HomeMy WebLinkAbout2006-1607.Mitchell et al.08-04-08 Decision
Commission de
Crown Employees
Grievance Settlement
règlement des griefs
Board
des employés de la
Couronne
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GSB# 2006-1607
UNION# 2006-0611-0003
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Mitchellet al.)
Union
- and -
The Crown in Right of Ontario
(Ministry of Natural Resources)
Employer
BEFOREVice-Chair
Bram Herlich
FOR THE UNION Mark Barclay
Grievance Officer
Ontario Public Service Employees Union
FOR THE EMPLOYER Michelle Dobranowski
Counsel
Ministry of Government and Consumer
Services
HEARING
March 18, 2008.
2
Decision
The collective agreement provides, in certain circumstances, for the payment of a shift
premium for hours worked between 5:00 p.m. and 7:00 a.m. (There is, however, a disentitlement
to the receipt of shift premium by employees whose hours of work normally fall within 7:00 a.m.
and 5:00 p.m. Put somewhat differently, employees who regularly work day shifts between 7:00
a.m. and 5:00 p.m. have no entitlement to shift premium even in circumstances where they may
work outside those hours.) The specific question the parties have put to the Board in these
proceedings is whether seasonal fire program staff ? (at least those) whose hours of work
normally fall outside 7:00 a.m. and 5:00 p.m. ? are entitled to be paid shift premium for hours
worked between 5:00 p.m. and 7:00 a.m. on what otherwise would have been a regular day off
(an ?RDO?) and in circumstances where the number of hours worked on the RDO is at least the
same as the number of hours worked in a regular shift.
While it is Article UN 6.1.3 and, to a much lesser extent, UN 6.2 which are at the centre
of the dispute between the parties, I set out Article 6 in full:
ARTICLE UN 6 - SHIFT PREMIUM
UN 6.1.1 Effective January 1, 1992, an employee shall receive a shift premium
of fifty-two cents (52¢) per hour for all hours worked between 5:00
p.m. and midnight. Where more than fifty percent (50%) of the hours
worked fall within this period, the fifty-two cents (52¢) per hour
premium shall be paid for all hours worked.
UN 6.1.2 Effective January 1, 1992, an employee shall receive a shift premium
of sixty-two cents (62¢) per hour for all hours worked between
midnight and 7:00 a.m. Where more than fifty percent (50%) of the
hours worked fall within this period, the sixty-two cents (62¢) per
hour premium shall be paid for all hours worked.
UN 6.1.3 Effective on May 5, 2002, an employee shall receive a shift premium
of seventy-eight cents (78¢) per hour for all hours worked between
5:00 p.m. and 7:00 a.m. Where more than fifty percent (50%) of the
hours worked fall within this period, the premium shall be paid for all
hours worked. Effective May 5, 2002, UN 6.1.1 and UN 6.1.2 shall
no longer apply.
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UN 6.2 Notwithstanding Articles UN 6.1.1, 6.1.2 and 6.1.3 where an
employee?s hours of work normally fall within 7:00 a.m. and 5:00
p.m., the employee shall not be entitled to receive a shift premium for
hours worked between 5:00 p.m. and 7:00 a.m.
UN 6.3 Shift premiums shall not be considered as part of an employees
basic hourly rate.
UN 6.4 Shift premium shall not be paid to an employee who for mutually
agreed upon reasons works a shift for which he or she would otherwise
be entitled to a shift premium.
The parties put their case to the Board by way of the following Agreed Statement of
Facts:
GSB #2006-1607
OPSEU #2006-0611-0003
In the Matter of a Grievance Arbitration Between:
(OPSEU) Mitchell, Darcy et al (Union)
and
The Crown in Right of Ontario (Ministry of Natural Resources) (Employer)
AGREED STATEMENT OF FACTS
1. This is a group grievance with 41 grievors who worked in the fire program out
of Wawa for the Ministry of Natural Resources (MNR). The grievance was
filed on August 23, 2006.
