HomeMy WebLinkAboutP-2017-3605.Hamilton.19-04-25 Decision
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PSGB# P-2017-3605
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Hamilton Complainant
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFORE Andrew Tremayne Vice-Chair
FOR THE
COMPLAINANT
Joshua Phillips
Ursel Phillips Fellows Hopkinson LLP
Counsel
FOR THE EMPLOYER Stewart McMahon
Treasury Board Secretariat
Legal Services Branch
Senior Counsel
HEARING October 10, November 14 and 21, 2018
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DECISION
[1] This decision deals with a preliminary objection raised by the employer with
respect to the complaint of Patricia Hamilton, a Health Care Manager who retired in
early 2018. From October 2016 until her retirement, she had been working at the
Vanier Centre for Women in an accommodated placement; her home position was at
the Ontario Correctional Institute. Before she retired, Ms Hamilton registered her
position with the employer’s Voluntary Exit Registry (VER) for
Management/Excluded employees. If an employee who has been declared surplus
meets the qualifications for a position that has been registered in the VER, the
surplus employee can be assigned to it. The employee who registered the position
receives an enhanced severance payment when they retire. Very briefly stated, Ms
Hamilton’s complaint is that an employee was assigned to her position but she did
not receive the enhanced severance payment.
[2] The employer takes the position that the Board has no jurisdiction to deal with
the complaint because the complaint was not filed with the Board within the time
limits required by the regulations. The Board has consistently held that the time
limits in Regulation 378/07 are mandatory. If they are not met, the Board is deprived
of jurisdiction to hear the complaint. The Board has also consistently held that it
does not have the discretion to relieve against these time limits. Counsel for the
complainant resists the employer’s motion, saying that the complaint was filed within
the time limits, and that in the alternative and in any event, the employer has waived
its right to object to the timeliness of the complaint. The employer replies that waiver
does not apply in this case.
[3] The parties’ disagreement about whether the complaint was filed within the time
limits required by the regulations is a mixed question of fact and law. The
complainant participated in two “meetings” (using that term in the most general
sense, for reasons which will be made clear below) on two different dates, and only
one of these meetings can be “the meeting” that started the 30-day countdown to the
end of the dispute resolution period. The end of the dispute resolution period opens
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the “window” for the filing of the complaint with the Board, so each meeting
potentially created a different “window” period. The complaint was filed during one
of the “window” periods but not the other, so the complaint is timely if “the meeting”
(that is, the meeting for the purposes of the regulations) took place on the earlier of
the two dates. The complaint is not timely if the meeting took place on the later
date. As a result, the parties called evidence on what occurred during the two
different meetings.
[4] The parties’ other disagreement, namely whether the doctrine of waiver applies
to this case, only matters if the second meeting is found to be “the meeting” for the
purposes of the regulations. This is because the employer does not dispute that the
complaint was filed within the time limits that follow from the first meeting. However,
if the second meeting is found to be “the meeting” then the Board must decide if the
doctrine of waiver applies. On this point, the employer concedes that the steps
which it has taken to respond to and otherwise deal with the complaint, when taken
together, constitute a “fresh step”, and the employer accepts that this would indicate
that it had waived its right to object to the timeliness of the filing of the complaint. To
summarize, if the second meeting is found to be “the meeting” for the purposes of
the regulations, and if the Board decides that the doctrine of waiver applies here, the
Board can infer from the employer’s conduct that the employer has waived its right
to object to the timeliness of the complaint. As a result, it was not necessary for the
parties to call evidence to establish the evidentiary foundation for waiver.
Background and Context
[5] It is useful to briefly review the Board’s statutory framework in order to place the
parties’ disagreement about the timeliness of the complaint in context.
[6] The Board only has the powers granted by the Public Service of Ontario Act,
2006 (PSOA) and the regulations made under that legislation, such as Regulation
378/07. That regulation sets out a very specific set of time limits or "windows" of
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time in which steps must be taken to file complaints about discipline or terms and
conditions of employment.
[7] Complaints concerning terms and condition of employment must comply with
the preconditions set out in Regulation 378/07, s. 4(1) in order for the Board to have
jurisdiction. Ms Hamilton gave notice to the deputy minister that she proposed to file
a complaint [s. 8(1)] in a letter dated January 19, 2018, and there is no issue about
the timeliness of that notice. It is the timing of the filing of her complaint with the
Board which is the source of the parties’ disagreement.
[8] Once a notice of proposal to file a complaint is made to the deputy minister, the
regulation creates a dispute resolution period which must expire before the
complainant is entitled to file a complaint with the Board [s. 9(1)]. A complaint will be
untimely in the sense of being too early if it is filed before that dispute resolution
period has expired, and too late if it is filed more than fourteen days after the dispute
resolution has expired. The end of the dispute resolution period is measured in
different ways, depending on whether or not there is a meeting between the
complainant and the deputy minister (or delegate) within 30 days after receipt of the
complainant's notice of proposal to file a complaint.
[9] If there is no meeting within those 30 days, the dispute resolution period
expires 30 days after the notice of proposal is given to the deputy minister [s. 9(5)].
Ms Hamilton gave notice on January 19, 2018, so if there had been no meeting
within the 30 days, the end of the dispute resolution period would have been
February 18, 2018. However, if there had been a meeting between the complainant
and the deputy minister (or delegate) within those same 30 days, the end of the
period of dispute resolution is changed to the earlier of the day that is 30 days after
the meeting, or the day on which the deputy minister gives written notice to the
complainant of their decision about the proposed complaint [section 9(3)]. The
deputy minister did not give written notice to Ms Hamilton of their decision about the
proposed complaint, so the date of “the meeting” is important.
