HomeMy WebLinkAbout1990-0541.Bousquet.91-03-01 Decision
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ONTARIO
CROWN EMPLOYEES
EMPLOYES DE LA COURONNE
DE L 'ONTARIO
GRIEVANCE
SETTLEMENT
BOARD
COMMISSION DE
REGLEMENT
DES GRIEFS
180 DUNDAS STREET WEST, SUITE 2100, TORONTO, ONTARIO. M5G IZ8
180, RUE DUNDAS OUEST, BUREAU 2/00, TORONTO IONTARIO). M5G IZ8
TELEPHONE/TELEPHONE: (416) 326-1388
FACS/MILE/TELECOPIE: (416) 326-1396
541/90, 542/90, 543/90
L~ .50(1
IN THE HATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
BETWEEN
BEFORE: .
FOR THE
GRIEVOR
FOR THE
EMPLOYER
HEARING:
Before
THE GRIEVANCE SETTLEMENT BOARD
OPSEU (Bousquet)
- and -
The Crown in Right of Ontario
(Ministry of Natural Resources)
M. Gorsky
M. Vorster
G. Milley
Grievor
Employer
Vice-Chairperson
Member
Member
A. Hudgins
Counsel
Cornish Roland
Barristers & Solicitors
A. Rae
Counsel
Winkler, Filion & Wakely
Barristers & Solicitors
September 20, 1990
s
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INTERIM DECISION
There are three grievances before us which were filed
by the Grievor, Romeo J. Bousquet, who is an Accounts Payable
Clerk employed by the Ministry of Natural Resources. The
grievances, all of which are dated April 19, 1990, are as
follows:
Grievance 541/90 states:
I grieve that the Employer, in continually
harassing me is violating the provision [sic] of
Article 18.1 of the Collective Agreement. The
Employer has further violated Article 18.1 in
condoning continued harassment of me by other
staff members in the office - the harassment is
effecting [sic] my health to the point of a
nervous breakdown - M.N.R. will be held
responsible for any deterioration of my health.
The settlement desired states:
That the harassment cease and desist by Bill Cowan
and other staff members. That I be treated with
the same respect and courtesy as other
unclassified and regular staff members.
Grievance 542/90 states:
I grieve that the letter of reprimand dated April
11, 1990 from John Kerr, Director, is unfair,
unwarranted and unjustified.
The settlement desired is:
'"
'"
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withdrawal of the letter dated April 11, 1990 and
expunged from all records. Removal of the water
cooler from the office.
Grievance 543/90 states:
That B. Cowan has discriminated against me,
because I am a francophone. He sent an english
[sic] speaking person on a french [sic] course
(back up person). I requested refresher course 2
years ago. Employment equity is not a priority in
our office for francophones, also sent
unclassified on course. That B. Cowan has been
harassing me for the last year, because I am a
francophone. Also, charges are to be laid with
the Human Rights Commission.
The settlement desired states:
That M.N.R. follow the guidelines set out in
employment equity as a francophone, I am in a
designated group. M.N.R. is to ensure that I have
as good a chance as anyone else to compete for
promotions. That M.N.R. provide training and
development to help me reach my potential. That
M.N.R. monitor this situation very carefully.
At the opening Of the hearing, counsel for the Employer
raised certain preliminary objections to the jurisdiction of the
Board. It was submitted that grievance 543/90 was inarbitrable,
and that grievance 541/90 was inarbitrable in part. Exhibit 4
was filed with us, being a letter dated September 12, 1990, from
counsel for the Grievor to counsel for the Employer. The letter
contained "particulars regarding Mr. Bousquet's harassment
grievance dated April 19, 1990 [541/90] and a discrimination
grievance of the same date [543/90].11 Paragraph 4 at page 3 of
)
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the said letter provides:
Fourthly, Mr. Bousquet was not given a fair opportunity
to go on training courses. See the paragraphs
regarding the discrimination grievance below. In
addition he was unfairly denied an assignment to help
train staff at the Maple office in January of 1990. An
unclassified member of the staff was sent instead.
Counsel for the Employer submitted that the said grievances were
inarbitrable to the extent that they were based on the
allegations quoted in the particulars.
There were two seperate elements to the objection to
the arbitrability of grievances 541/90 and 543/90. In the first,
counsel for the Employer argued that the Grievor was asking this
Board, in effect, to enforce the provisions of the ontario Human
Rights Code 5.0. 1981 c. 53 (the IICode"). The section of the
Code referred to was section 4:
(4) (1) Every person has a right to equal
treatment with respect to employment without
discrimination because of race, ancestry...
ethnic origin ...
(2) Every person who is an employee has a right
to freedom from harassment in the workplace by the employer
or agent of the employer or by another employee because of
race, ancestry... ethnic origin
It is evident, based on the objection to arbitrability,
that counsel of the Employer believes that the complaints in
grievances 541/90 and 543/90 may involve allegations that the
Grievor was discriminated against and harassed in not being sent
on a training course or given a development opportunity because
4
..
of his race, ancestry or ethnic origin. Because the grievances
were couched in language relating the alleged discrimination and
harassment to the fact that the Grievor was a francophone, we
cannot be certain that this is the case. "Francophone" is defined
in Webster's New World Dictionary - Third College Edition, as:
II... having to do with speakers of French - n. a person who
speaks French." If the Grievor was limiting his complaint to an
allegation that he had been discriminated against and harrased
because he was a person who speaks French, then this might not
amount to a claim that he was being harassed or discriminated
against because of his race, ancestry or ethnic origin. At this
time, we cannot be certain of what the Grievor meant when he used
the term "francophone.." For the sake of disposing of the
.
preliminary objection, we will assume, without deciding that
this is the case, that the Grievor intended to encompass, in his
use of the term "francophone," allegations that he was being
discriminated against and harassed not only because he spoke
French, but because of his race, ancestry or ethnic origin. The
fact that counsel for the Grievor did not agree that the alleged
acts of discrimination and harassment were not based on the
Grievor's race, ancestry or ethnic origin, and that the Grievor
wrote a letter to the Human Rights Commission about the alleged
acts of discrimination and harassment is consistent with the view
that he intended to complain about discrimination and harassment
based on grounds including those found in section 4 of the Code.
If the evidence discloses that this is not the case, then the
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5
objection to arbitrability based on the fact that the Grievor is
restricted to seeking redress under the Code would not have to be
further addressed.
It was also submitted that there was no provision in
the Collective Agreement alleged to have been violated by the
Employer in grievance 543/90,and that, accordingly, this Board
was without jurisdiction to dea~ with it. It was further
submitted that it was beyond the jurisdiction of the Board to
consider a grievance which, in any way, concerned the granting of
training or development opportunities. The second objection
raises a number of issues relating to the question of what
constraints are placed on management in exercising its discretion
with respect to the subjects of training and development, and
whether the rule is changed when the grievance involves a claim
that an employee's rights under the collective agreement, in this
case with respect to promotion opportunities, may be adversely
affected by the exercise of the management rights referred to. It
also raises the question whether it makes a difference, in
considering the last mentioned question, whether the right on an
employee under the collective agreement is a right in the
abstract, as where the grievance does not concern an actual
competition for which a grievor is an applicant. The issues
raised also concern the extent to which jurisprudence dealing
with the obligations on management in the exercise of its rights
under management rights provisions decided in cases outside of
.'
.
6
the Grievance Settlement Board's jurisdiction affects the Board's
jurisdiction. Of necessity, it will also be necessary to examine
the nature of the Board's jurisdiction under relevant legislation
and case law.
A. The obiection to arbitrability based on an alleqed
violation of the ontario Human Riqhts Code
Counsel for the Employer relied upon the case of Sinqh
240/79 (Eberts), where, at page 6, it was noted that the Board
was "asked to decline to hear the grievance on the ground that
this matter was more properly the subject of complaint under [the
"Code"] and reference was made to the provisions of section
4 ( 1) (b), R. S . o. 1970, c. 318 [now s. 4 (2) ] .
At page 9 of the Sinqh case, the Board noted: "Had the
grievor already submitted a complaint to the Human Rights
commission, different considerations might arise."