2. At the time the grievance was filed all but two of the grievors were
performing seasonal work. Generally speaking, the grievors performed forest
fire fighting or related duties during the fire season. Most of their contracts
ran from May through the end of August.
3. Two of the grievors, Mr. Tony Dierolf and Mr. Greg Kirkland were full-time
classified employees at the time the grievance was filed. Both Mr. Dierolf and
Mr. Kirkland were Fire Management Technicians at the time the grievance
was filed.
4
4. Most of the grievors were fire rangers who were members of three-person fire
crews consisting of one Fire Crew Leader (RT3), one Senior Crew Member
(RT2), and one Fire Crew Member (RT1). These workers were on Hours of
Work Schedule 4.7. UN 2.2 provides that the normal hours of work for
employees on Schedule 4.7 shall be forty (40) hours per week and eight (8)
hours per day.
5. The hours of work for fire rangers during the first couple of weeks of their
contracts are 9:30 a.m. to 5:30 p.m. Monday to Friday. As fire hazards
increase and daylight hours lengthen, the start times for these workers moves
to 10:30 a.m. During the heart of fire season, when there are no fire alerts or
hazards, the hours of work for fire crews are 11:30 a.m. until 8:00 p.m. (with a
30-minute unpaid lunch). However, throughout the season (during fire alerts
or hazards), start times vary widely and could include earlier start times (e.g.
7:00 a.m.) For example, fire crews are often required to report for work early
in the morning when fires are burning.
6. A small number of grievors were fire program staff in other seasonal
positions: Two Assistant Fire Management Clerks (OAG6) and one
Equipment Management Person (Clerk 2 Supply).
7. The two Assistant Fire Management Clerks were on Hours of Work Schedule
3.7. UN 2.1 provides that the normal hours of work for employees on
Schedule 3.7 shall be thirty-six and one quarter (36 ¼) hours per week and
seven and one quarter (7 ¼) hours per day. The two Assistant Fire
Management Clerks normally worked from either 9:00 a.m. until 5:00 p.m. or
12:00 p.m. until 8:00 p.m. (on a rotating basis) to ensure full coverage.
8. The Equipment Management Person was on Hours of Work Schedule 4.7. UN
2.2 provides that the normal hours of work for employees on schedule 4.7
shall be forty (40) hours per week and eight (8) hours per day. The
Equipment Management Person normally worked 10 hours per day, eight days
per pay period, from 8:00 a.m. until 6:30 p.m.
9. At the time the grievance was filed ?Article 32 ? Seasonal Employees?
applied to all of the grievors, except Mr. Dierolf and Mr. Kirkland, as noted
above.
10. Article 32.21.2 of the collective agreement specifically states that UN 6 (Shift
Premium) shall apply to seasonal employees.
11. On regular work days, the grievor?s entitlement to shift premium is
determined on a daily basis depending on the specific hours worked each day.
12. The grievors were regularly paid shift premiums on hours worked in
applicable periods when not working on their regular day off (RDO)
(alternatively referred to as a ?scheduled day off?).
5
13. At some points throughout the 2006 and 2007 seasons, the grievors were
approached by the employer to work on their regular days off. The employer
does not pay shift premium to seasonal fire program staff when they perform
work on a RDO. The grievors allege that they should be paid a shift premium
for eligible hours worked as per Article UN 6 on a regular day off.
14. The parties are in dispute about whether or not seasonal fire program staff are
entitled to a shift premium when they perform work on an RDO. The parties
agree that when seasonal fire program staff work on a RDO any hours worked
attract overtime pay as per the Collective Agreement.
15. Specifically, the parties ask the Board to decide whether seasonal fire program
staff are entitled to a Shift Premium on an RDO for hours worked between
5:00 p.m. and 7:00 a.m. if, on a regular scheduled workday, their hours of
work normally fall outside 7:00 a.m. and 5:00 p.m.
16. The parties agree that the grievors would not be entitled to a shift premium
when they work less than the normal hours of work per day as set out in UN
2.1 and 2.2 on an RDO.