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[10] In this case, there were two meetings (using the term in its most general
sense): one was a phone call which took place on January 23, 2018; the other was a
conference call which took place on February 7, 2018. The parties cannot agree on
which of these two meetings was “the meeting” for the purposes of s. 9(3). The
complainant was the only person who participated in both meetings. The other
participants will be identified below when the meetings are discussed in greater
detail.
[11] One of these two meetings started the 30-day countdown to the end of the
dispute resolution period, which in turn opened the “window” for the filing of the
complaint with the Board. If “the meeting” was on January 23, 2018, then the
“window” opened 30 days later on February 22, 2018 and it closed 14 days later on
March 8, 2018. If “the meeting” was on February 7, 2018, then the “window” opened
30 days later on March 9, 2018 and it closed 14 days later on March 23, 2018. The
complaint was received by the Board on March 6, 2018, so if “the meeting” was on
January 23, 2018, then the complaint was filed while the “window” was open, and
the complaint is timely. If “the meeting” was on February 7, 2018, then the complaint
was filed before the “window” opened, in which case the complaint is not timely.
Which Meeting is “The Meeting” for the Purposes of Regulation 378/07?
Evidence
January 23, 2018 meeting
[12] Ms Hamilton's notice of intent to file a complaint was received by the deputy
minister's office on January 19, 2018. It was forwarded to Bart Nowak, who at all
times relevant to this matter was the Acting Director of the Strategic Business Unit at
MCSCS. It is not disputed that on January 23, 2018, Ms Hamilton and Mr. Nowak
spoke on the phone. It is the complainant’s position that this phone call was “the
meeting” for the purposes of the regulations. The employer disagrees.
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[13] Mr. Nowak testified about his role in dealing with notices of intent such as the
one filed by Ms Hamilton. He is generally responsible for ensuring that the
executives in that Ministry receive timely and accurate advice in connection with
complaints brought by non-unionized employees. This includes working with people
in the Ministry of Government Services and Management Board to assist the
minister's office in dealing with complaints before the PSGB. When he received Ms
Hamilton’s notice of intent to file a complaint, he forwarded it to his assistant to
prepare a response.
[14] The purpose of the response, Mr. Nowak testified, is to confirm receipt of the
notice of intent and to provide information about next steps. The response is in the
form of a template, and the complainant's name and email address is added. The
email is sent under Mr. Nowak's name and comes from his email address, although
it is actually drafted and sent by his assistant. The text of the response is as follows:
Good afternoon Patricia,
On behalf of deputy Erry, I am acknowledging receipt of your
notice of intent to file a complaint (grievance) with the Public
Service Grievance Board under the Public Service of Ontario Act,
2006.
Under the dispute resolution provisions outlined in the Act, a
person delegated by the deputy minister will contact you within 30
business days to arrange a meeting. You are reminded that you
are obligated to follow the provision of the Public Service of
Ontario Act (PSOA) to maintain timelines for filing to The Public
Service Grievance Board (PSGB).
In the interim, if you wish to discuss this matter further, please feel
free to contact me at (416) 212-4133.
Thank you,
Bart Nowak
A/Director, HR Strategic Business Unit Corporate Services
Division
[15] Mr. Nowak says that sometimes he is contacted by a complainant in response
to the email that is sent confirming receipt of the complaint. He says that when he is
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contacted, the complainant usually has logistical questions, such as when is the
meeting, who is the person designated by the deputy minister, and whether the
complainant can bring a support person or legal counsel. Mr. Nowak does not
provide a substantive response to these questions because he does not have
access to that information, so he usually replies that the designate will contact them
with more information. He usually replies to other questions by telling the person
that they should ask the designate.
[16] Mr. Nowak says that he recalls a telephone conversation with a woman in
relation to his January 19, 2018 email, but he could not recall if it was Ms Hamilton.
It likely took place in January or February 2018, and he recalls receiving a voice mail
message and calling the person back. He was asked questions about next steps,
timing, and the person asked what she should do next. He does not recall what he
said, but it is likely that he would have replied to these questions in his usual
manner, namely by telling the person that the designate will contact them, or words
to that effect.
[17] In cross-examination, Mr. Nowak said that he did not draft the body of the
template that was used for the January 19, 2018 email, and that it was already in
use when he arrived. It was pointed out that the email reminds complainants to
follow the provision of the PSOA to maintain timelines for filing to the PSGB but that
the timelines for the filing of complaints are in the regulations, not the Act itself. It
was also noted that the email says “a person designated by the deputy minister will
contact you within 30 business days to arrange a meeting” but that the regulations
say that if there is a meeting, then the meeting itself will happen within 30 days. Mr.
Nowak disagreed that these were errors or that these statements misdirected
complainants about the process.
[18] Ms Hamilton says that she called Mr. Nowak at the phone number that was in
the January 19, 2018 email. She called him to clarify some information about the
PSGB, to ensure that her contact information was up to date because she was days
away from retiring, and to discuss next steps. She does not recall specifically what
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questions she asked or what Mr. Nowak answered, but she understood that she
would be receiving a call to set up a meeting to commence a mediation or a
conversation.
[19] Ms Hamilton says that she made some notes of this conversation, but she is
not sure if she made the notes before or after the call. In cross-examination, she
was pressed about a section of her notes that reads:
Next steps
?anyone avail. To guide me thru process?
?use of dispute resolution meeting when/where?
[20] She conceded that she asked Mr. Nowak where and when the dispute
resolution meeting would be, and that before she spoke to Mr. Nowak she knew
from the January 19, 2018 email that that there would be some form of dispute
resolution meeting. She agreed that when she was talking to Mr. Nowak, she knew
that their conversation was not the dispute resolution meeting.