At page 10, the Board stated:
It may be that where a complaint to the Human Rights
Commission has reached the stage where the Grievance
Settlement Board could be sure that a Board of Inquiry
would be hearing the complaint, the Grievance
Settlement Board would consider adjourning its
proceedings to await the outcome of the Board of
Inquiry.
Counsel for the Employer also relied on Aubin, 1044/85
7
(Gandz). At p. 4 of the Aubin case, the Board stated:
It may be that, indeed, this practice contravenes
the Human Riqhts Code. But the job of this board
is not to rule on violations of the Human Riqhts
Code. The Code has its own enforcement mechanisms
and these should be used to resolve complaints
arising under it. We would only use this statute
in the task of interpreting a collective
agreement. Since was have found no ambiguity in
the interpretation of the collective agreement,
the Human Riqhts Code simply does not corne into
play ... .
Counsel for the Employer also relied on Beintner,
1841/87, 1842/87 (R.J. Roberts). In the Beintner case, the Board
also had to deal with a preliminary objection that it lacked
jurisdiction to enforce the Code through arbitration. There, it
was submitted (at pp. 7-8): "... the grievor already has a
remedy of filing a complaint before the Human Rights Commission
and it would be error for the Board to afford him an alternative
route for relief through the arbitration procedure." Reference
was made to the Sinqh and Aubin cases.
In referring (at p. 10) to re Windsor Hospital Centre
Inc. and ontario Nurses Association (1979), 24 L.A.C. (2d) 35
(Ianni), the Board, in Beintner, noted that the board in the
Windsor case: "
rejected an attempt by the union to 'cloak'
as a violation of a prior practice regarding the calculation of
vacation entitlement an alleged contravention of positive
obligations under the Employment Standards Act." The Board (at
8
p. 10) quoted from the windsor case (at p. 39):
In these present grievances ... there are no
provisions of the collective agreement in conflict
with the Employment Standards Act, 1974. If, as
alleged by the Association, the parties in their
practices and procedures are violating the
Employment Standards Act, 1974 but are not
violating the collective agreement, then this 1S a
matter for the Director of Employment Standards
and not one for a board of arbitration.
Further, at pp. 10-11 of the Beintner case, the Board
stated:
On the other hand, where the claim is that a
provision of the Collective Agreement violates a
pUblic policy or is illegal because it contravenes
a statue, arbitrators have not hesitated to
consider the statute and render their
interpretation of it. Noone has ever doubted that
in such a case a board of arbitration or
arbitrator is obligated to acknowledge that impact
and refuse to enforce the offending provisions.
[Referring to re Denison Mines Limited and united
Steelworkers (1982) 5 L.A.C. (3d), 1928 (Adams)].
Counsel for the Grievor submitted that as the
Grievor had only written a letter to the Human Rights Commission
and had some conversations with one o~ its representatives
concerning the matter, and as the Commission has not even
commenced an investigation, nor has a complaint been issued,
there is no problem of either double jeopardy or res iudicata
referred to by the Board in the Singh case at p. 9. In arguing
in favour of the arbitrability of the grievance, counsel for the
.
9
Grievor was not suggesting that there remained a judicial policy
in favour of more forums in which discrimination and harassment
questions might be adjudicated based on breaches of the Code. In
the Beintner case (above), at pp. 16-17, the Board stated:
with respect to Sinqh, we note that the observations
made by Professor Eberts (as she then was) regarding
the perceived existence of a judicial policy in favour
of more rather than fewer forums in which
discrimination questions might be adjudicated were
based upon the decision of the ontario Court of Appeal
in Bhadauria vs. Seneca Colleqe(1980), 27 O.R. (2d)
142. The Bhadauria decision, however, was reversed by
the Supreme Court of Canada, which concluded.that the
plaintiff did not have an independent tort action for
discrimination which she could pursue in the courts but
was required to follow the procedure laid out in the
Human Rights Code. See Board of Governors of Seneca
Colleqe of Applied Arts and Technology v. Bhadauria
(1981), 124 DLR (3d) 193 (S.C.C.).
What concerned the Board in the Beintner case was the
.attempt to enforce II ... purely statutory rights through labour
arbitration. So, for example, where a statute places a positive
obligation on one party toa collective agreement and the
collective agreement is silent upon the matter, an arbitrator
will decline jurisdiction in order to avoid the spectre of re-
writing a collective agreement which served in the first place as
the basis for his jurisdiction." (Beintner, at p. 8). Counsel
for the Grievor stated that she was not urging us to enforce
purely statutory rights but submitted that we were being asked to
interpret the management rights provisions found in section 18(1)
of the Crown Employees Collective Barqaininq Act R.S.O., 1980 c.
10
108, as amended, (the "Act") in a manner consistent with the
general law.
Counsel for the Grievor also relied on re Wentworth
County Board of Education (1984), 14 L.A.C. (3d) 310 (DeVlin), at
pp. 322-323:
Despite any reservations as to whether decisions
of management pursuant to the management rights
clause must meet a general test of fairness or
reasonableness, the right of managemant to assign
job duties ought not to be interpreted in a way
which would enable management to conduct its
affairs in a manner that is either contrary to
public policy or to a public statute. In McLeod
et al v. Eqan et al (1974), 46 D.L.R. (3d) 150,
[1975] 1 S.C.R. 517, 5 L.A.C. (2d) 336 sub nom.
Re U..S.W., Local 2894 and Galt Metal Industries
Ltd. 74 C.L.L.C. para 14,220, the Supreme Court of
Canada determined that the Employment Standards
Act in prescribing maximum hours of work had
superseded the right of an employer to require an
employee to work beyond such hours except with the
agreement or consent of the employee. It was
found that a provision in the collective agreement
giving the employer the right to schedule its
operations in its discretion did not constitute
the necessary agreement or consent. In allowing
the appeal, the Supreme Court of Canada restored
the lower court order of the Honourable Mr.
Justice Morand who had held that while overtime
could normally be demanded as a management right,
that right had been limited by the Employment
Standards Act prescribing a maximum total work
week. It is also of note that Chief Justice
Laskin in concurring with the majority stated that
while similar deference will not be accorded to an
arbitrator's interpretation of the collective
agreement, an arbitrator must not refrain from
construing a statute involved in the issues which
have been brought before him.
The matter may also be viewed from another
perspective. The object or purpose of contractual
interpretation is to ascertain the intention of
11
the parties. Can it be assumed that in
negotiating the collective agreement the parties
intended that either one or the other could carry
out its rights and obligations in a manner
contrary to public policy or contrary to a public
statue. The answer must be in the negative. For
this reason it is appropriate to determine whether
the board's assignment of the grievor to the main
office pursuant to the management rights clause
was discriminatory in the sense that the grievor
was denied a right to equal treatment with respect
to employment without discrimination because of
handicap.
In this case it was the board's position that the
reassignment of the grievor to the main office
enabled it to make more efficient use of its
personnel. In addition, concern was expressed
with the grievor's continued ability to perform
the duties of secretary in the student services
department. Turning firstly to this latter
contention, it is clear that if a person is
incapable of performing the essential duties of a
particular job because of handicap there can be no
discrimination' which is contrary either to public
policy or the Human Rights Code, 1981. As a
consequence, it is necessary to assess the nature
of the concerns expressed.
Further, at p. 325 of the Wentworth case:
While the collective agreement gives to management
the right to assign job duties within a
classification, that right was carried out in a
manner which was discriminatory and which denied
the grievor equal treatment because of her
physical handicap. In consequence, that right was
exercised in a manner which is contrary to public
policy as enunciated in the Human Riqhts Code.
1981.
If we had concluded that this was a case where the
Grievor was attempting to use the alleged bad faith exercise of a
management right pursuant to section 18(1) (b): "... to 'cloak' a
12
naked submission that the Ministry discriminated against
[francophones] in violation of section 4 of the ... Codell when it
failed to send the Grievor on the refresher course, or to furnish
him the other training opportunity referred to, we would have
followed such cases as Beintner and Aubin.
However, this is a case such as the one referred to at
pp. 11-12 of Beintner, at p. 11:
Finally, one or more provisions of a statute may
be incorporated by reference into a collective
agreement. It has been held that "[w]here such is
the case, it is within the jurisdiction of the
arbitrator to interpret the statute." Re Toronto
Electric Commissioners and CUPE, Local 1 (1973), 2
L.A.C. (2d) 24 (Rayner), as reviewed in Re Nova
scotia civil Services commission and Nova scotia
Government Employees Assoc. (1980), 24 L.A.C. (2d)
319, 332 (Christie), and cited with approval in Re
Public Service Alliance of Canada and Alliance
Emplovees Union (1981), 29 L.A.C. (2d) 21
(Fraser) .