17. In terms of remedy, the grievors are seeking retroactive shift premium (for
eligible hours worked as per Article UN 6 on an RDO) for the 2006 and 2007
fire seasons.
As will become evident shortly, the multiplicity of scenarios which may engage an
interpretation of the relevant collective agreement provisions (or those similar or related to them)
is impressive. And despite the limited facts agreed to by the parties, they have opted, rather than
putting any specific particularized facts of any grievance or alleged contravention of the
collective agreement, to pose a question more generic in nature in the hope that the Board?s
ruling will assist them to resolve the issues relating (at least) to the 41 grievors referred to in the
parties? agreed facts.
A number of cases were referred to by the parties in support of their respective positions.
MorinCameronAttwood
These included: , GSB 74/77 (Adams); , GSB 124/77 (Adams); , GSB
RobbinsMcCormick
179/78 (Prichard); , GSB 165/78 (Swan); GSB 52/88 (Springate); and
Union Grievances
, GSB 1211/99 et al. (Petryshen). I will first briefly outline the positions of the
parties and then return to a more detailed consideration of the cases.
6
I should also note that I will refer to employees generally and not distinguish between
classified and seasonal employees. The grievors in question are almost exclusively seasonal
employees and there was nothing in the parties? submissions to enumerate any potentially
different treatment of seasonal or classified employees in the circumstances which concern us. I
feel compelled, however, to underscore that, while as a matter of convenience, I will not
continue to identify the employees in question as ?seasonal?, the question the parties have put to
me and the answer I will provide are both restricted to the treatment of seasonal employees.
The union?s position is simple and straight-forward: for the purposes of shift premium
entitlement, there is nothing in the collective agreement to distinguish between the hours worked
on an RDO from those worked on a regular day. To the extent that the employees in question are
paid shift premium for certain hours worked during their regular shifts, so too should they be
paid shift premium when they work the very same hours or even the same number of hours on
what would otherwise have been a day off.
The union acknowledges that some similar claims have been dismissed, but asserts that
McCormick
was on grounds not available in the instant case. For example, in the case, the
grievance was ultimately dismissed on the basis of the disentitlement now found in Article 6.2
(i.e. the grievor?s hours of work normally fell within 7:00 a.m. and 5:00 p.m.) ? such a
disentitlement is not operative here ? the parties have restricted their question to employees
Union
whose hours of work normally fall outside 7:00 a.m. and 5:00 p.m. Similarly, in the
Grievances
case (and, it would appear, a number of others as well) the union argued that
working any number of continuous hours (i.e. perhaps as few as 2 or 3) could give rise to an
entitlement to a shift premium. No such argument is being advanced in the instant case. Indeed,
the parties? agreed facts signal that the grievors would not be entitled to a shift premium when
they work less than the normal hours of work per day as set out in UN 2.1 and 2.2 on an RDO.
We are therefore only concerned with instances where employees work the same or the same
number of hours as a regular shift, albeit on a day which would otherwise be their day off.
This particular constellation of facts has not been previously adjudicated and, the union
urges, there is no reason not to require the payment of shift premium in these circumstances.
7
Not surprisingly, the employer views matters somewhat differently. It boldly and
unequivocally asserts that under no circumstances can a seasonal employee ever legitimately
claim entitlement to shift premium in respect of hours worked on an RDO.
The employer?s argument is rooted in a consideration of the word ?shift? as it appears in
both the title of Article UN 6 (Shift Premium) and in the body of UN 6.1.3 which, although it
provides a fixed number of cents per hour, still describes what it provides as a shiftpremium.
The employer concedes that work on an RDO entitles an employee to overtime pay. But,
says the employer, it does not also entitle the employee to shift premium. I should note, however,
that this was not presented as any issue of improper pyramiding (as will be seen, the
jurisprudential water seems to be well under that bridge). The employer merely asserted that
(whether or not overtime rates are otherwise payable and, it is conceded, they are) there is simply
no entitlement to shift premium for work on an RDO.
