within fifteen (15) days of the date 6f receipt by the
gri-vor of the decision of the College official at Step No.2, be
referred to arbitration as here inafterprovided,
And reference may also be made to article 11,.o4(d):
(d) The arbitration board shall not be authorized to alter, modify or
amend any part of the terms of this Agreement nor to make any decision
inconsistent therewith nor to deal with any matter that is not a proper
matter for grievance under this Agreement;
While it is clear that employees having seniority may not be dismissed without just
cause, it is equally clear that under this collective agreement, probationary
employees may be released without the employer being required to show just. cause
for that action, That is the agreement the parties have made, and similar
provisions appear in the vast majority of collective agreements,
-5-
While a probationary employee would have the same
access as any other to the grievance and arbitration procedure in respect of
differences arising from the interpretation, application, administration or alleged
violation of the collective agreement, the right to have such differences
determined is, it should be emphasized, a right to have them determined in
accordance with the provisions of the collective agreement. Having regard to the
facts of the instant case as we have found them to be, and to the provisions of the
collective agreement by which we must determine the matter, it is our conclusion
that the action of the employer in terminating the grievor's employment as it did
was an action which it was open to the employer to take, and which was not in
violation of the collective agreement, Whether or not the grievor was dismissed for
just cause is not an issue which is arbitrable under the collective agreement
before us.
It was argued that the provisions of the collective agreement in this respect were
invalid, and that the grievor would be entitled to proceed to arbitration on the
issue of just cause by virtue of what is now section 46(1) of The Colleges
Collective Bargaining Act, That section is as follows:
-6- 46(1) Every agreement shall provide for the
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final and binding settlement by arbitration of all differences between an
employer and the employee organization arising from the inter pretation,
application, administ~ation or alleged contravention of the agreement
including any question as to whether a matter is arbitrable.
It is clear to us that that provision does not have the effect suggested. It is a
general arbitration provision, and gives effect to a legislative policy with
respect to the determination of disputes arising under collective a-ree-. ments,
which has been in effect for many years. While The Colleges Collective Bargaining
Act is relatively new, a substantially identical provision appears in what is now
section 44 of The Labour Relations Act, and similar provisions are in effect in
much of the lecislation relating to collective bargaining and collective agreements
in this province and in this country, and involving both the public and private
sectors, Such provisions (and this is surely the case with The Colleges Collective
Bargaining Act as with The Labour Relations Act), call for the arbitration (failing
resolution by some internal procedure), of differences "arising from the
interpretation, application, administration or alleged contravention" (to quote the
collective agreement, which embodies the requirement of the statute), of the
collective agreement. That is a general arbitration provision, and is the basis for
-7-
arbitral determination of a range of issues as wide as
those dealt with by the collective agreement, It does not have the effect of
altering any 0- the substantive ]rovisionsof a collective agreement, and in
particular it does not have the effect of conferring any form of tenure (however
limited) on probationary employees.
It is true that an arbitrator or arbitration board may be called on, in a proper
case, to characterize an action taken with respect to an employee. Thus, under some
legislation relating to public employees, the question may arise whether or not an
employee whose em-Ioyment has been terminated was ,3 released" or "dis missed". An
arbitrator may have to characterize the action taken as one or the other, as in the
Jacmain case
(1977), 81 D,L,R. (3rd) 1 (S.C,C4.
In the more recent Leeming case (1981), 118 D,L,R. (3rd) 202 (S.C.C.) it was held,
notwithstanding the adjudicator's finding that the dismissal involved was a
disciplinary action, that under the relevant provisions of the collective agreement
there was no requirement for the employer to show just cause for the discharge of a
probationary employee. The legislation pursuant to which the collective agreement
involved in that case
-8-
was made contains not only provision for arbitration in
respect of the interpretation or a-lication of the provisions of the collective
agreement, but also provision for the arbitration of questions of disciplinary
action. The case is strong authority for the conclusion that a general legislative
requirement that collective agreements contain an arbitration clause does not
affect the substan tive content of collective agreements themselves nor,
particularly, invalidate collective agreement provisions as to the
non-arbitrability of questions of cause for the discharge of probationary
employees,
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The Leeming case is a strong authority, although it is a decision made with respect
to somewhat different legisla tion than that relating to this case. The Toronto
!il':dro case, (1980) 111 D.L,R, (3rd) 693 (ant, Div, Ct,) i aff'd (1980), 30 O.R, 92d)
64 (ant. C,A.), is not, with respect, authority for anything more than the
Divisional Court's view that the arbitrator in that case had interpreted the
collective agreement before him in a way that its terms could reasonably bear.
While the majority of the Divisional Court appear to have approved of that
interpretation, the members of the Court of Appeal withheld such approbation, and
it is clear frox- the remarks made by the Supreme Court of Canada in refusing leave
to appeal in that case that what was involved was the interpretation of the terms
of
-9-
a particular collective agreement --an agreement somewhat
different from the one before us. The view that legis lative provisions such as
section 44 of The L-bour Relations Act, or section 46 of The Colleges Collective
Bargaining Act invalidate collective agreement 'provisions such as those permitting
the dismissal of probationary employees without a showing of just cause, is simply
not supported by the cases.
This board is indebted to Professor Traves, one of its members, for drawing to our
attention the case-note of Professor Bendel dealing with the Toronto Hydro case,
(1981) 59 Can. Bar Rev. 396. With respect, we are unable to accept either the
conclusions there set out as to the effect of the decision in that case, or the
rather conten tious "policy considerations" urged in its favour. The question has
recently been reviewed in the Peel Board of Educationcase (1982), 4 L.A.C. (3d) 409
(Beck), (the decision being published after the hearing in this matter was held,
and indeed after the bulk of the reasons herein were drafted), and we are, with
respect, in agreement with the views there set out. Reference may also be made (and
again we are ind&bted to Professor Traves for drawing it to our attention). to the
recent Larry Elliston case, 11982) 2 Can LLBR 241, where the Canada Labour
Relations Board adopts a view similar to that of the majority of the Divisional
Court in
-w
-u
--V
-10-
the Toronto Hydro case. The material provisions of The
Canada Labour Code appear to be quite analogous to those of The Colleges Collective
Bargaining Act. With respect, we are unable to accept the Board's reasoning, which
would appear to confuse access to arbitration for deter mination of arbitrability
and for decision on differences relating to the interpretation of a collective
agreement (which the legislation has always required), with the quite different
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policy (not embodied in any of the legis lation), that any "differences" may be
determined by arbitrators,
For the reasons given earlier in this award, it is our view that the material
provisions of the collective agreement are not contrary to any applicable
legislation, and that the effect of those provisions in the circumstances of this
case is that the grievance, raising as it does the issue of just cause of' the
grievor's dismissal, is not arbitrable,
The second objection raised by counsel for the employer related to time limits. In
view of the decision we have reached with respect to the first objection, we do not
find it necessary to deal with that question at this time.
To the extent that the grievance involves any claim for
44
St-
-11-
compensation in respect of payment in lieu of notice, it
is properly before us, and such matter may be brought on for hearing provided a
request is made to that effect within thirty days of the date of this award.
Failing such request, the grievance is dismissed.
DATED AT TORONTO, this 6th day of December, 1982.
'--L
Ch a i n'na n
'-:1 concur" T. Traves (addendum
Union Noininee attached)
"I concur" W. Shuttleworth
Employer Nominee
ADDENDU-
OPSEU (R. Nclntyre) and D--az- College
While I concur with the aw~rd in this case, I wish to explain the basis of my
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decision in slightly different terms than those set out by the rest of the
arbitration board. contrary to the other members of the board, I do not believe
that the Leemine case (1%1) 118 D. L. R. (3rd) 202 (S.C.C,) offers much guidance in
this case, The New Brunswick legislation differs significantly from that prevailing
in Ontario and hence the Supreme court decision does not touch the issues before us
in this case, I find the review of issues raised by the Leeming case offered at
length in ReDominion Stores and Depar-nent Store Union, 30 LAC (2d) at pp. 200-202
to be convincing. I further disagree with the view th~t the principles first
ennunciated in the Toronto Hydro case (1980) 111 D. L. R, (3rd) 693 (Orzt. Div.
Ct.); aff'd (1980), 30 O. R. (92d) 64 (Ont. C. A,) and subsequently elaborated at
length in Elliston and Steelworkers (1982) 2 Can, L,R.B.R. 241 should not prevail
in these "probationary dismissal" arievances if the facts are substantially the
same. However, in this case the facts are not substantially the same as those raised in
the Toronto Hydro case and for this reason I cannot be guided by that decision,
Toronto Hydro stands for the principle that when a substantive right is conferred
upon all employees it cannot subsequently be withdrawn from a small group of
employees in the same unit because that would violate the provision in the Labour
Relations Act (and the colleges Collective Bargaining Act, section 46(1)) that "all
differences" shall be subject to settlement by binding arbitration, The crucial
difference between Toronto Hydro and this case is that in the former the
substantive right that "no employee shall be disciplined or discharged without just
and sufficient cause" (Art 55.01 of the Collective Agreement) initially stands free
of any invidious distinction between the rights of permanent and probationary
employees, In this case, however, no such substantive right is ever conveyed'
through the Collective Agreement unon alL employees, Articles 8.02 and 11.06
which'bear on the issue of dismissal without cause do not provide an
undifferentiated right upon all employees to rleve dis--issals. Indeed, in both
articles, the very sentence which affirms the right of permanent employees to
/2
2.
grieve dismissals (and hence creates a "difference" under the meaning of Section 46(1- ofthe
Colleges Collective 3arca""n2zg Act) at the same time denies this right to probationary employees
ano r_ence fails to create a similar difference Accordingly this case must be
distinguished factually frow the Toronto Hydro case on the grounds that no
substantive right was initially conferred upon a~ the employees and hence no
substantive right could subsequently be taken away from some of the employees, viz,
probationers, in violation of Section 46(1) of the Act..
It might well be argued that the dismissal of a probationary employee, given the
language of this Collective Agreement, could be deemed to be a. rbi trable on other grounds
/ see Elissa Blame and Algonquin College, 1982 (Bastedo) /but no claim was made that
the facts in this case warranted such a finding.
Tom Traves
union Nominee
, ord
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IN THE MATTER OF AN ARBITRATION
HEARING HELD IN TORONTO, ONTARIO,
ON THE 7TH DAY OF FEBRUARY, 1985
BETWEEN:
THE BOARD OF GOVERNORS OF SHERIDAN COLLEGE
OF APPLIED ARTS AND TECHNOLOGY
(College)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(Union)
AND IN THE MATTER OF THE GRIEVANCE OF
RONALD BRACKENRIDGE
BOARD OF ARBITRATION
P. JOHN BRUNNER CHAIRMAN
s(J-/
JERRY COURTNEY COLLEGE NOMINEE
SUSAN D. KAUFMAN UNION NOMINEE
APPEARANCES
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FOR THE COLLEGE T, F. STORIE, Q.C,
FOR THE UNION LINDA ROTHSTEIN
-2-
SUPPLEMENTARY AWARD
In the award of the Board of Arbitration dated November 22, 1984, a declaration was
issued that Ronald Brackenridge had, by May 20, 1983, completed the first year of
his probationary period and thereafter was covered by the provisions of the
Collective Agreement. No evidence had been led at the prior hearing as to
Brackenridge's status on or after May 20, 1983, and that matter had not been the
subject of argument by Counsel. For this reason we retained jurisdiction on this
question should an issue arise with respect thereto between the parties. The Board
in addi tion stated that there had been no evidence as to whether a Notice of
Release was at some point after May 20, 1983, given by the College to the grievor
and as to how and in what manner his employment, as alleged in the formal
grievance, had been improperly terminated.
The Board by its award also held that the formal grievance dated October 14, 1983,
was filed outside the mandatory time limit prescribed by the Collective Agreement,
However, as the grievance was a "continuing one" the declaration could neverthe
less be issued, but any consequential relief would be restricted to a period
commencing twenty days immediately preceeding September 12, 1983, the date on which
the grievor's complaint was first made, Jurisdiction as to the matter of
consequential relief was reserved.
-3-
Subsequent to the publication of the award, Counsel for the
Union requested that the Board reconvene its hearings as an issue had arisen as to
the grievor's status. As a result, on February 7, 1985, a further hearing was held
and evidence was led and submissions made by both parties.
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There is very little evidence as to Brackenridge's employ ment status after the end
of phase 3 of the W.I,T,T. program on May 20, 1983. He himself testified that there
was no "under standing" with the College that he would be involved with phase 4, if
indeed there was to be a continuation of the program in September, 1983, He said
that he "assumed" that there would be a place for him in that event.
The Director of Administration of Skills and Development/- Apprenticeship Division,
Karam Daljit, stated that no decision as to whether there was to be a phase 4 was
made until sometime during the month of August.
On June 16, 1983, Brackenridge taught two hours of classes
but it is not very clear as to what the subject was. He worked a
further hour later that month but that was the extent of his
assignment by the College after May 20, 1983,
-4-
The inference we draw from the evidence is that his
employment continued until at least the end of the month of June, 1983, Thereafter,
the evidence becomes hazy.
On August 18, 1983, the Queen Elizabeth Campus Administra tor, Joyce Reid, issued a
Memorandum (Exhibit 11) at the grievor' s request in order to assist him in an
application that he made to the University of Toronto for employment as a supply
teacher. It is not clear whether Brackenridge at this point was seeking permanent
or part time employment. The letter however is couched in language which would
indicate that, at least in the writer's opinion, his employment had ended,
On August 23, 1983, the College posted a Notice of Opening for a Teaching Master
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for what by now had been decided would be phase 4 of the W. I . T. T. program. The
qualif ications for the position however were materially different. from what they
had been during phase 3. It was conceeded by Brackenridge that he did not meet
these qualifications in several respects. Interested "internal" applicants were
instructed to forward their resume to the Director of Human Relations by August 30,
1983. There is no evidence as to whether the grievor did so or whether "external"
applicants were also considered, Nevertheless we were told that the grievor did
apply for the position and was interviewed on September I, 1983. On September 9,
1983, he was informed that he
-5-
had not been selected for the position. There is some evidence
that on September I, 1983, he was asked whether he would be interested in a
"partia~ load" assignment in the future but the matter was never pursued. In point
of fact, one Cutmore was appointed not as a full time but as a sessional employee
to. fill the position that was posted on August 23, 1983,
On Septembe r 12,
October 14, 1983,
1983, Brackenridge made his "complaint"
was reduced to a formal grievance.
which
subsequently
on
It is clear from the evidence that the grievor was never expressly told at any time
prior to October 14, 1983, that he was no longer a College employee. The reason for
this is probably that the College viewed his employment as having terminated on May
20, 1983, when phase 3 of the program ended and considered the work that he
performed in June, 1983, as casual work. On the other hand, it is equally plain
that Brackenridge no longer viewed himself as an employee by October 14, 1983. The
formal grievance acknowledges that "I have since been improperly terminated."
It is conceeded that he did not teach or perform any other work for the college
since the month of June, 1983, In August, one of the Campus Administrators in the
previously referred to
-6-
Memorandum, of which he received a copy, spoke of him in terms of
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having been an employee in the past. He himself submitted an applica tion for the
posted position of Teaching Master for phase 4 of the W.I.T.T~ program but was
turned down on the ground that he was not qualified. Some three days later, he made
a complaint with respect to his treatment by the College and then on October 14,
1983, submitted a grievance in whi ch he acknowledged that his employment had been
terminated.
In our view, he was certainly aware by September 12, 1983, that the College was no
longer treating him as an employee. With the greatest respect for those who contend
otherwise, there can be little doubt that by that date, neither he nor the College
considered that an employment relationship between them existed and it was common
ground that his status as an employee had ended. We do not think that there is
anything in the Collective Agreement nor indeed in the general law, which mandates
that the College can only terminate the employment of a probationary employee by
the use of express words, whether oral or in writing. There can be little doubt if
the only reasonable inference from all of the circumstances is that neither the
Employer nor the employee consider themselves as having a subsisting employment
relationship then by that date, the employment may be said to have terminated, In
our view, the express conduc t of the College over the period of time we have
described up until. September 12,
-7-
1983, is consistent only with the view that Brackenridge's
employment had been terminated, It was made clear to him that there was no further
work for him at this time. The position that he had held during the first three
phases of the W. I. T. T. program had been awarded to another. His application for
that position had been turned down and he was asked whether he would be interested
in a "partial" load" ass ignmen t in the future, to which he did not respond, In
these circumstances, the only reasonable conclusion to which one can come, is that
his employment had terminated by September 12, 1983.
As we have stated in our award, the grievor was by May 20, 1983, an employee who
had completed the first year of his probationary period and thereafter was covered
by the provisions of the Collective Agreement, In accordance with paragraph l(c) of
Appendix III, his probationary period continued for a further period of twelve
months. Accordingly, it is clear that on September 12, 1983, the date we find that
his employment was terminated, he was an employee within his probationary period,
At this juncture it becomes relevant to consider Articles 8.01(c), 8.02 and 11.06
of the Collective Agreement which we reproduce in full.
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"Article 8 -Seniorit~
8,Ol(c) During the probationary period an employee will be informed in writing of his
progress at intervals of four (4) months continuous employment or four (4) months of
accumu
-8-
lated non-continuous employment and a copy given to him.
Also, it is understood that an employee may be released during the first five (5) months of
continuous or non-contin uous accumulated employment following the commencement
date of his employment upon at least thirty (30) calendar days' written notice and during
the remainder of his probationary period upon at least ninety (90) calendar days' written
notice. If requested by the employee, the reason for such release will be given in writing.
8.02(a) It being understood that the release of an employee during the probationary period
shall not be the subject of a grievance under the Grievance Procedure, an employee who
has completed his probationary period and is discharged for cause may lodge a grievance
in the manner and to the extent provided in the Grievance Procedure.
8.02(b) An employee being discharged who has completed his probationary period shall
be notified in writing by the College President or the persons(s) he designates for that
purpose, When the reasons for discharge of the employee are not such as to warrant
immediate discharge, the College will give ninety (90) calendar days' written notification.
11.06 Dismissal
It being understood that the dismissal of an employee during the probationary period shall
not be the subject of a grievance, an employee who has completed his probationary period
may lodge a grievance in the manner set out in Sections 11.07 and 11.08."
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It is clear from Article 8.02(a) that the release of an employee during his
probat ionary period or his dismi ssal (Article 11.06) cannot be the subject of a
grievance and is not a matter that is arbitrable. Only an employee who has
completed this period can challenge his "discharge" or "dismissal-" through the
Grievance Procedure and has the substantive right not to be
-9 -
dismissed except for cause.
The Collective Agreement in question has carefully drawn a clear line between the
termination of an employee during his probationary period and thereafter, The
former is referred to as
"
a release" or "dismissal" while the latter has been termed as "discharge" or
"dismissal" ,
The predecessor to Article 8 .01 (c) was considered by the Divisional Court of the
High Court of Justice for Ontario on June 6, 1975, in Re Civil Service Association
of Ontario Inc, and Ontario Council of Regents of Colleges of Applied Arts and
Technology, It is not necessary to deal with the facts of that case, but it is
sufficient to say that Mr. Justice Zuber as he then was, speaking for the Court,
defined the word "release" as meaning "the total cessation of the relationship of
employer and employee", These provisions of the Collective Agreement which have not
materially altered over progressive amendments to the Collective Agreement were
also the subject of consideration in Re Ontario Council of Regents of Colleges of
Applied Arts and Technology and Civil Service Association of Ontario Inc. (Seneca
College), (1976) 13 L.A.C. (2d) 82 (Weatherill), In that case, the Board applied
the definit ion of the term "release" ennunci ated by the Divisional Court and
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expressed agreement with it. Insofar as any difference or distinction between the
words
-10 -
II release "or "dismissal" was concerned, the majority of the Board
put the matter in this way at page 84:
"In the instant case, we think it is clear that what the employer sought
to do was to 'release' the grievor, pursuant to art, 8.02(a). Certainly
it may be said to have 'dismissed' her within the meaning of art.9.06.
The two terms are not quite synonymous: 'dismissal' has, we think, a
somewhat broader connotation, and would likely include 'release'. Where,
as in this collective agreement however, the two terms are used with
reference to a termination of employment during a probationary period, we
think there is no substantial significance in the difference of
terminology as between art.8.02(a) and art.9.06. The substance of the
agreement is clear: where the employer terminates the employment of an employee
during his probationary period, that termination 'shall not be the
subject of a grievance'. It is not for this board to consider the wisdom
or otherwise of the employer's act, nor to conclude that the employer may
have had ample opportunity to assess the employee even before the expiry
of the period. Our jurisdiction in the matter turns on our finding
whether or not the grievor was 'released' or 'dismissed' during her
probationary period, We make this determination in the exercise of our
jurisdiction to determine 'whether the matter is arbitrable', pursuant to
art. 9.04(a) of the collective agreement. "
The Board went on to state at page 85:
"In our view, where art. 8.01(a) of the collective agreement provides that the
employer may release a probationary employee upon notice, it does not
make the giving of such notice a necessary condition precedent to the
release. Failure to give such notice would be a violation of the
agreement for which an appropriate remedy (such as payment in lieu of notice) could
be granted. It is our view, however, that it would take express language in the collective
agreement to establish the giving of notice as a necessary condition precedent to the
release of probationary employees, and to effectively alter the express provision of the
agreement that the probationary period 'shall be of two years' duration'. Such language
does not appear in this collective agreement. "
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-11 -
It follows from the reasoning of the Divisional Court and of
the award in the Seneca College case, as well as from the clear words of the
Collec ti ve Agreement, that the termination of employment of Brackenridge which we
have found to have taken place on September 12, 1983, could not be made the subject
of a grievance and was not arbitrable, The termination of his employment on the
date in question amounted to a "release "as there. was a total cessation of the
relationship of employer /- employee and his only right under Article 8.01 (c) was
that he be given at least ninety days' written notice. Failure to give such notice
was not a condition precedent to his "release" but was a violation of the
collective agreement for which in our opinion the appropriate remedy is to order
that the College pay him ninety days' wages, in lieu of the notice that should have
been given, at the applicable rate, (See the Seneca College case and The Ontario
Council of Regents for Colleges of Applied Arts and Technology (St. Clair College)
and Ontario Public Service Employees Union (Grievance of G. L. Minto) dated
February 20, 1979 (Brandt).
There were a number of other arguments that were addressed at the hearing on
February 7, 1985, but in view of the result we have reached it is not necessary to
deal with them.
-12 -
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The above is sufficient enough to finally dispose of this
grievance subject to retaining jurisdiction over the matter in the event any
difficulties arise in the implementation of our Supplementary Award.
DATED at Toronto this 8th day of May, 1985,
P.JOHN BRUNNER, CHAIRMAN
JERRY COURTNEY, COLLEGE NOMINEE
SUSAN D, KAUFMAN, UNION NOMINEE
ADDENDUM TO SUPPLEMENTAY AWARD OF APRIL 1985
IT WOULD BE REASONABLE TO AGREE THAT NINETY DAY'S (90) WAGES IN LIEU OF
NOTICE IS APPROPRIATE IF A VIOLATION AS DESCRIBED TOOK PLACE.
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I CANNOT CONCUR, HOWEVER, BECAUSE OF THE DISSENT I MADE ON
THE AWARD OF THE BOARD DATED NOVEMBER 22, 19 84, THAT ANY COMPENSATION IS
FORTHCOMING IN THIS MATTER, THIS IS CONSISTENT WITH MY ORIGINAL POSITION
ON THE MATTER,
J. T. Courtney.
April 16, 1985,
Thunder Bay, Ontario.
DISSENT
I am unable to agree with the supplementary award of the majority.
My notes do not indicate that the Grievor testified "that there was no
'understanding' with the College that he would be involved with phase 4, if indeed
there was to be a continuation of the program in September, 2983" as set out in the
awardof the majority. They do not r~flect "that he 'as- sumed' that there would be
a place for him in any event,"
Rather, my notes indicate that when the Grievor was asked by his own counsel whether he had any
understanding that he would be teaching the course, he replied, that he assumed he would (be
teaching the course) because he was asked to arrange courses for September classes.
He taught and was paid for teaching a couple of non-traditional courses in the
afternoons in the summer and he visited Blakelock High School to arrange machine
facilities for the next W.I.T,T. course, This took place after May 20, 1983.
On about August 16, 1983, the Grievor received a letter of acceptance from a
university of Toronto program which would enable him to get a job in a high school
doing supply
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teaching if, in his words, "Manpower didn't fund the W.I.T.T.course in september." He then
asked Joyce Reid for a letter of reference, which reads as follows:
Sheridan College of Applied Arts
and Technology
178 South Service Rd. East,
Oakville, Ontario L6J 2XS
842-0105
Queen Elizabeth Campus
83 08 18
TO WHOM IT MAY CONCERN
Ronald Brackenridge has been a sessional faculty member of Sheridan
College since March IS, 1982,
. Mr, Brackenridge has been a trades instructor in the Women Into Trades and
Technology program. During his peliod of employment with us, he has demonstrated
his ability to work well w'ith students, fellow faculty members and
Administration.
When Mr. Brackenridge joined our staff, his initial responsibility was to
assist in setting up a pilot program for the Women Into Trades and Technology
program. He dedicated himself to making this pilot program a success and
continued to teach in subse quent Women Into Trades and Technology
programs. In a program involving students with a wide variety of
educational and cultural backgrounds and ranging in age from 18 -34,
considerable flexibility and innovativeness has been required, Mr.
Brackenridge has met the challenge well,
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I have been pleased to have Mr. Brackenridge as a member of our teaching
staff.
Sincerely,
Mrs. Joyce Reid
Campus Administrator
JR: ld
3.