[21] Ms Hamilton agreed that she was told by Mr. Nowak that she would be
contacted by someone to arrange a meeting. She also agreed that when she later
received an email on January 29, 2018 inviting her to a meeting, she understood it to
be exactly what Mr. Nowak said it would be.
February 7, 2018 Meeting
[22] At all relevant times Christine Hayhow was a Labour Management Liaison
providing advice and support to regional directors in the institutional services side of
MCSCS. She also provides advice and consultation to the deputy minister's office
on labour relations matters and acts as a delegate or designate for the deputy
minister for the majority of complaints to the PSGB. It is not disputed that on
February 7, 2018, Ms Hamilton, Ms Hayhow, and others participated in a conference
call. It is the employer’s position that this conference call was “the meeting” for the
purposes of the regulations. The complainant disagrees.
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[23] Ms Hayhow described the process whereby she becomes the deputy minster's
delegate or designate. After a complaint is received by the deputy minister, it is
forwarded to the director of the Strategic Business Unit. The director or his office
confirms with the complainant that the complaint has been received and sends it to
Employee Relations at Management Board for their review. The manager of the
appropriate Employee Relations team contacts the appropriate deputy minister so
that a delegate or designate can be assigned, and if she is the delegate or
designate, she receives a letter accordingly. In this case, she received a letter dated
January 19, 2018 from Brian Scott, a manager with the Employee Relations
Advisory Services at Treasury Board Secretariat. The letter states as follows:
Patricia Hamilton has submitted a notice of proposal to file a
complaint in accordance with Section 8(1)1 of Ontario Regulation
378/07 of the Public Service Act of Ontario. The Deputy Minister
was advised of this on January 19, 2018 as per the attached.
Under Section 9(3) of Ontario Regulation 378/07 you have been
designated to respond to this matter. Unless time limits are
extended, the meeting should take place by February 19, 2018.
Copies of your response are to be forwarded to this office and the
Assistant Deputy Minister's Office.
Your cooperation in this matter is appreciated.
[24] Once Ms Hayhow is so identified, her administrative assistant communicates
with the complainant and schedules a call with her and with the Employee Relations
advisor who has been assigned to the file. An email is sent by an administrative
assistant to the complainant accordingly, and in this case the following email was
sent to Ms Hamilton on January 29, 2018:
Ms. Hamilton,
Your January 19, 2018 notice of intent to file a complaint has been
forwarded by the office of Deputy Minister Erry to Ms. Christie
Hayhow, Labour Management liaison Advisor and Mr. David
Marincola, Employee Relations Advisor to schedule a hearing with
you.
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This hearing, by teleconference, will be scheduled between
February 5th and 16th 2018. An electronic invitation will follow
with the time and call details.
Upon receipt of the invitation, please confirm your acceptance of
the call date and time.
[25] Ms Hayhow says that the purpose of the teleconference is to gather information
about the complaint, to try to work towards a solution, or to investigate the matter
further. Although it is referred to as a meeting, or a hearing, these events are almost
always held by teleconference. Overall, the point is to determine whether or not
there has been a violation of the terms and conditions of employment. As the
delegate of the deputy minister, she holds the meeting, reviews the circumstances of
the complaint, considers the issues, and makes a decision. Generally she writes a
decision but not always.
[26] Ms Hayhow attended the meeting, along with David Marincola, the Employee
Relations Advisor, Ms Hamilton, and Chris Whittaker, who was Ms Hamilton's
support person. Ms Hayhow remembers the meeting because she hears most of
the complaints in this area, and this was the only one she has heard that dealt with
these issues. The meeting also stands out because the complainant was retiring, so
there were some scheduling concerns. Ms Hayhow says that she began the call by
introducing herself as the deputy minister's designee for hearing complaints and
identifying the date of the complaint, which was important because sometimes there
are several versions. She identified who was on the phone at her end, asked who
else was on the call, then she read the complaint. She explained that the purpose of
the call was to gather information and invited Ms Hamilton to tell her about the
complaint.
[27] Ms Hayhow testified that Ms Hamilton described the circumstances of her
complaint. Ms Hayhow then asked some questions for clarification. She recalls that
Ms Hamilton said that she was going on vacation shortly and then retiring, so she
confirmed that her contact information was accurate and up to date. Mr. Whittaker
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spoke, but Ms Hayhow does not recall what he said. There was a question about
the Voluntary Exit Policy, and she recalls Mr. Marincola speaking to that.
[28] Ms Hayhow says that at the end of the call, she would have said that she has
30 days to respond, and if she did not do so then the 30 day window would close,
and the complaint could be forwarded to the PSGB. She does not have an
independent recollection of saying these things on this particular call, but this is
standard for the many similar calls in which she takes part.
[29] Ms Hayhow testified that Ms Hamilton did not mention anything about a
previous call or a previous meeting. She would have asked questions and
investigated further if Ms Hamilton had raised this, because it has never happened
and it would be unusual. Ms Hayhow took about one page of notes during the
meeting. Near the top, the notes say “explain role as designee” and “read
complaint”. Most of the rest of the page recounts Ms Hamilton explaining her
complaint or responding to questions.
[30] Ms Hamilton says that she does not recall Ms Hayhow saying that she had
been designated or explaining her role. Ms Hamilton says that the meeting was brief
and the she did most of the talking. The only thing she recalls Ms Hayhow saying is
that she would look into the policy and get back to her. Ms Hamilton wrote a very
brief summary of the meeting on the bottom of a printed copy of the January 29,
2018 email from Ms Hayhow’s office. She wrote the summary a short time after the
meeting but does not recall when. Her notes read:
I did have phone conf. Feb 7, 2018 10:30 am
basically me reviewing my [complaint]
asking for policy clarific[ation]
I to date have not rec’d any further info’n
Parties’ Submissions
[31] The employer submits that the meeting contemplated by s. 9(3) of Regulation
378/07 must be with the deputy minister or his or her delegate. In the context of s.