MorinUnion Grievances
Relying primarily on the decisions in and the case, the
employer asserts that to earn shift premium, one must work a shift. A shift is more than any
collection of consecutive hours worked. Indeed, even working the very same (or the same
number of) hours that might correspond to a normal shift is not sufficient. Relying on the two
cited cases, the employer essentially argues that entitlement to shift premium rests on and is
payable only in relation to hours worked on (and perhaps immediately preceding and following)
the employee?s regularly scheduled shift. Entitlement therefore cannot arise in respect of hours
worked on an RDO.
In order to dispose of the case, I need to review the authorities pointed to, cases which
deal with identical, similar or related language found in current or predecessor collective
agreements between these parties.
Morin
The jurisprudential trail begins with .
Oddly enough, however, that case did not address any issue of shift premium entitlement.
The grievance arose out of what was then Article 10, which dealt with shift schedules. It
provided that the employer would make every reasonable effort to avoid scheduling the
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commencement of a shift within 12 hours of the completion of ?the employee?s previous shift?
and required the payment of certain premiums where that 12 hour period had not been respected.
The grievor in the case was called in to work on an emergency basis for a period of time which
concluded less than 12 hours prior to the start of his next scheduled shift. The issue was whether
the contemplated premium payments were required.
In making its determination, the Board considered the meaning of the word ?shift?, as
used in the collective agreement phrase ?the employee?s previous shift?. It posited three possible
meanings for the term ?shift?. The first: ?any period of time that an employee has worked? was
quickly rejected. The Board observed that, in the industrial relations community, the term usually
refers to ?a period of time that would ordinarily constitute a day?s work? (thus excluding an ad
hoc 3 or 4 hour work assignment). The next meaning considered was ?any period of work which
prior to it being worked is predetermined in length and of a duration that would ordinarily
constitute a day?s work?. Such a definition could include both ?regularly scheduled? and
?temporary or additional? shifts alike.
The Board, however, chose to favour the third possible meaning posited, i.e. that the
collective agreement phrase ?the employee?s previous shift? referred to the employee?s
previously scheduled regular shift as found in the posted shift schedule. It came to this
conclusion largely because the article in which the provision was found was entitled and dealt
with Shift Schedules i.e. the scheduling of regular or normal work hours. In that context, the ?12-
hour? provision was seen as a constraint on the scheduling of normal or regular hours, but not
one which operated in respect of additional or temporary or emergency work demands not
captured in the posted shift schedule regulated by the article. Thus, the Board concluded that the
phrase ?the employee?s previous shift?, in the context of that provision of the collective
agreement,referred to the employee?s previously scheduled regular shift.
In some ways it is unfortunate to identify this case as the point of departure for the
jurisprudence relevant to our inquiry. As already indicated, the case did not involve any issue of
entitlement to shift premium. Further, reliance on the case to suggest that any reference to the
word ?shift? in the parties? collective agreement must be taken to mean an employee?s regularly
scheduled shift is dubious at best. That should be obvious from the very specific context in
which the case was being decided. And even if that clarity might otherwise elude, a subsequent
9
CameronMorin
decision of the Board, in (decided in the very same year as by a panel also
chaired by the then Chair), makes it evident.
Cameron
The facts in are less than clearly set out, perhaps because, as in the instant
case, the parties chose to put specific questions to the Board. It appears that the grievor regularly
worked extended shifts at least some portion of which extended into the 5:00 p.m. to 7:00 a.m.
shift premium period. To that extent he was paid shift premium in respect of those regularly
scheduled hours. The issue was whether he should receive shift premium in respect of overtime
hours worked immediately before or after his regularly scheduled extended shift (or on a
statutory holiday). In that case the parties asked whether a shift premium would be payable in
respect of hours for which an overtime or statutory holiday premium was also required. The case
turned on an analysis of ?pyramiding? (an issue not before us). The Board concluded that the
payment of shift premium in those circumstances did not involve any duplication or pyramiding
of benefits. It was, however, some of the Board?s concluding remarks which are of interest (at p.