The letter does not purport to be a termination of employment. It speaks of the
Grievor's teaching activities in the past tense because his sessional appointments
were concluded at the time she was asked to write the letter, and Phase 4 had not
yet been funded. The Grievor was expecting to be asked back provided that the
W. I. T. T. program was funded. There is no evidence to suggest Miss Reid thought
otherwise,
The Grievor was not told he would not be asked back after May 20, 1983. The College
engaged his services after May 20, 1983, and his status was in limbo, He still remained,
in theory at least, a probationary employee,
The cases relied upon by the majority to find that his employ~ent terminated as of
September 20, 1983, are posited on fact situations where the employer clearly
intended to release the employee. In this case, the majority appears to equate the
cessation of employment at the end of a session with an inten tion to release. The
supplementary award of the majority implies a constructive intention to release
and from there con eludes a constructive dismissal has occurred.
with the greatest of deference to my colleagues, this is an inappropriate inference
to draw from the facts of this case. There is very skimpy evidence to support an
intention to release. It is simply too remote an inference upon which to
4.
base an award,
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In effect, the Board is concluding from the ex post facto evidence of Karam Daljit
given February 7, 1985, that had the College known that it had failed to release
the Grievor, it would have released him before September, 1983, (That evidence was
admitted, subject to the weight the Board would give it, overtheobjection of Counsel
for the Employee,)
This Board could just as. reasonably, and, in my opinion, more reasonably, infer
that had the college known it had failed to release the Grievor in May, 1983, that,
if it realized this in September, 1983, it would have kept the Grievor on as a
sessional W.I.T.T, trades instructor for Phase 4 instead of posting a com petition
for a full-time trades instructor.
In the context of this Collective Agreement a notice of release must be formal,
Constructi ve release of a probation ary employee is simply not contemplated under this
Collective Agreement. In The Board of Governors of Algonquin college of Applied Arts
and Technology and O.P.S.E.U. (Brunner) 1983 (Grievance of Gatien) the Arbitrator
commented that a College's failure to hire someone back is not sufficient to
constitute a notice of release. Here the College failed to hire the Grievor back as
Trades Instructor for Phase 4. The fact that the Grievor complained that this was
so in September, 1983, does not
5.
and should not make the College's failure to hire him back any more a notice of release
than it did in the Gatien case.
The Grievor was a probationary employee as of May 20, 1983. If he had been able to fulfil
24 months of non-continuous employmentiriperiodsofatleastone full month, under
Article 8.01(b) within 48 months of the date of his initial sessional appointment, he
would have completed his probationary period, and attained status under the Collective
Agreement,
However, the Grievor must have been offered and accepted employment with the
College for that to have happened.
The College circumvented this by, as we heard, departing from an "heir-apparent"
approach in filling the Trades Instructor position for Phase 4. The College
re-characterized the Grievor's originally full-time sessional position as
partial-load in spring 1983 and characterized it as full-time for September, 1983.
It posted the full-time position as requiring a basic knowledge of electronics
(which the Grievor had) and left the posting silent regarding the need for math
teaching skills. The College alleges it denied the Grievor the full-time position
because he was not qualified to teach math, and then, having chosen another incum
bent, made the posted full-time position a sessional one.
Mr. Daljit admitted to this Board that sessional positions could be and were
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tailored to the person chosen to
6,
fill them. By its actions the College made it impossible for the Grievor to complete his
probationary period, Only by the College's actions in re-characterizing the
position at least twice and by refusing the Grievor what was essentially his former
position, was the Grievor made aware the College no longer wished to utilize his talents, which,
until then, had been quite satis factory for the W,l.T.T. program,
From this perspective, it is unfair and outside of the spirit and intention of the
Collective Agreement to infer a notice of release, triggering a mere 90 days pay in
lieu of notice.
I would have found the Grievor had maintained his pro bationary status from May,
1983, and had accrued seniority from the date of the commencement of Phase 4 of the
W.I.T,T. program and any successor programs, I would have found him entitled to the
full salary and benefits of the W,I.T.T. trades instructor, together with interest,
from the date Phase 4 commenced in September, 1983 until January 22, 1985, the date
upon which the College gave him written notice of release.
Further, I would have found that he had attained his full rights under the
Collective Agreement once the hours of the incumbent W.I.T.T. trades instructor
had, if the Grievor had ac tually worked them, satisfied Article 8.01(a) or (b)
7,
I would have retained jurisdiction with regard to the question of compensation,
Dated at Toronto this 6th day of May, 1985.
S. D. Kaufman
Union Nominee
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Concerning an arbitration
Between:
SENECA COLLEGE
and
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
Grievance ofF. Roy concerning status and termination, 87S67
Board of Arbitration
J, W. Samuels, Chairman
R. J. Gallivan, College Nominee
W, Majesky, Union Nominee
For the Parties
College
R, W. Little, Counsel
M. Fogel, Director of Employee Relations
Union
S. Ballantyne, Counsel
T. Montgomery, Local President
F. Roy, Grievor
, Ol .:)
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Hearing in Toronto, January 14, 1988
Frederick Roy was engaged by the College as a sessional teacher in July 1985. He served three distinct
periods as a sessional employee, the last one ending on May 15, 1987, The College did not reengage
him because at the time it was not in a position to hire regular faculty, The College did make it clear
that it was pleased with his work in his three different course areas. The grievor claims that, by the
time of his termination, he should have been considered to be a full-time employee on probation, with
the rights of such an employee under the collective agreement.
The Union relies on Article l(c) in Appendix 1171, which says that "If a sessional employee is
continued in employment for more than the period set out in paragraph (a) above, such an employee
shall be considered as having completed the first year of the two (2) year probationary period and
thereafter covered by the other provisions of the Agreement". The period set out in paragraph ( a), to
which reference is made in paragraph (c), is "up to twelve (12) full months of continuous or
non-continuous accumulated employment in a twenty-four (24) calendar month period".
The Union argues that Mr. Roy was employed as a sessional employee for more than "twelve full
months" in the twenty-four calendar month period of July 1, 1985 to June 30, 1987, and therefore
should have been considered as having completed the first year of the two-year probationary peliod
and now covered by the collective agreement.
For the purposes of this case, the parties have agreed that the definition of "full month" is the one set
out in Article 8.01 (b) of the collective agreement. The second clause in this article reads:
For the purpose of this paragraph, effective September 1, 1976, a calendar month in
which the employee completes fifteen (15) or more days worked shall be considered a
"full month".
It is to be noted that this clause says clearly that this definition is only "for the purpose of this
paragraph", and the paragraph as a whole is not relevant to
2
our case. Nonetheless, this is the definition of "full month" which the parties agreed we should use,
The grievor's three periods of employment were July 3 to September 6, 1985; June 2 to August 29,
1986; and October 14, 1986 to May 15, 1987 (this last period is the result of an initial contract and
then several extensions), It is agreed by the parties that there are eleven months in these periods which
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do consist of fifteen or more days worked---July and August 1985; June, July, and August 1986;
November and December 1986; January, February, March and April 1987, In addition, the parties
agree that the days worked in October 1986 can be combined with the days worked in May 1987,
being the beginning and end ora period of employment, to give a twelfth "full month" (this would be
according to the third clause in Article 8.01(b)).
However, these twelve full months would run to May 15, 1987, at which time the grievor's period of
employment as a sessional employee was over, and he would not have "continued in employment" for
more than the twelve full months, The Union suggested that we could now count the six days worked
in September 1985 to give the grievor "more than" the twelve full months. But Article l(c) in
Appendix III requires not just "more than" the twelve full months. The employee must be "continued
in employment" beyond the twelve full months.
Thus, for the grievor to have "continued in employment for more than" the twelve full months, we
have to find that October 1986 was a "full
month" on its own. If this were so, the grievor's twelve full months would end on April 30, 1987, and
his service in May 1987 would be the continuance beyond the twelve full months. Thus in May 1987
he would be considered to
be a probationary employee who had completed twelve months of his probationary period, and he
would be entitled to the rights of a probationary employee under the collective agreement.
In October 1986, the grievor commenced employment on the 14th. This gave him 14 teaching contact
days in the month, on Monday to Friday each week. In addition, it is agreed that he actually worked on
the two
3
weekends between the 14th and 31st, giving him 18 actual days worked, The issue is---can one count
the weekend days as "days worked" under the definition adopted by the parties in Article 8.01 (b). The
grievor needs 15 "days worked" to count October 1986 as a "full month",
In our view, "days worked" must mean more than "teaching contact days". This collective agreement
recognizes clearly that there is more "work" to be done than simply teaching students in scheduled
classes. Article 4.01 (2), which deals with workload, says that "Total workload assigned and attributed
by the College to a teacher shall not exceed forty-four (44) hours in any week "(emphasis added), and
then provides that workload factors to be considered are "(i) teaching contact hours, (ii) attributed
hours for preparation, (iii) attributed hours for evaluation and feedback, (iv) attributed hours for
complementary functions", Article 4.01(4)( a) gives a fonnula for calculation of attributed hours for
preparation, which depends on whether the course was new, established, or repeated. Article 4.01 (5)
gives a formula for calculation of attributed hours for evaluation and feedback, depending on whether
the course involved an essay or project, whether it was routine or assisted, or whether it was
in-process. And Article 4.01 (6) provides for the calculation of hours attributed for complementary
functions.
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We were not told what courses the grievor was assigned in October 1986, so we can't calculate his
attributed hours with any precision, But it does seem pretty clear that, with assigned contact hours on
14 days, he would have sufficient attributed hours to make up 15 "days worked" in total, if this is the
way to calculate "days worked".
Furthermore, we agree with the analysis of the Board of Arbitration in Loyalist College and OPSEU
(grievance of Daniels, unrep0l1ed decision of Delisle, dated February 7, 1985), when the Board says
(at pages 6-7):
In counting days worked we do not limit ourselves to Monday through Friday, Teaching
masters hired on a full-time faculty member basis or on a sessional basis are hired for
periods of time. The
4
College contracts for the teacher's services over the full period of time, There is no
warrant in suggesting that only contact days can be counted. There are a variety of other
duties contemplated by the Collective Agreement. The necessary duties of marking
assignments and preparing classes frequently need to be done on weekends and in this
case, by the unchallenged evidence of the grievor, were in fact done.
There are two possible interpretations of this passage. On the one hand, the Board may be saying that
one should count the "full period of time" for which the teacher's services are contracted---that is, the
teacher's "days worked" are equal to the calendar days in the month for which the employment runs.
On the other hand, the Board may be saying that one should count the actual days worked.
Whichever view is taken, in our case Mr. Roy had 15 "days worked" in October 1986.
Thus, whether "days worked" means the total days assigned and attributed under the formulae in
Article 4, or calendar days, or actual days worked in the particular case (and our preference would be
the first of these possibilities), our grievor had 15 "days worked" in October 1986,
This means that by May 1987 he was continued in employment beyond
the allowable sessional period in Appendix III, and was to be considered as a
probationary employee having completed his first year of probation on April
30, 1987.
As a probationary employee, he was entitled to the rights set out in Article 8,OI(c) of the collective
agreement. This provision reads:
During the probationary period an employee will be informed in writing of the employee's
progress at intervals of four (4) months continuous employment or four (4) months of
accumulated non-continuous employment and a copy given to the employee. Also, it is
understood that an employee may be released during the first five (5)
5
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months of continuous or non-continuous accumulated employment following the
commencement date of the employee's employment upon at least thirty (30) calendar
days' written notice and during the remainder of the employee's probationary period upon
at least ninety (90) calendar days' written notice. If requested by the employee, the reason
for such release will be given in writing.
The critical element in this provision is the f,1fievor's right to at least 90 calendar days' written notice
that he would be released. The fact that the College did not do any performance appraisals in writing
of the grievor is not critical for two reasons. Firstly, the grievor became a probationary employee on
April 30, 1987, by operation of Article 1(c)of Appendix Ill, and he had not yet served four months as
a probationary employee. Article 1 ( c) deems him to have completed 12 months of the probationary
period, but his actual service was as a sessional employee and as a sessional employee he did not have
a contractual right to performance appraisals. Secondly, even where a probationary employee had a
right to performance appraisals and did not get them, this was held not to be a bar to release by the
College [see Seneca College and OPSEU (grievance of O'Neill, unreported decision of Brent, dated
February 28, 1984), at pages 7-8}, and we agree with this decision.
Pursuant to Article 8.02(a), a probationary employee cannot grieve a release { see Seneca College and
OPSEU (grievance of Moran, unreported decision of Samuels, dated September 18, 1985); and
Mohawk College and OPSEU (grievance of Ennis, unreported decision of Samuels, dated March 26,
1986) 1, but he can grieve the College's failure to give the 90 days' notice.
The College argued that the grievor was given 90 days' notice because he knew from the outset of his
third sessional appointment that his employment would end in May 1987. In fact, this is not accurate.
On October 9, 1986, the grievor was engaged from October 14, 1986 to January 30, 1987. Later this
was extended to May 19, 1987 (the document is not well
6
reproduced, but the date of this extension appears to be sometime in January 1987, because it is "as
per authorization received January 14, 1987"). Then on April 16, 1987, the period of employment was
extended to May 22, 1987. And finally on April 27, 1987, the grievor was informed that his period of
employment would end on May 15, 1987. Therefore, in our view, the grievor was not notified of the
May 15, 1987 terminal date until April 27, 1987.
Was this the requisite notification of "release"? The Union argues that it can't be a release unless the
College knows it is effecting a "release", and since the College didn't consider Mr. Roy to be a
probationary employee, it couldn't have turned its mind to a "release". In our view, a "release" is
nothing more than the tennination of employment of a probationary employee pursuant to Article
8.01 (c). It is the reality which matters. There is no doubt here that the College intended to terminate
the employment of the grievor. Because Mr. Roy was a probationary employee at the time of this
tennination, it was a "release".
But the College failed to give the requisite 90 calendar days' notice. The grievor is entitled to
compensation in lieu of notice [see Re Ontario Council of Regents of Colleges of Applied Arts and
Technology and Civil Service Association of Ontario (Inc.) (1976), 13 LAC (2d) 82 (Weatherill), at
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page 85 1/2]. Mr. Roy received notice on April 27, 1987 that his employment would end on May 15,
which is 18 calendar days' notice. He is entitled to compensation in lieu of notice for an additional 72
calendar days. This amount is to be calculated as follows---take the gross amount paid to Mr. Roy for
the employment period October 14, 1986 to May 15, 1987; divide this amount by the number of
calendar days in this employment period, to arrive at a "rate of remuneration per calendar day"; and
multiply this "rate of remuneration per calendar day" by 72. The figure arrived at is his gross
7
compensation in lieu of notice, which would be subject to any lawful deductions, such as income tax.
We will reserve our jurisdiction to deal with any matter related to compensation, if the parties have
any problem implementing this order.
Done at London, Ontario, this day of, 1988.
J. W. Samuels, Chairman
R. J. Gallivan, College Nominee
I CONCUR
W. Majesky, Union Nominee
ADDENDUM
I am in receipt of chairman I s award in the above matter and concur with the
decision, however, I think the award merits an additional comment.
The decision clearly accepts that the grievor was a probationary teacher and had
the right to grieve the improper notice given regarding his termination. The
collective agreement expressly provides for 90 days notice, and provides for no
"split the difference" remedy, where, if the employer is remise in notifying the
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employee within the 90 day timelines, then whatever days notice have been provided,
are subtracted from 90, and the grievor compensated for the remaining days.
I believe that the grievor was entitled to receive 90 days notice and that the
Chairman has the jurisdiction to award damages for an improper notice of lay-off,
re Lufkin Rule Co. of Canada Ltd. (1970), 22 L.A.C. 276 (Shime). If a claim for
damages is to be awarded in these circumstances, it must clearly be shown that
failure to give improper notice in some way prejudiced him or caused him harm, re
Red Lake Board of Education (1982), 6 L.A.C.
(3d) 20 (R.L. Kennedy); Rexwood Products Ltd. (1981), 3 L.A.c.
(3d) 83 (Brown); John Inglis co. Ltd. (1964), 14 L.A.C. 341
(cross) .
I believe the employee was prejudiced by not receiving proper notice. The employer,
although failing to apply the notification provisions of the collective agreement,
has shown an extreme propensity to observe the provisions of the collective
agreement regarding language on sessional and probationary teachers. If the
employer were to apply as much scrutiny to the notification provisions as with the
rest of the agreement, this issue would not have arose.
If this employee were an electrician in the construction industry, he/she could
merely go to the hiring hall the day after lay-off. The circumstances in this case
are entirely different. The grievor is a teacher and a member of a profession whose
members work under entirely different working conditions, particularly whether a
teacher can get a job the next day or go into a centr~l supply pool. Though the
term "supply pool" is more apt to School Boards and their Teachers, it consequently
is not an available recourse for which the grievor could turn. Thus making it more
difficult for the grievor to find' suitable or alternate' employment without the
ninety (90) days notice.
Since the grievor was a faculty member, the language in the agreement regarding
notice is of particular importance and has a unique purpose to members of the
Community college teaching profession. The unique purpose of the 90 days is to
provide enough lead-time for teachers to search for employment in another
jurisdiction, or, with another employer once notified of their terminal date of
employment. But, more importantly, teachers do not just walk into jobs all year
round and are subject to the timing and rhythm of the semester system. In addition,
the teaching profession is also extremely limited in securing employment, or
conversely, only potentially able to apply for employment at certain times of the
year.
These certain times are windows of opportunity in the teaching profession. Thus, if
a teacher misses the hiring phase of the next semester, an individual teacher will
be unduly prejudiced if he/she were to seek work in the other 22 community colleges
in Ontario, as well as school boards. As well, the collective agreement provides no
rationale why 90 days is required. It is certainly my belief that the 90 days is
meant to provide an individual employee under contract with the college ample time
to plan for his/her livelyhood once their teaching contract has expired.
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In addition, the collective agreement provides for no mechanism or right to suspend
the lay-off notice provisions of the collective agreement, whether for emergency or
any other reason. If you examine how the college administratively handled this
situation, you find that the employer notified the grievor on April 16, 1987, that
his period of employment was being extended to May 22, 1987. Then on April 27,
1987, the grievor was notified that a policy decision was made which terminated his
employment as of May 15, 1987.
The process that the college applied in notifying the grievor of his contract being
extended, then terminated, leaves something to be desired. At best I would describe
it as unprofessional, lacking an element of good faith and an example of
insensitive management. One would hope that a large public institution which
teaches business student courses on productivity, public administrat ion and human
resources, would surely know their obligations under the applicable collective
agreement. Especially the frequently applied provisions of the lay-off procedure,
which requires employers to apprize employees who are to be laid off of that fact
some time before the occurrence of the actual event.
For the reasons .enumerated above, I believe the grievor was prejudiced by not
having the full benefit of 90 days notice, and should be entitled to the full 90
ninety days notice as specified in the collective agreement. Article 8.01(c),
states that a teacher who has been a teacher for more than five months is for the
remainder of the employee's probationary period, entitled to at least ninety (90)
calendar days' written notice. If re quested by the employee, the reason for such
release will be given in writing.
. . .3
The grievor in this instance had been a teacher for more than five (5) months and
therefore entitled to ninety (90) days notice.
If the agreement contemplated subtracting the number of days notice provided by the
employer from ninety (90), and paying the employee for the days he wasn't notified,
then there should be language in the collective agreement to support such a remedy.
But, in this case there is no such language, it says ninety, and that is why I
would have awarded the grievor ninety (90) days pay in lieu of notice.
Respectfully Submitted By:
wally Maj esky
Union Nominee
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IN THE MATTER OF AN ARBITRATION
BETWEEN LOYALIST COLLEGE OF APPLIED ARTS AND TECHNOLOGY
(The Employer)
AND ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF THE GRIEVANCE OF ROY CHAPMAN (FILE #88A755)
BOARD OF ARBITRATION H.D. BROWN, CHAIRMAN
J. MCMANUS, UNION NOMINEE R.J. GALLIVAN, EMPLOYER NOMINEE
APPEARANCES FOR
THE EMPLOYER ANN BURKE, COUNSEL
D. BUTLER, DIR. OF PERSONNEL
APPEARANCES FOR
THE UNION JANET E. MOSHER, COUNSEL
H. PLUMMER, LOCAL PRESIDENT
R. CHAPMAN, GRIEVOR
A HEARING IN THIS MATTER WAS HELD AT TORONTO ON JULY 12,1988.
AWARD
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A grievance was filed on March 4, 1988 under the
provisions of a collective agreemen then in effect between the parties which claims
as follows:
"As a probationary employee with more than five months service, I have a
substantive right to 90 calendar days written notice of termination (Art.
8.01(c). I received a letter of termination on February 17/88 making my
termination effective May 6, 1988. 'This notice is less than the required
90 calendar days.
I request the full 90 calendar days notice. If given proper notice of 90
calendar days, my "termination" date would be on or about May 17, 1988 at
which time I would qualify as a full-time non-probationary employee and
would have claim to all rights and priveleges of the co~lective
agreement.
The parties agree that the Board was properly
constituted and that it had jurisdiction to deal with the dispute.
By letter dated February 17, 1988 the Employer informed the grievor that
"your probationary position at the College
will be terminated with effect from May 6, 1988,
which will be your last working day. . .
-2-
The Union's position is that the notice of termination
was 79 days while the grievor was entitled under Article 8.01(c) to 90 calendar
days written notice. This Article is as follows:
(c) During the probationary periodan employee will be informed in writing ofthe
employee's progress at intervals of four (4) months continuous employment or four (4) full
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months of accumulated non-continuous employment and a copy given to the employee.
Also, it is understood that an employee may be released during the first five (5) months of
continuous or non-continuous accumulated employment following the commencement
date of the employee's employment upon at least thirty (30) calendar days' written notice
and during the remainder of the employee's probationary period upon at least ninety (90)
calendar days' written notice. If requested by the employee, the reason for such release
will be given in writing.
As of May 7 the grievor would have completed his probationary period so that he
would have been covered by the collective agreement. Therefore had 90 days notice
been given to him, it is alleged that the termination would have become effective
on May 17, at which time he would have acquired benefits under the collective
agreement having completed his probationary period. On May .6 the grievor received a
cash payment which reflected hours of overtime, retroactive pay and vacation pay.
The Employer by memo to the grievor dated March 9, 1988 advised him that he had
115.25 days notice from February 17, 1988 as he woulld be receiving a
-3-
cheque for the equivalent of 36 1/4 days pay plus the 79 calendar
days of notice. At that time the grievor was also advised that "the college does
not consider. the release of an employee during the probationary period to be
grievable under 8.02(a) and thus your step one grievance dated March 4,1988 is
invalid. . ." The 36 1/4 days referred to in that memo was the grievor' s accrued
- - vacation entitlement which the College paid as part of the pay in lieu of notice to
the grievor. The grievance was denied by the Employer at the subsequent grievance
steps on the basis that he had received a total of 115 days in advance of the
stated date of termination and that the College objected to the grievance of the
grievor as a probationary employee. These matters were
subsequently referred to arbi tration and came on for hearing as
parties agreed to deal firstly with the preliminary objections
which the Board has determined in this award.
above noted. The
of the Employer
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The Union I s posi tion is that the grievor had not been given proper notice which
would, had it been given, have extended his employment to May 17~ Therefore the
question is whether the Employer had the right to discharge the grievor on May 6,
which the Union submits it did not but had violated Article 8.01; secondly, it is
the Union's position that the grievor had not been
-4-
given 90 days notice in the calculation of pay in lieu which
included accrued vacation pay which was improper so that the Union takes issue that
vacation pay can be part of the pay in lieu of notice. In its submission that does
not involve an amendment to the grievance which claims that the release on May 6
was not. val i d.
The submission for the College is that under Article 7.01 (b) it has the right to
discharge a probationary employee during the probationary period and by Art icles
8.02 (a) and 11.06 the probationary employee does not have a right to grieve the
discharge except in circumstances of discrimination or unlawful conduct which does
not arise in the present' circumstances. A bad faith allegation is not part of the
grievance. Reference in this regard was made to Re Sheridan College of Applied Arts
and Technology and OPSEU (Brown - September, 1987); Re Seneca College and OPSEU
(Samuels ~ September, 1985); Re Seneca College and OPSEU (Swan).
It was further submitted that the Union's position concerning the accrued vacation
pay to be not included as pay in lieu of notice is not part of the grievance which
would be
-5-
required to be amended to involve that dispute. It was submitted
that a probationary employee is enti tled only to proper notice and if the College
was required to give 90 days written notice prior to the expiry of the probationary
period, the period under the agreement would then be two years less three months,
which would be an amendment of the agreement. It was submitted that the Employer's
right to discharge a probationary employee is not impacted by the provisions of
Article 8.01(c) which is not a condition precedent to the valid release. That
section, in its submission, cannot be used to undo the legal effect of his
discharge as a probationary employee on May 6 after which the employment
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relationship did not continue. Reference was made to Re Algonquin college and OPSEU
(Brown - November, 1985); Re 91l_t~Ti~_~ouncil:........<=>J_Regents_,~_Coll~3es_~nd_A12I:>_~.~,~s!
Arts And Technology and Civil Service Assoc. of Ontario , 13 L.A.C. (2d) 82
(Weatherill). It was further submitted that the notice of 72 days exceeded the
provisions for notice under the Employment Standards Act which was therefore not
relevant.Re Fanaken v. Bell, Temple, 7 C.C.E.L 317.
-6-
It was the submission for the Union that it did not take
issue with the jurisprudence that a probationary employee cannot grieve his release
or dismissal except where there has been bad faith or discrimination, but argued
that the grievor has not grieved his release but the notice period under Article
8.01 (c), Re Seneca College and OPSEU (Samuels - September, 1985), Re Seneca college
and OPSEU (Swan).. A substantive right in the collective agreement cannot be
procedurally removed and therefore the grievor does have the right to grieve the
Employer's failure to give proper notice. In its submission, proper notice was 90
calendar days written notice of termination and in interpreting that phrase it is a
requirement to apply the Employment Standards Act, Re McLeod v. Eagen, 46 D.L.R.
(3d) 150. By section 20f the Act part 12 applies so that by Section 40 (1), which
in part is:
"No Employer shall terminate the employment of an employee who has been
employed for three months or more unless the Employer gives,
(b) two weeks notice in writing to the employee if his or her period of
employment is one
year or more but less than three years;...
and such notice has expired.