The danger that concerned the Board in the Beintner
case related to a situation :
... where a statute places a positive obligation
on one party to a collective agreement and the
collective agreement is silent upon the matter...
In such case:'
... an arbitrator will decline jurisdiction in
order to avoid the spectre of re-writing a
collective agreement which served in the first
place as the basis for its jurisdiction.
13
In carrying out legitimate government purposes the
Employer would have to adhere to the public policy as enunciated
in the Code,in particular section 4. The policy inherent in that
section must be applied in ascertaining whether an employer has
behaved in good faith. If the real allegation against the
Employer involves a a breach of the public policy inherent in s.
4 of the Code, and if the Employer is found to have discriminated
against the Grievor or harassed him for any of the prohibited
grounds contained in section 4, this will have a considerable
bearing on finding a lack of good faith on its part in exercising
its management rights under s. 18(1) (b) of the Act with respect
to affording training and development opportunities to employees.
In dealing with the impact of the Code on the
administration of the collective agreement, arbitrator Hinnegan,
in Re Glenqarrv Industries (1989) 3 L.A.C. (4th) 326, referred to
the statement in Re Chrysler Canada Limited (1986), 23 L.A.C.
(3d) 366 (Kennedy) at p. 373:
In determining the collective agreement obligations of
these parties, it is clear that reference must be made
to statutes of general application governing the
matters being considered.
In the Chrysler and Glenqarry cases, the provisions of the Code
were considered. Reference was made to Re stelco Wire (1986), 25
L.A.C. (3d) 427 (Brent), being another case where it was found,
at p. 440, that the jurisdiction of a board of arbitration is not
to deal with alleged violations of the Code but to interpret the
14
collective agreement taking into account all relevant
legislation, including the Code. While it is not within the
jurisdiction of a board of arbitration to enforce the provisions
of the Code, it cannot ignore the general law of the land where
there is conflict between the collective agreement provisions and
the relevant statutory provisions. So, where the Code precludes
the application of a specific article in a collective agreement
to a grievor in particular circumstances, the application of that
article would be declared invalid. (See, Glenqarry, at p. 332.)
In finding that we have jurisdiction .to adjudicate on
the allegations of the Grievorthat the provisions of Code may
preclude the application of the rights granted to the Employer
with respect to training and development under s. 18(1) (b) of the
Act, we have taken into consideration not only the oral argument
presented by counsel at the hearing, but, as well, the written
argument submitted by them.
B. The objection to arbitrability based on the
submission that the Employer has unfettered discretion with
respect to the subjects of traininq and development and that
there is no statutory provision that alters, or any provision in
the collective aqreement that can alter the extent of its
discretion
The second objection to the arbitrability of the above
15
grievance is the same as was raised in Flinn et al, 22/88 (R.L.
Kennedy). At p. 5 of the Flinn case, the Board stated:
... The argument of counsel for the Employer in support
of the preliminary objection was that the grievance did
not raise any matter covered in the collective
agreement; it did not raise any matter pursuant to
which a right of grievance was given to an employee
pursuant to section 18(2) of The Crown Employees'
Collective Barqaininq Act, R.S.O. 1980, c. 108 [the
"Act"] and the only issue that it did appear to raise
was one relating to training and development, which by
the specific provisions of section 18(1) (b), was an
exclusive function of the Employer and could not be the
subject of collective bargaining or come within the
juriSdiction of the GFievance Settlement Board.
There was no suggestion in the Flinn case that the
Employer had acted in bad faith, and the Board did not find any
evidence in that regard. Nor did the Board find that the action
of the Employer complained about raised any matter to which a
right of grievance was. provided under s. 18 (2) of the the Act".
The relevant portions of s. 18(1) of the Act are as
follows:
18 ( 1)
Every collective agreement shall be deemed to
provide that it is the exclusive function of the
employer to manage, which function, without
limiting the generality of the foregoing, includes
the right to determine
(b) training and development ...
and such matters will not be the subject of
collective bargining nor come
within the jurisdiction of a board.
16
In the Flinn case, at p. 6, the Board noted that:
II ... It is clear that th~ sole issue between the parties is that
the Grievors have not been permitted to take a specific training
course, and the only relief requested is that they be allowed to
take that course." Although the settlement desired in grievance
543{90 refers to a number of matters, it is essentially a request
that the Grievor be allowed to take the course referred to in the
statement of grievance and be given development opportunities
such as the one referred to in the particulars.
In the Flinn case, at pp. 6-7, the Board stated that:
We cannot conceive of any issue that is more
clearly and exclusively an issue of training and
development, which by reason of specific
provisions of s. 18(1) cannot come within our
jurisdiction. If authority were needed, reference
can be made to OPSEU Union Grievance 672/84
(Palmer) and Brick and Roth 244/82 (Roberts).
Counsel for the Employer also relied on the last
mentioned case (Brick and Roth) at p. 2.:
The issue raised in the preliminary objection of
the Employer was whether the Affirmative Action
Program of the Employer, as applied in the
Property Agent Training Program of the Central
Region of the Ministry of Transportation and
Communications in late 1981 and early 1982,
constituted an exercise of the Employer's
exclusive right to determine training and
development or a" matter of promotion subject to
the terms of Article 4.3 of the collective
agreement. We find that it was a matter of
training and development falling within the
17
exclusive management right of the Employer under
section 18(1) (b) of the Crown Employees'
Collective Bargaining Act. Accordingly this Board
lacks jurisdiction to hear the grievances.
What counsel for the Union wished us to do was to find
that even if the Board had no jurisdiction to adjudicate a
grievance which challenged management's rights with respect to
training and development under s.18(1) (b) of the Act, we might do
so where the rights of employees found in the articles of the
collective agreement, such as art. 4.3, may be adversely affected
by the exercise by management of a right created by s. 18(1) of
the Act.
In the Brick and Roth case, the Board specifically
found (at p.14) no evidence of bad faith on the part of the
Employer in designating training opportunities. Nor, in the
circumstances, was it possible to treat the actions of the
Employer as amounting to an exercise of article 4.3 rights, a
violation of which would be arbitrable. (pp.2 and 14.)
Counsel for the Grievor also relied on Reitsma, 93/89
(McCamus), where the majority of the Board stated, at pp. 13-15:
The Employer has further argued, in support of its
preliminary objection, that the Board lacks
jurisdiction to deal with the grievance as argued at
this stage by the Union on the basis that it touches
upon a question of reorganization, this being an area
of discretion secured to the Employer under section
18(1) (a) of the Crown Employees Collective Barqaining
18
Act. ...
The Employer submits that this legislation has the
effect of prohibiting this Board from assuming
jurisdiction to investigate the Employer's reasons for
reorganizing the work place and reassigning work.
While we are persuaded that this is an area of
management discretion which is normally beyond the
purview of review in proceedings of this kind, we note
that it is well established in the arbitral
jurisprudence that "there is a general arbitral
presumption that the right to reorganize the work force
must not be carried out in bad faith, arbitrarily, or
discriminatorily" (See Brown and Beatty, Canadian
Labour Arbitration, 3rd ed., 1988p. 5-25. section
18(1) (a) of the Act, by stipulating that a provision
concerning management rights in this and in other areas
shall be deemed to be included in every collective
agreement covered by the statute, does not appear to
preclude the application of jurisprudence of this kind.
Indeed, it would be surprising if the intention of the
legislature was to exclude review on such grounds.
Accordingly, one would wish to find explicit language
in the statute to that effect in order to reach such a
conclusion. For purposes of dealing with this
preliminary objection, of course, it must be assumed
that there is merit in the allegations of bad faith
made by the Union. If, indeed, it were the case that
an alleged re~rganization were undertaken not for
legitimate reasons but for the very purpose of denying
an individual recall rights otherwise secured to an
employee by Article 3.20.1 of the Collective Agreement,
we are prepared to assume that this would be sufficient
evidence of bad faith that it would confer jurisdiction
on this Board to' consider the grievance in question.