28):
The Board is of the opinion that the second question [regarding work on a
statutory holiday] must also be answered affirmatively provided the grievor is
scheduled to work the number of hours that would normally constitute a shift.
While such a shift would not be a regularly scheduled shift there is nothing in art.
11:00 indicating that this must be the case. The employer made reference to the
term shift as it is used in art. 10 and submitted that given the nature of art. 10 the
parties must have intended it to be a reference to regularly scheduled shifts. The
Board, as held in the Morin case (74/77), agrees with this suggested meaning for
the purposes of art. 10 but this does not mean the term is used in a uniform way
throughout the agreement. The term shift commonly means a fixed period of time
constituting a normal day?s work, although this definition can be narrowed when
the context of its use requires. In Morin the Board was satisfied that in art. 10 the
parties were referring to regularly scheduled shifts but we see no reason to impute
this limitation in art. 11.
The next relevant case, in what a cynical observer might be tempted to suggest was
Morin
another volley in a ?ping-pong? approach to jurisprudence, was decided not long after
Cameron.Attwood
and In the issue was whether shift premium would be payable (in addition
to the overtime premium) in respect of overtime hours worked either immediately preceding or
following the employee?s normal day shift.
10
In dismissing the grievance, the Board considered the significance of the word ?shift? in
the collective agreement shift premium language. It reasoned that the shift premium must be
referable to a shift and, in the case before it, the only shift to which it might apply was the
grievor?s regular day shift. And as that shift did not attract any shift premium, neither did the
overtime hours attached to it (even if the latter as opposed to the former otherwise fell within the
hours in which shift premium might arise).
Robbins
The next case, , dealt with facts which the Board understandably viewed as
AttwoodAttwood
indistinguishable from . Just as in , the issue was whether overtime hours
worked immediately before or after the grievor?s regularly scheduled day shift gave rise to shift
premium entitlement.
The Board clearly struggled with its decision, suggesting that the two prior cases read
together would produce some anomalous results. It observed as follows (at page 13):
It would therefore appear that, based on the two awards, various
bargaining unit employees working the same overtime hours between 5:00 p.m.
and 7:00 p.m. might receive or not receive shift premium, and perhaps for
differing reasons, depending on various combinations of circumstances. Someone
in the grievor?s position, on 8:00 a.m. to 4:30 p.m. shifts in an establishment with
Attwood
no evening or night shifts, would not receive it, as in ; someone on 12
hour shifts extending past 5:00 p.m. in an establishment on three-shift operation
Cameron.
would receive it, as in It appears that someone on 12 hour (or even
shorter) shifts extending past 5:00 p.m. might receive it even in a one-shift
operation, or that even someone on a shift ending before 5:00 p.m. in a multiple
Atwood
shift operation would receive it, if the justifications set out in are taken
literally. If so, since the ? office operates on one shift only from April to October
? [the grievor] could receive shift premium for an overtime hour in December
that would not attract the payment in July.
This is a single collective agreement designed to provide for system-wide
working conditions across all categories of the bargaining unit. While the Board?s
cases are not entirely free of anomalous results, this situation seems so capricious
that it hardly seems possible that the parties could have intended such an outcome.
However, notwithstanding its concerns, as the facts it was dealing with were
Attwood
indistinguishable from those considered in , the Board, while not necessarily agreeing
11
Atwood
with the result, was not prepared to go so far as to call it ?manifestly wrong? and
therefore felt constrained to follow it. The grievance was dismissed.
It is useful to pause to consider the nature and current significance of the anomalies
Cameron
which troubled the Board. What is the essential difference between the grievor in and
Attwood/Robbins?
those in Both cases raise the issue of whether overtime hours worked
immediately before and after a regularly scheduled shift can also attract a shift premium. In
Cameron
, the regular hours worked by the grievor (or at least some of them) attracted a shift
Attwood/Robbins
premium payment. In they did not. It was this distinction upon which the
Board fastened to generate the potentially anomalous results which concerned it ? e.g. different
employees working the same (overtime or additional) hours with different entitlements to shift
premium, depending on the hours of their regular shifts.