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9, the delegate must be someone who is the delegate for the purposes of attempting
to resolve the dispute: the role of the delegate is tied to the dispute resolution
process. That is, the delegate must be someone who will gather information about
the complaint, inquire into its merits, and then, if the deputy minister chooses to give
written notice to the complainant of his or her decision about the proposed
complaint, assist or advise the deputy minister in connection with the written notice.
[32] In his email, Mr. Nowak says that he is acknowledging receipt of Ms Hamilton’s
notice of intent to file a complaint on behalf of the deputy minister. Mr. Nowak
cannot be the delegate of the deputy minister, because the email says “under the
dispute resolution provisions outlined in the Act, a person delegated by the deputy
minister will contact you within 30 business days to arrange a meeting”. It is clear
from any objective reading of this statement that Mr. Nowak, the author of the email,
is not the delegate for the purposes of the dispute resolution process. The
distinction is clear. Mr. Nowak is simply acknowledging receipt of the notice. The
delegate will meet later with Ms Hamilton “under the dispute resolution provisions”.
As a result, any subsequent telephone call or meeting between Ms Hamilton and Mr.
Nowak cannot be the meeting contemplated by s. 9(3).
[33] The evidence about what was said during the two meetings is important,
submits the employer. Ms Hamilton’s own evidence is that she and Mr. Nowak did
not engage in anything that resembled a dispute resolution process. They did not
talk about the substance of her complaint nor how it should be disposed of. It is
important that Ms Hamilton admitted that she knew that Mr. Nowak was not the
person to whom the deputy minister had delegated responsibility for the dispute
resolution meeting. She also agreed that she knew that she would be contacted
later by someone else who would be the delegate for that purpose.
[34] Ms Hamilton’s notes of the first meeting are most likely a combination of notes
that she made to herself before the call with Mr. Nowak and notes that she made
during or after the call, although her evidence about this was not entirely clear. She
conceded that her note “?use of dispute resolution meeting when/where?” shows
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that the telephone call with Mr. Nowak was not the dispute resolution meeting, and
that the dispute resolution meeting would take place later.
[35] In any event, the employer argues, Ms Hamilton’s subjective understanding or
belief of Mr. Nowak’s role in the process is irrelevant. It might have been relevant
when the Board had the discretion to extend or abridge the time limits for the filing of
a complaint, because that evidence might go to whether the Board should exercise
its discretion in a particular case. In the absence of that discretionary power, the
only thing that is relevant is whether the meeting with Mr. Nowak was a meeting with
the person to whom the deputy minister had delegated responsibility for the dispute
resolution meeting, and he was not. That person was Ms Hayhow, who gave
extensive evidence about the mechanics by which she was designated by the
deputy minister to deal with the complaint. It was clear from her evidence that this
was her role, and that the meeting she had with Ms Hamilton on February 7, 2018
was the meeting for the purposes of s. 9(3).
[36] Counsel for the complainant agrees that Ms Hamilton’s subjective
understanding of the meetings is not relevant. The question is whether the objective
requirements of s. 9(3) are met by the January 23, 2018 meeting. In fact, argues the
complainant, all that s. 9(3) requires is a meeting between the deputy minister or his
or her delegate and the complainant – there are no other requirements. There is not
even a requirement to have a meeting, but if one is held, no method, format, or
purpose for the meeting is prescribed. The meeting is not described anywhere in
the regulations as a fact finding, resolution, discovery, step, or grievance meeting.
The idea that it must be a “dispute resolution meeting” is not supported by a fair
reading of the regulations. The employer has argued that it must be a dispute
resolution meeting, but that is a requirement of the employer’s own invention. The
meeting does not even have to be a substantive discussion – a discussion about
process would fit the bill.
[37] In any event, the January 23, 2018 meeting better meets the requirements of s.
9(3) than the meeting of February 7, 2018, argues the complainant. Mr. Nowak’s
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email identifies him as acting on behalf of the deputy minister. It was reasonable for
Ms Hamilton to have understood that everything Mr. Nowak said in his email would
have been said on behalf of the deputy minister. The email describes the process,
albeit in a flawed way, and he does not say that there are any limits on his authority
to deal with the matter. This is in contrast to the email from Ms Hayhow’s office,
which does not actually say that she has been delegated by the deputy minster to do
anything.
[38] Mr. Nowak did not have a firm recollection of what was discussed in the
January 23, 2018 meeting, and although Ms Hamilton’s evidence was vague, she
was reasonably clear that they discussed process issues. She said that the reason
she called Mr. Nowak was to discuss next steps and how her complaint would be
handled, which was important to her because she was going to be leaving the
workplace soon. Regardless, the complainant argues, Ms Hamilton’s complaint was
the subject of their discussion, and it does not matter for the purposes of s. 9(3)
whether the discussion was about process or substance.
[39] The February 7, 2018 call scarcely dealt with the complaint, the complainant
submits. Ms Hamilton says that she described her complaint and that she did most
of the talking, and the employer did not share or discuss its position. Both meetings
were on the phone, both lasted less than 10 minutes, and both were held within 30
days after the deputy minister received notice of the proposal to file the complaint,
as per the regulations.
[40] The Board has held that multiple meetings do not extend the time limits: it is the
first meeting that counts, because the regulations do not contemplate more than one
meeting. As a result, the January 23, 2018 meeting is the first meeting that meets
the criteria of s. 9(3), so it ought to be treated as the relevant meeting, submits the
complainant.