-7-
It was argued that until the notice has expired, the employee
cannot be terminated under this legislation. The collective agreement provides for
90 days notice of termination which is a greater benefit than provided in the Act,
which is referred to in Section 4, but the principle remains the same that
termination is after the expiry of the notice period. In its submission, in the
application of Article 8.01 (c) the above section must be appl ied to give the
reading which the Union urges that the employee must be given 90 days advance
notice of termination. That Article fetters management's discretion to discharge an
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employee under Article 7 of the agreement. Where there has not been proper notice
given under Article 8.01(c), the grievor should be placed as a matter of remedy, in
the position that he should have been had there not been a breach of the collective
agreement. It was submitted that a remedy therefore of eleven days pay to complete
the notice 'period of 90 days would not satisfy the claim as had the Employer not
breached Article 8.01(c), the grievor would have completed his probationary period
and would be entitled to all rights under the collective agreement.
-8-
It was further submitted that if the Board found against
the Union's position set out above, then an issue would arise as to whether the
Employer could combine vacation pay with in lieu pay for the purposes of notice of
termination which, in its submission" is not an amendment to the grievance' as there
is an allega tion of failure to give proper notice. In the alternative, the grievor
would be entitled to 11 days pay at the minimum, but the claim does not change the
substance of the grievance which is that he did not receive proper notice of
termination and that does not give rise to a new claim concerning the vacation
entitlement which can be included in the claim for proper notice.
The issue of whether a probationary employee can grieve his dismissal has been the
subject of many arbitration awards between these parties and as a proposition as
held by the various awards, is accepted by the Union in this case. For reference
however, in that regard, the current state of such issue has been dealt with by
this Chairman in the Sheridan College and Algonquin College awards, which need not
be repeated in this award.
The Union maintains in the present matter that the grievor is not grieving his
release as a probationary employee,
-9-
but his lack of proper notice under Article 8.01(c). The facts
are not in dispute that the grievor was given notice of termination on February 17,
1988, effective May 6, 1988 which was 79 calendar days after the written notice was
given to him. His last day of work was May 6 at which date he was a probationary
employee. The probationary period under the collective agreement as set out in
Article 8.01(a) as:
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(i) A full-time employee will be on probation until the completion
,of the probationary period which shall be two (2) years' continuous
employment.
Under Article 8.01 (c) a probationary employee within the two year period can be
released after five months on at least 90 calendar days written notice. The
Employer provided 79 calendar days of written notice and payment in lieu of notice
which it claimed to allow 115 days. The first issue however to be determined, is
whether there was a breach of Article 8.01(c) by the Employer which could lead to a
negation of the notice of termination or to an extension of time for the notice to
take effect unti 1 May 17, at which time the grievor would have completed the two
year probationary period. What the Union urges is that the Employer
-10 -
must give 90 days written notice of termination under Article
8.01(c) and therefore by giving 79 days plus payment in lieu, it did not comply
with this section and at May 6 the grievor was not properly terminated but should
have been maintained as an employee until the expiry of the proper notice period at
May 17. If that was correct, then the grievor could claim the rights of the
collective agreement as a regular employee.
The Union's position concerning the effect of the notice under Article 8.01(c)
would allow the grievor to indirectly contest his release as a probationary
employee when that is not an issue which is arbitrable under the collective
agreement. When the griever was given notice of termination he was a probationary
employee. Article 11.06 provides that:
"It being understood that the dismissal of an employee during the
probationary period shall not be the subject of a grievance. . .
Article 8.01(c) does not condition the right of the Employer to discharge an
~mployee but provides the right of a probationary employee to notice. The term of
the probationary period is not
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-11 -
qualified by the requirement to give 90 days notice prior to its
expiry That would mean that the probationary period would be two years less three
months and if a notice of terminationwas not given within that period, the
probationary period would automatically end at the end of two years and that
employee, although subject to a notice of something less than 90 calendar days,
would fall within the provisions of the collective agreement, which is the
grievor's position in this case. In our view, the Union's position on this issue
would require an amendment to Article 8.01 (a), which this Board could not make
having regard to the restriction on its authority in Article 11.04 (d).
The issue of whether a notice of release of a probationary employee is effective on
the date of such notice or after the expiry of the notice period was dealt with in
the CSAO award (supra) where the Board chaired by Mr. Weatherill at page 83
-12
said:
"In the instant case, the employer purported to, and took appropriate
steps to "release" the grievor, that is to terminate the empl~yment
relationship during the probationary period. That is something which the
collective agreement contemplates the employer may do. Under art. 8.01
(a) however, such release may be affected on notice. The question which
arises in the instant case is whether or note, since there was no such
notice, the release or termination must be said to be a nullity."
And at page 85, the Board stated:
8 0111
"In our view, where art. 8.01(a) of the collective agreement provides
that the employer may release a probationary employee upon notice, it
does not make the giving of such notice a necessary condition precedent
to the release. Failure to give such notice would be a violation of the
agreement for which an appropriate remedy (such as payment in lieu of
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notice) could be granted. It is our view, however, that it would take
express language in the collective agreement to establish the giving of
notice as a necessary condition precedent to the release of probationary
employees, and to effectively alter the express provision of the
agreement that the probationary period "shall be of two years' duration".
Such language does not appear in this collective agreement."
-13 -
The same result as to the language of the collective agreement
applies in the instant case. In our view, the above mentioned case has determined
the very issue now raised by the Union in this grievance. In the Seneca College -
Roy grievance, the Board stated at page 6:
"In our view, a "release" is nothing more than the termination of
employment of a probationary employee pursuant to Article8.01(c). It is
the reality which matters. There is no doubt here that the College
intended to terminate the employement of the grievor. Because Mr. Roy was
a probationary employee at the time of this termination, it was a
"release
But the College failed to give the requisite 90 days' notice. The grievor
is entitled to compensation in lieu of notice... Mr. Roy received notice
on April 27, 1987 that his employment would end on May 15, which is 18
calendar days' notice. He is entitled to compensation in lieu of notice
for an additional 72 calendar days."
-14 -
That Board relied on the ratio of the CSAO case referred to above.
The grievor was dismissed during his probationary period on February 17, 1988 when
he was released from his employment and that dismissal was in accordance with
Article 7 which is not conditioned by Article 8.01 (c). What the grievor is entitled
to under that section is at least 90 calendar days of notice. That is the only
issue, in our view, which arises from the circumstances of his release from
employment on February 17, 1988.
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The Employer is not required by the agreement to give 90 calendar days of notice as
a condition of release of a probationary employee. Where the notice provided under
Article 8.01(c) has not been met, the issue can only be the amount of notice and
compensation for any deficiency, but a breach of Article 8.01(c) does not lead to
an extension of the time for termination in order to exceed, and therefore
complete, the probationary period under Article 8.01 (a). The grievor was terminated
as a proba tionary employee on February 17, He is enti tled as of tha t date to 90
days notice and therefore payment, but that does not extend his employment
relationship which has been severed by the Employer when the grievor was a
probationary employee.
-15 -
Section 4 of the Employment Standards Act provides that
the provisions of the Act are minimum and where the collective agreement provides a
greater right, the greater right prevails. Clearly, this collective agreement
provides a greater right to notice than the Employment Standards Act which
therefore does not have any application in these circumstances.
The Board finds that the claim of the grievor is limited to compensation with
regard to the notice actually given to him at the time of his termination on
February 17. That involves an issue of remedy as to whether vacation pay can be
combined with severance pay to provide the required 90 day notice period. That is
an issue of remedy which flows from the claim in the grievance and is not an
amendment of the grievance as submi tted by counsel for the College. The Board
cannot conclude at this point as that issue was not dealt with on its merits by the
parties, whether there was a breach of Article 8.01(c) If the Employer's position
is correct that its payment for 79 calendar days plus 36 1/4 days of vacation pay
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consti tutesnotice which then would amount to 115 days exceeding the requirement of
Article 8.01(c), there would then not be a violation of that Section. On the other
hand, if that position is not allowed, the Employer would be found
-16
to have made a deficient,payment under this Article, and therefore
be required to compensate the grievor to the extent of 11 days of pay. That is the
narrow issue remaining in this dispute.
For these reasons, the Board finds that the grievor's employment as a probationary
employee was terminated on February 17, 1988. The Board finds that the Employer was
not in violation of the collective agreement in the release of the grievor as a
probat ionary employee and which is not an arbitrable issue under this .agreement.
The Board retains jurisdiction to deal with the remaining issue of the remedy in
the application of Article 8.01(c).
DATED AT OAKVILLE THIS.6TH. DAY OF SEPTEMBER, 1988.
H.D. BROWN, CHAIRMAN
J. MCMANUS, UNION NOMINEE
R.J. GALLIVAN, EMPLOYER NOMINEE
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IN THE MATTER OF AN ARBITRATION
BETWEEN:
F ANSHA WE COLLEGE
(the" College ")
- and:-
.
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(the "Union")
RE RELEASE IN RESPECT OF MARCIA ROBSON
BOARD OF ARBITRATION: Pamela C. Picher - Chairperson
Rene St. Onge - Employer Nominee
iohn McManus - Union Nominee
APPEARING FOR THE
COLLEGE: Pamela Chapman - Counsel
APPEARING FOR THE
UNION: Brenda Bowiby - Counsel
:k-
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Hearings in this matter were held in London on May 19 and June 27, 1988.
AWARD
The Union maintains that the College failed to give the grievor, Ms. Marcia Robson, notice of release
from employment that was in compliance with the tenns of the collective agreement. It is the position
of the Union that the grievor, a full-time probationary employee at the time of her release, was entitled
to at least ninety days written notice of release pursuant to the combined operation of article 1 ( c) of
Appendix III (Sessional Employees) to the collective agreement and article8.0 l(c) of the agreement.
Those and other relevant provisions are set out below:
APPEND IX III
SESSIONAL EMPLOYEES
l(a) A sessional empIoyee is defined as a full-time employee appointed on a sessional basis
for up to twelve (12) full nnntts of continuous or non-continuous accumulated
employment in a twenty-four (24) calendar month period. Such sessional employee may be
released upon two (2) weeks'written notice and shall resign by giving two (2) weeks' written
notice.
(c) If a sessional employee is continued in employment for more than the period set out in
paragraph (a) above, such an employee shall be considered as having completed the first
year of the two (2) year probationary period and there after covered by the other
provisions of the Agreement. The balance of such an employee's probationary period shall
be twelve (12) full months of continuous or non-continuous accumulated employment
during the immediately following twenty-four (24) calendar month period.
Article I
RECOGNITION
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1.01 The Union is recognized as the exclusive collective bargaining agency for all academic
employees of the Colleges engaged as teachers (includihg teachers of Physical Education),
counsellors and librarians, all as more particularly set out in Appendix I hereto save and
except Chairmen, Department Heads .and Directors, persons above the rank of Chairman,
Department
-2-
Head or Director, persons covered by the Memorandum of Agreement with the Ontario Public Service
Employees Union in the support staff bargaining unit, and other persons excluded by the legislation
and teachers, counsellors and librarians employed on a part-time or sessional basis.
NOTE A: "Part-time in this context stall include persons who teach six hours per week or less)'
NOTE B: "Sessional in this context shall mean an appointment of not more than twelve months
duration in any twenty-four month period."
Article 8
SENIORITY
8.01 (a)(i) A full-time employee will be on probation until the completion of the probationary
period which shall be two (2) years' continuous employment.
(ii) A full-time employee hired after September 1, 1981,' who has completed a probationary
period at another Ontario College of Applied Arts and Technology or who holds a valid Ontario
Teacher's Certificate and who has one year or more of teaching experience in Ontario will be on
probation until the completion of the probationary period which shall be one year's continuous
employment..
(b) Effective September 1, 1976, the probationary period shall also consist of twenty-four (24) full
months of non-continuous employment (in periods of at least one (1) full month each) in a forty-eight
(48) calendar month period. For this purpose, only the period after September 1, 1975, shall be
considered and no prior employment or calendar period shall be taken into account or credited.
However, an employee's continuous service acquired in accordance with the provisions of the
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previous agreement dated the 17th day of September 1975, as at August 31, 1976, for the period back
to September
1, 1975, shall count as continuous employment or months of non-continuous accumulated
employfuent for the purpose of this Section.
For the purpose of this paragraph, effective September 1, 1976, a calendar month in which the
employee completes fifteen (15) or more days worked shall be considered a "full month".
-3-
(c) During the probationary period an employee will be informed in writing of the employee's
progress at intervals of four (4) months continuous employment or four (4) full months of
accumulated non-continuous employment and a copy given to the employee. Also, it is
understood that an employee may be released during the first five (5) months of continuous or
non-continuous accumulated employment following the commencement date of the employee's
en$oynnn upon at least thirty (30) calendar days' written notice and during the remainder of the
employee's probationary period upon at least ninety (90) calendar days' written notice. If
requested by the employee, the reason for such release will be given in writing.
(d) Upon the completion of the employee's probationary period, a full-time employee shall be
credited with two (2) years' seniority if treated under 8.0l(a)(i) or one (1) year's seniority if
treated under 8.0 l(a)(ii). An employee who commenced full-time employment with the College
directly from the College's predecessor educational institutions shall be credited for the purpose
of this Article with seniority equal to the employee's continuous service in such predecessor
institution. The list of predecessor educational institutions referred to herein is attached as
Appendix VIII of the Collective Agreement.
[emphasis added]
The grievor has been employed by the College through a series of partial load or full-time sessional
appointments since 1979. By March of 1979 she had completed "twelve (12) full months of
continuous or non-continuous accumulated employment in a
twenty-four (24) calendar month period" within the meaning of article 1 (a) of Appendix Ill, set out
1- 01]]
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above. Ms. Robson was then continued in employment for a further period, the period in dispute
which gives rise to this arbitration.
'~- ::
By a letter dated April 9, 1986, Ms. Robson was offered "temporary" employment as a full-time
probationary teacher for a definite term extending from April 14, 1986 to May] 6, ] 986. The letter
further stipulated that her employment with the College would cease on May 16, 1986. Ms. Robson
was thus provided with approximately 37 days
-4-
notice of release through the same letter that offered her a term contract of employment of
approximately 32 days. The letter dated April 9, 1986 reads as follows:
Dear Ms. Robson:
As a followup to your recent conversation with Mr.M. Black, we are pleased to be able to
confirm an offer of temporary employment as a 'Full-Time Probationary' teacher in the
Preparatory Studies Division of the College, for the period 1986 04 14 to 1986 05 16 inclusive.
The teaching assignment has been established with you and will onlybe altered if necessary,
after discussion with you.
Unless you are advised otherwise in writing, your employment with the College will cease on
1986 05 16 without further written notice.
The terms and conditions of this employment are in accordance with the Collective Agreement
for Academic Employees. Please contact Human Resources should you require a copy of that
document. Your pay will be based on a rate of$28,377.00 per annum, and you will be paid on
or about the 24th of each month, into a bank account designated by you. The above- quoted rate
includes vacation pay. Deductions such as Income Tax, Canada Pension, Unemployment
Insurance and CHIP will be made as applicable.
Please sign and return a copy of this letter to our Human Resources Department (Room 81056)
to indicate your understanding of and acceptance of this offer of temporary employment. Would
you also please phone Human Resources (452-4246) to arrange for an interview for the purpose
of completing any necessary documentation. Note that your pay will be initiated only upon
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completion of both of the above actions.
Any queries regarding your teaching assignment should be directed to your department head.
Yours sincerely,
"Harry Rawson"
President
-5-
It is undisputed that for the period of employment under review Ms. Robson was no longer a sessional
employee, excluded from the bargaining unit. Instead she had attained the status of a full-time
probationary teacher within the bargaining unit. She no longer was paid an hourly wage but was paid
on the basis of an annual salary with benefits and deductions. Ms. Robson testified that when she read
the terms of the April 9th letter offering her a limited term appointment of approximately 32 days she
was concerned that she was not being provided with proper notification of her release from that
appointment and thus consulted the Union. As requested, Ms. Robson signed the contract and letter
from President Rawson but submitted at the same time the following letter of explanation and
position:
1986 04 10
Dear Mr. Rawson:
Please find enclosed a copy of my 'Full-Time Probationary' contract for the period 198604 14 to
1986 05 16 inclusive.
Assuming that this contract is in accordance with the Collective Agreement, I accept the
conditions of this agreement.
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Sincerely,
"Marcia Robson"
On or about May 29, 1986, Ms. Robson filed a grievance alleging that she had received inappropriate
notice of release.
On June 12, 1986, Ms. Robson sent the College a memo indicating that she would be unavailable for
employment from June 30, 1986 to August 15, 1987 and further stating
-6-
that upon her return she wanted to resume her relationship with the College. Ms. Robson utilized the
period for personal professional development. It is common ground that when she became unavailable
she was not currently employed by the College and thus was not given 'permission" to leave. She did
not take a "leave of absence" as that term is commonly understood in the employment context. When
Ms. Robson developed the intention to become unavailable to work for the College from June 30,
1986 to August 15, 1987 and whether she communicated that intention to the College prior to her
memorandum dated June 12, 1986 was not revealed in evidence.
The Union argues that article 8.01(c) entitled the grievor to at least 90 days written notice of release.
The Union submits that at the point of her April-May 1986 appointment the grievor was in the second
year of her two year probationary period, and thus was well beyond the first five months of her
probationary period during which only 30 days notice of release would be required. To place the
grievor in the second year of the two year probationary period where she would be entitled to 90 days
notice of release, the Union relies on article l(c) of the collective agreement which provides that a
sessional employee who has completed 12 months of continuous or non-continuous accumulated
employment in a 24 calendar month period "shall be considered as having completed the first year of
the two (2) year probationary period and thereafter covered by the other provisions of the Agreement".
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It is the position of the Union that proper notice of release is a mandatory condition precedent to the
effcctiveness of the release and that in the abscnce of due notice the release is void ab initIo. In
support of this position, counsel relies on the decision in Re CIP Containers Ltd. and Intemational
Chemical Workers, Local 229 (1973),
-7-
2 L.A.C. (2d) 308 (FED. Brown). Accordingly, counsel maintains that the grievor is still employed
and that effective release would now require 90 days notice.
The College has a different view of the grievor's rights. First, counsel for the College argues that the
grievor was not "released" within the meaning of article 8.01 (c) of the agreement because her definite
term of employment from April 14, 1986 to May 16, 1986 just came to its natural end. Counsel
maintains that a teacher is "released" for the purposes of article 8.01 (c) if the College seeks to
terminate the teacher during an indefinite appointment or if it seeks to end ahead of its scheduled end
a definite term appointment such as the grievor's. The College maintains that since it did not try to
prematurely end the grievor's 30 day definite term appointment, the notice provisions in article 8.01(c)
were not triggered.
The second and alternative posItlon of the College is that if the notice proVISIOns apply to a
termination at the expiration of a definite tenn appointment then the grievor would only be entitled to
30 days notice because she was within the first 5 months of her period of employment with the
College as an employee within the bargaining unit. Counsel argues that the five months referred to in
article 8.01(c) must speak to the period of the grievor's employment as a full-time probationary
employee within the bargaining unit and cannot reach back to a point when she was a sessional
employee and not included in the bargaining unit.
As a further alternative position, counsel for the College maintains that even if the notice provisions
apply to the natural expiration of a definite term appointment and even if the grievor was entitled to
90 days notice of release, the failure to give due notice does not void the release. In support of this
position the College relies on the
-8-
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decision in Board of Governors of Sheridan College of Applied Arts and Technology and
Q.P.S.E.U. (grievance of Ronald Brackenridge) unreported decision of 3. Brunner dated May 6,
1985. Counsel maintains that at most the College would be obligated to compensate the grievor for
the shortfall in the notice that was actually given. Moreover, counsel maintains that the grievor should
not be compensated for any portion of the 90 days that would extend beyond June 30, 1986 since she,
by her own volition, became unavailable for work at that point.
After carefully considering the submissions of the parties the Board concludes that the plain meaning
of articles l(a) of Appendix III and article 8.01(c) is that once a sessional employee has completed 12
full months of accumulated employment in a 24 month period (as had the grievor by March of 1986),
that emploxee, at the commencement of a period of subsequent employment, (at least within the
. immediately following 24-month period), becomes a full-time probationary employee within the
bargaining unit having completed the first year of the two-year probationary period. Crediting an .
employee within the bargaining unit with probationary service thraigh work performed outside the
bargaining unit is not an alien concept in collective agreements and, we conclude, is expressly
provided f or in Appendix III of this collective agreement.
The clear wording of article 8.0 1 (c) indicates that the 30-day notice period which operates during "the
first five (5) months of continuous or non-continuous accumulated employment following the
commencement date of the employee's employment" refers to the first 5 months of the probation
period and is not restricted to the first five months of employment in the bargaining unit. This
interpretation flows directly from a full reading of the clause which expressly provides for a 90-day
notice period "during the remainder of the employee's probationary period ...". The use
-9-
of the word, "remainder" in this part of the clause makes it clear that the prior reference to the "first
five (5) months" means the first five months ofthe probationary period.
The Board concludes then that when the grievor performed her work from April 14 to May 16, 1986
she did so as a full-time probationary employee who through the operation of article 1 (a) of Appendix
III had been credited with one year of probationary service and thus was standing at the
commencement of her second year of probation. She thus had completed well more than 5 months of
accumulated employment and was entitled to at least 90 days wlitten notice of release. We observe
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that this conclusion does not prevent the College from giving a teacher in the grievor's position a term
of employment of less than 90 days. Rather it requires the notice of release to be 90 days.
The Board does not accept the assertion of the Union that the College's release was void ab mi-tb by
Virtue of its failure to give due notice. The release was effective but it was done in violation of the
collective agreement. Accordingly, the grievor should be compensated for the breach by being placed
in the position she would have been in had there been no violation of the collective agreement.
It was on April 9, 1986 that the College gave its notice of the release to be effective on May 16, 1986.
It thus provided approximately 37 days notice of release and the grievor was entitled to another 53
days notice. The evidence before the Board does not establish that the grievor would not have been
available to work throughout that 90 day period. Her notice to the College of her unavailability from
June 30, 1986 to August 15, 1987 was dated June 12, 1986 and thus followed her actual release. Once
the failure to give adequate notice has been established, the burden rests with the
- 10-
College to establish a proper basis for circumscribing the grievor's entitlement to compensation for the
shortfall in the notice. That burden has not been met ib this instance. It may well be that if the grievor
had been asked to work through the 90 day period instead of being released prematurely she would not
have become unavailable for work on June 30th. The date of her stated unavailability was formally
communicated by a letter dated June 12th, a date after her release. The College has not established
that the grievor would not have been available to work through the 90 day period if she had been
asked in a timely manner.
Accordingly, the Board concludes that the appropriate remedy for the College's breach of the
collective agreement is to compensate the grievor for 53 days wages in lieu of the notice she should
have received.
For the reasons set out above the Board finds that the College breached the collective agreement
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through its failure to provide the grievor with 90 days notice of release. The College is directed to
fully compensate the grievor for her losses on the basis of 53 days wages in lieu of notice. The Board
remains seized in the event that a dispute, arises over the implementation of this Award.
DATED at Toronto this 9th day of September, 1988.
Pamela C. Picher
Chair
"Rene St. Onge"
I CONCUR.
Employer Nominee
I CONCUR. "John McManus"
Union Nominee
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IN THE MATTER OF AN ARBITRATION BET WEE N:
')(.~1C
-
ST. LAWRENCE COLLEGE
(The Employer)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF THE GRIEVANCE OF A. ABEL -#87E45
BOARD OF ARBITRATION: Kenneth P. Swan, Chairman
R.J. Gallivan, Employer Nominee
Jane Bern, Union Nominee
Appearances:
For the Employer: Chris White, Counsel
For the Union: C.G. Paliare, Counsel
AWARD
At the hearing in this matter, the parties were agreed that the board of
arbitration had been properly appointed, and that we had jurisdiction to hear and
determine the matter at issue between the parties. Although the matter is quite
complex, counsel were able to proceed by documentary evidence admitted on consent
and oral submissions, without the necessity of calling witnesses.
Despite its agreement on our general jurisdiction in this matter, the Employer
argued that we were without jurisdic tion to hear the merits of the matter for two
substantial reasons, which were raised as preliminary obj ecti ons . The first of
these is that the grievance was filed beyond the time limits set out in the
collective agreement. The second, and more fundamental objection, is that the
grievor was a probationary employee at the time of the termination of his
employment, and that the present grievance, which effectively characterizes that
termination as discharge without cause, is not arbitrable. We shall deal with the
second objection first.
Before turning to the undisputed facts of this matter, it is useful to set out the
provisions of the collective agree ment on which the parties rely:
1.01 The Union is .recognized as the exclusive collective bargaining
agency for all academic employees of the Colleges engaged as teachers
(including teachers of Physical Education), counsellors and librari ans,
all as more particularly set out in Appendix I hereto save and except
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Chairman, Department Heads and Directors, persons above
-2-
the rank of Chairman, Department Head or
Director, persons covered by the Memorandum of Agreement with the Ontario Public
Servic e Employees Union in the support staf f barga in ing uni t, and other persons
excluded by the legislation and teachers, counsellors and librarians employed on a
part-time or sessional basis.
NOTE A: "Part-time in this context shall include persons who teach six hours per
week or less."
NOTE B: "Sessional in this context shall mean an appointment of not more than
twelve months duration in any twenty-four month period."
3.03 (1) The Salary scales as set out in
more than twelve (12) hours on a regular
up to and inc luding twelve (12) hours
paragraph (2) hereto and Appendix II.
Appendix I will apply to persons teaching
basis. Per.sons teaching over six (6) and
on a regular basis will be covered by
3.03 (2) Persons who teach over six (6) and up to and including twelve (12) hours
per week on a regular basis shall be referred to as "partial-load" employees and
shall not receive salary, vacations, holidays or fringe benefits (except for
coverage of worker's Compensat ion and liabili ty insurance) under this Memorandum
and Appendix I but shall be paid for the performance of each teaching hour at an
hourly rate within the range of hourly rates set out in Appendix II and in
accordance with the other provisions of Appendix II.