Although it is perhaps only with the benefit of what the parties have done subsequent to
these awards, one may rightfully question just how capricious that distinction may be. Indeed,
Attwood
even in the case, the Board referred to the general principle (whether or not it was
specifically reflected in the collective agreement at the time) that shift premium is designed to
compensate, not so much for individual atypical assignments, but rather for circumstances where
employees are regularly asked to work hours viewed as undesirable.
And for our purposes, it is most significant that since the above collection of cases, the
parties have opted to amend the terms of their agreement which, in particular, now contains the
following:
UN 6.2 Notwithstanding Articles UN 6.1.1, 6.1.2 and 6.1.3 where an
employee?s hours of work normally fall within 7:00 a.m. and
5:00 p.m., the employee shall not be entitled to receive a shift
premium for hours worked between 5:00 p.m. and 7:00 a.m.
Whether or not the parties viewed this change as codifying the Board?s
jurisprudence or otherwise capturing their shared intention is of no moment. What it does
is clear, however. And at the risk of sacrificing utter precision in the interests of clarity,
it effectively precludes employees whose regular hours of work are ?straight days? from
12
ever claiming the benefit of shift premium. In other words, it clearly exhibits the parties?
agreement that two different individuals working the very same hours may or may not be
entitled to shift premium, depending upon when their hours of work normally fall. Put
somewhat differently, shift premium is a benefit reserved for employees whose hours of
work normally include (at least some) hours between 5:00 p.m. and 7:00 a.m. This new
provision perhaps renders the Board?s prior jurisprudence of little more than academic or
archival interest.
Perhaps the testament to the new found clarity associated with this change in
collective agreement language is to be seen in the fact that the next case the parties
McCormick
referred me to, , was not decided until some 7 years later. And it is of little
more than passing interest. The case turned on whether or not the grievor?s hours of work
normally fell within the period of 7:00 a.m. to 5:00 p.m. On the facts before it, the Board
concluded (at least with respect to the time period being considered) that they did and
that the grievor was therefore not entitled to claim shift premium as he was not being
inconvenienced by being required to normally work outside the hours of 7:00 a.m. to 5:00
p.m. The grievance was dismissed.
Union
The last of the cases referred to is of more recent vintage. In the
Grievances
case, it was the interpretation of COR6.1.3 which was at issue. That
provision, which is found in the Shift Premium article of the Corrections collective
agreement, provides (potentially in addition to ?standard? shift premium) for a weekend
premium to be paid for all shifts worked during the weekend (as defined therein). The
parties referred six different union grievances to the Board for determination. All
involved entitlement to the weekend premium, a benefit unique to the Corrections
bargaining unit. The parties, rather than dealing with the specific facts of any particular
grievance, chose to put six different scenarios (with anywhere from 1 to 7 questions
attached to each scenario) to the Board for determination.
13
The specific scenario and questions pointed to as relevant for our purposes are the
following:
Scenario 6 ? Unclassified Employees
?
B. Unclassified employee Z works 6 hours on a Saturday to
cover an unexpected institutional need. This is not a regularly
scheduled shift and employee Z is not replacing any other
employee. Is employee Z entitled to be paid week-end
premium for those hours worked?
C. Unclassified employee Z works from 7 a.m. to 7 p.m. on a
Saturday to cover an unexpected institutional need. Employee
Z is not replacing any other employee but there are other
employees working regularly scheduled shifts from 7 a.m. to
7 p.m. Is employee Z entitled to be paid week-end premium
for those hours worked?