The above statements are equally applicable to the case
before us to the extent that they relate to the subject of
training and developement. If the Employer was denying the
Grievor certain training and development opportunities for the
purpose of making it difficult for him to compete for promotions
under art. 4.3 of the collective agreement, this.would indicate
that the exercise of management's authority was not being carried
19
out in good faith. We will have more to say about the meaning of
good faith in the context of this case and the ones to be
referred to.
In the Reitsma case, the grievor was a seasonal member
of the unclassified staff who had worked for a number of years as
a Program Technician (Resource Technician 3) at the G. Howard
Ferguson Forest station for the Ministry of Natural Resources.
During the 1988 work season, this position was held by the
grievor and another employee. As a result of a reorganization of
the work force at the station in 1988, the Program Technician
position was eliminated and replaced by a new seasonal position
at a lower classification level. The employer determined that
only one seasonal employee was required for the new seasonal
position and the other employee was appointed to the position.
The grievor filed a grievance:
I grieve violation of, but not limited to Article
3.20.1 of the Collective Agreement in that I was not
recalled to my former position.
Paragraph 3.20.1 provides:
Seasonal employees who have completed their
probationary period shall be offered employment in
their former positions in the following season on the
basis of seniority.
The union alleged that the grievor had greater
20
seniority than the inc~mbent and it was alleged that the new
position was, in reality, the former position.
Counsel for the Grievor, in the case before us, also
argued that the Employer, in failing to afford the Grievor the
training opportunities referred to, had interfered with his
rights to promotion as provided for in ar~icle 4.3 of the
collective agreement:
4.3 In filling a vacancy, the Employer shall give
primary consideration to qualifications and
ability to perform the required duties. Where
qualifications and ability are relatively equal,
length of continuous service shall be a
consideration.
It was argued that when the Employer, in bad faith, does not
furnish an employee with training and development opportunities,
the employee's rights under Article 4.3, are undermined where the
employee would ,be put at a disadvantage in applying for a posted
position. We also understood counsel for the Grievor to have
submitted that the good faith obligations of management owed to
the Grievor in connection with his art. 4.3 rights were greater
than those to which he was otherwise entitled in the absence of
consideration being given to that article.
Counsel for the Grievor also relied on Blaine Warden,
1152/87 (Dissanayake). In that case, counsel for the employer
argued that the grievance was not arbitrable because it did not
21
allege the breach of any provision of the collective agreement or
the Act, as would give the Board jurisdiction to entertain it:
He submitted that the grievance is an attempt to
challenge the employer's conduct relating to staff
complement and job assignment which pursuant to section
18(1) of the Act are clearly exclusive management
rights which are not subject to collective bargaining
or to the jurisdiction of this board (at p. 1).
Counsel for the grievor in the Warden case argued that the
grievance,in that case, was based on Article 18.1 of the
collective agreement which, in part, states that: "The Employer
shall continue to make reasonable provisions for the safety and
health of its employees during the hours of their employment."
The Board's ruling on the preliminary objection, at pp.
2-3, was
The Board agrees with counsel for the grievor that
it is not essential that the grievance refer
specifically to a particular article in the
collective agreement or provision in the Act
before it becomes arbitrable. Nor are we unduly
concerned that the grievance did not use the
phrase "health and safety" and did not articulate
a health and safety issue precisely. In that we
recognize that grievances are not written
necessarily by legally trained persons, the Board
will not refuse to accept a grievance merely
because of technical defaults or imprecise
language. All that is required is that the true
nature of the grievance must be communicated to
the employer.
The Board does not agree with the employer that in
all cases the employer has an unfettered right to
exercise its management rights in any manner it
sees fit. These management rights may be
restricted expressly or impliedly by other
22
provisions of the agreement. Specifically, we
find that the employer may not exercise a
management right in such a manner as would put at
risk the employees' health and safety, because
that would be contrary to article 18.1 If the
thrust of a grievance is a health and safety issue
under article 18-.1, then in our respectful view
that grievance is arbitrable despite the fact that
the resolution of that grievance may necessitate
an inquiry relating to the employer's exercise of
management rights.
Counsel for the Union also relied on Welsh, 122/89
(Watters). In that case (at pp. 15-16), the Board approved of
the reasoning in the Warden case. The Board, in Welsh, also
referred to Van Der Akker,2542/87 (Fisher). The following
comments were made in the Welsh case concerning the Van Der Akker
case (at pp. 16-18):
In Van Der Akker, the work location of the grievor was
changed without notice as a result of which he became
ill. The .grievor alleged that the change in work
assignment was a form of harassment and claimed
compensation for' the shift that he missed due to his
illness. The Board sustained a preliminary objection
brought by the Employer and ruled that it lacked the
requisite jurisdiction to entertain the grievance. In
so doing, it adopted the following statement of law
contained in Tsianq, 352/81 (Jolliffe):
We have not been referred to any language therein
which would require the employer to assign to a
grievor a "fair share" of the word processing work
assigned to incumbents of the position described
in Exhibits #3 and #4 nor do we find any provision
to that effect anywhere in the Agreement. Indeed
it is unlikely or at least, doubtful that the
parties could legally agree to such a requirement.
The Act specifically reserves to the employer's
certain exclusive rights set out in sub-section 1
of section 18 of the Crown Employees Collective
23
Barqaininq Act. ... In assigning to Ms. Tsiang
less word processing than what is assigned to
others, the employer, in our view, is exercising
the function of "organization, assignment ... work
methods and procedures, kinds and locations of
equipment ... training and development" referred
to in section 18(1). How these things are done
may often be regarded by some as arbitrary, unfair
or inequitable, but they are in law and in
practice part of a management function.
The Board found that the content of work is also
an exclusive management function insofar as it
properly formed part of the job description of the
position. It fu~ther concluded that an allegation
of harassment could not itself form the basis of a
grievance unless there was also specific violation
of the Collective Agreement upon which a grievance
was based. There is no reference in Van Der Akker
to article 18.1 of the collective agreement. We
therefore assume that the Union did not make a
claim similar to the one advanced in this case.
The question was therefore decided on an
interpretation of the management rights clause
without reference to health and safety. In this
respect, that grievance is distinguishable from
the one presently being considered. The Board
does agree, however, that the approach there taken
to harassment may also be applied to
discrimination. That is, discrimination cannot
form the basis of a grievance unless a specific
violation of the collective agreement is
established. As stated above, the Board has not
been able to find that this grievor was
discriminated against. It is therefore
unnecessary to address the second issue as to
whether such alleged discrimination had adverse
health and safety consequences which were caught
by article 18.1. .
Lastly, in Alaksa,[l130, 1136, 1137/84 (Brent),
the Board was unable to find a causal relationship
between the shift schedule and certain physical
symptoms exhibited by the grievors. In this case,
we are prepared to accept that a causal
relationship existed between the reassignment and
the stress experienced by the grievor. The
medical evidence presented is supportive of such a
relationship. The symptoms alone, however, cannot
serve as the foundation for the remedy claimed as,
they flow, in our assessment, from a valid
exercise of management's rights.
24
Grievance 543/90 does not directly deal with an
alleged violation of a provision of the Collective Agreement.
What the grievance alleges, in essence, is that the Employer has'
acted in bad faith by discriminating against him in carrying out
its exclusive functions under section 18(1) (b) rel~ting to
"training and development." Counsel for the Grievor also argued
that, as in the Reitsma case (above), the Grievor, in this case,
by having been the subject of a bad faith decision to deny him
training and development opportunities, based on discrimination
because he was a francophone, was denied a right to be fairly
considered for promotion under art. 4.3 of the Collective
Agreement.
In Grievance 541/90; the Grievor takes the position, in
part, that the employer in harassing him by failing to send him
on the training and development oportunities referred to, has
violated the health and safety provisions of the collective
agreement (s.18.1).
In this case, if the Grievor is successful in
establishing that the Employer was pursuing some other goal under
the guise of exercising an exclusive management function, then it
could not be said to be exercising the function in good faith.
While management may exercise the exclusive rights
granted to it under section 18(1) of the Act with a good deal of
25
impunity, they must be exercised, at least, in good faith. Given
the nature of the allegations contained in the statement of
grievance and particulars, if they are established, it would go a
long way to proving a lack of good faith.