3.03 (3) It is recognized that a full- time teacher who may be assigned by the
college to an instructional assignment of less than thirteen (13) hours per week
shall continue to be paid on the basis of salary rather than on an hourly rate
except as may occur through the application of Article 8, seniority, or as may be
mutually agreed between the employee and the College.
-3-
8.01 (a) (i) A full-time employee will be on probation until the completion of the
probationary period which shall be two (2) years' continuous employment.
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(ii) A full-time employee hired after September 1, 1981, who has completed a
period at another Ontario College of Applied Arts and Technology or
valid Ontario Teacher's Certificate and who has one year or more
experience in Ontario will be on probation until the completion of the
period which shall be one year's con tinuous employment.
probationary
who holds a
of teaching
probationary
(b) Effective September 1, 1976,
the probationary period shall also consist of twenty-four (24) full months of non-
continuous employment (in periods of at least one (1) full month each) in a forty-eight
(48) calendar month period. For this purpose, only the period after September 1,
1975, shall be considered and no prior employment or calendar period shall be taken
into account or credited. However, an employee's continuous service acquired in
accordance with the provisions of the previous agreement dated the 17th day of
September 1975, as at August 31, 1976, for the ped,od back to September 1, 1975,
shall count as continuous employment or months of non-continuous accumulated
employment for the purpose of this Section.
For the purpose of this paragraph, effective September 1, 1976, a calendar month in
which the employee completes fifteen (15) or more days worked shall be considered a
"full month".
Effective September 1, 1981, if an employee completes less than fifteen (15) days
worked in each of the calendar months at the start and end of the employee's period
of employment and such days worked, when added together, exceed fifteen (15) days
worked an additional full month shall be considered to be completed.
1
(c) During the probationary period
an employee will be informed in writing of the employee's progress at intervals of
four (4) months continuous employment or four (4) full months of accumulated
non-continuous employment and a copy given to the employee. Also, it is understood
that an employee may be released during the first five (5) months of continuous or
non-continuous accumulated employment following the commencement date of the
employee's employment upon at least thirty (30) calendar days' written notice and
during the remainder of the employee's probat ionary period upon at least ninety
(90) calendar days' written notice. If requested by the employee, the reason for
such release will be given in writing.
(d) Upon the completion of the employee's probationary period, a full-time employee shall be
credited with two (2) years- seniority if treated under 8.01(a) (i) or one (1)
year's seniority if treated under 8.01(a) (ii) An employee who commenced full-
time employment with the College directly from the' college's predecessor
educational institutions shall be credited for the purpose of this Article with
seniority equal to the employee's continuous service in such predecessor
institution. The list of predecessor educational institutions referred to herein is
attached as Appendix VIII of the Collective Agreement.
8.02 (a) It being understood that the release of an employee during the probation
ary period shall not be the subject of a grievance under the Grievance Procedure,
an employee who has completed the probat ionary period and is discharged for cause
may lodge a grievance in the manner and to the extent provided in the Grievance
Procedure.
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Appendix II
PARTIAL-LOAD EMPLOYEES
2. It is agreed that Art icle 8 has no application to partial-load teachers except
-5-
as referred to in section 8.05 (d) and Section
8.1S(b). Such partial-load teachers may be released upon two (2) weeks'
written notice and shall resign by giving two (2) weeks' written notice.
3. For the purpose of determining the service of a partial-load teacher under
Section 8.oS(d) a partial-load teacher will be entitled to credit for
service from september 1, 1971 (but not earlier) on the basis of one-half
(1/2) month's credit for each full month of service up to January 1, 1977
and thereafter on the basis of one-half (1(1) month's credit for each
calendar month in which .the employee teaches thirty (30) hours or more.
Appendix IV
In the administration of Section 8.0S(d) and for that purpose only, a
part-time employee shall be considered to have service based on
one-quarter (1/4) month's credit respectively for each full month of
employ ment with the College.
Article 8.05 (d), which is referred to in the above provisions, relates to the
relative priority of full-time, partial-load or part-time employees on lay-off.
Reference will be made to this provision below, but there is no need to quote it in
its entirety.
The grievor's service with the College began in 1983 on a part-time basis, and
ended with a letter of termination dated september 25, 1986. The precise nature of
the grievor's employ ment record is central to this case, so we shall set it out in
detail. However, his employment is covered by nearly 20 over lapping payroll
authdrization forms, and we have decided to
-6-
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summarize these for the purpose of our assessment of his rights
in this matter. The following is our summary, based on the evidence presented:
1. From September 14, 1983 to September 9, 1984, the grievor was on a series of
part-time academic staff appointments. While these specific appointment documents
overlap somewhat, it appears that this can be treated as one single stretch of
employment, but on a part-time basis only.
2. From September 10, 1984 to January 27, 1985, the grievor was on a partial-load
academic staff appointment, which was interrupted by a strike from late September
to early November
1984.
3. From January 28, 1985 to January 5, 1986, the grievor was on a series of
sessional and partial-load and academic staff appointments, which both parties
agree should be treated as continuous sessional employment for the purposes of this
grievance.
4. From January 6, 1986 to October 10, 1986, he was on a probationary academic
staff appointment, which was terminated by notice of his release by letter dated
September 26, 1986, to be effective on October 10, 1986,
Based on this employment record, the parties are agreed that the grievor is
entitled to count service from January 28, 1985 to October 10, 1986 as service
toward the completion of his probationary period. The dispute is whether he can
count any other appointment toward his probationary period, and if so how
-7-
that affects the determination of his probationary status at the
time of his release. There are really three aspects to the disputed parts of the
grievor's service:
1. Is the grievor entitled to count any of his service prior to January 28, 1985
toward his probationary period?
2. Is the 90 day notice period specified in Article
8.01(c), which in this case was partially worked and partially paid out, required
to be counted toward the employee's probation ary period?
3. At the time of the termination of his employment, the grievor had accumulated 18
days of unused vacation, which was paid out by the Employer. Was the grievor
entitled to use those 18 days toward his probationary period?
The period of service which both parties agree that the grievor worked appears to
be one year and 256 days, although there were a few brief' interruptions in the
grievor 's sessional appointments and there is scope for arguing for a slightly
lower count. As will be seen, however, it is sufficient in this case to take the
one year and 256 day period as the basis for con side ration.
We turn first to the question of whether the grievor is entitled to count any of
his periods of part-time or partial-load employment prior to January 28, 1985. This
issue divides into two separate considerations. During 1984, the grievor I s employ
ment always fell below the 13 hour per week limit for partial load employees, but
during the month of January, because of
-8-
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additional assignments, his workload in the third week rose to 28
hours, while his workload in the fourth week was at 16 hours.
that last week, he began the sessional appoint ment from which
service counts.
Immediatel y after
time his accepted
The Union argues first that the provisions of Appendix II, . paragraph 3 entitle the
grievor to count his partial-load employment from September to December at one-half
month's credit for each of those months. The argument is based first on a
compar ison with Appendix IV, which speci fies . that part-time employees are
considered to accrue service credits "in the administrat ion of Section 8 . 05 (d) and
for that purpose only", and Appendix .11, paragraphs 2 and 3 in which no such
restrictive language as "for that purpose only" is found. In our view, however, the
effect of reading paragraph 2 of Appendix II, which provides that Article 8 has no
application to partial-load teachers except for 8.05 (d) and. 8.15 (b), combined with
the service calculation set out in paragraph 3 of that Appendix, was clearly
intended to achieve the same result as the wording used in Appendix IV. Given that
the probationa ry period calculation is found in Article 8.01, and that Artic le 8
has no application to partial-load teachers except as specified, we are of the view
that no credit is given for partial-load service towards the probationary period.
The Union also refers, however, to Re Sheridan College and Ontario Public Service
Employees Union (Smith), unreported, May 17, 1982 (Weatherill). This suggests that partial-load
-9-
service may be counted at the half-time basis specified in
Appendix II, paragraph 3 for the purposes of determining the position on a seniority
list of an employee who has already completed a probationary period.
The Employer argues that this case is simply wrong, but in our view it may readily
be distinguished in any event from the matter before us. In that case, there is no
discussion of counting time as a partial-load employee toward the completion of a
probationary period. The concept of "seniority" appears throughout clause 8.05, and
it is entirely possible that the board in the Sheridan College (Smith) case was
considering it in that context. In any event, there is nothing in the case to
suggest that the question now before us was raised before that board and considered
before they caine to the conclusion which they did. In our view, the clear words of
Appendix II mean that the grievor is not entitled to account any of his
partia l-load service toward his probat ionary period, whether or not such service
may be used to establish seniority once the probation is completed.
We turn next, therefore, to the situation in January 1985. During this period, the
grievor taught two weeks for a number of hours which clearly exceeded the
definition of partial load employee, which at the time was limited to 13 hours per
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week. The issue is whether the grievor can be said to have been teaching "on a
regular basis" beyond the definition.
,(-
,ri
~', -'l
This matter has been ,dealt with between-th'.e parties in
-10 -
l,l
Re St. Lawrenc~College and Ontario Public Service Employees
union (Arsenault), unreported, November 16, 1982 (Brent). At page 7 of that award,
the unanimous decision concludes:
It is our view that anyone who teaches more than six hours per week and
who also cannot be said to teach between seven and 13 hours per week "on
a regular basis" must be considered to be a full-time teacher. It is the
phrase "on a regular basis", which occurs in Article 3.03(b), which must
be given meaning.
The award continued to find that in a month when an employee worked for 13 hours per week for 10
teaching days and for 22 hours per week for 11 teaching days, that person could not be
said to have worked between six and 13 hOllrs "on a regular basis" during that month.
In a recent award, Re Algonquin College and Ontario Public Service Employees Union,
unreported, April 26, 1988 (Swan), the present chairman decided that not only the
quanti ty but also the quality of the assignment must be considered to decide whether
an assignment over the partial-load limit is on a regular basis. In this case, we really have very little
evidence from either party to assist us to assess the nature of the extra work assigned. What we
are able to infer from the documentation is that it was likely overload work of a
non-recurring nature. Some of it, indeed, seems to have involved course outline
work and student interviews on a one-time basis. In our view, this can hardly be
called a "regular" assignment.
We have come to the conclusion that, looked at as a
-11 -
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whole, the month of January 1985 must
'I
~.:,I'l'
t'
b ;'ti~ated
".':;\~~' -
as partial-load
"
employment, and the grievor therefore is.' not entitled to count this service toward
his probationary period. The extremely",high workload in the second week must be
seen in light of the pattern of the gr''tevor's employment prior to that week, and
indeed in light of what occurred after until he began his full-time sessional
employment following January 28. On balah~e, we think the Employer is right on this
issue.
, .
The second issue to be considered is' the' 90 day notice period. This notice is
required by Article 8.01 (c), and is expr~ssed to be "at least ninety (90) calendar
days' written notice" to be given "during the. .probationary period". This matter
has been considered in a number of earlier cases involving this collective
agreement and its ,predecessors, including Re Ontario College of Regents of Colleges
of Applied Arts and Technology and Ci vB service Association of Ontario (1976), 13
L.A.C. (2d) 82 (Weatherill), Re Fanshawe College and Ontario Public Service
Employees Union (Safran), unreported, January 21, 1981 (Rayner), Re Durham College
of Appl ied Art sand Technologx_ and ,Ontario Public Service Employees Union
(McIntyre), un reported, December 6, 1982 (Weatherill) and Re Sheridan College of
Applied Arts and Technology and Ohtario Public Service Employees Union
(Brackenridge) , unreported, May 8, 1985 (Brunner). All of these cases find, in
effect, that the entitle ment to three months' notice is entirely independent of
the two year duration of the probationary period, and that a release
-12 -
within the last three months of the probation period is equally
effective as one before, provided always that the full three months' notice must be given. Where
the notice period is not to be worked, the cases also conclude that payment in lieu
of notice is,sufficient.
The Union attacks all of these cases on the basis of the underlying principles, but
we are of the view that the decisions outline what is a perfectly reasonable
interpretation of all of the language of th~'collective agreement, and that it is an
interpretation which has persisted',,:,between the parties through several
renegotiations of the collective agreement. Some of these decisions, we observe,
have been unanimous.
In our
parties
view,
have
it would be wrong to disturb a line of
relied to regulate their relationship,
jurisprudence
and which is
on
of
which the
such long
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standing. In addition, however, we think we should observe that, while the matter
is not entirely free of doubt, we would have reached the same conclusion as to the
meaning of the collective agreement.
We turn finally to the question of whether the grievor is entitled to count the 18
days accrued but unused vacation to which he was entitled as of the termination of
his employment toward his probationary period. From the findings we have already made,
it will be obvious that our decision on this matter will not be conclusive of
anything, but we shall nevertheless respond to the arguments made by counsel.
The only provision in the collect i ve ag reemen t to which
-13 -
we were referred is clause 8.02 (b). That r~fers to the discharge
of an employee who has completed the probationary period, so it is of no direct
relevance here. It does, however, contemplate that vacation may be paid out in
addition to the notice period. While once again there is scope for some doubt, it
would appear to be an unusual practice to permit accrued vacation to count toward a proba t i onary
period unless specifi cally provided for. in the collective agreement. Under the
employment standards legislation applicable to most employment in this province,
vacation pay accrues from day to day, and is the subject of a statutory trust. The Union's reasoning
would therefore have th?e effect of making any express probationary period reduced by
the amount of accrued vacation, surely a rather extraordinary and complicated
approach to the measurement of probationary periods.
However, the Union also argues that vacation may not be a part of the notice
period, because Regulation 286 under the Employment Standards Act provides, in
section 11, that the length of notice of termination of employment shall not include
any week of vacation without the agreement of the employee terminated. The Employer
points out, however, in our view correctly, that Regulation 286 applies to the
so-called mass termination provi sions of the Employment Standards Act, and that
section 11 must therefore be read as applying to the statutory notice periods set
out in that provision. Therefore it cannot have general effect, and it does not apply to
the particular circumstances of this case. We find this argument persuasi ve, and we
therefore find
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that the 18 days of accrued vacation do not count toward the
grievor' s probationary period.
In the result, the grievor was still well wi thin his probationary period at the time of
his termination of employment, and his grievance against that termination, pursuant to
Article 8.02 (a), which has been interpreted in a number of cases involv ing this
collective agreement, is not arbitrable. In these circumstances, it is not
necessary for us to deal with the Employer's preliminary obj ect ion relating to
timeliness.
The grievance is therefore denied.
DATED AT TORONTO, Ontario this 19th day of January, 1989.
I concur "RJ. Gallivan"
R.J. Gallivan, Employer Nominee
"Jane Bern II
Jane Bern, Union Nominee
I dissent; see attached
ADDENDUM
We have received and considered our colleague's careful dissent in this matter, but
we regret that we still differ from her. There is, however, one point which she
raises which requires us to clarify the basis of the majority award.
On the issue of whether the 90 day notice period must be given, in effect, prior to
the expiration of 21 months of the probationary period, so that the notice period
may be served, day for day, within the two year probationary period, she relies on
Re C.S.A.O (Inc.) and The Ontario council of Regents for Colleges of Applied Arts
and Technology, et al., unreported, June 18, 1975 (Ont. Div. Ct.), which may be
referred to as the "Aitchison cases. She concludes, quoting us, that it would not be
-wrong to disturb a line of jurisprudence" when the Divisional Court has spoken so
clearly.
The line of jurisprudence of which we speak, however, is based upon Re Ontario
council of Regents of Colleges of Applied Arts and Technology and Civil. Service
Association of Ontario (Inc.), (1976) 13 L.A.C. (2d) 82 (Weatherill). In that case,
the majority distinguished the Aitchison case from the facts of the case before it.
In Aitchison, the effective date of release was outside the probation period; in
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the second case, the employee was terminated wi thin the last three months of the
probation period, but the termination was made of immediate effect, and payment in
lieu of notice was provided. The majority concluded that payment in lieu of notice
was suffi cient compensa tion for the loss of an actual three months' notice, and
that
-2-
termination of employment during the two year not ice period was
sufficient to satisfy the principles set out in the Ai tchison case, even where it took place
during the last 90 days of the probationary period. This decision, and in particular
its reasoning distinguishing the Aitchison case, was upheld on judicial review by
another panel of the Divisional Court in Re C.S.A.O (Inc.) and Ontario Council of
Regents for Colleges of Applied Arts and Technology, unreported, March 7, 1977
(Ont. Div. Ct.).
The case before us falls squarely into the reasoning of the board of arbitration
chaired by Mr. weatherill, which reasoning has received not only the "blessing" of
the Divisional Court, but the reasoned concurrence of a number of other boards of
arbitration, referred to in our original decision, since that time. As we have
observed, the interpretation is not beyond reasonable disagreement, but it is the
interpretation upon which the parties have conducted themselves for a decade, and
we think it would be wrong to disturb it now.
with the greatest of respect for our
disagree; as we have already suggested,
this issue.
colleague, therefor"e, we must continue
reasonable people may reasonably do so
to
on
IN THE MATTER OF AN ARBITRATION
BET WEE N:
ST. LAWRENCE COLLEGE
(The Employer)
-and-
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF THE GRIEVANCE OF A. ABEL -#87E4S
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BOARD OF ARBITRATION:
Appearances:
For the Employer:
For the Union:
Kenneth P. Swan, Chairman
R. J. Gallivan, Employer Nominee
Jane Bern, Union Nominee
Chris White, Counsel
C.G. paliare, Counsel
DISSENT
I have had an opportunity to review the award of the majority and disagree with a
number of the findings as well as the result.
At page six, Mr. Swan makes it clear that the parties agreed that the grievor was
entitled to count service from January 28, 1985 to October 10, 1986, as service
towards the completion of his probationary period. Thus, the grievor had
-2-
approximately one year and nine months of service toward his
probationary period of two years. I find it simpler to deal with this matter in
terms of months rather than to say that the grievor had one year and 256 days to
his credit.
I would have come to a different conclusion than the majority with respect to each
of the questions asked. I will simply follow the order as set out in the draft
award.
Can the Grievor Count Part-Time or Partial Load Em-lovment
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My conclusion is different than those of the majority at pages eight and nine. In
my view, both the provisions of Appendix II, Paragraph three and the Re Sheridan
College and Ontario Public Service Employees Union (Smith) case lead to the
conclusion that the grievor would have been entitled to one-half months' credit for
each month of employment from September to December, 1984. The distinction drawn by
the majority in the Sheridan College (Smith) case is not one that can be made on a
full and fair reading of that decision.
Then, for the month of January, 1985, where the grievor worked two weeks in excess
of 13 hours per week, coupled with his appointment to a regular full-time position,
can only lead to the
-3-
conclusion that the grievor began working full-time "on a regular
basis" at the beginning rather than at the end of that month. Thus, the entire
month of January ought to count towards the probationary period as well.
Ninety Day Notice Period
without question, this aspect of the majority decision has caused me the most
amount of concern because the decision is clearly contrary to the plain wording of
the collective agreement. Also, the majority has totally ignored a Divisional Court
decision squarely on point which contradicts the arbiprudence quoted by the
majori ty. The issue is one of whether the employer must give 90 calendar days
written notice during the probationary period or whether the employer can give
payment in lieu of notice thus shortening the probationary period. The grievor
received his letter of termination september 26, 1986, with a purported effective
termination date of October 10, 1986. Thus, he received approximately two weeks' written
notice. The Union argued that he was entitled to three months' written notice such
that he could not have been terminated in the circumstances of this case until at
least December 26, 1986.
-4-
The starting point in considering the validi ty of the
Union's argument, is the wording of the collective agreement. Article 8.01(c)
reads, in the relevant portions, as follows:
"Also, it is understood that an employee may be released during the first
five (5) months of continuous or non-continuous accumulated employment
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following the commencement date of the employee's employment upon at
least thirty (30) calendar days' written notice and during the remainder
of the employee's probationary period upon at least ninety (90) calendar
days' written notice."
It is obvious that the parties contemplated that a probationary employee who had
survived five months of the probationary period was entitled to at least 90 days'
written notice in order to be terminated. The purpose of such a clause in a
teaching context would be to ensure that the teacher had an opportunity to find
alternate employment while still maintaining a teaching position. It is obviously
clear that it is easier to find a job when one has a job and the parties must have
had this simple proposition in mind when they agreed upon the clause in question.
It would have been an easy matter to have said that employees were entitled to 90
days' notice had the parties intended that payment in lieu of notice would have
been adequate. Rather, the parties specifically stated that the employee was
entitled to 90 days' written notice and not money in lieu thereof. The majority has
obviously "written out" the requirement of written notice in Article 8.01(c).
Amending the collective
-5-
agreement in this fashion is expressly prohibited under this
collective agreement.
It may be that the result of the interpretation which the Union advanced and which
I accept is that the probationary period is shortened by 90 days but, this appears to be what
the parties contemplated. Obviously, this would not work any great injustice upon
the employer since the probationary period is a very lengthy two years.
Moreover, the Divisional Court clearly dealt with a decision which had erroneously
interpreted Article 8.01(c) in the same way as the majority. In that case the Court
stated:
In our view, the term 'release' must mean the total cessation of the
relationship of employer and employee and this cessation of the
relationship in this case must occur before the expiration of the two
year period.
-6-
The mere notification that such termination
will occur in the future does not of itself terminate the relationship.
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In adopting this view, we recognize the fact that this interpretation of
the term 'release' will have the effect of shortening the probationary
period to 21 months as it will then be incumbent upon an emPloyer in
circumstances like this to give the three months' notice at a time
sufficiently distant from the expiration of the probationary period to
allow the three months to run within the two year period. I should add as
well that. in our view, this interpretation of the agreement is not only
the -ro-er one. but also the only interpretation that the lan-ua-e of
this aareement could reasonably bear. " (emphasis added)
The Civil Service Association of Ontario
(Inc.) and The Ontario council of Regents for
Colleges of Applied Arts and Technology. et
al. (unreported decision of the Divisional
Court, June 18, 1975, Zuber, Morden and Reid,
JJ. )
In the face of the clear wording of the Divisional Court and the clear wording of
Article 8.01 (c) of the collective agreement, it is difficult to understand how the
majority has opted for relying upon arbitral awards to the contrary. Thus, it would
not be "wrong to disturb a line of jurisprudence" when the Divisional Court has
spoken so clearly.
-7-
Vacation Days
I read the provisions of the Em-lovment Standards Act differently than the
majority. In my view, Section 11 of Regulation 286 does not apply simply to mass
terminations. An employer cannot shorten a notice period by deducting vacation.
Therefore, it logically follows that the vacation period must be included in
determining the period of employment for the employee in question. I would have
found that the 18 days in question should have been counted. Obviously, if the
employee had taken the 18 days vacat ion at an earlier time, no one would have
argued that he had not completed his two year probationary period simply because he
took the amount of vacation that he was entitled to during the two year time frame.
In other words, the probationary period is not elongated beyond the two year time
frame to include the amount of vacation to which an employee is properly entitled.
Accordingly, in my view, the employee has exceeded the probationary period and we
should have dealt with the merits of this case in terms of determining whether he
15=uf 16
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was dismissed for cause.
ANE BERN
16"0116
03/12/2007 1 :57 PM
"
(~r'3S-
IN THE MATTER OF AN ARBITRATION
BET WEE N:
ST. LAWRENCE COLLEGE
(The Employer)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF THE GRIEVANCE OF A. ABEL - i87E45
BOARD OF ARBITRATION:
Kenneth P. Swan, Chairman
R. J. Gallivan, Employer Nominee
Jane Bern, Union Nominee
Appearances:
For the Employer:
Chris White, Counsel
For the Union:
C.G. Paliare, Counsel
D I SSE N T
I have had an opportunity to review the award of the
majority and disagree with a number of the findings as well as
the result.
At page six, Mr. Swan makes it clear that the parties
agreed that the grievor was entitled to count service from
January 28, 1985 to October 10, 1986, as service towards the
completion of his prObationary period. Thus, the grievor had
- 2 -
approximately one year and nine months of service toward his
probationary period of two years. I find it simpler to deal with
this matter in terms of months rather than to say that the
grievor had one year and 256 days to his credit.
I would have come to a different conclusion than the
majority with respect to each of the questions asked. I will
simply follow the order as set out in the draft award.
Can the Grievor Count Part-Time or Partial Load Em~loyment
My conclusion is different than those of the majority
at pages eight and nine. In my view, both the provisions of
Appendix II, Paragraph three and the Re Sheridan College and
ontario Public Service Employees Union (Smith) case lead to the
conclusion that the grievor would have been entitled to one-half
months I credit for each month. of employment from September to
December, 1984. The distinction drawn by the majority in the
Sheridan Colleqe (Smith) case is not one that can be made on a
full and fair reading of that decision.
Then, for the month of January, 1985, where the grievor
worked two weeks in excess of 13 hours per week, coupled with his
appointment to a regular full-time position, can only lead to the
,.
- 3 -
conclusion that the grievor began working full-time "on a regular
basis" at the beginning rather than at the end of that month.
Thus, the entire month of January ought to count towards the
probationary period as well.
Ninety Dav Notice Period
without question, this aspect of the majority decision has
caused me the most amount of concern because the decision is
clearly contrary to the plain wording of the collective
agreement. Also, the majority has totally ignored a Divisional
Court decision squarely on point which contradicts the
arbiprudence quoted by the majority. The issue is one of whether
the employer must give 90 calendar days written notice during the
probationary period or whether the employer can give payment in
lieu of notice thus shortening the probationary period. The
grievor received his letter of termination September 26, 1986,
with a purported effective termination date of October 10, 1986.
Thus, he received approximately two weeks' written notice. The
Union argued that he was entitled to three months' written
notice such that he could not have been terminated in the
circumstances of this case until at least December 26, 1986.
~~~
- 4 -
The starting point in considering the validity of the
union I S argument, is the wording of the collective agreement.
Article 8.01(c) reads, in the relevant portions, as follows:
"Also, it is understood that an employee may be
released during the first five (5) months of continuous
or non-continuous accumulated employment following the
commencement date of the employee's employment upon at
least thirty (30) calendar days' written notice and
during the remainder of the employee's probationary
period upon at least ninety (90) calendar days' written
notice."