[41] The Board should adopt the perspective of a reasonable person, acting as a
complainant, when it looks at the time limits and at Regulation 378/07 generally, the
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complainant argues. The employer is in complete control of the process: it decides
whether there is going to be a meeting, it contacts the complainant, it may or may
not give a written decision, and it decides what will be done and when. The
employer should be required to demonstrate that it has acted in a fair and
transparent manner, and in such a way as to allow a reasonable person in Ms
Hamilton’s position to comply with the procedural requirements. The complainant
submits that the employer has not met the standard.
[42] Finally, Mr. Nowak’s January 19, 2018 email contains several inaccuracies and
misstatements: it says that a person designated by the deputy minister will contact
you within 30 days, but it is the meeting that must take place within 30 days, not the
initial contact; it refers to following timelines in the PSOA for filing a complaint with
the PSGB, but the timelines are in the regulations, not the PSOA. More importantly,
nobody ever said to Ms Hamilton “this is the meeting that triggers the mandatory
time limits” or told her that there was a 14 day window for filing a complaint. The
employer’s representatives withheld this key information, and the employer should
not be permitted to take advantage of its lack of clarity.
Analysis and Findings
[43] I will briefly address the last two points, which can be summarized as follows:
the complaint process under the PSOA and Regulation 378/07 is complicated and
difficult; and the employer’s communications with Ms Hamilton made things worse.
Without disputing their accuracy, these observations might have been relevant when
the Board had the discretion to extend or abridge the time limits for the filing of a
complaint. The Board addressed similar arguments in Bourgeault v. Ontario
(Ministry of Community Safety and Correctional Services), 2013 CanLII 84294 (ON
PSGB) and Telford v. Ontario (Finance), 2016 CanLII 36364 (ON PSGB), finding in
both cases that the reasons for not meeting the time limits, however sympathetic or
compelling, do not assist the Board when it lacks the power to relieve against them.
I see no reason to depart from those decisions.
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[44] In this case, the employer’s delay in raising its objection is nevertheless a
concern. On the first page of Ms Hamilton’s complaint (Form 1) she replied “Yes” to
the question: “Was there a meeting held in accordance with Section 9 of Regulation
378/09 of the Act?” and wrote “Jan 23/2018 - telephone” on the form. She clearly
identified the first meeting as “the meeting” for the purposes of Regulation 378/07.
The employer filed its response, participated in a mediation, and agreed to a number
of hearing dates before it raised the preliminary objection that the complaint was not
filed with the Board within the time limits required by the regulations. In my view, it
was incumbent on the employer to raise this objection sooner than it did.
[45] Before the Board holds a formal hearing, it provides the parties with an
opportunity to mediate their differences and settle complaints. The mediation
process is designed to assist the parties in reaching a settlement without the
expense and delay arising from more formal proceedings. Parties often participate
in mediation while reserving the right to raise preliminary objections if the complaint
is not settled. In this case, it took three days of hearing to fully address all aspects
of the parties’ positions on the employer’s preliminary objection. It is generally
helpful in mediation for both parties to have as complete a picture as possible of
what will happen next if a dispute is not resolved. Here, a more complete picture of
the employer’s position may have assisted the parties in their settlement
discussions.
[46] The first issue to be addressed is which meeting, as between the meeting that
took place on January 23, 2018 and one took place on February 7, 2018, was “the
meeting” for the purposes of s. 9(3). To begin with, the heading above Section 9 of
Regulation 378/07 is “Period for dispute resolution”. The term “dispute resolution”
appears in ss. 9(1), 9(3), 9(4), and 9(5). I accept that the meeting in s. 9(3) is not
specifically called a “dispute resolution meeting”, but in my view, it is reasonable to
conclude from the context in which this meeting is found within Regulation 378/07
that its purpose is dispute resolution. No method, format, or purpose for the meeting
is prescribed, but none is required: there are many ways of resolving, or attempting
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to resolve, workplace disputes. Dispute resolution meetings can take many different
forms.
[47] Having heard and carefully considered the parties’ evidence and submissions,
it is very difficult to see how the telephone call between Ms Hamilton and Mr. Nowak
had any purpose connected to dispute resolution. Ms Hamilton’s evidence, which is
supported by her notes, strongly suggests that she called Mr. Nowak to ask where
and when the dispute resolution meeting would be. According to her notes, she may
have also asked whether anyone was available to guide her through the steps and
the use, or purpose, of the dispute resolution meeting. This call consisted of Ms
Hamilton asking a few very limited questions about scheduling and process. There
is no evidence that they even discussed what her complaint was about.
[48] Ms Hamilton and Ms Hayhow offered different recollections of the February 7,
2018 meeting. Ms Hayhow says that she began the call by introducing herself as
the deputy minister's designee for hearing complaints and identifying the date of the
complaint. She identified who was on the phone at her end, asked who else was on
the call, and read the complaint. She explained that the purpose of the call was to
gather information and invited Ms Hamilton to tell her about the complaint which she
did. Ms Hayhow asked some questions for clarification. There was a question
about the Voluntary Exit Policy, and Mr. Marincola replied to that.
[49] Ms Hayhow says that at the end of the call, she would have said that Ms
Hamilton has 30 days to respond, and that if she did not respond the 30 day window
would close, and the complaint could be forwarded to the PSGB. She does not have
an independent recollection of saying these things on this particular call, but this is a
standard part of what she routinely says in similar calls.
[50] Ms Hamilton says that she does not recall Ms Hayhow saying that she had
been designated or explaining her role. The meeting was brief and Ms Hamilton did
most of the talking. The only thing she recalls Ms Hayhow saying is that she would
look into the policy and get back to her.
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[51] Ms Hayhow says that she remembers the meeting because the issues raised in
Ms Hamilton’s complaint were, in her experience, unique. The meeting also stands
out in her memory because Ms Hamilton was retiring, so there were some
scheduling concerns. Ms Hayhow’s independent recollection of the meeting aligned
with her notes, which show that the parties discussed the complaint on its merits.