Bringing us full circle, the positions advanced by the parties were reminiscent of
Morin
those advanced in the decision. In relation to the meaning of the word ?shift? as it
appears in the weekend premium provision, the employer argued that shift must mean a
regularly scheduled shift; the union argued that a shift is simply a continuous period of
work and that the performance of work of whatever duration constitutes a shift. In having
to choose between those two options, the Board selected for the former. But its discussion
of the matter perhaps leaves certain questions open. After observing that other cases
dealing with the use of the word ?shift? in other provisions of the agreement were not
determinative, the Board went on to make the following pertinent observations (at p. 13
and following):
?In the context of the parties? submissions, the term ?shift? either
means any continuous period of time that an employee has worked, whether
it be for 2, 4 or 7 hours, or it refers to a regularly scheduled shift. Upon
reviewing the language of the collective agreement and particularly the
language in COR6, it is my conclusion that the parties did not intend the
term ?shift? to apply to the performance of any work irrespective of its
duration, as argued by the Union?
14
In considering the Union?s position, I have also had regard to certain
Morin
comments made by Arbitrator Adams in the decision?I agree with
the view that the term ?shift? usually refers to a period of time that would
ordinarily constitute a day?s work. There is nothing in 6.1.3 which would
suggest that the parties intended something other than the usual meaning to
apply. Of the two possible interpretations advanced by the parties, it is my
conclusion that the Employer?s interpretation reflects the intention of the
parties. Accordingly, it is my conclusion that the term ?shift? in 6.1.3 refers
to the Employer?s regularly scheduled shifts.
Based on that reasoning, the Board then went on to conclude that, in the two
questions set out earlier, Z is not entitled to be paid the week-end premium since, in each
case, he is not working a regular shift.
The employer urges me to follow this award and sees it as support for its view that
?shift? means not merely any random amount of consecutivework time; not merely
consecutive hours worked equal in number to those in a ?normal? shift; and not even
consecutive hours worked identical to the hours of a normal shift. ?Shift?, the employer
argues, must mean the employee?s normal shift (thereby precluding work on an RDO
from constituting a shift).
It is not entirely clear to me that the award relied upon supports the view that
?shift? means the employee?s regular shift. The choice offered to the Board in that case
was between ?any period of time worked? as the union argued and ?a regularly scheduled
shift? as advanced by the employer. The Board expressed its agreement, as do I, with the
view that the term ?shift? usually refers to a period of time that would ordinarily
constitute a day?s work. It then went on to conclude that ?of the two possible
interpretations advanced by the parties?, the employer?s view was preferable. As a
consequence, it ruled in Question 6C the employee was not entitled to the premium since
he was ?not working a regularly scheduled shift?. The facts, however, disclosed that the
hours worked were the very same hours that would otherwise constitute a regular shift
and that those hours were also being simultaneously worked by other employees as their
15
regular hours. But they were certainly not the employee?s (i.e. the notional grievor Z?s)
regular hours. It is that gloss on the award that permits the employer to argue, as it did
before me, that the source, nature or quantum of hours worked on an RDO is irrelevant
since, by definition, they are not the employee?s regular hours.
Having considered the authorities cited and the submissions of the parties, I am
persuaded that the answer to the question posed is yes: seasonal fire program staff are
entitled to a shift premium on an RDO for hours worked between 5:00 p.m. and 7:00 a.m.
if, on a regular scheduled workday, their hours of work normally fall outside 7:00 a.m.
and 5:00 p.m. In coming to this conclusion, I have been influenced by the following.
Morin
While the Board concluded that the phrase ?the employee?s previous shift?, in
the context of the different provision of the collective agreement there under consideration,
referred to the employee?s previously scheduled regular shift, the Chair of that panel of the
Cameron)
Board took an early opportunity (in to cautionthat there was no reason to impute that
limitation in an interpretation of the shift premium provisions of the collective agreement. I
agree.
Attwood Robbins
The next following decisions i.e. and are both distinguishable and, in
view of subsequent changes to the collective agreement, may be of little more than archival
interest. They are distinguishable because, unlike the case before me, they dealt with claims for
shift premium entitlement in respect of hours worked immediately preceding or following an
Cameron
employee?s regular shift. (And, I note further, they may be distinguishable from
insofar as they dealt with such hours in relation to a regularly scheduled shift which otherwise
attracted no shift premium).