It is obvious that the parties contemplated that a
probationary employee who had survived five months of the
probationary period was entitled to at least 90 days J written
notice in order to be terminated. The purpose of such a clause in
a teaching context would be to ensure that the teacher had an
opportunity to find alternate employment while still maintaining
a teaching position.. It is obviously clear that it is easier to
find a job when one has a job and the parties must have had this
simple proposition in mind when they agreed upon the clause in
question. It would have been an easy matter to have said that
employees were entitled to 90 days' notice had the parties
intended that payment in lieu of notice would have been adequate.
Rather, the parties specifically stated that the employee was
entitled to 90 days' written notice and not money in lieu
thereof. The majority has obviously "written out" the requirement
of written notice in Article 8.01 (c). Amending the collect ive
- 5 -
agreement in this fashion is expressly prohibited under this
collective agreement.
It may be that the result of the interpretation which
the Union. advanced and which I accept is that the probationary
period is shortened by 90 days but, this appears to be what the
parties contemplated. Obviously, this would not work any great
injustice upon the employer since the probationary period is a
very lengthy two years.
Moreover, the oi visional Court clearly dealt with a
decision which had erroneously interpreted Article a.OI(c) in the
same way as the majority. In that case the Court stated:
" In our view, the term 'release' must
mean the total cessation of the relationship
of employer and employee and this cessation
of the relationship in this case must occur
before the expiration of the two year period.
- 6 -
The mere notification that such termination
will occur in the future does not of itself
terminate the relationship. In adopting this
view. we recoanize the fact that this
interpretation of the term 'release' will
have the effect of shortenina the
-probationarY period to 21 months as . it will
then be incumbent upon an emploverin
circumstances like this to aive the three
months' notice at a time sufficientlY distant
from the expiration of the probationary
period to allow the three months to' run
within the two year period. I should add as
well that. in our view. this interoretation
of the agreement is not onlY the proper one.
but also the onlvinteroretation that the
lanquaqe of this agreement could reasonabl v
bear." (emphasis added)
The civil Service Association of OntariQ
lInc.) and The ontario council of Reaents for
Colleqes of Applied Arts and Technoloav. et
2L... (unreported decision of the Divisional
Court, June 18, 1975, Zuber, Morden and Reid,
JJ. )
In the face of the clear wording of the Divisional
Court and the clear wording of Article, 8.01 ec) of the collective
agreement, it is difficult to understand how the majority has
opted for relying upon arbitral awards to the contrary. Thus, it
would not be "wrong to disturb a line of jurisprudence" when the
Divisional Court has spoken so clearly.
" ~-~..,
- 7 -
Vacation Davs
I read the provisions of the EmDloyment Standards Act
differently than the majority. In my view, Section 11 of
1 - ~
Regulation 286 does not apply simply to mass terminations. An
employer cannot shorten a notice period by deducting vacation.
Therefore, it logically follows that the vacation period must be
included in determining the period of employment for the employee
in question. I would have found that the 18 days in question
should have been counted. Obviously, if the employee had taken
the 18 days vacation at an earlier time, no one would have argued
that he had not completed his two year probationary period simply
because he took the amount of vacation that he was entitled to
during the two year time frame. In other words, the probationary
period is not elongated beyond the two year time frame to include
the amount of vacation to which an employee is properly entitled.
Accordingly, in my view, the employee has exceeded the
probationary period and we should have dealt with the merits of
this case in terms of determining whether he was dismissed for
cause.
~"
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IN THE MATTER OF AN ARBITRATION
RECEIVED BY
JUN 2 fi 1996
BET WEE N:
HUMAN RESOURCES SE::Rf:TARIAT
ONTARIO COUNCIL OF Ri:GENTS
ST. CLAIR COLLEGE
(The College)
and
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF THE GRIEVANCE OF F. CHESTERTON - #94E243
BOARD OF ARBITRATION:
Kenneth P. Swan, Chairman
George Metcalfe, College Nominee
Jon McManus, Union Nominee
APPEARANCES:
For the College:
Barry Brown, Counsel
Kurt Moser
Kevin Mailloux
For the Union:
Nelson Roland, Counsel
F. Chesterton, Grievor
J. Jones, Steward
L. Smith, Steward
A WAR D
A hearing in this matter commenced in windsor on January
9, 1995, and continued on April 11 and 17, August 30 and October
11, 1995. At the outset, the parties were agreed that the board of
arbitration had been properly appointed, and that we had juris-
diction to hear and determine the matter at issue between them.
That matter is the grievance of Mr. Frank Chesterton,
dated May 20, 1994, which is in the following terms:
I grieve termination during second year of probation
without cause and with work for which I am qualified
available and being performed by others with less service
than I.
The grievor is certified as a General Machinist in the
province of Ontario. He apprenticed as a Machinist in the United
Kingdom, and worked at a variety of skilled jobs prior to immigrat-
ing to Canada in 1982.
He continued his employment as a trades-
person until 1992, when he was first engaged as an instructor at
the Industrial Resource Centre on the Rhodes campus of the College.
His duties there related to the Industrial General Machinist
course; in relation to which he taught a number of skills on
various pieces of equipment.
In the autumn of 1993, an unexpected vacancy was created
in the Contract Training department when another faculty member was
suspended because of pending criminal charges. The vacancy was of
an unknown duration, and the grievor was hired on a sessional
teaching contract from October 5, 1993 to March 31, 1994 to assume
most, but not all of the duties of the absent faculty member. In
!E:i! (
2
particular, the grievor was not equipped to teach Computer
Numerical Control (CNC) machining skills. While he asserted in his
evidence that he could have learned to do so, the only previous
experience on which he could rely was a period of time working on
a numerically controlled (NC) boring mill in England during the
1960s and 70s, and we conclude that thegrievor would have needed
significant re-training in order to attain CNC skills.
As a
consequence, the CNC aspects of the teaching load which he assumed
at this time were handled by Larry Smith, another faculty member of
the Industrial Resource Centre, and the Union Steward for the
Rhodes campus.
The sessional contract was dated October 6, 1993,
and actually signed by the grievor on October 22, 1993.
Sessional employment is covered by Appendix VIII of the
collective agreement, which defines a sessional employee as "a
full-time employee appointed on a sessional basis for up to 12 full
months of continuous or non-continuous accumulated employment in a
24 calendar month period". Paragraph 3 of Appendix VIII, however,
provides 'for what is sometimes called "roll-over" into probationary
employment.
That paragraph is as follows:
If a sessional employee is continued in employment for
more than the period set out in Appendix VIII, I, such an
employee shall be considered as having completed the
first year of the two year probationary period and
thereafter covered by the other provisions of the
Agreement. The balance of such an employee's probation-
ary period shall be 12 full months of continuous or non-
continuous accumulated employment during the immediately
following 24 calendar month period.
~::!:l
3
The combination of the grievor's earlier teaching
experience at the College, coupled with the sessional appointment
beginning October 5, 1993, had the effect of satisfying the
provisions of Article 8, paragraph 3 effective January 15, 1994.
It is not clear to what extent this factor was clearly in the minds
of those who were involved in hiring the grievor to replace the
suspended employee in October 1993.
It seems likely that factor
was overlooked in the need to fill the position quickly, particu-
larly because the Chair of the Contract Training Department, Mr.
Jack Costello, was to be replaced in January 1994 by Mr. Curt
Moser, and matters were somewhat in flux.
In any case , this
consideration was recognized at the latest by December 22, 1993, at
which time a revision to the appointment letter was created. That
revision included the following sentence:
Effective 1994-01-15 your status will change from
Sessional Instructor to Probationary. Please note that
the completion date of 1994-03-31 does provide proper
notice as per the Academic Collective Agreement.
Mr. Kevin Mailloux, who was Director of Human Resources
for the College at the material time, testified that the revised
letter was produced after it was discovered that the original
sessional contract would have the effect of allowing the grievor to
roll-over to probationary status.
There a.re pol icies and pro-
cedures established at the College for recruitment and selection,
and Mr. Mailloux testified that the implementation of those
policies requires that roll-overs be approved by a member of the
College's Executive Council, in effect the Vice-President. When it
~
4
appeared that the grievor's new sessional appointment would have
the effect of rolling him over into probationary status, Mr.
Mailloux took the matter to a member of the Executive Council,
although he cannot now remember who, and approval was granted to
allow the roll-over to take its course. Mr. Mailloux's testimony
was that such approval would have to come from the President.
Therefore, when the revision to the appointment letter was issued
on December 22, 1993, it was in effect a considered ratification of
the effect of a previously unconsidered administrative act.
~ ,
There is no doubt that the College takes the roll-over
matter very seriously.
Some sense of how seriously may be seen
from a memorandum dated March 1, 1995 from the President of the
College to all members of the Executive Council on the subject.
While this memorandum was issued after the grievance, and indeed
after the present arbitration had begun, its trenchant tone casts
some light on one of the arguments to be made by the Union, and we
therefore reproduce it here:
You are aware of my policy on staff rollovers to full
time status. The restrictions on hiring and prohibition
of unauthorized rollovers predate my arrival, and have
been expressed at executive Council and in my presenta-
tion to all managers. At the most recentEC meeting, I
had occasion to express my feelings on two violations
which occurred, and the lack of early warning and
alternative solutions which are required to be provided
by managers. I am led to believe that there are at least
five more staff vying for full time status because their
workloads have qualified them for such. I also under-
stand that the managers involved have been encouraging
these people to seek full time status themselves rather
than have the managers represent them. I do not consider
such practices qualify as either management or leader-
ship, but the abrogation of responsibility. If these
rollovers materialize, I will hold you personally
~
5
responsible.
I will also hold the managers between you and the
individuals who rollover, or who are potential rollover
candidates, responsible. The late notice to EC of
potential rollover problems is not an excuse or a reason
to proceed without holding those who failed to manage
accountable.
You may wish to discuss this with the candidates you are
interviewing for administrative positions.
In the result, therefore, by the operation of Appendix
VIrI of the collective agreement, the grievor became a probationary
employee effective January 15, 1994.
That caused him to be
entitled to the benefits of the collective agreement as they apply
to probationary employees, and also caused him to raise the
question of whether his workload should be charted on a Standard
Workload Form (SWF) , an exercise which would apparently entitle him
to some lieu time off in order to compensate for an overload. This
issue became a matter of disagreement between the grievor and Mr.
Moser which the grievor alleges to be part of the real reason for
terminating his employment.
We shall return to the evidence on
this issue below.
As March 1995 approached, discussions were taking place
among the Human Resources office and the management of the Rhodes
campus.
The grievor's original appointment to March 31 would
terminate about a month before the course with which he was
involved would end, and there was some thought that it would be
unfair to change instructors so close to the end of the program.
On the other hand, a number of items of dissatisfaction had arisen
wi th respect to the grievor' s performance, according to the
~
6
College's evidence.
His inability to teach CNC COlJrses was an
ongoing concern, one which was known from the beginning. In
addition, however, there were concerns about the extent to which he
was exercising proper supervision over his students, and concerns
about his consumption of alcohol over lunch breaks.
The grievor
denies the latter allegations, and we shall deal with that issue
below as well.
Finally, however, it was decided to extend the
grievor's contract by one month, and a new appointment letter dated
March 9, 1994 was sent, in the following terms:
This is to confirm that your current employment contract
has now been extended to 1994-04-29.
I am pleased to inform you that your original lay-off
scheduled for 1994-03-31 has now been deferred until
1994-04-29. All other conditions of employment will
remain unchanged.
In the result, therefore, the grievor taught until the
end of the current course on April 29, 1994 and thereafter was
glven no further teaching assignments and was treated as termin-
ated. There appears to have been no attempt to 'consider a recall
for the gri~vor; he was simply allowed to drift away while the
grievance was processed and referred to arbitration.
There is obviously a considerable degree of confusion
about the grievor's precise status at the time in question. At the
hearing, however, counsel for both parties acknowledged that by
April 29, 1994 he was a probationary emp~oyee, having attained that
status by the operation of paragraph 3 of Appendix VIII on January
15, 1994. It is therefore of importance to set out the provisions
7
of the collective agreement which bear upon probationary status,
and upon the other issues which this grievance raises.
Those
provisions are as follows:
Article 1
RECOGNITION
1.01 The Union is recognized as the exclusive
collective bargaining agency for all academic employees
of the Colleges engaged as teachers, counsellors and
librarians, all as more particularly set out in Article
14, Salaries, except for those listed below:
(i)
Chairs, Department Heads and Directors,
( i i)
persons above the rank of Chair, Depart-
ment Head or Director,
(iii)
persons covered by the
Agreement with the Ontario
Employees Union in the
bargaining unit,
Memorandum of
Public Service
support staff
(iv) other persons excluded by the legisla-
tion, and
(v)
teachers,
employed
basis.
counsellors . and
on a part-time or
librarians
sessional
NOTE A: Part-time in this context shall include persons
who teach six hours per week or less.
NOTE B: Sessional in this context shall mean an
appointment of not more than 12 months duration in any 24
month period.
Article 2
STAFFING
2.01 The Colleges shall not reclassify professors as
instructors except through the application of Article 27,
Job Security.
2.02 The College will give preference to the
designation of full-time positions as regular rather than
partia l-load teaching pos i tions subj ect to such oper-
ational requirements as the qual i ty of the programs,
attainment of the program objectives, the need for
E~
8
special qualifications and the market accepta-ollity of
the programs to employers, students, and the community.
2.03A The College will give preference to the
designation of full-time positions as regular continuing
teaching positions rather than sessional teaching
positions including, in particular, positions arising as
a result of new .post-secondary programs subject to such
operational requirements as the quality of the programs,
enrolment patterns and expectations, attainment of
program objectives, the need for special qualifications
and the market acceptability of the programs to
employers, students, and the community. The College will
not abuse sessional appointments by failing to fill
ongoing positions as soon as possible subject to such
operational requirements as the quality of the programs,
attainment of program objectives, the need for special
qualifications, and enrolment patterns and expectations.
2.03B The College will not abuse the usage of
sessional appointments by combining sessional with
partial-load service and thereby maintaining an employ-
ment relationship with the College in order to circumvent
the completion of the minimum 12 months sessional
employment in a 24 month period.
2.03C If the College continues a full~time position
beyond one full academic year of staffing the position
with sessional appointments, the College shall designate
the position as a regular full-time bargaining unit
position and shall fill the position with a member of the
bargaining unit as soon as a person capable ofperforrning
the work is available for hiring on this basis.
Article 27
JOB SECURITY
27.01 On successful completion of the probationary
period, a full-time employee shall then be appointed to
regular status and be credited with seniority equal to
the probationary period served.
Probationary Period
27.02 A1 A full-time employee will be on probation until
the completion of the probationary period. This shall be
two years' continuous employment except as amended in
this Article.
9
27.02B The probationary period shall also consist of
24 full months of non-continuous employment (in periods
of at least one full month each) in a 48 calendar month
period. For the purposes of 27.02 B, a calendar month in
which the employee completes 15 or more days worked shall
be considered a "full month".
If an employee completes less than 15 days worked in each
of the calendar months at the start and end of the
employee's period of employment and such days worked,
when added together, exceed 15 days worked, an additional
full month shall be considered to be completed.
27..02C During the probationary period an employee will
be informed in writing of the employee's progress at
intervals of four months continuous employment or four
full months of accumulated non-continuous employment and
a copy given to the employee. Also, it is understood
that an employee may be released during the first five
months of continuous or non-continuous accumulated
employment following the commencement date of the
employee's employment upon at least 30 calendar days'
written notice and during the remainder of the employee's
probationary period upon at least 90 calendar days'
written notice. If requested by the employee, the reason
for such release will be given in writing.
27.02D The Union Local shall be advised of the date on
which an employee completes the probationary period.
Discharge
27.14A An employee being discharged who has completed
the probationary period shall be notified in writing by
the College President or the person(s) the 'College
President designates for that purpose. When the reasons
for discharge of the employee are no such as to warrant
immediate discharge, the College will give 90 calendar
days' written notification. Any vacation entitlement of
an employee shall be paid in addition to the 90 days'
notice period or to any payment in lieu thereof.
27.14B It being understood that the release of an
employee during the probationary period shall not be the
subject of a grievance under Article 32, Grievance
Procedures, but may be subject to the internal complaint
process as referred to in 7.02(iii), an employee who has
completed the probationary period and is discharged for
10
causemayu lodge a. grievance in the manner--,aRat0 the
extent provided in Grievance Procedure.
It is of some passing interest to observe that the lay-
off and recall provisions, found in clause 27.05 to 27.11, apply
only to full-time employees who have completed the probationary
period; those provisions are thus not applicable to someone in the
grievor's position at the time his employment terminated.
The Union relies on the award in Re Reqional Municipalitv
of ottawa-Carleton and Ottawa-Carleton Public Emplovees Union,
Local 503 (1987), 31 L.A.C. (3d) 422 (Gorsky).
At page 430, the
award sets out the following standards for the treatment of
employees during a probationary period:
There was no cause furnished for terminating the
grievor except for the completion of the term for which
he had been hired. The employer never considered the
grievor to be a probationary employee who might, on
completing six consecutive calendar months of service, as
defined in art. 9.3, become a seniority employee. The
employer did not do so because it was of the view that it
did not have to treat the grievor as it would a proba-
tionary employee. That is, to genuinely consider him for
seniority employment, wherein the employer would consider
a number of matters including questions of compatibility
and potentiality: cf. Brown and Beatty, Canadian Labour
Arbitration, 2nd. ed. (1984) para. 7:5020, at p. 510.
Before terminating the grievor, the employer would have
to establish that the' grievor was, in good faith,
assessed as being suitable or unsuitable for the attain-
ment of seniority status. It cannot be said that the
employer acted in good faith, here, as it had no inten-
tion of furnishing the grievor with "a fair opportunity
to demonstrate whether or not. . . [he]. . . possesses the
appropriate qualifications and suitability for permanent
employment and that the employer had made a fair assess-
ment of [his] qualifications arid suitability for perma-
nent employment": see Re Pacific Western Airlines Ltd.
and C.A.L.F.A.A. (1981), 30 L.A.C. (2d) 68 (Sychuk) at p.
76. At the very least, the employer, under the collec-
tive agreement, is required to bona fide consider the
E=3
c:. ~
11
grievor for permanent employment following the probation-
ary period. As limited as the rights or a probationer
are, he/she is entitled to be considered during the
probationary period for permanent employment. I do not
have to go any farther than this. As the grievor was
never considered for permanent employment, being treated
as a temporary employee who need not be considered for
permanent employment, my finding is limited to the issue
presented to the board.
We observe, however, that the collective agreement
language on which this decision was based is significantly
different from the language in the collective agreement before us.
That language has been interpreted by other boards of arbitration,
and has been the subject of judicial review proceedings as well.
We propose here simply to review briefly the central elements of
that jurisprudence before proceeding to apply the language of the
collective agreement to the grievor's situation.
In Re st. Lawrence Colleqe and ontario Publ ic Service
Employees Union (1987), 32 L.A.C. (3d) 322 (Brent), the board of
arbitration discussed the award in Re Seneca Colleqe and Ontario
Public Service Employees Union (Hacker), unreported, September 17,
1986 (Swan), an award written by the present chair.
The Seneca
Colleqe award discussed the implications of two well-known court
decisions, Re Council of printinq Industries of Canada and Toronto
printinq Pressmen and Assistants' Union, No. 10 (1983), 149 D.L.R.
(3d) 53 (C.A.), leave to appeal to S.C.C. refused 52 N.R. 308n.,
and Re Metropolitan Toronto Board of Commissioners of Police and
Metropolitan Toronto Police Association (1981), 124 D.L.R. (3d) 684
(C.A.), leave to appeal to S.C.C. 34 N.R. 449n. The st. Lawrence
Colleqe board quoted the following passages from the Seneca Colleqe
12
award, which it then applied to the facts before it:
While matters of this nature ought not to be decided in
the abstract, in the absence of facts, we think it is a
reasonable interpretation of this provision [the prede-
cessor of clause 27.02 (c)] that conduct in bad faith
intended to subvert the protections given to probationary
employees by this clause, or to avoid the obvious
obligations of the employer under this clause, could be
a breach of the clause. Since the grievor has alleged,
in her grievance, bad faith in respect of her release on
probation, and her counsel has identified, in the course
of argument, that the bad faith was in relation to the
employer's obligations under [what is now clause
27..02 (c) ], we think that the grievor is entitled to offer
her proof of this allegation so that we can assess . . .
whether or not there has been a breach of that clause.
As a matter of contractual interpretation, there-
fore, we have found that the grievor is entitled to
pursue her grievance to the extent that it alleges bad
faith in the administration of her probationary employ-
ment, and to the extent that it alleges discrimination.
In respect of both of those allegations, the onus is on
the grievor to make out her case. The grievor is not
entitled to pursue, however, her allegation that her
dismissal was not for just cause, and the employer is put
to no obligation to demonstrate that it had just or any
cause for releasing or dismissing her.
The st. Lawrence College award concluded that this
statement ot the proper test was intended to convey the meaning of
the following paragraph from the Divisional Court in Re Municipali-
ty of Metropolitan Toronto and Canadian Union of Public Employees,
Local 43, an unreported decision which is, however, summarized at
9 A.C.W.S. (2d) 347. That decision, which is quoted at pp. 328-329
of the st. Lawrence Colleqe case, includes the following sentence:
A probationary employee would be entitled to succeed on
a grievance in relation to discharge only if he were able
to affirmatively establish that the action of the
~ ~ .
13
employer was taken in bad faith in the sense that the
decision was motivated by unlawful considerations or
resul ted from management actions which precluded' the
probationary employee from doing his best.
This test, which the st. Lawrence Colleqe award charac-
terizes as lIillegality or obstructionll, appears on the face of it
to be a very narrow reading of the IIbad faithll concept identified
in the Re Seneca Colleqe case. However ,the narrower test has been
applied in other cases, including Re Centennial College and ontario
Public Service Employees Union (preliminary award), unreported,
December 8, 1988 (Samuels).
In that award, the board of arbitra-
tion adopted the st. Lawrence Colleqe test, and made the following
statement in so doing:
IIBad faith" is not simply lIunfairnessll or "unreasonable-
ness II , but is conduct which goes beyond these two
circumstances. Bad fai th involves' conduct which 1S
inimical to the contractual relationship itself. It
involves illegality or obstruction.
The st. Lawrence Colleqe award, however, was the subject
of an application for judicial review. While the decision of the
ontario Divisional Court 1n that matter is not reported, the
following note appears at 41 L.A.C. (4th) 128:
Upon application for judicial review, the above-noted
award was quashed by the ontario Divisional Court in a
decision dated February 17, 1989 (Campbell, Reid and
O'Brien J.J. [unreported]). The Court held that the
board of arbitration erred in limiting its jurisdiction
to the tests of illegality and obstruction in considering
whether the grievor, a probationary employee, had been
terminated in bad faith. The Court found that the
collective agreement imposed a code of positive obliga-
tions on the employer with respect to the treatment of
probationary employees; and for that reason. it concluded
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14
that the board of arbitration had jurisdiction to
consider bad faith in a broader sense. The Court
therefore remitted the matter to the board of arbitration
to determine whether the conduct of the employer involved
bad faith in that broader sense. In a decision dated
November 8, 1989 [16 C.L.A.S. 71], the board of arbitra-
tion found that the employer's power to release the
grievor on probation had been exercised in bad faith, in
that the employer had failed in its contractual obliga~
tion to give reasons for the release.
It would therefore appear that the Divisional Court has
simply reminded the board of arbitration in the st. Lawrence
Colleqe case of the paramountcy of the language of the collective
agreement itself. That paramountcy appears to have been recognized
in the Seneca Colleqe case, which uses the language "conduct in bad
faith intended to subvert the protections given to probationary
employees by this clause, or to avoid the obvious obligations of
the Employer under this clause". In conclusion, therefore, we are
entitled simply to apply here the test of bad faith as set out in
the Seneca College award.
In our view, what occurred here is that, sometime after
January 15, 1994, the College found itself with a probationary
employee whose services it did not wish to retain.
The reasons
which it advanced for corning to that conclusion included the
grievor's inability to teach CNC machining, as well as a general
absence of state-of-the-art technological skills which the College
would have preferred to have in an instructor being considered for
a permanent appointment. It also had concerns about the grievor's
attentiveness to his supervisory responsibilities for students
engaged in learning to operate inherently dangerous
machinery,
~_:~ .
15
and about the grievor' s consumption of alcoholic 'beverages at
lunch, thus further reducing the College's confidence in his
supervisory capacity.
These are all, in our view, legitimate concerns. The
Union's position, however, is that they are essentially trumped up
after the fact, and that the real reason for the College's decision
. was either the animosity which had arisen between the grievor,
assisted by Mr. Smith, and Mr. Moser, or the application of a
College policy not to allow unauthorized roll-overs to continue.
We must therefore consider first of all the validity of the
College's ostensible reasons, and then the validity of the Union's
allegations of other, unstated motives for the action which was
taken.
As to the grievor's lack of current technological
knowledge and skills, related in particular to CNCprocesses but
not restricted to that, we think the evidence makes clear that it
was a legitimate concern. Nothing in the evidence of the grievor
gave us any confidence that he actually had skills of such
currency, or that he could gain them with any speed. In our view,
the evidence makes it clear that the grievor had a skill set
sufficient to teach the non-CNC elements of the course which he
picked up, but certainly not a skill set which would make him a
desirable candidate for continued employment on a permanent basis
without some significant re-training. Nothing in the collective
agreement places any obligation on the College to provide re-
training to probationary employees.
~
16
As to the matter of the consumption of alcohol, while the
grievor denies it, three College witnesses testified that they
noticed alcohol on the grievor's breath from time to time during
the afternoon, and it was apparently a matter of some discussion
among them.
The evidence of one of these employees was subjected
by the Union to considerable criticism because of the date at which
a wri ttenreport of such observations was made, and a degree of
apparent animosity between that employee and the grievor.
Nevertheless, there is sufficient evidence at the very least to
indicate that there was a legitimate concern which would not fall
into the category of bad faith.
It is common ground that no member of management had any
discussion with the grievor about consumption of alcohol over the
lunch break.