Ms Hamilton does not recall Ms Hayhow saying that she had been designated or
explaining her role, and she does not recall Ms Hayhow reading her complaint. Both
of these points are mentioned briefly at the start of Ms Hayhow’s notes, and it was
Ms Hayhow’s evidence that it was her practice to begin meetings like this one with
these statements. Ms Hayhow’s recollection of the meeting aligns more closely with
the only notes taken during the meeting, namely her own.
[52] Ms Hamilton concedes that she did not write her brief summary of the meeting
until later. She begins with the words “I did have phone conf”. This strongly
suggests that she wrote these words after the dispute arose between the parties
about the timeliness of the filing of the complaint, because this is an unlikely choice
of words if someone is simply summarizing a meeting. The final words “I to date
have not rec’d any further info’n” strongly suggest that a fair amount of time had
already passed after the meeting, because it is unlikely that a person would expect
to receive any such information right away. In any event, the notes say “basically
me reviewing my [complaint] asking for policy clarific[ation],” which would likely have
been part of a dispute resolution meeting.
[53] Having considered the evidence of both witnesses, who have differing but not
directly contradictory recollections of the February 7, 2018 meeting, I find on a
balance of probabilities that the purpose of this meeting was dispute resolution.
[54] Who attends the meeting is also important. According to s. 9(3), if the
complainant and the deputy minister or his or her delegate attend the meeting, the
30 day countdown starts to the end of the dispute resolution period. Returning to
Mr. Nowak’s January 19, 2018 email, it is fair to say that it did three things: it
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acknowledged receipt of Ms Hamilton’s notice of intent to file a complaint; it told her
that “a person delegated by the deputy minister will contact you within 30 business
days to arrange a meeting”; and it said “in the interim, if you wish to discuss this
matter further, please feel free to contact me.”
[55] Several conclusions follow from the plain meaning of these statements.
Someone other than Mr. Nowak will be contacting Ms Hamilton to arrange a
meeting, and that person will be a person delegated by the deputy minister. That
person is not Mr. Nowak, because if it was, he would have said “I will contact you
within 30 business days . . .” Instead, he refers to “a person” which cannot, on any
reasonable construction of the language used, be the author of the email, namely
Mr. Nowak. Next, the invitation to contact Mr. Nowak is not an invitation to the
meeting, because the meeting will be arranged later. The email says “in the interim”
which shows that calling Mr. Nowak would be something different, and something
that could happen, if Ms Hamilton chose to do so, before she is contacted to arrange
the meeting. It is also an invitation to contact “me” namely Mr. Nowak, and as stated
above, a reasonable construction of the language is that Mr. Nowak is not the
person who will be contacting Ms Hamilton to arrange the meeting.
[56] These conclusions are strongly supported by Ms Hamilton’s evidence: she
knew that Mr. Nowak was not the person to whom the deputy minister had delegated
responsibility for the dispute resolution meeting, and she knew that she would be
contacted later by someone else who would be the delegate for that purpose. The
January 29, 2018 email from Ms Hayhow’s office completes the picture. It tells Ms
Hamilton that her notice of intent to file a complaint has been forwarded by the
deputy minister’s office to Ms Hayhow and Mr. Marincola “to schedule a hearing with
you” and the date that is eventually set for this is February 7, 2018.
[57] As a result, for all of the reasons set out above, the meeting that took place on
February 7, 2018, was “the meeting” for the purposes of s. 9(3) of Regulation
378/07. The “window” opened 30 days later on March 9, 2018 and it closed 14 days
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after that on March 23, 2018. The complaint was received by the Board on March 6,
2018, so it was filed before the “window” opened and is therefore not timely.
Waiver
[58] Having found that the second meeting is “the meeting” for the purposes of the
regulations, the Board must decide if the doctrine of waiver applies. As stated
above, the employer concedes that the steps which it has taken to respond to and
otherwise deal with the complaint, when taken together, would indicate that it had
waived its right to object to the timeliness of the filing of the complaint. As a result,
although the parties disagree about whether the doctrine of waiver applies here, it
was not necessary for the parties to call evidence to establish the evidentiary
foundation for waiver.
The Parties’ Submissions
[59] There are some true jurisdictional issues where waiver does not apply, argues
the complainant, but mandatory time limits have not been treated as one of those
issues. Rather, mandatory time limits are a matter of form or procedure, and the
right to object to the timeliness of a grievance or complaint can be waived. The
complainant cites Seneca College of Applied Arts and Technology v. Ontario Public
Service Employees Union (Balevi Grievance), 2012 OLAA No. 487, 2012 CanLII
53497 (ONLA) (Bendel); and Ontario Public Service Employees Union v. Ontario
(Ministry of Children and Youth Services) (Moody). [2012] O.G.S.B.A. No. 94, 2012
CanLII 35048 (ON GSB) (Abramsky) in support of its position.
[60] The Board has considered whether the mandatory time limits in Regulation
378/07 have been waived. The Board also entertained a waiver analysis and
recognized that waiver can be applied in Bourgeault; Telford; and Doyle v. Ontario
(Ministry of Municipal Affairs), CanLII 52705 (ON PSGB). Moreover, in both
Bourgeault and Doyle, the Board confirmed that under s. 4 of the Statutory Powers
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and Procedures Act (SPPA), the Board is able to waive time limits. This section of
the SPPA reads as follows:
Waiver of procedural requirement
4. (1) Any procedural requirement of this Act, or of another Act or
a regulation that applies to a proceeding, may be waived with the
consent of the parties and the tribunal. 1997, C. 23, S. 13 (1).