Because of the submissions made by counsel for the
Union, arguing that the limitations imposed on the Board's
jurisdiction by s. 18(1) do not affect the application in this
case of the jurisprudence in the private sector relating to the
obligations imposed on management in administering the collective
agreement, it is necessary to review that jurisprudence in the
light of certain cases decided by the Board and by the courts as
they relate to the jurisdiction of the Board.
In re Metropolitan TO!Onto Board of Commissioners of
Police and Toronto Metropolitan Police Association et al (1981),
330.R. (2d) 476 (C.A.), Houlden J.A., sta~ed, at p. 479, that
the lengthy and detailed nature of the collective agreement was a
factor in causing the court to conclude that there was "no
necessity in [that] case to imply a term that the management
rights clause [would] be applied fairly and without
discrimination." The Court stated that within the exclusive
authority of the management rights clause management may act
"unfairly and discriminatively." (Ibid.) Not only may the
employer behave unfairly and discriminatively, but the Court of
Appeal also reinforced its opinion by stating that the board of
26
arbitration had "no jurisdiction to deal with the dispute because
of an alleged and improper exercise of management rights"
(Ibid.). It followed, of necessity, that: "... when the
arbitrator determined that there was no provision in the
collective agreement that governed the taking of inventory and
the distribution of overtime [being the work in dispute] she
should have ruled that she had no jurisdiction to deal with the
dispute because of an alleged improper exercise of management
rights." (Ibid).
It is of significance that when the matter was remitted
back to the arbitrator, the issue was whether the action of the
Board of Commissioner of Police was disciplinary in nature rather
than a good faith exercise of'a management right; the position of
the Board of Commissioners of Police being that the denial of
overtime was not a matter of discipline. The arbitrator, in an
unreported decision, found that the true nature of the denial of
overtime was discipiinary, and it was acknowledged by the Board
of Commissioners of Police tha~ if this were the case, there was
no just cause for having imposed it. This is an example of the
purported exercise of a right under a management rights clause
being a subterfuge. The real reason for the act had nothing to
do with business efficacy. In such case, the act was not engaged
in bona fide.
In an unreported case decided by the ontario Divisional
27
Court on December 3, 1982, Her Majesty the Queen in Riqht of
Ontario as Represented by the Minister of Health and Ontario
Public Service Employee Service Union, G.R. Lenehan and the
Grievance Settlement Board, the Board, whose decision was being
reviewed, after having decided that there was no provision in the
collective agreement which governed the matter in issue,
nevertheless held that:
... obviously the employer in administering the
collective agreement is not entitled to benefit
one employee over the other on the basis that the
former may give evidence on behalf of the employer
while the latter will give evidence on his own
behalf.
In the result the grievance succeeds on the basis
of the fairness argument advanced by the grievor.
The court held that the case failed to be decided under
the principles enunciated in the Metro Police case and quashed
the award. It is significant, however, that the court stated:
"It should be noted that there was no evidence of bad faith in
this case, which may have placed things in a different light."
If the decision was not an honest one, in the sense that it did
not represent a genuine (even if misguided) exercise of an
exclusive management function, then it would not have been
exercised under the authority of the management rights clause. In
OPSEU (Lenehan),the issue not being one that was subject to the
grievance procedure, the court quashed the award because of the
Board's having exceeded its jurisdiction.
28
The most cited case on the subject of "fairness" in the
administration of collective agreements since Metro Police is Re
council of printinq Industries of Canada and Toronto printinq
Pressmen and Assistants' Union No. 10 et al (1983), 42 O.R. (2d)
404 (C.A.). In the C.P.I. case, the Court of Appeal held that
the provisions of art. 22 of the collective agreement (which
dealt with the permanent classification of certain employees by
the employer), being outside of the absolute restrictions of the
management rights clause, should be interpreted by employing
certain conventional rules of contract interpretation. It was
held that the articles, should be read along with others in the
agreement, and that an attempt should be made to harmonize
competing clauses. (Ibid. at 411.) In the absence of a clear
right to exercise unfettered discretion as might, according to
Metro Police, be granted by a properly worded management rights
clause, it could be argued that to give practical and business
efficacy to the agreement, the exercise o~ a right by management
ought to accommodate certain employee and union rights contained
in other provisions of the collective agreement.
Counsel for the Grievor relied on the principles
enunciated in the C.P.I. case as being applcable to the facts of
the case before us, notwithstanding the language of s. 18(1) of
the Act.
As noted above, the objection to the arbitrability of
29
grievance 543/90 relates to the Grievor's not being given a fair
opportunity to go on training courses and being denied an
assignment to help train staff at the Maple office in January of
1990. Part of the facts related to grievance 543/90 are involved
in grievance 541/90. The difference in grievance 541/90 is that
there is an alleged violation of Article 18.1 of the Collective
Agreement.
Counsel for the Grievor relied on the case of re Crown
in Riqht of ontario (Ministry of Correctional Services) and
ontario Public Service Employees' Union (1986), 27 L.A.C. (3d)
233 (Roberts). That case concerned the application of article
18.1 of the collective agreement, although it is there referred
to as article 18.01. At pp. 237-8 of the latter case, the Board
stated:
The law relating to the application of art. 18.01 of
the collective agreement to health and safety issues
was set forth by the board in two awards: Re Gonneau
and Ministry of Attorney-General (1982), G.S.B. No.
227/81 (Teplitsky), upheld by the ontario Divisional
Court [unreported] in March, 1983; and Re OPSEU (Union
Grievance) and Ministry of Correctional Services
(1984), G.S.B. No. 69/84 (Samuels). In Gonneau/ the
board concluded that art. 18.01 was more than a mere
declaration of intention, that it "imposes an
obligation on the employer", supra, at p. 6. In the
Samuels award, the nature of this obligation was
expressed as follows at pp. 6-7:
Article 18.01 speaks to "reasonable provisions"
[emphasis added] for the safety and health of the
employees. And this is echoed in s. 14(2) (g) of
the Occupational Health and Safety Act, R.S.O.
1980, c. 321, which imposes a duty on an employer
to "take every precaution reasonable in the
30
, circumstances for the protection of a worker"
[emphasis added]. There is no obligation to
guarantee an employee's safety against every
possible risk, no matter how remote the
possibility that it will occur. The collective
agreement and the legislation contemplate
. "reasonable" precaution ...
without deciding the point, it is arguable that
some of the acts of harassment alleged to have been engaged in or
permitted by management could or did amount to a breach of the
employer's responsibilities under article 18.1. without finding
that the allegations contained in paragraph '4 at page 3 of the
particulars of harassment with respect to Grievance 541/90 amount
to harassment, if it is established that they do, the Grievor
should have an opportunity to establish that they led to health
problems or that they may reasonably be seen to be capable of ,
leading to health problems. For the reasons set out below, the
Union will have to establish that the Employer, in purporting to
exercise its exclusive functions with respect to training and
development pursuant to s. 18(1), did so in bad faith.
management rights in collectiv~ agreements. In the Canadian Union
of Public Employees. Metropolitan Toronto civic Employees Union,
Local 43 and The Municipality of Metropolitan Toronto (1990), 74
O.R. 239, the court was dealing with an appeal by the union from
a decision of the Divisional Court which allowed an application
31
for judicial review and quashed the majority award of the board
of arbitration. This case was not brought to our attention or
argued at the hearing. Because of the position taken by counsel
for the Union, when the Metro Toronto case came to our attention
after the hearing (when it was reported), we requested counsel to
furnish us with written submissions as to its impact, if any, on
the case before us. We have considered the written submissions of
counsel in arriving at our decision.
In its award in the Metro Toronto case, the board ruled
that the management rights clause in the relevant agreement did
not preclude it from considering a number of grievances
challenging a unilaterally imposed employer rule. Upon
application for judicial review of the award by the employer, the
Divisional Court quashed the board's award on the grounds that it
was patently unreasonable.
The Court of Appeal (at p. 242) had to deal with two
issues concerning whether the board fell into reviewable error in
holding that:
(1) the grievances in that case were arbitrable in the
absence of actual discipline; and
( 2 )
the employer was required to act reasonably in
promulgating rules with disciplinary consequences.