It appears that the reason for this is that the
grievor's termination at the end of the course for which he had
been retained had already been decid€d on the basis of a general
lack of qualifications for permanent employment, and that it was
decided not to deal with the embarrassment of confronting the
grlevor on this issue.
We think we should observe, in passing,
that if this were the sole reason for releasing the grievor on
probation, it might very well constitute bad faith to simply ignore
this issue without bringing it to the grievor's attention. On the
other hand, there is evidence that there was a College policy about
consumption of alcohol over the lunch period, and that this policy
had been brought to the grievor's attention by Mr. Smith, who had
indicated to him his view that such conduct would be unpro-
~. OJ
17
fessional. Taken as a whole, therefore, the evidence-en,th-is issue
may well disclose a certain degree of undue reticence on the
College's part, but does not disclose bad faith.
The Union's two assertions of improper motive must also
be considered. As to the assertion that Mr. Moser was somehow so
angered by the dispute about the SWF that he retaliated against the
grievor, that assertion simply does not hold up. While there had
been discussions before, the formal exchange of memoranda on the
subject occurred on April 15, 1994, when the grievorwrote to Mr.
Moser, and on April 19, 1994 when Mr. Moser replied. By that time,
on the basis of all of the evidence, Mr. Moser and his superiors,
in consultation with the Human Resources Department, had already
considered the grievor's case, and the grievor had been given
notice that his employment would be extended until the end of April
and no longer.
As to the issue of a College policy against unauthorized
roll-overs, while the College denies that such a policy exists, it
patently clear to us that the College is indeed anxious to prevent
a roll-over to probationary status occurring through the kind of
inadvertence that accompanied the grievor's case. Indeed, we think
that the College should have such a policy, and should ensure that
only persons whom it intends to consider seriously as permanent
full-time employees should be allowed to gain probationary status.
To treat probationary status less seriously would be incompatible
with the obligations which the College has assumed under Article 2,
and would be clearly unfair to the individuals concerned.
What
18
occurred in the present case is that, following an-inadVertent
roll-over to probationary status, the College made a consideration
of its obligations to the grievor, and decided that it did not wish
~ "")
to pursue a permanent full-time relationship with him.
Had the
contract before it turned into a probationary contract by the
passage of time.
Insteaq, the College elected to keep him until
the end of the course, and then to deal with his case as a
probationary employee.
In our view, therefore, there simply is not sufficient
evidence of any of the allegations made by the Union to found a
case of bad faith against the College.
The worst that could be
said about the College is that the administration of the grievor's
employment was inattentive.
Once the full implications of that
inattention had been discovered, the College carried on with the
obligations which it had undertaken, and did not attempt to escape
their implications, except, as we shall see, in one material
respect.
Once the grievor had become a probationary employee, he
was entitled to compliance by the College with the provisions of
clause 27. 02C.
Since four months had not elapsed since the
establishment of the probationary period by the time of the
grievor's termination, we do not think that it could be said that
the obligation to issue the grievor written progress reports had
yet arisen, so that the failure to do so, which is here admitted,
19
would constitute a breach of this provision.
On the other hand, the effect of the roll-over was that
the grievor became entitled to "at least 90 calendar days' written
notice", and if requested by him, the reason for his release was
required to be given in writing.
There is no evidence that the
grievor ever invoked the requirement for reasons in writing, but it
is our view that there was a breach of the requirement for 90 days'
written notice.
According to evidence which we accept, the College
considered the continuing employment of the grievor beyond the end
of March, and decided that it would extend his employment to April
29, but no longer. This is communicated to the grievor by a letter
dated March 9, 1994.
In doing so, the College simply repeated an
error which it had made throughout the process in dealing with the
grievor's case.
Both of the letters appointing the grievor to the
position from which he was terminated were based upon the College's
usual form of sessional appointment. The fact is, when the grievor
rolled over to probationary status, he became a probationary
employee and therefore was an employee on an indefinite term,
rather than an employee on a fixed contract.
In our view,
therefore, the College could no longer rely after January 15, 1994
on the termination date set out 1n the appointment letter of
October 6, 1993 and reiterated in the revision dated December 22,
1993, as constituting appropriate notice of release.
For one
thing, it was clearly intended not to be notice of release at all,
-:: ~
20
but to be notice of a fixed contractual term. When thegrievor
became probationary, and thus on an indefinite term of employment,
the College was required to act affirmatively if it wished to give
him notice of release. The only attempt to do so was the letter of
March 9, 1~94, which certainly did not constitute 90 days' notice
of release, and indeed did not constitute notice of release at all,
since it purported to rely on notice already given at a time when
the grievor was not a probationary employee.
In our view, therefore, the College was in breach of its
obligations under clause 27.02C to the extent that it failed to
give the grievor three months' notice. That breach is one which
can be cured in damages. It is not a breach which entitles the
grievor to continued employment or ln particular to the kind of
continued employment envisaged by the Union, namely a continued
altered teaching load to accommodate the fact that the grievor had
no CNC qualifications and was therefore unable to teach the
entirety of the teaching load which he was engaged to pick up.
In the result, the present grievance must be dismissed to
the extent that it alleges bad faith in the termination of the
grievor's employment, but must be allowed to the extent that the
grievor did not receive the notice to which he was entitled
pursuant to the collective agreement. We therefore order that the
grievor be compensated by a payment equivalent to 90 calendar days
of salary and benefits. With the agreement of the parties, we
retain jurisdiction to whatever extent is necessary to bring this
matter to a full and final conclusion.
o
.~
.:~ -
I concur
I concur
21
DATED AT TORONTO this 17th day of June, 1996.
~~
Ke neth P. Swan, Chairman
"Georqe Metcalfe"
George Metcalfe, College Nominee
"Jon McManus"
Jon McManus, Union Nominee
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IN THE MATTER OF AN ARBITRATION
BETWEEN
ALGONQUIN COLLEGE
(Hereinafter referred to as the "Employer")
AND
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(Hereinafter referred to as the "Union ")
RE: Grievance of Janet Mullins INTERIM AWARD
BOARD OF ARBITRATION Loretta Mikus, Chair
Robert Gallivan, Employer Nominee
Ron Cochrane, Union Nominee
APPEARANCES FOR THE EMPLOYER Ms. Delores Barbini, Counsel
APPEARANCES FOR THE UNION Mr. Gavin Leeb, OPSEU Grievance Officer
DATE OF AWARD June 28,1998
C- The grievor, Janet Mullins, was hired by the College on August 14, 1995 as a full-time Professor
for the Environmental Technology Program (hereinafter referred to as "Program"). She was
subsequently.terminated, which precipitated the instant grievance. The parties provided the Board
with the following Agreed Statement of Facts.
In the MATTER of an Arbitration'
on behalf ofJ. Mullins
BETWEEN:
ALGONQUIN COLLEGE
(the "College")
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OPSEU
(the "Union")
AGREED STATEMENT OF FACTS
1. Janet Mullins (the "Grievor") was hired by the College effective August 14,
1995 as a full-time Professor for the Environmental Technology Program (the
"Program,t).
2. From August 14 through August 18, 1995, the Grievor attended the "Eastern College
Teacher Development Program" training seminar in Kingston, Ontario, at the direction of
the College.
3. Accordingly, the Grievor did not commence teaching at the College until August 28,
1995.
4. The Environmental Technology Program was a new program introduced in September
of 1994. The Grievor was the only full-time Professor employed by the College for this
Program.
5. The Grievor taught from August 28, 1995 through to December 4, 1995. Thereafter,
she was on pregnancy leave until March 29, 1996 and on parental
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leave from April 1, 1996 to May 3, 1996. The Grievor was again on parental leave from June
10,1996 through to July 2,1996 and then on vacation from July 12, 1996 to August 9,1996.
The Grievor returned to work thereafter and commenced teaching on August 26; 1996.
6. Between May 3, 1996 and June 10, 1996, the Grievor attended Professional Development
. courses and prepared for her classes, but she did not teach during this period.
7. The Grievor marked student exams while on pregnancy leave in December
1996.
8. From August 28, 1995 to December 4, 1995 the College was satisfied with the grievor's
performance and there had been no concerns raised by anyone at this time regarding her
performance as a Professor.
9. Sometime in late November or early December 1996, the Chair of Chemical and Health
Technology (Pierre de Champlain, hereinafter the "Chairt,) who is responsible for the Program
and the Grievor's performance, received a complaint from a student of the Program. The Chair
advised the Grievor of this complaint and it was agreed that they would wait until the Course
Assessments from the students were received and then the matter would be discussed further.
The Grievor does not recall this conversation however she does not dispute it occurred.
10. The Course Assessments were received from the students enrolled in the Program at the end
of January 1997. In the interim, further complaints from students enrolled in the Program had
been received by the Chair regarding the Grievor.
11. In attendance at the February 12, 1997 were the Chair, the Grievorand two representative
students from the Program. The students raised their concerns regarding the Grievor and the
Program. The Grievor was given an opportunity to respond to the concerns raised at the
meeting. The Chair and the Grievor met with the entire class (approximately 16 students) on
February 20,1997 at which time numerous concerns were raised by the students about the
Grievor and the Program.
12. The Chair provided the Grievor with a Memorandum, subject "Your Evaluation" and dated
March 26, 1997 (attached as Exhibit #4).
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13. The Grievor provided the Chair with the attached memorandum dated March
30, 1997 (attached as Exhibit #5).
3
The Exhibit 4 referred to in the Agreed Statement of Fact refers to a memorandum dated March 26,
1997 from the Chair of the Chemical Environmental and Safety Department, Pierre de Champlain.
That memo made reference toa conversation between the grievor and Mr. Champlain of that same
date during which she was told that her students had formally presented the College with some
criticisms of her teaching. The memo went on to note that since those criticisms, they had met with
class representatives and the class as a whole and included the following comment:
Their comments warrant immediate action on your part so that a noticeable change is obvious
between now and the end of the semester."
There were specific criticisms about the high proportion of lecture hours that had been cancelled due
toa lack of speakers. Mr. de Champlain pointed out that he had assigned the course to the grievor
early enough that she should have been able to identifY topics and find speakers. He reminded her that
the ultimate responsibility for the course was hers and said "I insist that you review your plans for this
course and ensure that the students get a meaningful learning experience out of this course and that no
more lecture hours are cancelled."
Another critieism concerned the impression that the students had gained during the environmental
audit course of the current semester and the hydro geology course of the previous semester that the
grievor was not qualified to teach. Mr. de Champlain reminded her that. she had been assigned those
courses based on her own identification of her speciaity.
Additional criticisms included a comment that the Current Topics Course was not well organized and
that the grievor was unfamiliar with the subject matter of the Environmental Audit-Theory
4
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Course. Finally, on the Quality of the Environment-Water Course, he noted that the lab manual had
been prepared the previous year by another professor and that she had the support of a technologist.
Nevertheless he had received complaints that she knew little about the methods or equipment used
and that often the technologist had to come to her rescue. Mr. de Champlain commented on the fact
that during the meeting they had discussed the Course AssessmcntForms forher courses. Mr. de
Champlain requested the following:
1. A copy of the final exam for the Hydrogeology Course she taught last fall. I asked for a
copy of that exam a few weeks ago but had not received it as yet. I want this copy by
March 31 at the latest.
2. A written document outlining the specific steps you will be taking to address the
student concerns that I raised above.
3. A follow-up meeting at the end of April to review the situation.
He also advised her that he would be visiting one of her theory classes over the next week to observe
her teaching and concluded with the following comment.
You must improve the situation considerably in order to be an effective teacher. I advise you to
take steps to correct the discrepancies with your courses immediately. You assured me that you
have the skills and experience needed to teach the courses that you were assigned. You will
have to take steps to improve your teaching and to transmit the knowledge in such a way to your
students that they develop more confidence in you. I am afraid that some of the students I have
seen over the last month have all but lost this important confidence in you as a teacher.
The Exhibit 5 referred to in the above Agreed Statement of Facts is dated March 30, 1997 and is the
grievor's response to Mr. de Champlain's memorandum of March 26, 1997. It outlined the specific
steps she had taken since the middle of February and would be taking over the last four weeks of the
term to address the students' concerns. The memo was lengthy, seven pages in total, and contained her
future plans for her courses. Rather than repeat all of those plans, the content of the memo is summed
up under the heading of General Comments and reads as follows:
5
In the last six weeks since the students' concerns were first raised, I feel that I have put a great
deal of effort and time into increasing m(sic) effectiveness as a teacher while addressing their
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concems. I have tried several different formats with the current topics course, I have created six
new environmental auditing laboratories, and reorganize the format of the environmental
auditing lectures.
I hope that the above outlined my course of action since the middle of February imd for the
month of April and has addressed these concerns. I am continuing to make changes as I have
outlined above, for those remaining classes in April which are not taken up by oral
presentations.
I have also reviewed the comments and scoring on the Course Assessment Forms with the view
to improve my effectiveness as a teacher. I also look forward to you (sic) comments on my
lecturing style and any suggestions you may have.
I am looking forward to discussing these issues at the end of April, so that I can make effective
use of my time in May and June to implement changes for next year as well. I would also
request that we sit down with Dr. Kroeger and discuss the scheduling of the proposed course
changes with a view to (1) update the course outlines, so they are not misleading for the students
and do not create unrealistic expectations on their part, and (2) to detenmine which courses I
will be teaching next fall and winter.
At the commencement of the hearing the Union raised a preliminary issue with respect to Article
27.02 C of the collective agreement which reads as follows:
During the probationary period an employee will be informed in writing of the employee's
progress at intervals of four months continuous employment or four full months of accumulated
non-continuous employment and a copy given to the employee. Also, it is understood that an
employee may be released during the first five months of continuous or non-accumulated
employment following the commencement date of the employee's employment upon at least 30
calendar days' written notice and during the remainder of the employee's probationary period
upon at least 90 calendar days written notice. If requested by the employee, the reason for such a
release will be given in writing.
It was the position of the Union that the College's failure to comply with the requirement to provide
progress reports at four month intervals renders the dismissal null and void. It argued that the oniy
appropriate and meaningful remedy would be to void the termination.
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Mr. Leeb, for the Union, stressed the importance of performance appraisals, particularly during the
probationary period. They are of fundamental importance to an employee. They allow for an
6
improved perfonl1ance level by ensuring that employees know and are committed to achieving what is
expected of them. They assist employees to develop their job skills through coaching, counselling and
training. They improve communications and working relationships between employees and managers
and provide for a better understanding of organizational objectives. Performance appraisals, asserted
the Union, provide a clear indication of an employee's strengths and weaknesses. The corollary is that
employees are then in a position to know their shortcomings and to take the appropriate steps to
improve their performance.
Performance appraisals during a probationary period are even more important given that the employee
is new to the position and the organization. The Union asserted that the parties to this collective
agreement have recognized the importance of performance appraisals during the probationary period
by incorporating a mandatory requirement for regular reviews in Article 27.02
C. A failure to follow those mandatory procedural requirements must be viewed very seriously by this
Board.
It was pointed out that the grievor commenced employment with the College on August 14, 1995. She
marked exams while on a maternity leave that commenced on December 4, 1995. She returned to
work during May and June of 1996, for approximately five weeks. Accordingly, it was argued, Ms.
Mullins first appraisal or progress report was due, at the latest, in June of 1996. She returned to work
following a vacation that ended on August 9, 1996 and a second appraisal was due in December of
1996. The Union argued that the College objectively failed to comply with its obligation to provide
the grievor with progress reports at either the four or eight month interval.
7
The Union submitted that since the College had concerns about the grievor's performance as early as
November of 1996, its failure to provide her with a written appraisal at or aboutthat time deprived her
of an opportunity to respond to those concerns until it was virtually too late. The College did not
document its concerns and therefore the grievor could not respond by altering her teaching methods.
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The March 26, 1996 memorandum refers to conversations that took place more than one month earlier
about criticisms of her work. Again, because she was not advised in a prompt fashion about those
concerns she did not take steps to address them until her memo of March 30, 1996. In that memo she
outlines in great detail theactions that she had taken since the middle of February and intended to take
for the rest of the semester. Notwithstanding the significant efforts made by the grievor and without
any subsequent complaint or feedback to her, the College terminated her employment.
The Union took the position that Exhibits 4 and 5 are indicative of the behaviour of both the College
and the grievor throughout the entire episode. It submitted that the College did not take any steps
towards ensuring that the grievor had a fair opportunity to complete her probationary period. It waited
until it was almost too late to provide Ms. Mullins with virtually any feedback until March 26, 1997
and there was no subsequent feedback about that memo. On the other hand Exhibit 5 indicates that the
grievor was determined to correct any deficiencies that had been brought to her attention. It was the
Union's position that it is obvious that if concerns had been raised with the grievor earlier, as should
have been the case, she would have taken steps to obtain any necessary
8
assistance to overcome those concerns. The College's failure to provide timely progress reports
deprived her of an opportunity to do so. It was submitted that the grievor should not have to bear the
consequences of the College's failure to comply with the Collective Agreement.
The Union took the position that "jt is a common place of the law that the existence of a right implies
the existence of a remedy." (Re Ontario Public Service Employeest Union and Carol Berry et al
and the Crown in Right of Ontario (Ministry of Community and Social Services)
March 12, 196), unreported, (Divisional Court). Mr. Justice Reid recognized that unless there is an
appropriate remedy, a right is rendered nugatory. The provision for written reports at intervals of four
months are mandatory requirements under the Collective Agreement and if the Employer chooses not
to comply with those requirements, it does so at its peril.
so, to
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In the instant case it was submitted that the Employer's obligations in this regard are part of a
negotiated agreement between the parties. They agreed that the Employer would do certain things for
the grievor. A remedy of anything less than reinstatement, with full compensation, would render the
grievor's rights meaningless and the language in Article 27.02C, worthiess. That is not what the
parties intended. Boards bfArbitration havenregularly held at that failure to comply-with the stipulated
process results in the Employer's actions being voided. The reason for such findings is that the
language of the parties' bargain must serve a purpose. Contractual obligations cannot be ignored,
otherwise the parties' agreement is meaningless and serves no purpose. The Union submitted that the
grievor should be reinstated with full compensation.
9
Jn support of its position the Union relied on the following cases: Re Canada Post Corp. and
Canadian Union of Postal Workers (Gibson) (1992), 29 L.A.C. (4th) 7 (Burkett); Re
Government of Province of British Columbia (Personnel Services Division) and British
Columbia Government Employees' Union (Canham) (1991), 21 L.A.C. (4th) 325 (Bird); Re
Management Board of Cabinet and OPSEU (September 1, 1993), unreported (O.B. Shime); Re
George Brown College and Ontario Public Service Employees Union (Ellis) (November 14,
1990), unreported (Mitchnick Herbert Guptill); Re Ministry of Transportation and OPSEU
(Dadula), 1993 GSB #1089/92; Re Centennial College and OPSEU (Prentice) (August 2, 1983),
unreported (Weatherill, Switzman, Gray); Re Ministry of Natural Resources and OPSEU
(Augustine/Spaans) (1996), GSB #428/96 (Briggs); Re Ministry of Solicitor General and
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Correctional Services and OPSEU (Metcalf/Mercer) (1997), GSB #926/96 and 927/96
(Dissanayake ).
Ms. Barbii, counsel for the College, took the position that the preliminary issue should be decided in
favour of the College. The grievor was hired on August 14, 1995 as a probationary professor and
commenced teaching on August 28, 1995. She taught for the first three months of the fall semester
(September, October and November) and during that time there were no concerns about her
perfonnance and ability as a professor. Since she had not completed four months of continuous
service with the College a written review was not due. Even if the College had performed a written
evaluation at the time, it would have been positive.
The grievor did not teach atall during the 1996 winter and summer sessions. From December 4,
10
1995 through to May 3, 1996 the grievor was on pregnancy and parental leave. Although she did
return to work at the College from May 3, 1996 through to June 10, 1996, she attended professional
development courses and did not teach. It was not until she returned to the College in September of
1996 that she resumed teaching. It was the College's submission that during the earlier part of the
1996 fall session the College was satisfied with her performance and there were no complaints or
concerns with her teaching. It was not until late November or early December of 1996 that the Chair
of her department received a complaint from a student. The Chair immediately advised the grievor of
the complaint and it was agreed that they would wait until the course assessments were received from
the students before discussing the matter further. The College submitted that the grievor was
immediately apprised of the students' concerns as soon as they were brought to the Chair's attention.
The Course Assessments were received from the students at the end of January, 1997. In the interim
the Chair had received further complaints from other students about the grievor's teaching and the
program. A meeting was scheduled for February 12, 1997 between the Chair, the grievor and two
representative students to discuss the situation. At that meeting concerns were discussed and the
grievor was given an opportunity to respond to those concerns. The grievor denied some of the
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allegatio'ns and explained others. The Chair and the f,1fievor decided to meet with the whole class the
next day. Ultimately the Chair visited the class alone, with the grievor's consent. The students!
comments at that meeting led the Chair to conclude that the grievor had to take immediate steps to
improve her performance and the program, otherwise her continued employmentwithJhe College was
in jeopardy. It was at that point that the Chair provided the grievor with a written evaluation
11
outlining all of the concerns (Exhibit 4). The Union concedes that these concerns had been raised with
the grievor at least one month prior to the written evaluation. The grievor's response dated March 30,
1996 proved that she had been immediately made aware' of the concems by the College and
recognized that she was able to rectif~r some of them on her own.
In summary, the College took the position that the grievor had taught for a total of oniy eleven
months, three in the fall 1995 semester, four in the fall 1996 semester and four in the winter 1997
semester. For the first five' of those months the College had no problems or concerns with her
teaching. As soon as it became aware of complaints in late November or early December of 1996 she
was immediately advised. Thereafter the concerns were addressed and handled by the Chair and the
grievor together. The Chair chose not to take formal written action in the hope of finding a
professionai resolution. The Chair provided the grievor with an opportunity to rectif~' the situation
and resolve the concerns. The concerns persisted and at that point a written evaluation was provided.
The grievor's response to that evaluation, coupled with her failure to improve her performance, led the
College to reiease her from employment during the probationary period.
The College asserted, as well, that the preliminary objection be dismissed on the grounds that it would
be an excess of jurisdiction to read into the Collective Agreement a condition that does not exist nor
was intended by the parties. In the alternative, and in any event, the College argued that Article
27.02C had been complied with and even if there had been a breach, the College should not be
precluded from being able to release the employment of a probationary employee simply on the basis
of a technical breach.
12
The College took the position that this issue has already been addressed and dismissed by at least two
other College sector Boards of Arbitration. The basis for dismissing the argument was that, although
the College is required to provide written evaluations every four months, it is not a precondition to the
employee's release or dismissal. An Arbitration Board could only grant the Union's request if it were
prepared to read this condition into the Collective Agreement, which is beyond its jurisdiction.
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In the case of Re Seneca College and OPSEU (O'Neill) (February 28, 1984), unreported, (Brent), the
College did not give a probationary employee written evaluations at the prescribed intervals as
required by Article 27.02C. In discussing the effect the College's violation of Article 27.02C would
have on its decision to terminate the probationary employee, the Board stated at page 7-8:
We agree that the article can reasonably be interpreted as making it mandatory for the College
to give periodic information of progress at the prescribed intervals. The article does not,
however, in any way limit the College's right to terminate the employment of a probationary
employee upon giving him appropriate notice. In particular, the periodic appraisals are not a
condition precedent to the making of any decision about whether or not to continue the
employment ofa probationary employee. If that were the case, then we would expect the
Collective Agreement to state it explicitly.
The College reminded the Board that the parties to this Collective Agreement are educated and
sophisticated. This is a provincially negotiated Collective Agreement applicable to all Colleges in
Ontario. If these parties had intended Article 27.02C to operate as a condition precedent to the
termination of a probationary employee, they would have explicitly so provided. For example, Article
27.02C does not state that the College "shall not discipline or terminate the employment of a
probationary employee unless regular written performance appraisals are provided." If this Arbitration
Board should find that the College's failure to provide periodic evaluations renders the
13
grievor's termination void, it would be imposing an obligation on the College that is not created by the
wording of the Collective Agreement or negotiated by the parties.
In Re Association of Radio and Television Employees of Canada (CUPE-CLC) v. Canadian
Broadcasting Corporations, 119751 40 DLR (3d) 1 (SCC), at page7, the Court concluded that a
Board of Arbitration exceeded its jurisdiction when it imposed a condition in respect of a
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competition for employment for which there was no basis in the Collective Agreement. It said:
In my opinion, the Board had no power to order any remedy which was not contemplated either
expressly or impliedly, by the agreement itself its order was not one which required the
Respondent to put the Appellant in the position in which it should have been, save for the
. breach, by requiring the Respondent to perform its contract. It required the Respondent to do
something other than what it was, by contract, obligated to do in making the direction contained
in para (b) of the award it acted in excess of its powers.
The College also asserted that the right to release an employee during the probationary period is a
significant management right. The probationary period allows the employer to objectively assess a
new employee's performance and suitability for the job. The exercise of this particular management
right should only be constrained if the Collective Agreement expressly and unambiguously so
provides.
The second instance in which a Board refused to vitiate a discharge was that of Re Fanshaw College
and OPSEU (Robson) (September 9, 1988), unreported, (P. Picher). In that case a probationary
employee was not given proper notice under Article 27.02C prior to her termination. The Union
argued that the proper notice was a mandatory condition precedent to the effectiveness of the release
and that in the absence of due notice the release was void ab initio. The Board, in explicit
disagreement with the Union, held at page 9 that:
14
The Board does not accept the assertion of the Union that the Colleges release was void ab
initio by virtue of its failure to give due notice.