The Board has treated time limits as a procedural matter and has never viewed the
mandatory time limits in Regulation 378/07 as being a fundamental jurisdictional
issue that would preclude it from considering waiver, argues the complainant.
[61] The employer replies that the Board has repeatedly stated that time limits go to
its jurisdiction to hear a complaint. In a line of decisions starting with St. Amant v.
Ontario (Ministry of Community Safety and Correctional Services), 2013 CanLII 4673
(ON PSGB); the Board has addressed different factual scenarios that have arisen:
Hauth v. Ontario (Ministry of Community Safety and Correctional Services), 2013
CanLII 74165 (ON PSGB); Hasted/Berezowsky v. Ontario (Ministry of Community
Safety and Correctional Services), 2016 CanLII 7473 (ON PSGB); Burkholder v.
Ontario (Ministry of Community Safety and Correctional Services), 2013 CanLII
84293 (ON PSGB); Telford; and Doyle. All of these decisions say that compliance
with the time limits is a true precondition to the Board having jurisdiction over a
complaint.
[62] The employer submits that waiver cannot apply to complaints before this Board.
The Board is a tribunal of limited jurisdiction, and the parties cannot give such a
tribunal more jurisdiction. No number of fresh steps can grant the Board jurisdiction
that it does not have. The applicability of waiver in the context of administrative
tribunals has been set out in authorities such as Robert W. Macaulay, James L.H.
Sprague, and Lorne Sossin, Practice and Procedure Before Administrative
Tribunals, (Toronto: Thomson Reuters Canada Ltd. 2004) and Blake, Sara,
Administrative Law in Canada, 4th ed., Blake (Toronto: LexisNexis Canada, 2006)
and can be summarized as follows:
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However, one cannot bestow jurisdiction upon a statutory decision
maker by waiver or consent.
. . . .
Parliament intends its statutory agencies to have only the authority
that Parliament grants them. That type of jurisdiction cannot be
granted by waiver or consent.
Practice and Procedure Before Administrative Tribunals, s. 12.22 (a)
If a tribunal decides that it does not have the power to do what is
requested of it, the parties cannot by consent confer the power
upon it. Lack of power may not be waived, nor may parties by their
acquiescence confer on a tribunal a power that it does not have.
Powers cannot be expanded by contract between the tribunal and
the parties it regulates.
Administrative Law in Canada, 4th ed., p. 119
[63] In Hunter Rose Co. v Graphic Arts International Union, Local 28B (1979), 24
OR (2d) 608 (C.A.), 1979 CanLII 2028 (ON CA) the Ontario Court of Appeal
confirmed that labour arbitration boards are an exception, but the Court was clear
that this is because the jurisdiction of a board of arbitration is founded on the
agreement of the parties. For the same reason, argues the employer, the arbitration
awards cited by the complainant which stand for the proposition that the failure to
comply with time limits is a procedural irregularity arise out of proceedings that were
conducted under the terms of a collective agreement, so they are of no assistance to
the Board.
[64] The SPPA contemplates a process whereby the parties can agree and ask for
the Board’s consent to waive a procedural requirement. Without conceding that the
mandatory time limits in Regulation 387/07 meet the definition of a procedural
requirement, it is clear that the parties would need to be pro-active and ask for the
Board’s consent, and if they do not, then the “window” closes, submits the employer.
The question of waiver was not squarely before the Board in Bourgealt, Doyle, and
Telford; there is no sense that the parties in those cases fully argued the issues that
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time limits go to the heart of the Board’s jurisdiction or that parties cannot grant
jurisdiction to a Board of limited jurisdiction.
Analysis and Findings
[65] Beginning with St. Amant, the Board’s decisions have been clear that
complaints not filed in accordance with Regulation 378/07 are not within the Board’s
jurisdiction. While the Board is not necessarily obliged to follow prior decisions, it is
generally accepted that where the issue is similar, an earlier decision should be
followed for the sake of consistency and predictability. Consistency is particularly
important when it comes to an issue that arises not infrequently between the parties
who come before the Board, such as whether an untimely complaint is within the
Board’s jurisdiction. The Board is also required to be correct with respect to
questions about its own jurisdiction.
[66] The Board has dealt with many different factual scenarios when it has
considered this issue, but among the more compelling are the facts in Telford. In
that case, Mr. Telford’s complaint was filed outside the time limits of Regulation
378/07 because of the death of his lawyer. Acknowledging that the Board’s
interpretation of this regulation can work hardship in particular cases, the Board
declined to depart from its established jurisprudence. The Board made the following
comment:
[37] Further, consistency, short of rigidity, in tribunal decision making is
highly desirable, as affirmed by the Supreme Court of Canada, in
IWA v. Consolidated-Bathurst Packaging Ltd., [1990] 1 SCR 282,
1990 Can LII 132 (SCC). This Board's interpretation of the time
limits in Regulation 378/07 has been articulated in a consistent way
whenever issues have been raised about them, and it is for the
regulatory process to change course if so advised.
[67] The Board’s case law has accurately interpreted and applied Regulation
378/07, and for this reason alone, it is not appropriate to depart from those carefully
reasoned decisions. The Board has been clear: complaints that are not filed in
accordance with Regulation 378/07 are not within the Board’s jurisdiction.
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[68] Similarly, the applicability of the doctrine of waiver in an administrative law
context is well settled: only a “procedural” right, as opposed to a “substantive” right is
capable of being waived. The distinction between “procedural” and “substantive”
rights or provisions may, as in this case, become critical. In this regard, guidance
can be found in Palmer and Snyder, Collective Agreement Arbitration in Canada, an
authority which was cited in many of the authorities relied upon by the complainant.