32
In the case before us, the position taken on behalf of
the Employer was that the provisions of section 18(1) of the Act
vested in the Employer an unqualified right to decide which
employees received training and development, as that exclusive
function could in no way be cut down by any provision in the
collective agreement, and there was no statutory provision which
had to be accomodated by it. That is, the parties could not
negotiate with respect to the subject: in this case, training and
development. If they did, their agreement could have no effect.
In the Metro Toronto case, the effect of the management
rights provision was dealt with, commencing at page 255 of the
reasons for judgment, under the heading "Management's Duty to
Make 'Reasonable' Rules and the Finding that June 10, 1982, was
Unreasonable." Counsel for the employer in Metro Toronto (at p.
255) disputed the authority of a board of arbitration to: "infer
from the collective agreement that management had a duty to act
'reasonably' when exercising its 'uncontrolled discretion' under
article 3.01(iii) 'generally to manage ... and without
restricting the generality of the foregoing, to select, install
and require the operation of any equipment, plant and
machinery'."
In the reasons for judgement of the Court of Appeal (at
p.255) it is noted that the Divisional Court did not directly
comment on the issue of management rights in holding that the
33
c
board had interpreted the collective agreement in a "patently
unreasonable" manner.
At page 256 of the Metro Toronto case, the court noted
the union's submission that the reasonableness of a rule
promulgated under the authority of the management rights clause
can be reviewed by a board of arbitration where the rule impacts
on rights of employees under the collective agreement; in that
case, whether the rule had disciplinary consequences (where the
collective agreement provided that discipline must be for
reasonable cause). Counsel for the Union takes the same position
in the case before us.
In its reasons for judgement, the Court of Appeal
reviewed the Metro Toronto Police and CPI cases and concluded, at
pp. 256 :
In other words, it is not patently unreasonable
for an arbitrator to oblige management to exercise
its discretion reasonably, where to do so
unreasonably would be to create a conflict with or
undermine the rights conferred by some other
provision in the collective agreement.
At page 257 of the Metro Toronto case, the Court of
Appeal noted that the management rights clause in the relevant
agreement specifically obliged the employer to exercise its
discretion under that clause in a manner not "inconsistent with
the provisions of this agreement.1I It then quoted from the award
34
of the board in that case:
Management cannot use its powers under the
management rights clause to issue directives,
rules, or orders which undermine the reasonable
cause provision. Even in the absence of Article
3.02 it is a fundamental principle of
interpretation that the collective agreement ought
to be read as a whole, and that one provision
ought not to be read in a way which negates
another. The presence of Article 3.02 ... puts
the point beyond doubt. The Employer cannot, by
exercising its management functions, issue
unreasonable rules. and then discipline employees
for failure to follow them. Such discipline would
simply by without reasonable cause. To permit
such action would be to invite subversion of the
reasonable cause clause.
It is significant that the management rights
provision in the collective agreement in Metro Police, CPI and
Metro Toronto were essentially the same. Section 18(1) of the
Act, being a statutorily mandated management rights clause
incorporated in every collective agreement, is substantially
different. Does the language of s. 18(1) of the Act prevent the
Board from implying a term imposing on management some aspect of
fairness in the administration of its powers, beyond good faith,
with respect to training and development?
In Metro Police, Houlden J.A., held, at p. 479, that
no term need be implied that management rights would: "be
applied fairly and without discrimination." Immediately before
arriving at this conclusion, Houlden J.A., IImade allowance for
the case in which powers conferred on management by a management
35
rights clause 'are ... circumscribed by express provisions of
the collective agreement. '" (Referred to in Metro Toronto at p.
257) What this comment means is elaborated in the Metro Toronto
case at p. 257:
It would seem that this was exactly the loophole
used by this court in Re council of printinq
Industries, supra, to find a duty to act
reasonably. The arbitrator's use of Article 3.02
and the "reasonable cause for discipline"
provision in Article 3.01(ii) is of a similar
character. In neither of these cases was the
provision relied on entirely explicit. However,
it does not seem patently unreasonable to view the
collective agreement in a holistic manner, where
even management rights may be circumscribed in
order to avoid negating or unduly limiting the
scope of other provisions. (Emphasis in the
original. )
Thus, the significant fact required to place a
limitation on the unfettered exercise of a management right is
the existence of a provision in the collective agreement which
would either be negated or unduly limited by a particular
application of such right.
As noted above, if it could be demonstrated that the
Employer had discriminated against the Grievor in denying him
training and development opportunities with a view to undermining
his advancement opportunities under article 4, then its actions
could not be said to have been carried out in good faith, for
genuine government purposes. There is nothing in the collective
agreement that requires the Employer to consider the advancement
36
opportunities of employees. However,it cannot use its management
rights under s.18(1) of the Act in a way which would amount to a
deliberate attempt to interfere with an employee's right to
compete for a promotion. The Employer cannot deliberately tilt
the field with a view to preferring one employee over another.
However, where in good faith and for genuine government purposes
an employee is denied a training or development opportunity,
where the denial is not founded on a deliberate attempt to
undermine the employee's opportunities for promotion, the
decision will not be interfered with.
Counsel for the Employer objected to our considering
article 4 of the collective agreement, inasmuch as specific
reference to it was apparently not made until the hearing. An
examination of grievance 543/90 discloses that the Employer was
alerted to the fact that the Grievor was complaining about the
impact of its failure to grant him the training and development
opportunities referred to on his opportunities for promotion.
(Cf. Warden, above.)
In Re st. Lawrence Colleqe and O.P.S.E.U. (1987),
L.A.C. (3d) 322 (Brent), the majority of the board, at pp. 328-9,
indicated the'standard of review that it regarded as being
applicable, in that case involving the exercise of management's
right to dismiss a probationary employee:
37
Both parties agreed that the Divisional Court of
the Supreme Court of ontario set out a standard of
review in the release of probationary employees in
reviewing the decision in Re Municipality of
Metropolitan Toronto and C.U.P.E., Loc. 43 (1980),
26 L.A.C. (2d) 320 (Simmons). The Divisional
Court decision is not reported [summarized 9
A.C.W.S. (2d) 347] but it is cited at length in Re
Municipality of Metropolitan Toronto and C.U.P.E..
Loc. 79 (1984), 18 L.A.C. (3d) 52 (O'Shea) at pp.
55-6. That is the source of the quotation which
appears in both the Alqonquin Colleqe, supra, and
Cambrian Colleqe. supra, decisions. In order to
come to grips with the issue in this case, we
propose to set out in some length the Divisional
Court decision as found at p. 56 of Metro Toronto
and C.ll.P.E.. Local 79, supra:
In our opinion, since the municipality had
the right under the agreement to discharge a
probationary employee without reasonable
cause, there was an error of law on the face
of the record when the board decided that the
grievance was established because the
employer failed to establish the grievor's
performanc~ was unsatisfactory. By taking
this course the board put the grievor into
the same position as that of an employee who
had completed the probationary period and in
so doing erred.
A distinction must be drawn between the scope
of the review of the board in the case of the
discharge of an employee who has acquired
seniority and in the case of the discharge of
a probationary employee. In the case of an
employee who has acquired seniority, the
collective agreement allows the board to look
at the reasonableness of the cause of the
discharge. In the case of the probationary
employee, for the board to look at the
reasonableness of the cause of the discharge
which it has done here, is to put the
probationer into the same position as that of
an employee who had acquired seniority and
thereby ignored the provisions of art. 3.01
and art. 3.03 ...
The municip'ality is not required to justify
the dismissal by affirmatively establishing
reasonable or any cause. A probationary
employee would be entitled to succeed on a
38
grievance in relation to discharge only if he
were able to affirmatively establish that the
action of the employer was taken in bad faith
in the sense that the decision was motivated
by unlawful considerations or resulted from
management actions which precluded the
probationary employee from doing his best.
The respondent urged the court to imply a
term that the management rights' clause would
be applied .fairly and reasonably,
notwithstanding the discretion granted to the
municipality. It is significant that in this
agreement the right to discharge a
probationary employee has been reserved to
the management rights' clause. If such a
term were to be implied, it would derogate
from the "exclusive right" given to the
municipality in relation to this matter.
This would be contrary to the intent of the
collective agreement ...