In any event, the College asserted, it complied with the spirit of Article 27.02C. Prior to November of
1996 there were no concerns with the grievor's performance or with the program she taught. She was
not prejudiced by the fact no written evaluation had been provided. As soon as complaints were
received, the Chair ensured that the grievor was aware of them and took immediate steps to resolve
those concerns with the grievor and the students. Rather than reducing the concerns to writing in a
formal review that would remain on her record, the Chair chose to deal with the situation
professionally to maximize the grievor's opportunity to rectify the situation as soon as possible. That
was for the grievor's benefit. It was only after it became apparent to the Chair that the concerns could
not be resolved and that the situation would not improve that he wrote a formal evaluation. Whether
or not this action was in strict compliance with Article 27.02C, the spirit of the provision was surely
complied with. The grievor was not prejudiced or adversely affected by not having been provided with
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reviews at four month intervals. The College should not be restricted from exercising its management
right to release her from employment. Even in the cases relied on by the Union it is clear that the
parties never intended the requirement to provide written appraisals as a precondition to the release of
a probationary employee. In the Dadula case (supra), the grievor, a probationary employee, was
released from his employment. He was notprovided with regular written evaluafions'aith-ollgh he had
been verbally apprised of his shortcomings. The grievor in that case was provided with his first
written review on the eve of his release. Mr. Leeb represented the Union at that hearing and made the
same preliminary argument before that Board; that is, that a failure to provide written evaluations
rendered the release null and void. The panel hearing that case
15
dismissed the argument and said at page 50:
Providing written appraisals is a matter of fairness to the employee and as the Guidelines
indicate, they are the preferred manner in which the information should be conveyed, however,
we cannot find that the directive requires written appraisals as a precondition to the release of a
probationary employee, nor can we find, in the circumstances of this case, that there was any
question but that the grievor was not meeting the requirements ofthe position, and that the
directive was complied with in so far as this information was regularly and consistently
communicated to him.
In summary, the College took the position that the requirement for evaluations at four-month intervals
is not a condition precedent to the release of a probationary employee and for this Board to find
otherwise would be an excess of its jurisdiction. Furthenl10re the spirit of the article was complied
with and the grievor suffered no prejudice having been immediately apprised of all of the concerns
and problems and having been given a full opportunity to improve. It asks that the grievance be
dismissed.
DECISION
As can be seen, there is no dispute concerning the facts of this case. The grievor began teaching at the
College on August 28,1995. She was on pregnancy leave from December 4,1995 to March 29,1996,
followed by parental leave until May 3, 1996. From December of 1996 to June of 1997 she perfonned
some non-teaching duties but did not return to teaching until September of 1997. In all of that time the
College was satisfied with her performance. By late November or early December one student had
complained about the grievor and it was agreed that any further discussion about that complaint would
take place after the course assessments in January. By then more complaints had been received and,
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after meeting with the students, the first formal perfonnance appraisal of the f,1fievor was completed.
16
The College does not dispute the Union's allegation that it failed to comply with the requirement
under the collective agreement to inform the grievor of her progress at four month intervals. The issue
for this Board is the effect of that non-compliance. The Union has argued that the tennination should
be voided: the College takes the position that it complied in spirit with the collective agreement and
that its right to release a probationary employee should not be interfered with absent clear language to
. that effect.
As a general statement of principle, an employer's right to release a probationary employee is a
significant management prerogative that should not be restricted absent clear and precise language to
that effect. Balancing that is a probationary employee's right to be given an opportunity to meet the
employer's expectations. which includes the right to be advised of his/her shortcomings in a timely
fashion so that changes and/or improvements might be made. In this collective agreement in
particular, the parties have recognized both of these principles by clearly defining the length of the
probationary period and by requiring written. notification of an employee's progress at regular
intervals.
We are of the opinion, however, that the language of this collective agreement does not support that
Union's claim. We come to that conclusion from a review of the clause itself and from the collective
agreement as a whole. Article 27.02C reads as follows:
During the probationary period an employee will be informed in writing of the employee's
progress at intervals of four months continuous employment or four full months of accumulated
non-continuous employment and a copy given to the employee. Also, it is understood that an
employee may be released during the first five months of continuous or non-accumulated
employment following the commencement date of the employee's
17
employment upon at least 30 calendar dayst written notice and during the remainder of the
employee's probationary period upon at least 90 calendar days written notice. If requested by the
employee, the reason for such a release will be given in writing.
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In the first instance, the clause refers to a written statement of the employee's progress. The
requirement is notfor-afonnalperfonnanceappraisalnbut simply some written notification of the
employee's ability and suitability for the job. That notification could take the form of a comprehensive
appraisal or a brief comment on the perfonl1ance. If the parties had intended to obligate the College to
provide a probationary employee with the former, they could have and would have stated so explicitly.
As well, it is clear that the College could release a probationary employee before he/she reached the
four month threshold providing it gives that employee the requisite notice. That, in our view, is
another indication that the parties did not intend this provision to operate as a condition precedent to
the release of a probationary employee.
Finally, we note that the parties used the word "will" as opposed to "shall", which has been interpreted
by arbitrators as being permissive, not mandatory.
There have been disagreements between these parties in the past about the interpretation and
application of these provisions. The College took the position that this matter has been dealt with by
other Boards of Arbitration and this Board's decision should be consistent with those decisions. We
believe that our ruling in this matter is consistent with the cases provided to us.
18
The College referred us to the Seneca College case, (supra), and took the position that the Board in
that case specifically found that the performance appraisals mentioned in article 27.02C were not a
condition precedent to a decision to release a probationary employee. The grievance in that case
alleged that the College had failed to show the grievor his performance appraisals or give him an
opportunity to respond to them contrary to article 26.01 which read as follows:
Performance appraisals, including written progress reports referred to in Section 8.01 which are
to be filed on the employee's record, shall be shown to the employee in advance. The employee
may add his views to such appraisal before it is filed. Each employee Shall receive a copy of any
disciplinary notice to be placed in his personnel file. Access of an employee to his file
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containing performance appraisals, records of educational achievement and disciplinary notices
shall be the subject of discussion under Section 14.02 if requested.
At the hearing the union raised an issue that the Board characterized as "an entirely different and
separate cause of action which was never raised in the original grievance"; namely that the College
had failed to make timely appraisals as required under article 8.01, which is virtually identical to
article 27.02C. The Board's comments, in full, on that article read as follows:
Because we heard a fair amount of argument concerning the meaning of Article 8.0l( c) and in
the event that we are wrong in considering that it expanded the grievance to include an entirely
new cause of action, perhaps we should make some remarks concerning that article. We agree
that the article can reasonable be interpreted as making it mandatory for the College to give
periodic information of progress at the prescribed intervals. The article does not, however, in
any way limit the College's right to terminate the employment of a probationary employee upon
giving him the appropriate notice. In particular, the periodic appraisals are not a condition
precedent to the making of any decision about whether or not to continue the employment of a
probationary employee. If that were the case, then we would have expected the collective
agreement to state it explicitly. Therefore, while we would agree that if the College failed to
make the evaluations as required, the grievor could be entitled to a remedy, we would not agree
that the appropriate remedy would always necessarily be the grievor' s reinstatement. In
assessing whether a remedy ought to be given at all, we would have to consider and give weight
to the College's argument that the grievor's failure to complain about the evaluations not being
done should be taken as evidence of his having waived his rights to those periodic assessments.
Under the circumstances of this case, we would consider that a declaration that the collective
agreement had been breached would be the only remedy which could be considered.
We begin first by noting that the Board's comments regarding article 8.01 are obiter. It had
19
dismissed the grievance on either grounds and added these comments only as alternative grounds to
dismiss the grievance. In any event, we interpret the Board's decision to be that, while the requirement
to give periodic appraisals could be mandatory, an employer's decision to release a probationary
employee is not contingent on those' appraisals. We also interpret the decision to say that the
appropriate remedy for a breach of this article will depend on the individual circumstances of each
case.
The Fanshawe College case (supra), the College did not give a probationary employee the required
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notice under the collective agreement before terminating her services and, while the Board rejected the
union's argument that the termination was void ab initio, it compensated the grievor for the breach by
awarding her the difference in the notice period, that is 53 day's pay.
Finally, in the Dadula decision (supra), the comments of the dissenting member of the Board suggest
that, had the employer breached the management's Directives as opposed the their. Guidelines, the
Board would have allowed the grievance and reinstated the grievor. That Board, however, was dealing
with the merits of the grievance and where not asked to determine the issue as a preliminary matter
going to jurisdiction. In that case, the Board was asked to' determine whether the actions of the
College in not following its own guidelines constituted bad faith. That is the position of the Union in
this case and we will proceed to hear its evidence and submissions on that position at the next day of
hearing.
The Union's preliminary issue is therefore dismissed. The hearing will proceed on its merits on a
20
date to be agreed to by the parties.
Signed this 28th day of June, 1998
"I concur~~
Robert Gallivan Employer Nominee
Dissent Attached
Ron Cochrane Union Nominee
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UNION NOMINEE'S DISSENT
1 have read the draft-anducannot agree with the rational e or the decision.
As I understand the Union's submissions, it advanced the argument that the release on probation
should be rescinded because the Employer had failed to provide the grievor with the periodic reviews
contemplated by the collective agreement.
Article 27.02( c) requires the College to give probationary employees written reports on their progress
"..at intervals of four (4) months continuous employment or four (4) full months of accumulated
non-continuous employment". The College admits that it breached this provision. It offers the
. explanation that it had no concern about the
~oretta Mikus Chair
21
employee's work at that point in time. The language used in 27.02<<;) is not written as a discretionary
provision. The parties used the word "will", which has been interpreted by the vast majority of
arbitrators to be imperative it is most often interchanged with the word' shall". The issue therefore at
this stage of the hearing is to decide whether a breach of this Article has the impact of nullifying the
employee's release.
A close reading of Article 27.02 (c) reveals that an employee can be released "... during the first five
(5) months of continuous or non-accumulated employment.." which means that the employee could be
released prior to a written progress report contemplated by the Article.
However, as the employee accumulates more employment he/she also accumulates more protection.
An employee with less than four (4) months employment could be released with thirty (30) days
notice. An employee with four (4) or more months of employment can be released with thirty (30)
days notice but the employee is also entitled to a written progress report. If the employee requests
he/she is also entitled to reasons for his/her release.
Once the employee accumulates more than five (5) months of employment he/she is entitled to written
progress reports, more notice of termination and if requested, the reasons expressed in writing for the
termination.
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22
The grievor in this case was well over the five (5) month mark and the College neglected its
obligations with respect to-the written progress.reports. TheEmployer'~(}bligationinthis
circumstance can be compared to other cases where the Employer has been found to be in technical
breach of the collective agreement. For example, arbitrators have found where the Employer has failed
to provide union representation or failed to provide timely written reasons to the employee, the
terminations have been rescinded. Unions who have failed to process grievances through the
grievance process, where it has been detemlined that the time limits are mandatory, have had the
grievances dismissed without ever addressing the merits. Should we treat this violation any
differently? Is it open to the Employer to argue that its too late for the union to raise this as a
violation? In my view, the employee could have grieved the absence of the progress reports at four(4)
month intervals, but the fact that she hasn't should not be used against her. The reports were meant as
a "shield" not a "sword". When an Employer wants to release an employee on probation, its best be
sure that is has all of its ducks lined up. If the employee has more than five (5) months of
employment, it better come prepared to show that it followed the collective agreement to the tee.
I say this because the standard for review of employees who are released while on probation is
considerably less than it is for non-probationary employees.
For all of these reasons I would agree with the union submissions to advance this technical violation
as reason to rescind the release rather than advance this argument
23
later as evidence of "bad faith". By this, I am not suggesting that the Union would be prevented from
raising this during a hearing on the merits if it had come to that point in a hearing.
I would uphold the grievance on the grounds that the Employer had violated the collective agreement
when it released the grievor, and order her full reinstatement.
R, A. Cochrane
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Rizzo & Rizzo Shoes Ltd. (Re), [1998] 1 S.C.R. 27
Philippe Adrien, Emilia Berardi, Paul Creador,
Lorenzo Abel Vasquez and Lindy Wagner
on their own behalf and on behalf of the other
former employees of Rizzo & Rizzo Shoes Limited
v.
Zittrer, Siblin & Associates, Inc., Trustees in Bankruptcy
of the Estate of Rizzo & Rizzo Shoes Limited
and
The Ministry of Labour for the Province of Ontario,
Employment Standards Branch
Party
Indexed as: Rizzo & Rizzo Shoes Ltd. (Re)
File No.: 24711.
1997: October 16; 1998: January 22.
Present: Gonthier, Cory, McLachlin, Iacobucci and Major JJ.
on appeal from the court of appeal for ontario
Employmentlaw -- Bankruptcy -- Termination pay and severance available
when employment terminated by the employer -- Whether bankruptcy can be said to be
termination by the employer-- Employment Standards Act, R.S. 0. 1980, c. 137, ss, 7(5),
40(1), (7), 40a -- Employment Standards Amendment Act, 1981, s.o. 1981, c. 22, s. 2(3)
~-~
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- 2 -
__ Bankruptcy Act, R.S.e., 1985, c. B:-3, s. 121(1) -- Interpretation Act, R.S.a. 1990,
c. Ill, ss. 10, 17.
A bankrupt firm's employees lost their jobs when a receiving order was
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made with respect to the firm's property. All wages, salaries, commissions and vacation
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pay were paid to the date of the receiving order. The province's Ministry of Labour
audited the firm's records to determine if any outstanding termination or severance pay
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was owing to former employees under the Employment Standards Act ("ESA") and
delivered a proof of claim to the Trustee. The Trustee disallowed the claims on the
ground that the bankruptcy of an employer does not constitute dismissal from
employment and accordingly creates no entitlement to severance, termination or vacation
pay under the ESA. The Ministry successfully appealed to the Ontario Court (General
Division) but the Ontario Court of Appeal overturned that court's ruling and restored the
Trustee's decision. The Ministry sought leave to appeal from the Court of Appeal
judgment but discontinued its application. Following the discontinuance ofthe appeal,
the Trustee paid a dividend to Rizzo's creditors, thereby leaving significantly less funds
in the estate. Subsequently, the appellants, five former employees of Rizzo, moved to
set aside the discontinuance, add themselves as parties to the proceedings, and requested
and were granted an order granting them leave to appeal. At issue here is whether the
termination of employment caused by the bankruptcy of an employer give rise to a claim
provable in bankruptcy for termination pay and severance pay in accordance with the
provisions of the ESA.
Held: The appeal should be allowed.
At the heart of this conflict is an issue of statutory interpretation. Although
the plain language of ss. 40 and 40a of the ESA suggests that termination pay and
- 3 -
severance pay are payable only when the employer terminates the employment, statutory
interpretation cannot be founded on the wording ofthe legislation alone. The words of
an Act are to be read in their entire context and in their grammatical and ordinary sense
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harmoniously with the scheme of the Act, the object of the Act, and the intention of
Parliament. Moreover, s. 10 of Ontario's Interpretation Act provides that every Act
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"shall be deemed to be remedial" and directs that every Act shall "receive such fair, large
,
....
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and liberal construction and interpretation as will best ensure the attainment of the object
of the Act according to its true intent, meaning and spirit".
The objects of the ESA and of the termination and severance pay provisions
themselves are broadly premised upon the need to protect employees~ Finding ss. 40 and
40ato be inapplicable in bankruptcy situations is incompatible with both the object of
the ESA and the termination and severance pay provisions. The legislature does not
intend to produce absurd consequences and such a consequence would result if
employees dismissed before the bankruptcy were to be entitled to these benefits while
those dismissed after a bankruptcy would not be so entitled. A distinction would be
made between employees merely on the basis of the timing of their dismissal and such
a result would arbitrarily deprive some of a means to cope with economic dislocation.
The use of legislative history as a tool for determining the intention of the
legislature is an entirely appropriate exercise. Section 2(3) of the Employment Standards
AmendmentAct, 1981 exempted from severance pay obligations employers who became
bankrupt and lost control of their assets between the coming into force of the amendment
and its receipt of royal assent. Section 2(3) necessarily implies that the severance pay
obligation does in fact extend to bankrupt employers. If this were not the case, no
readily apparent purpose would be served by this transitional provision. Further, since
the ESA is benefits-conferring legislation, it ought to be interpreted in a broad and
- 4-
generous manner. Any doubt arising from difficulties of language should be resolved
in favour of the claimant.
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When the express words of ss. 40 and 40a are examined in their entire
if)
context, the words "terminated by an employer" must be interpreted to include
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termination resulting from the bankruptcy of the employer. The impetus behind the
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termination of employment has no bearing upon the ability of the dismissed employee
to cope with the sudden economic dislocation caused by unemployment. As all
dismissed employees are equally in need of the protections provided by the ESA, any
distinction between employees whose termination resulted from the bankruptcy of their
employer and those who have been terminated for some other reason would be arbitrary
and inequitable. Such an interpretation would defeat the true meaning, intent and spirit
of the ESA. Termination as a result of an employer's bankruptcy therefore does give rise
to an unsecured claim provable in bankruptcy pursuant to s. 121 of the Bankruptcy Act
for termination and severance pay in accordance with ss.40 and 40a of the ESA. It was
not necessary to address tlie applicability of s. 7(5) of the ESA.
~:
Cases Cited
Distinguished: Re Malone Lynch Securities Ltd., [1972] 3 O.R. 725; Re
Kemp Products Ltd. (1978),27 C.B.R. (N.S.) 1; Mills-Hughes v. Raynor (1988),63 O.R.
(2d) 343; referred to: u.F. C. W, Loc. 617P v. Royal Dressed Meats Inc. (Trustee oj)
(1989),76 C.B.R. (N.S.) 86; R. v. Hydro-Quebec, [1997] 3 S.C.R. 213*; Royal Bank of
Canada v. Sparrow Electric Corp., [1997] 1 S.C.R. 411; Verdun v. Toronto-Dominion
Bank, [1996] 3 S.c.R. 550; Friesen v. Canada, [1995] 3 S.c.R. 103; Machtinger v. HOJ
* See Erratum [1999] 2 S.C.R. iv
:_~ ?
- 5 -
Industries Ltd., [1992] 1 S.C.R. 986; Wallace v. United Grain Growers Ltd., [1997] 3
S.C.R. 701; R. v. TNT Canada Inc. (1996), 27 O.R (3d) 546; Re Telegram Publishing
Co. v. Zwelling (1972),1 L.A.C. (2d) 1; R. v. Vasil, [1981] 1 S.C.R 469; Paul v. The
f
Queen, [1982] 1 S.C.R. 621; R. v. Morgentaler, [1993] 3 S.C.R. 463; Abrahams v.
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Attorney General of Canada, [1983] 1 S.C.R. 2; Hills v. Canada (Attorney General),
[1988] 1 S.C.R. 513; British Columbia (Director of Employment Standards) v. Eland
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Distributors Ltd. (Trustee oj) (1996), 40 C.B.R.(3d) 25; R. v. Z. (D.A.), [1992] 2 S.C.R
1025.
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Statutes and Regulations Cited
Bankruptcy Act, RS.C., 1985, c. B-3 [now the Bankruptcy and Insolvency Act],
s.121(1).
Employment Standards Act, RS.O. 1970, c. 147, s. 13(2).
Employment Standards Act, R.S.O. 1980, c. 137, ss. 7(5) [rep. & sub. 1986, c. 51, s. 2],
40(1) [rep. & sub. 1987, c. 30, s. 4(1)], (7), 40a(l) [rep. & sub. ibid.,s. 5(1)].
Employment Standards Act, 1974, S.O. 1974, c. 112, s. 40(7).
Employment Standards Amendment Act, 1981, S.O. 1981, c. 22, s. 2.
Interpretation Act, R.S.O. 1980, c. 219 [now RS.O. 1990, c. 1.11], ss. 10, 17.
Labour Relations and Employment Statute Law Amendment Act, 1995, S.O. 1995, c. 1,
ss. 74(1), 75(1).
Authors Cited
Christie, Innis, Geoffrey England and Brent Cotter. Employment Law in Canada, 2nd
ed. Toronto: Butterworths, 1993.
Cote, Pierre-Andre. The Interpretation of Legislation in Canada, 2nd ed. Cowansville,
Que.: Yvon Blais, 1991.
Driedger, Elmer A. Construction of Statutes, 2nd ed. Toronto: Butterworths, 1983.
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Ontario. Legislature of Ontario Debates, 1 st sess., 32nd ParI., June 4, 1981,
pp. 1236-37.
Ontario. Legislature of Ontario Debates, 1st sess., 32nd ParI., June 16, 1981, p. 1699.
Sullivan, Ruth. Driedger on the COnstruction oj Statutes, 3rd ed. Toronto:
Butterworths, 1994.
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Sullivan, Ruth. Statutory Interpretation. Concord,Ont.: Irwin Law, 1997.
(f)
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APPEAL from a judgment of the Ontario Court of Appeal (1995), 22 O.R.
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(3d) 385, 80 0.A.e. 201, 30 C.B.R. (3d) 1,9 C.e.E.L. (2d) 264, 95 e.L.L.C. ~21O-020,
[1995] OJ. No. 586 (QL), reversing a judgment of the Ontario Court (Gtmeral Division)
(1991), 6 O.R. (3d) 441, 11 C.B.R. (3d) 246, 92 C.L.L.e. ~14,013, ruling that the
Ministry of Labour could prove claims on behalf of employees of the bankrupt. Appeal
allowed.
Steven M. Barrett and Kathleen Martin, for the appellants.
Raymond M Slattery, for the respondent.
David Vickers, for the Ministry of Labour for the Province of Ontario,
Employment Standards Branch.
//Iacobucci J.//
The judgment ofthe Court was delivered by
1
IACOBUCCI J. -- This is an appeal by the former employees of a now
bankrupt employer from an order disallowing their claims for termination pay (including
vacation pay thereon) and severance pay. The case turns on an issue of statutory
::: :;
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interpretation. Specifically, the appeal decides whether, under the relevant legislation
in effect at the time of the bankruptcy, employees are entitled to claim termination and
severance payments where their employment has been terminated by reason of their
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employer's bankruptcy.
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1. Facts
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2
Prior to its bankruptcy, Rizzo & Rizzo Shoes Limited ("Rizzo") owned and
operated a chain of retail shoe stores across Canada. Approximately 65 percent of those
stores were located in Ontario. On April 13, 1989, a petition in bankruptcy was filed
against the chain. The follpwing day, a receiving order was made on consent in respect
of Rizzo's property. Upon the making of that order, the employment of Rizzo's
employees came to an end.
3
Pursuant to the receiving order, the respondent, Zittrer, Siblin &Associates,
Inc. (the "Trustee") was appointed as trustee in bankruptcy of Rizzo's estate. The Bank
of Nova Scotia privately appointed Peat Marwick Limited ("PML") as receiver and
manager. By the end of July 1989, PML had liquidated Rizzo's property and assets and
closed the stores. PML paid all wages, salaries, commissions and vacation pay that had
been earned by Rizzo's employees up to the date on which the receiving order was made.
4
In November 1989, the Ministry of Labour for the Province of Ontario,
Employment Standards Branch (the "Ministry") audited Rizzo's records to determine if
there was any outstanding termination or severance pay owing to former employees
under the Employment Standards Act, RS.O. 1980, c. 137, as amended(the "ESA"). On
August 23, 1990, the Ministry delivered a proof of claim to the respondent Trustee on
behalf of the former employees of Rizzo for termination pay and vacation pay thereon
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in the amount of approximately $2.6 million and for severance pay totalling $14,215.
The Trustee disallowed the claims, issuing a Notice of Disallowance on January 28,
1991. For the purposes of this appeal, the relevant ground for disallowing the claim was
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the Trustee's opinion that the bankruptcy of an employer does not constitute a dismissal
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from employment and thus, no entitlement to severance, termination or vacation pay is
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created under the ESA.
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5
The Ministry ~ppealed the Trustee's decision to the Ontario Court (General
Division) which reversed the Trustee's disallowance and allowed the claims as
unsecured claims provable in bankruptcy. On appeal, the Ontario Court of Appeal
overturned the trial court's ruling and restored the decision of the Trustee. The Ministry
sought leave to appeal from the Court of Appeal judgment, but discontinued its
application on August 30, 1993. Following the discontinuance of the appeal, the Trustee
paid a dividend to Rizzo's creditors, thereby leaving significantly less funds in the estate.
Subsequently, the appellants, five former employees of Rizzo, moved to set aside the
discontinuance, add themselves as parties to the proceedings, and requested an order
granting them leave to appeal. This Court's order granting those applications was issued
on December 5, 1996.
2. Relevant Statutorv Provisions
6
The relevant versions of the Bankruptcy Act (now the Bankruptcy and
Insolvency Act) and the Employment Standards Act for the purposes of this appeal are
R.S.C., 1985, c. B-3 (the "BA"), and RS.O. 1980, c. 137, as amended to April 14, 1989
(the "ESA") respectively.
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Employment Standards Act, R.S.O. 1980, c. 137, as amended:
7. --
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(5) Every contract of employment shall be deemed to include the
following provision:
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All severance pay and termination pay become payable and shall be .
paid by the employer to the employee in two weekly instalments
beginning with the first full week following termination of employment
and shall be allocated to such weeks accordingly. This provision does
not apply to severance pay if the employee has elected to maintain a
right of recall as provided in subsection 40a (7) of the Employment
Standards Act.
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40. -- (1) No employer shall terminate the employment of an employee
who has been employed for three months or more unless the employee gives,
(a) one weeks notice in writing to the employee ifhis or her period
of employment is less than one year;
(b) two weeks notice in writing to the employee ifhis or her period
of employment is one year or more but less than three years;
(c) three weeks notice in writing to the employee ifhis or her period
of employment is three years or more but less than four years;
(d) four weeks notice in writing to the employee ifhis or her period
of employment is four years or more but less than five years;
( e) five weeks notice in writing to the employee if his or her period
of employment is five years or more but less than six years;
(t) six weeks notice in writing to the employee if his or her period
of employment is six years or more but less than seven years;
(g)
seven weeks notice in writing to the employee if his or her
period of employment is seven years or more but less than eight
years;
(h) eight weeks notice in writing to the employee ifhis or her period
of employment is eight years or more,
and such notice has expired.