Union Grievances
Thecase warrants a number of comments. First, of course, I must
note that it deals with a weekend premium entitlement under the Corrections collective
agreement which has no analogous provision in the agreement before me. There is, however,
something about the process the parties chose in that case which is similar to the one before me.
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The parties frequently opt, rather than litigating certain specific individual facts or sets of
facts, to pose generic questions or scenarios to the Board for determination and the Board
generally facilitates that approach. The parties must recognize that such an approach has its
limitations. As the cases referred to make clear, there is an impressive configuration of potential
fact scenarios which may generate issues around shift premium entitlement. It is likely that a
generic question will fail to capture all of the possible factual permutations or that the nuances of
actual facts may be more varied than a generic question affords. This is not to say that there is no
value in proceeding in this fashion where there are a large number of actual and potential claims.
The parties must be aware, however, that by so doing they provide the Board with a tool more in
nature of a mallet than a scalpel to perform its operations.
Union Grievances
Those limitations are perhaps evident in the decision. The Board was
presented with two interpretive options. And while the Board expressed its endorsement of the
well established arbitral view that ?shift? usually refers to a period of time that would ordinarily
constitute a day?s work, that was not a specific interpretive option presented to it and we do not
know what it might have decided had that option been advocated by either of the parties. In
choosing between the two options presented, the Board adopted the one which was not utterly
inconsistent with usual meaning of shift. Faced with that choice, I would likely have come to the
same conclusion.
The content of the issue before me is different, but the form of its presentation bears
some similarity, perhaps as a result of the manner in which the parties have chosen to litigate the
issue. I am asked to answer a single largely generic question. No alternatives or refinements to
the two interpretive options advanced by the parties were posed, posited or advanced. For
example, one may easily conceive of a range of circumstances which might lead to an employee
working on an RDO, e.g. to replace a fellow employee absent from his/her scheduled shift; to
meet unanticipated additional operational demands during the same hours as other employees?
regular shifts; or even to work unscheduled hours during a period of time which does not
conform (except in quantum) to the hours of any regular shift. The employer argues that in any
and all of those (or, indeed, any other) circumstances there can be no shift premium entitlement
for an employee working on their RDO. The union asserts that so long as an employee works the
hours of a regular shift (whether or not it is the employee?s regular shift) or a number of
consecutive hours at least equal to those that would comprise a regular shift, the employee, in the
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circumstances otherwise adverted to in the agreed facts is entitled to shift premium for the
relevant hours. The union?s position is entirely consistent with the view, endorsed by this Board
on more than one occasion, that ?shift? usually refers to a period of time that would ordinarily
constitute a day?s work. The employer seeks to impose the additional qualification that the shift
be a regularly scheduled shift and perhaps even the employee?s regularly scheduled shift.
Robbins
Like the Board in , I am concerned about some of the anomalies that result from
the employer?s proffered interpretation. It is agreed that the hours of work of the employees in
question normally fall (though not in their entirety) outside 7:00 a.m. and 5:00 p.m. and that they
are paid shift premium for hours worked outside those hours on their regular shifts. The
employer?s interpretation means that that while an employee will receive a shift premium for
working after 5 p.m. on a regularly scheduled shift, no such premium would be paid to the same
employee for hours worked after 5 p.m. on an RDO. Similarly, two fellow employees working
together side by side on after 5 p.m. hours would receive disparate shift premium treatment if
one was working on an RDO and the other not. While that is a result the parties are free to
negotiate (as they did with respect to eliminating shift premium entitlement for employees
working straight days), it is not a result to which I am drawn on the language of the agreement.
It is for these reasons that, as between the interpretive options advanced by the parties, I
prefer the one advocated by the union and have therefore answered the question put to me in the
affirmative.
The union seeks damages by way of remedy. As there are no specific facts before me, I
cannot but remit the matter to the parties and remain seized with respect to remedy or other
issues relating to the implementation of this award.
th
Dated at Toronto this 8 day of April 2008.
Bram Herlich, Vice-Chair