It is necessary to set out in full the reasoning of the
Board in the st. Lawrence, at pp. 329-332, case in order to
appreciate why it was not deferred to by the Divisional Court in
its unreported decision dated, February 17, 1989 :
Before looking at the Seneca Colleqe, supra,
decision, it may be of some use in putting the
Divisional Court's decision in perspective by
looking at the decision which it was reviewing.
As noted above, the arbitration board's decision
is reported at 26 L.A.C. (2d) 320. At. p. 326 the
board said the following:
The issue remaining is, what is the standard
of review of management's decision to
terminate the services of a probationer?
While the collective agreement does not make
any distinctions between probationers and
employees who have acquired seniority,
arbitral jurisprudence establishes that the
employer need not meet the same standard of
just or reasonable cause when dismissing
probationers ... It is noted that some
39
arbitrators will not overturn employers'
decisions to terminate the probationers'
services at will providing there is no
element of discrimination present. All that
is required is for the employer to establish
that the probationer is unsatisfactory.
It is therefore clear that the Divisional Court
was looking at a case where a board of arbitration
had placed the onus on an employer to show that
the probationary employee was unsatisfactory. The
Divisional Court rejected this standard and held
that the standard of review was illegality and
obstruction on the part of the employer and that
the union bore the onus of establishing that.
In Seneca Colleqe. supra, the argument concerned
whether a board of arbitration could imply a duty
to administer a particular clause of the
collective agreement in good faith. At pp. 21-2
of the decision there is a discussion of the
decisions in Re Council of printinq Industries of
Canada and Toronto Printinq Pressman & Assistants'
Union, No. 10 (1983), 149 D.L.R. (3d) 53, 42 O.R.
(2d) 104, 83 C.L.L.C. 14,050 (C.A.) [leave to
appeal to S.C.C. refused 52 N.R. 308n], and Re
Metropolitan Toronto Board of Com'rs of police and
Metropolitan Toronto Police Assn. (1981), 124
D.L.R. (3d) 684, 33 O.R. (2d) 476, 81 C.L.L.C.
14, 116 (C.A.) [leave to appeal to S.C.C. refused
D.L.R. and O.R. loco cit., 39 N.R. 449n]. At
those pages the following passage occurs in the
context of that discussion:
The Metropolitan Toronto Police case simply
says, as we read it, that there is no
doctrine that management rights clauses must
be administered fairly, while the Council of
printinq Industries case says that where, as
a matter of contractual interpretation, it is
a reasonable interpretation of a collective
agreement provision that it requires fair
administration, the courts will not
interfere. It is the function and obligation
of boards of arbitration to inquire, where
the issue is raised, whether a particular set
of facts establishing bad faith, or the
absence of good faith, constitute a breach of
a particular clause in the collective
agreement. As it happens, it is not here the
management rights clause that is asserted to
connote a requirement not to act in bad
40
faith, but a provision setting out
affirmative obligations upon the employer in
respect of its conduct in relation to
probationary employees, cl. 8.01(c). While
matters of this nature ought not to be
decided in the abstract, in the absence of
facts, we think it is a reasonable
interpretation of this provision that conduct
in bad faith intended to subvert the
protections given to probationary employees
by this clause, could be p breach of the
clause. since the grievor has alleged, in
her grievance, bad faith in respect of her
release on probation, and her counsel has
identified, in the course of argument, that
the bad faith was in relation to the
employer's obligations under cl. 8.01(c), we
think that the grievor is entitled to offer
her proof of this allegation so that we can
assess ... whether or not there has been a
breach of that clause.
In the very next paragraph, the first full
paragraph on p. 23, the following passage occurs:
As a matter of contractual interpretation,
therefore, we have found that the grievor is
entitled ta pursue her grievance to the
extent that it alleges bad faith in the
administration of her probationary
employment, and to the extent that it alleges
discrimination. In respect of both of those
allegations, the onus is on the grievor to
make out her case. The grievor is not
entitled to pursue, however, her allegation
that her dismissal was not for just cause,
and the employer is put to no obligation to
demonstrate that it had just or any cause for
releasing or dismissing her.
We do not consider that the above passages from
this case indicate that the board there was
enlarging upon the concept of bad faith as set out
in the Metropolitan Toronto case, supra, by the
Divisional Court. Clearly, one issue before that
board was whether the allegation that the
dismissal was because of discrimination based on
sex and/or creed was arbitrable, and the other was
whether the allegation that art. 8.01(c) was
breached because, the employer allegedly
administered her probationary period in bad faith
was arbitrable. The board's comments about "bad
41
faith in the administration of her probationary
employment" must be read in the context of the
art. 8.01(c) allegations, and the board's finding
that if an employer administered that clause in
bad faith so as "to subvert the protections given
to probationary employees by th[e] clause" such
conduct "could be a breach of the clause".
Therefore, while not defining bad faith in the
context of the test to be used when determining if
a probationary employee has been properly
dismissed, the board did determine that where
there were positive collective agreement
obligations intended to benefit the probationary
employee, the employer's conduct in bad faith
intending to subvert those collective agreement
protections could be a breach of the clause, and
arbitrable. Hence the comment about "bad faith in
the administration of her probationary period" has
to be read in the context of the discussion about
the ability to imply a duty to act in good faith
in art. 8.01(c), which dealt specifically with
aspects of the administration of the probationary
period.
In our view, the test to be applied when
determining if a probationary employee was
properly dismissed is still that set out by the
Divisional Court, that is illegality or
obstruction. When the court's decision is read,
it is clear that it determined that the board"of
arbitration whose decision was before it had erred
in law when it decided that an employer must show
unsatisfactory performance in order to justify the
dismissal of a probationary employee. The court
also noted that if a board of arbitration reviewed
the "reasonableness II of the cause for dismissal it
was placing the probationary employee in the same
position as the employee with seniority and
therefore exceeding its jurisdiction under the
collective agreement. The court also refused to
imply a term that the management rights' clause
must be interpreted reasonably and fairly in
connection with the exercise of discretion to
dismiss employees during their probationary
period.
Accepting then that there is an onus on the union
to demonstrate that there was bad faith by the
college in the decision to dismiss the grievor,
and that bad faith is defined as being "motivated
by unlawful considerations" or as having "resulted
from management actions which precluded the
42
probationary employee from doing his best", what
does the evidence disclose? In the first place,
it discloses that on balance, given the evidence
before us, the grievor can be said to have been
performing satisfactorily without any serious
problems with his work. It can also be concluded
that, whatever the long~term plans for the
department were, they were never communicated
either to the grievor or to the chairperson in
such a way as to lead them to believe that the
grievor did not fit into them until April, 1987,
after the grievor's work-load for the next term
had been established and after his latest student
evaluations had been received. There is no
evidence to suggest that there was any reason
operating in the dean's mind other than the ones
put forward in various conversations, that is, (1)
the grievor not fitting into the long-term plans
of the department, (2) the grievor being deficient
.in formal education, and (3) dissatisfaction with
the student evaluations. There is no suggestion
that the dismissal was motivated by anti-union
animus, by considerations of race, religion, sex,
or any other illegal ground of that sort.
In its reasons, the court in the st. Lawrence case
found that the board had erred in treating the Metro Toronto and
C.D.P.E., Loc. 43 case as having been decided on identical facts
to those before it:
We think the board thereby declined jurisdiction.
The Board's jurisdiction was not limited by the
Metropolitan decision, which turned very narrowly
on its own unique facts, including the specific
language of management rights clause 3.03 in the
context of that agreement which apparently lacked
a code of positive obligations governing the
probationary period such as clause 8.01(c) of this
agreement.
It is clear from Council of printinq Industries
(1983) 42 O.R. (2d) 404 that different language in
a different agreement read as a whole might
properly be interpreted as giving a Board
jurisdiction to consider good faith, in a sense
43
broader than that used in Metropolitan Toronto, as
the subject of a grievance. Having regard to the
language ox this agreement we think this is such a
case.
As another board said in Seneca Colleqe and OPSEU
(Hacker Grievance), 1986 unreported (Swan): at p.
22:
It is not here the management rights clause
that is asserted to connote a requirement not
to act in bad faith, but a provision setting
out affirmative obligations upon the Employer
in respect of its conduct in relation to
probationary employees, clause 8.01(c).