(7) Where the employment of an employee is terminated contrary to this
section,
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(a)
the employer shall pay termination pay in an amount equal to the
wages that the employee would have been entitled to receive at
his regular rate for a regular non-overtime work week for the
period of notice prescribed by subsection (1) or (2), and any
wages to which he is entitled;
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(a) fifty or more employees have their employment terminated by
an employer in a period of six months or less and the
terminations are caused by the permanent discontinuance of all
or part of the business of the employer at an establishment; or
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(la) Where,
(b) one or more employees have their employment terminated by an
employer with a payroll of $2.5 million or more,
the employer shall pay severance pay to each employee whose employment
has been terminated and who has been employed by the employer for five
or more years.
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Employment Standards Amendment Act, 1981, S.O. 1981, c. 22
2.--( 1) Part XII of the said Act is amended by adding thereto the following
section:
(3)
Section 40a of the said Act does not apply to an employer who
became a bankrupt or an insolvent person within the meaning of
the Bankruptcy Act (Canada) and whose assets have been
distributed among his creditors or to an employer whose
proposal within the meaning of the Bankruptcy Act (Canada) has
been accepted by his creditors in the period from and including
the 1st day of January, 1981, to and including the day
immediately before the day this Act receives Royal Assent.
Bankruptcy Act, RS.C., 1985, c. B-3
121. (1) All debts and liabilities, present or future, to which the
bankrupt is subject at the date of the bankruptcy or to which he may become
subject before pis discharge by reason of any obligation incurred before the
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date of the bankruptcy shall be deemed to be claims provable in proceedings
under this Act.
Interpretation Act, RS.O. 1990, c. 1.11
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10. Every Act shall be deemed to be remedial, whether its immediate.
purport is to direct the doing of anything that the Legislature deems to be for
the public good or to prevent or punish the doing of any thing that it deems
to be contrary to the public good, and shall accordingly receive such fair,
large and liberal construction and interpretation as will best ensure the
attainment of the object ofthe Act according to its true intent, meaning and
spirit.
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17. The repeal or amendment of an Act shall be deemed not to be or to
involve any declaration as to the previous state of the law.
3. Judicial History
A. Ontario Court (General Division) (1991), 6 O.R. (3d) 441
7
Having disposed of several issues which do not arise on this appeal, Farley
J. turned to the question of whether termination pay and severance pay are provable
claims under the BA. Relying on u.F.C.W, Loc. 617P v. Royal Dressed Meats Inc.
(Trustee oj) (1989), 76 C.B.R. (N.S.) 86 (Ont. S.C. in Bankruptcy), he found that it is
clear that claims for termination and severance pay are provable in bankruptcy where the
statutory obligation to provide such payments arose prior to the bankruptcy.
Accordingly, he reasoned that the essential matter to be resolved in the case at bar was
whether bankruptcy acted as a termination of employment thereby triggering the
termination and severance pay provisions of the ESA such that liability for such
payments would arise on bankruptcy as well.
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8
In addressing this question, Farley J. began by noting that the object and
intent of the ESA is to provide minimum employment standards and to benefit and
protect the interests of employees. Thus, he concluded that the ESA is remedial
legislation and as such it should be interpreted in a fair, large and liberal manner to
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ensure that its object is attained according to its true meaning, spirit and intent.
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Farley J. then held that denying employees in this case the right to claim
termination and severancb pay would lead to the arbitrary and unfair result that an
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employee whose employment is terminated just prior to a bankruptcy would be entitled
to termination and severance pay, whereas one whose employment is terminated by the
bankruptcy itself would not have that right. This result, he stated, would defeat the
intended working of the ESA.
10
Farley J. saw no reason why the claims of the employees in the present case
would not generally be contemplated as wages or other claims under the BA. He
emphasized that the former employees in the case at bar had not alleged that termination
pay and severance pay should receive a priority in the distribution of the estate, but
merely that they are provable (unsecured and unpreferred) claims in a bankruptcy. For
this reason, he found it inappropriate to maKe reference to authorities whose focus was
the interpretation of priority provisions in the BA.
11
Even if bankruptcy does not terminate the employment relationship so as
to trigger the ESA termination and severance pay provisions, Farley J. was of the view
that the employees in the instant case would nevertheless be entitled to such payments
as these were liabilities incurred prior to the date of the bankruptcy by virtue of s. 7(5)
of the ESA. He found that s. 7(5) deems every employment contract to include a
provision to provide termination and severance pay following the termination of
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employment and concluded that a contingent obligation is thereby created for a bankrupt
employer to make such payments from the outset of the relationship, long before the
bankruptcy.
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12
Farley J. also considered s. 2(3) of the Employment Standards Amendment
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Act, 1981, S.O. 1981, c. 22 (the "ESAA"), which is a transitional provision that exempted
certain bankrupt employers from the newly introduced severance pay obligations until
the amendments received royal assent. He was of the view that this provision would not
have been necessary ifthe obligations of employers upon termination of employment had
not been intended to apply to bankrupt employers under the ESA. Farley J. concluded
that the claim by Rizzo's former employees for termination pay and severance pay could
be provided as unsecured and unpreferred debts in a bankruptcy. Accordingly, he
allowed the appeal from the decision of the Trustee.
B. Ontario Court of Appeal (1995),22 O.R. (3d) 385
13
Austin J.A., writing for a unanimous court, began his analysis of the
principal issue in this appeal by focussing upon the language of the termination pay and
severance pay provisions of the ESA. He noted, at p. 390, that the termination pay
provisions use phrases such as "[ n]o employer shall terminate the employment of an
employee" (s. 40( 1)), "the notice required by an employer to terminate the employment"
(s. 40(2)), and "[a]n employer who has terminated or who proposes to terminate the
employment of employees" (s. 40(5)). Turning to severance pay, he quoted s. 40a(1 )(a)
(at p. 391) which includes the phrase "employees have their employment terminated by
an employer". Austin J.A.. concluded that this language limits the obligation to provide
~
termination and severance pay to situations in which the employer terminates the
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employment. The operation of the ESA, he stated, is not triggered by the termination of
employment resulting from an act of law such as bankruptcy.
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14
In support of his conclusion, Austin J .A. reviewed the leading cases in this
(f)
area of law. He cited Re Malone Lynch Securities LId., [1972] 3 O.R. 725 (S.e. in
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bankruptcy), wherein Houlden J. (as he then was) concluded that the ESA termination
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pay provisions were not designed to apply to a bankrupt employer. He also relied upon
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Rtf Kemp Products Ltd. (1978), 27 C.B.R. (N.S.) 1 (Ont. S.e. in bankruptcy), for the
proposition that the bankruptcy of a company at the instance of a creditor does not
constitute dismissal. He concluded as follows at p. 395:
The plain language of ss. 40 and 40a does not give rise to any liability to pay
termination or severance pay except where the employment is terminated by
the employer. In our case, the employment was terminated, not by the
employer, but by the making of a receiving order against Rizzo on April 14,
1989, following a petition by one of its creditors. No entitlement to either
termination or severance pay ever arose.
15
Regarding s. 7(5) of the ESA, Austin J.A. rejected the trial judge's
interpretation and found that the section does not create a liability. Rather, in his
opinion, it merely states when a liability otherwise created is to be paid and therefore it
was not considered relevant to the issue before the court. Similarly, Austin J.A. did not
accept the lower court's view of s. 2(3), the transitional provision in the ESAA. He found
that that section had no effect upon the intention of the Legislature as evidenced by the
terminology used in ss. 40 and 40a.
16
Austin J.A. cdncluded that, because the employment of Rizzo's former
employees was terminated by the order of bankruptcy and not by the act of the employer,
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no liability arose with respect to termination, severance or vacation pay. The order of
the trial judge was set aside and the Trustee's disallowance of the claims was restored.
4. Issues
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17
This appeal raises one issue: does the termination of employment caused by
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the bankruptcy of an employer give rise to a claim provable in bankruptcy for
termination pay and severance pay in accordance with the provisions of the ESA?
5. Analysis
18 The statutory obligation upon employers to provide both termination pay and
i
severance pay is governed by ss. 40 and 40a of the ESA, respectively. The Court of
Appeal noted that the plairt language of those provisions suggests that termination pay
and severance pay are payable only when the employer terminates the employment. For
,
example, the opening words of s. 40(1) are: "No employer shall terminate the
employment of an employee. . . ." Similarly, s. 40a(1a) begins with the words, "Where
. . . fifty or more employees have their employment terminated by an employer. . . ."
Therefore, the question on which this appeal turns is whether, when bankruptcy occurs,
the employment can be said to be terminated "by an employer".
19
The Court of Appeal answered this question in the negative, holding that,
where an employer is petitioned into bankruptcy by a creditor, the employment of its
employees is not terminated "by an employer", but rather by operation oflaw. Thus, the
Court of Appeal reasoned that, in the circumstances of the present case, the ESA
termination pay and severance pay provisions were not applicable and no obligations
arose. In answer, the appellants submit that the phrase "terminated by an employer" is
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best interpreted as reflecting a distinction between involuntary and voluntary termination
of employment. It is their position that this language was intended to relieve employers
of their obligation to pay termination and severance pay when employees leave their jobs
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voluntarily. However, the appellants maintain that where an employee's employment
is involuntarily terminated by reason Of their employer's bankruptcy, this constitutes
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termination "by an employer" for the purpose of triggering entitlement to termination
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and severance pay under the ESA.
20
At the heart of this conflict is an issue of statutory interpretation. Consistent
with the findings of the Court of Appeal, the plain meaning of the words of the
provisions here in question appears to restrict the obligation to pay termination and
severance pay to those employers who have actively terminated the employment of their
employees. At first blush, bankruptcy does not fit comfortably into this interpretation.
However, with respect, I believe this analysis is incomplete.
21
Although much has been written about the interpretation oflegislation (see,
e.g., Ruth Sullivan, Statutory Interpretation (1997); Ruth Sullivan, Driedger on the
Construction of Statutes (3rd ed. 1994) (hereinafter "Construction of Statutes"); Pierre-
Andre Cote, The Interpretation of Legislation in Canada (2nd ed. 1991)), Elmer
Driedger in Construction of Statutes (2nd ed. 1983) best encapsulates the approach upon
which I prefer to rely. He recognizes that statutory interpretation cannot be founded on
the wording of the legislation alone. At p. 87 he states:
Today there is only one principle or approach, namely, the words of an
Act are to be read in their entire context and in their grammatical and
ordinary sense harmoniously with the scheme of the Act, the object of the
Act, and the intention of Parliament.
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Recent cases which have cited the above passage with approval include: R. v. Hydro-
Quebec, [1997] 3 S.C.R 213**; Royal Bank of Canada v. Sparrow Electric Corp., [1997]
I S.C.R. 411; Verdun v. Toronto-Dominion Bank, [1996] 3 S.e.R. 550; Friesen v.
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Canada, [1995] 3 S.e.R 103.
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22
I also rely upon s. 10 of the Intelpretation Act, RS.O. 1980, c. 219, which
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provides that every Act "shall be deemed to be remedial" and directs that every Act shall
"receive such fair, large and liberal construction and interpretation as will best ensure
the attainment of the object of the Act according to its true intent, meaning and spirit".
23
Although the Court of Appeal looked to the plain meaning of the specific
provisions in question in the present case, with respect, I believe that the court did not
pay sufficient attention to the scheme of the ESA, its object or the intention of the
legislature; nor was the context of the words in issue appropriately recognized. I now
turn to a discussion of these issues.
24
In Machtinger v. HOJ Industries Ltd., [1992] 1 S.e.R. 986, at p. 1002, the
majority ofthis Court recognized the importance that our society accords to employment
and the fundamental role that it has assumed in the life of the individual. The manner
in which employment can be terminated was said to be equally important (see also
~
Wallace v. United Grain Growers Ltd., [1997] 3 S.e.R. 701). It was in this context that
the majority in Machtinger described, at p. 1003, the object of the ESA as being the
protection of ". . . the interests of employees by requiring employers to comply with
certain minimum standards, including minimum periods of notice of termination".
Accordingly, the majority concluded, at p. 1003, that, ". . . an interpretation of the Act
** See Erratum [1999] 2 S.e.R iv
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which encourages employers to comply with the minimum requirements ofthe Act, and
so extends its protections to as many employees as possible, is to be favoured over one
that does not".
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25
The objects of the termination and severance pay provisions themselves are
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also broadly premised upon the need to protect employees. Section 40 of the ESA
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requires employers to give their employees reasonable notice of termination based upon
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length of service. One of the primary purposes of this notice period is to provide
employees with an opportunity to take preparatory measures and seek alternative
employment. It follows that s. 40(7)(a), which provides for termination pay in lieu of
notice when an employer has failed to give the required statutory notice, is intended to
"cushion" employees against the adverse effects of economic dislocation likely to follow
from the absence of an opportunity to search for alternative employment. (Innis Christie,
Geoffrey England and Brent Cotter, Employment Law in Canada (2nd ed. 1993), at pp.
572-81.)
26
Similarly, s. 40a, which provides for severance pay, acts to compensate long~
serving employees for their years of service and investment in the employer's business
and for the special losses they suffer when their employment terminates. In R. v. TNT
Canada Inc. (1996), 27 O.R. (3d) 546, Robins J.A. quoted with approval at pp. 556-57
from the words of D. D. Carter in the course of an employment standards determination
in Re Telegram Publishing Co. v. Zwelling (1972), 1 L.A.e. (2d) 1 (Ont.), at p. 19,
wherein he described the role of severance pay as follows:
Severance pay recognizes that an employee does make an investment in his
employer's business -- the extent of this investment being directly related to
the length of the employee's service. This investment is the seniority that
the employee builds up during his years of service. . . . Upon termination of
the employment relationship, this investment of years of service is lost, and
€3
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the employee must start to rebuild seniority at another place of work. The
severance pay, based on length of service, is some compensation for this loss
of investment.
27
In my opinion, the consequences or effects which result from the Court of
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Appeal's interpretation of ss. 40 and 40a of the ESA are incompatible with both the
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object of the Act and with/he object of the termination and severance pay provisions
themselves. It is a well established principle of statutory interpretation that the
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legislature does not intend to produce absurd consequences. According to Cote, supra,
an interpretation can be.considered absurd if it leads to ridiculous or frivolous
consequences, if it is extremely unreasonable or inequitable, if it is illogical or
incoherent, or if it is incompatible with other provisions or with the object of the
legislative enactment (at pp. 378-80). Sullivan echoes these comments noting that a
label of absurdity can be attached to interpretations which defeat the purpose of a statute
or render some aspect of it pointless or futile (Sullivan, Construction of Statutes, supra,
at p. 88).
28
The trial judge properly noted that, if the ESA termination and severance pay
provisions do not apply in circumstances of bankruptcy, those employees "fortunate"
enough to have been dismissed the day before a bankruptcy would be entitled to such
payments, but those terminated on the day the bankruptcy becomes final would not be
so entitled. In my view, the absurdity of this consequence is particularly evident in a
unionized workplace where seniority is a factor in determining the orderoflay-off. The
more senior the employee, the larger the investment he or she has made in the employer
and the greater the entitlement to termination and severance pay. However, it is the more
senior personnel who are likely to be employed up until the time of the bankruptcy and.
who would thereby lose their entitlements to these payments.
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29
If the Court of Appeal's interpretation of the termination and severance pay
provisions is correct, it would be acceptable to distinguish between employees merely
on the basis of the timing of their dismissal. It seems to me that such a result would
arbitrarily deprive some employees of a means to cope with the economic dislocation
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caused by unemployment. In this way the protections of the ESA would be limited rather
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this is an unreasonable result.
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than extended, thereby defeating the intended workingofthe legislation. In my opinion,
30
In addition to the termination and severance pay proVIsIons, both the
appellants and the respondent relied upon various other sections of the ESA to advance
their arguments regarding the intention of the legislature. In my view, although the
majority of these sections offer little interpretive assistance, one transitional provision
is particularly instructive. In 1981, s. 2( I) ofthe ESAA introduced s. 40a, the severance
pay provision, to the ESA. Section 2(2) deemed that provision to come into force on
January 1, 1981. Section 2(3), the transitional provision in question provided as follows:
2... .
(3)
Section 40a of the said Act does not apply to an employer who
became a bankrupt or an insolvent person within the meaning of
the Bankruptcy Act (Canada) and whose assets have been
distributed among his creditors or to an employer whose
proposal within the meaning oftheBankruptcy Act (Canada) has
been accepted by his creditors in the period from and including
the 1 st day of January, 1981, to and including the day
immediately before the day this Act receives ~oyal Assent.
31
The Court of Appeal found that it was neither necessary nor appropriate to
determine the intention of the legislature in enacting this provisional subsection.
Nevertheless, the court took the position that the intention of the legislature as evidenced
by the introductory words of ss. 40 and 40a was clear, namely, that termination by
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reason of a bankruptcy will not trigger the severance and termination pay obligations of
the ESA. The court held that this intention remained unchanged by the introduction of
the transitional provision. With respect, I do not agree with either of these findings.
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Firstly, in my opinion, the use of legislative history as a tool for determining the
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intention of the legislature is an entirely appropriate exercise and one which has often
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been employed by this Court (see, e.g., R. v. Vasil, [1981] 1 S.C.R. 469, at p. 487; Paul
v. The Queen, [1982] 1 S.e.R. 621, at pp. 635, 653 and 660). Secondly, I believe that
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the transitional provision indicates that the Legislature intended that termination and
severance pay obligations should arise upon an employers' bankruptcy:
32
In my view, by extending an exemption to employers who became bankrupt
and lost control of their assets between the coming into force of the amendrnent and its
receipt of royal assent, s. 2(3) necessarily implies that the severance pay obligation does
in fact extend to bankrupt employers. It seems to me that, if this were not the case, no
readily apparent purpose would be served by this transitional provision.
33
I find support for my conclusion in the decision of Saunders J. in Royal
Dressed Meats Inc., supra. Having reviewed s. 2(3) of the ESAA, he commented as
follows (at p. 89):
. . . any doubt about the intention of the Ontario Legislature has been put to
rest, in my opinion, by the transitional provision which introduced severance
payments into the E.S.A. . . . it seems to me an inescapable inference that the
legislature intended liability for severance payments to arise on a
bankruptcy. That intention would, in my opinion, extend to termination
payments which are similar in character.
34
This interpretation is also consistent with statements made by the Minister
of Labour at the time he introduced the 1981 amendments to the ESA. With regard to
the new severance pay provision he stated:
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The circumstances surrounding a closure will govern the applicability
of the severance pay legislation in some defined situations. For example, a
bankrupt or insolvent firm will still be required to pay severance pay to
employees to the extent that assets are available to satisfy their claims.
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. . . the proposed severance pay measures will, as I indicated earlier, be
retroactive to January I of this year. That retroactive provision, however,
will not apply in those cases ofbankruptcy and insolvency where the assets
have already been distributed or where an agreement on a proposal to
creditors has already been reached.
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(Legislature of Ontario Debates, 1 st sess., 32nd ParI., June 4, 1981, at pp.
1236-37.)
Moreover, in the legislative debates regarding the proposed amendments the Minister
stated:
For purposes of retroactIvIty, severance pay will not apply to
bankruptcies under the Bankruptcy Act where assets have been distributed.
However, once this act receives royal assent, employees in bankruptcy
closures will be covered by the severance pay provisions.
(Legislature of Ontario Debates, 1st sess., 32nd ParI., June 16,1981, at p.
1699. )
Although the frailties .of Hansard evidence are many, this Court has
recognized that it can playa limited role in the interpretation oflegislation. Writing for
the Court in R. v. Morgentaler, [1993] 3 S.e.R. 463, at p. 484, Sopinka J. stated:
. . . until recently the courts have balked at admitting evidence oflegislative
debates and speeches. . . . The main criticism of such evidence has been that
it cannot represent the "intent" of the legislature, an incorporeal body, but
that is equally true of other forms of legislative history. Provided that the
court remains mindful of the limited reliability and weight of Hansard
evidence, it should be admitted as relevant to both the background and the
purpose of legislation.
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36
Finally, with regard to the scheme of the legislation, since the ESA is a
mechanism for providing minimum benefits and standards to protect the interests of
employees, it can be characterized as benefits-conferring legislation. As such, according
to several decisions of this Court, it ought to be interpreted in a broad and generous
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manner. Any doubt arising from difficulties of language should be resolved in favour of
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the claimant (see, e.g., Abrahams v. Attorney General of Canada, [1983] I S.C.R. 2,at
p. 10; Hills v. Canada (Attorney General), [1988] I S.e.R. 513, atp. 537). It seems to
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me that, by limiting its analysis to the plain meaning of ss. 40 and 40a of the ESA, the
Court of Appeal adopted an overly restrictive approach that is inconsistent with the
scheme of the Act.
37
The Court of Appeal's reasons relied heavily upon the decision in Malone
Lynch, supra. In Malone Lynch, Houlden J. held that s. 13, the group termination
provision of the former ESA, RS.O. 1970, c. 147, and the predecessor tos. 40 at issue
in the present case, was not applicable where termination resulted from the bankruptcy
of the employer. Section 13(2) of the ESA then in force provided that, if an employer
wishes to termina.te the employment of 50 or more employees, the employer must give
notice of termination for the period prescribed in the regulations, "and until the expiry
of such notice the terminations shall not take effect". Houlden J. reasoned that
termination of employment through bankruptcy could not trigger the termination
payment provision, as employees in this situation had not received the written notice
required by the statute, and therefore could not be said to have been terminated in
accordance with the Act.
38
Two years after Malone Lynch was decided, the 1970 ESA termination pay
provisions were amended by The Employment Standards Act, 1974, S.O. 1974, c. 112.
As amended, s. 40(7) of the 1974 ESA ellminated the requirement that notice be given
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before termination can take effect. This provision makes it clear that termination pay "is
owing where an employer fails to give notice of termination and that employment
terminates irrespective of whether or not proper notice has been given. Therefore, in my
opinion it is clear that the Malone Lynch decision turned on statutory provisions which
are materially different from those applicable in the instant case. It seems to me that
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no application to a bankrupt employer. For this reason, I do not accept the Malone
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Houlden J.'s holding goes no further than to say that the provisions of the 1970 ESA have
Lynch decision as persuasive authority for the Court of Appeal's findings. I note that the
courts in Royal Dressed Meats, supra, and British Columbia (Director of Employment
Standards) v. Eland Distributors Ltd. (Trustee oj) (1996),40 C.B.R. (3d) 25 (B.C.S.e.),
declined to rely upon Malone Lynch based upon similar reasoning.
39
The Court of Appeal also relied upon Re Kemp Products Ltd., supra, forthe
proposition that although the employment relationship will terminate upon an employer's
bankruptcy, this does not constitute a "dismissal". I note that this case did not arise
under the provisions of the ESA. Rather, it turned on the interpretation of the term
"dismissal" in what the complainant alleged to be an employment contract. As such, I
do not accept it as authoritative jurisprudence in the circumstances of this case. For the
reasons discussed above, I also disagree with the Court of Appeal's reliance on Mills-
Hughes v. Raynor (1988),63 O.R. (2d) 343 (e.A.), which cited the decision in Malone
Lynch, supra, with approval.
40
As I see the matter, when the express words of ss. 40 and 40a of the ESA are
examined in their entire context, there is ample support for the conclusion that the words
"terminated by the employh" must be interpreted to include termination resulting from
the bankruptcy of the employer. Using the broad and generous approach to
interpretation appropriate for benefits-conferring legislation, I. believe that these words
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42
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can reasonably bear that construction (see R. v. Z. (D.A.), [1992] 2 S.C.R. 1025). I also
note that the intention of the Legislature as evidenced in s. 2(3) of the ESAA, clearly
favours this interpretation. Further, in my opinion, to deny employees the right to claim
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ESA termination and severance pay where their termination has resulted from their
employer's bankruptcy, would be inconsistent with the purpose of the termination and
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severance pay provisions and would undennine the object of the ESA, namely, to protect
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the interests of as many employees as possible.
In my view, the impetus behind the termination of employment has no
bearing upon the ability of the dismissed employee to cope with the sudden economic
dislocation caused by unemploym~nt. As all dismissed employees are equally in need
of the protections provided by the ESA, any distinction between employees whose
termination resulted from the bankruptcy of their employer and those who have been
terminated for some other reason would be arbitrary and inequitable. Further, I believe
that such an interpretation would defeat the true meaning, intent and spirit of the ESA.
Therefore, I conclude that termination as a result of an employer's bankruptcy does give
rise to an unsecured claim provable in bankruptcy pursuant to s. 121 of the BA for
termination and severance pay in accordance with ss. 40 and 40a of the ESA. Because
of this conclusion, I do not find it necessary to address the alternative finding of the trial
judge as to the applicability of s. 7(5) of the ESA.
I note that spbsequent to the Rizzo bankruptcy, the termination and
severance pay provisions of the ESA underwent another amendment. Sections 74( 1) and
75(1) of the Labour Relations and Employment Statute Law Amendment Act, 1995, S.O.
1995, c. 1, amend those provisions so that they now expressly provide that where
employment is terminated by operation of law as a result of the bankruptcy of the
employer, the employer wiil be deemed to have terminated the employment. However,
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s. 17 of the Interpretation Act directs that, "[t]he repeal or amendment of an Act shall be
deemed not to be or to involve any declaration as to the previous state of the law". As
a result, I note that the subsequent change in the legislation has played no role in
determining the present appeal.
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6. Disposition and Costs
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I would allow the appeal and set aside paragraph 1 of the order of the Court
of Appeal. In lieu thereof, I would substitute an order declaring that Rizzo's former
employees are entitled to make claims for termination pay (including vacation pay due
thereon) and severance pay as unsecured creditors. As to costs, the Ministry of Labour
led no evidence regarding what effort it made in notifying or securing the consent of the
Rizzo employees before it discontinued its application for leave to appeal to this Court
on their behalf. In light of these circumstances, I would order that the costs in this Court
be paid to the appellant by the Ministry on a party-and-party basis. I would not disturb
the orders of the courts below with respect to costs. .
Appeal allowed with costs.
Solicitorsfor the appellants: Sack, Goldblatt, Mitchell, Toronto.
Solicitors for the respondent: Minden, Gross, Grafstein & Greenstein,
Toronto.
Solicitor jor the Minisl1y of Labour for the Province of Ontario, Employment
Standards Branch: The Attorney Generalfor Ontario, Toronto.