The following excerpts show that the applicability of waiver in a labour arbitration
context can be readily distinguished from its applicability before statutory tribunals of
limited jurisdiction, such as the Board:
Waiver has been defined as "a legal barrier to the exercise of
rights in a particular case, erected by the conduct or words of the
parties". In this context, waiver has the effect of preventing a party
from insisting on strict compliance by the other party with
procedural requirements in the grievance process. [emphasis
added]
Section 3.75
Waiver arises therefore where it can be concluded that one of the
parties has given up its right to invoke the procedural provisions of
the collective agreement. [emphasis added]
Section 3.76
Certain defects cannot be waived and objections concerning these
can be made at any time. The reason is that jurisdiction cannot be
conferred on an arbitrator through a party's failure to object
promptly. The cases have thus distinguished between
fundamental issues of jurisdiction to which waiver never applies,
and irregularities of form or procedure to which the doctrine is
applicable. Failure to comply with mandatory time limits in the
collective agreement; filing of a grievance as a policy rather than
an individual grievance; defects in the grievance form itself; and
failure to proceed through all the specified steps of the grievance
procedure have been held to be procedural irregularities which
can be waived. [emphasis added]
Section 3.77
[69] These excerpts refer to “procedural requirements in the grievance process,” the
“procedural provisions of the collective agreement”, and “mandatory time limits in the
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collective agreement.” Arbitrators derive their jurisdiction from the collective
agreement under which they are appointed. The parties who appear before the
Board have not negotiated a collective agreement and they have not agreed on a
grievance process. The PSOA and its regulations are not a collective agreement.
The complaints that are properly within the Board’s jurisdiction exist only because
they are authorized by the PSOA and its regulations.
[70] The Board only has the powers granted by the Public Service of Ontario Act,
2006 (PSOA) and the regulations made under that legislation, such as Regulation
378/07. Having consistently held that complaints not filed in accordance with that
regulation are not within the Board’s jurisdiction, the logical conclusion for the Board
to reach is that the time limits in the Regulation 370/07 are substantive, not
procedural, within the meaning of those terms as they have been used and
understood in the jurisprudence and the relevant authorities discussed above.
[71] The remaining issue to be considered is the applicability of s. 4.1 of the SPPA.
The Board has mentioned s. 4.1 in Bourgeault and in Doyle. In Bourgeault, the
Board found that the complaints were not filed with the Board in a manner and at a
time which gave the Board the power to deal with them. The Board said the
following with respect to waiver and the SPPA:
[30] Another concept that can be found in arbitration decisions,
especially those under collective agreements, which sometimes
results in a grievance going forward, despite missed time lines, is
waiver of time lines or other procedural rules. Although it is possible
for parties to waive procedural requirements in certain
circumstances, there is no indication that the employer waived any
of its rights to object to the timeliness of these complaints. . . .Under
the Statutory Power Procedures Act, s. 4 (1), procedural
requirements may be waived with the consent of the parties and a
tribunal such as this Board, but there is no evidence that the parties
discussed or agreed that the time lines set out in the regulation be
waived. It is clear that the Board was not approached to agree to
any such waiver by the parties.
[72] In Doyle, the employer raised several preliminary objections to the complaints.
Among the objections was that one of the complaints was not referred to the Board
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within the 14 day time period allowed by the regulations after the close of the dispute
resolution period. The complainant argued that meetings which took place after the
end of the dispute resolution period extended the regulatory time lines. The Board
rejected this argument, and made the following comment about waiver:
[29] The fact that parties to complaints before this Board often continue
to attempt to resolve issues after the end of the dispute resolution
period defined in the regulation does not alter the operation of the
regulatory time lines. Although it would have been open to the
parties to agree to extend the dispute resolution period with the
consent of the Board, as provided in section 4 (1) of the Statutory
Power Procedures Act there is no evidence of such an agreement
between the parties.
[73] First, the Board did not turn its mind to whether the time limits in the Regulation
370/07 are substantive or procedural in these decisions. That issue does not appear
to have been identified and argued by the parties, because the Board’s comments
are directed towards whether the parties had discussed or agreed to waive the time
limits, and if so, whether the Board’s consent had been sought. Second, it is clear
from a careful reading of both Bourgeault and Doyle that the Board in those cases
did not have the benefit of the thorough and detailed submissions of counsel on the
applicability of the doctrine of waiver that were presented to the Board in this case.
Third, and in light of the first two considerations, two decisions do not necessarily
establish a level of consistency and predictability that the Board should follow.
[74] Section 4 of the SPPA is about the ability to waive procedural requirements.
Having found that the time limits in the Regulation 378/07 are substantive, not
procedural, s. 4 does not apply in this case. The time limits cannot be waived,
because they are not procedural requirements. As a result, the employer did not
waive its right to object to the timeliness of the complaint. It did not waive its right to
do so because it cannot waive its right to do so.
[75] In any event, and to the extent that Bourgeault and Doyle can be applied in this
case, the same observation with respect one of the basic criteria of this section of
the SPPA can be made here: the Board was not approached to agree to any such
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waiver by the parties. For this reason alone, the requirements of s. 4 of the SPPA
have not been met on the facts of this case.
Disposition
[76] To summarize, having carefully considered the evidence and the submissions
of the parties, the dispute resolution meeting took place on February 7, 2018. This
was the meeting for the purposes of s. 9(3) of Regulation 378/07. The “window”
opened 30 days later on March 9, 2018 and it closed 14 days after that on March 23,
2018. The complaint was received by the Board on March 6, 2018, so it was filed
before the “window” opened and is therefore not timely. The complaint is dismissed
and will not proceed to a hearing on the merits.
Dated at Toronto, Ontario this 25th day of April, 2019.
“Andrew Tremayne”
_______________________
Andrew Tremayne, Vice-Chair