Instead of fettering its jurisdiction as it did
the Board in this case should have gone on to
consider the employer's good faith or lack thereof
in discharging its positive obligations in article
8.01(c), a code for the administration of the
probationary period which was apparently not
before the court in Metropolitan Toronto.
Had it not so fettered its jurisdiction the Board
would have gone on to decide whether or not it was
satisfied in the circumstances of this case that
the employer's overall administration of the code
governing probationary employees involved the kind
of bad faith found by the dissenting union
nominee.
By applying to this case too narrow a test taken
from a case which turned on a very different
management rights clause and no code of positive
obligations such as clause 8.01(c), and by
considering its jurisdiction fettered by that
inapplicable test, the Board committed
jurisdictional error.
Thus the court, in the st. Lawrence case, found that
the board had employed a too narrow test of good faith because of
the existence of a positive obligation relating to the allegation
of bad faith found outside of the management rights clause. The
court referred to the "kind of bad faith found by the dissenting
44
union nominee".
The court in st. Lawrence referred to two kinds of bad
faith as identified by the Board in the Seneca case:
case:
As it happens, it is not here the management
rights clause that is asserted to connote a
requirement not to act in bad faith, but a
provision setting out affirmative obligations upon
the employer in respect of its conduct ...
Identifying what actions would constitute bad faith in
the administration of a clause in a collective agreement outside
of the management rights provision was seen to be something
different from identifying what behaviour would constitute bad
faith in the administration of a management rights clause. What
behaviour will amount to bad faith depends on the facts of each
case and will usually not be decided in the abstract.
In the dissent of the union nominee in the st. Lawrence
case, a number of other matters pertaining to bad faith were
relied upon in addition to the decision having been motivated-by
"unlawful considerations or [thpt it] resulted from management
actions which precluded the probationary employee from doing his
best." These additional elements of bad faith were found in
relation to the employer's particular breaches of the article
relating to probationary employees. It is significant that the
examples of bad faith found by the union nominee are specific to
45
the administration of the provision in the agreement relating to
probationary employees and are not duties in the abstract. These
included (at pp. 9-13):
As pointed out in Cambrian Colleqe and OPSEU (File
85k 31), (1986) unreported (G. Brent) it would be
difficult, if not impossible, to ~et out a
comprehensive catalogue of those considerations
which could be called unlawful. I would agree with
Arbitrator Brent in that case wherein she found
that the "common feature of all of these elements
is some action or actively pursued intention on
the part of the employer which is inconsistent
with the prime purpose of the probationary period,
which is to give the employer an opportunity to
assess the newly-hired employee in a working
environment to see if he/she is really an
appropriate candidate for permanent emploYment."
Equally so, the probationary period provides the
employee an opportunity to demonstrate his ability
to do the job. It is the expectation of all
parties that if the employee satisfactorily
demonstrates his ability to perform the duties of
the position, then the emploYment relationship
will continue. In this respect, probationary
emploYment differs fundamentally from an
appointment for a fixed term, such as a sessional
or partial load appointment. In an appointment
for a fixed term, there is not the same
expectation for the continuation of the emploYment
relationship. It is precisely this difference
which resulted in the grievor rejecting the
sessional appointment which the College offered to
h~;
In assessing the abilities of the employee the
employer is required to do so based upon valid
work-related criterion and not upon erroneous
considerations. Moreover, the employee is
entitled to be assessed against the same standard
as other new employees. These requirements flow
from the nature of the probationary period itself.
In addition, the College is required to administer
the probationary period in accordance with the
provisions of the Collective Agreement.
In my view, in considering the question of whether
or not the termination of the grievor was made in
46
bad faith, one must address the question of
whether the probationary period was administered
in good faith. In my view, it has not been. The
grievor did not receive progress reports on four
month intervals as is required by Article 8.01(c).
He was given work assignments that exceeded the
maximum allowed under the Collective Agreement.
He was charged with the responsibility along with
others, of developing courses for a new program.
In short, the College placed a number of obstacles
in the path of accomplishment, yet despite these,
the evidence suggests that the grievor performed
more than satisfactorily. The one progress report
which he did receive revealed not a single
complaint or concern about his performance. If
there were complaints, [sic] (and as pointed out
above there was no evidence of any), it was the
obligation of the College to draw those to the
attention of the grievor to give him an
opportunity to demonstrate his ability in response
to those particular complaints. It would clearly
be bad faith on the part of the employer to hide
its complaints or concerns about the grievor until
too late in the day for the grievor to address
such complaints ?r concerns.
In my view, the facts of this case more clearly
demonstrate bad faith. The College had provided
absolutely no reasons for the termination of the
grievor, even though required to do so under
Article 8.03(c). As no reasons have been
provided, one must assume that the College was
entirely satisfied with his performance up to and
including the date of his termination. The
inference must be drawn that the grievor has not
been evaluated on his performance or on valid
work-related criteria. I would agree with the
majority where at page 10 it concludes that "it
would appear that he [the grievor] was not judged
on his performance ...". The majority also
concludes that the grievor's performance was
satisfactory. In my view, this alone constitutes
sufficient evidence of bad faith.
In addition, I would find the different treatment
accorded to Mr. Roughton and the grievor, to
constitute bad faith. Mr. Roughton and the
grievor commenced their full-time employment in
the spring of 1986. On the completion of their
first semester of teaching, the performance
appraisals of the two men were almost identical
if anything, the grievor's performance appraisal
47
_/
was slightly better than Mr. Roughton's. Mr.
Roughton also t~~tified that his student
appraisals in second term were fairly similar to
those [of] the grievor. Mr. Roughton's employment
with the College was not terminated. In my view,
this must lead one to a conclusion that the
College has applied a different standard in Mr.
Roughton's case than in the grievor's.
Finally, and most importantly in my view, the
conduct of the College is totally inconsistent
with the very concept of a probationary period.
The College induced the grievor into its employ
upon representations of continued employment if he
performed satisfactorily. As pointed out earlier,
the very basis of probationary employment carries
with it this expectation of continued employment.
The grievor worked very hard to meet the
expectations of his employer and as the majority
points out, it must be concluded that his work was
satisfactory. Yet the College terminated his
employment without any explanation. Surely such
conduct has rendered the entire probationary
period a sham.
It is also significant that the Divisional Court in st.
Lawrence did not find fault with the majority of the board's view
of good faith as it related to a case where only the management
rights' clause was being considered. The board's reference was
(at p. 332): "There is no suggestion that the dismissal was
motivated by anti-union animus, by considerations of race,
religion, sex, or any other illegal ground of that sort." Nor
was there any disagreement with the majority of the board's
statement that bad faith would be found where the employer made
it impossible for the grievor: "to perform his job or [where} the
whole probationary relationship was a sham from the beginning."
(Ibid.)
48
So, in the case before us, if the motivation for
denying the Grievor the training and development opportunities
sought by him involved a desire to make it difficult for him to
compete for a posted position pursuant to art. 4; to punish him
because he was a francophone; o~ for reasons prohibited by s.4 of
the Code, the Employer would be acting in bad faith. While the
exclusive power of management to determine which employees
receive training and development opportunities is all
encompassing, it must be exercised bona fides and not as a
subterfuge.
In Metro Toronto, one of the issues concerned whether
the loophole, recognized in Metro Police and employed by the
board with the approval of the court in council of printinq
Industries, could be employed where the breach complained of had
not yet resulted in the breach of the article relied upon: in
that case, the provision that discipline could only be imposed
for just cause. That is, the grievance involved the board in
hearing a case relating to ~discipline in the abstract." (Metro
Toronto, at p.251.)
In the case before us, there is a similair issue in
that there has not yet been a denial of selection to a posted
position as a result of a competition under article 4 of the
collective agreement. Is the reasoning of the Court of Appeal in
Metro Toronto, in a case involving the "obey now, grieve later"
49
rule, applicable in the case before us? There, the court stated,
at pp. 254-5:
... it seems clear that under an "obey now, grieve
later II rule, an arbitrator is practically required to
take jurisdiction to hear a grievance against a
directive, at least in a case where a breach is likely
to constitute insubordination and subject the employee
to disciplinary action. ... In my respectful opinion
the Board, in taking jurisdiction, acted in accordance
with both the letter and spirit of the collective
agreement ... To decide otherwise would be to invite
anarchy in the workplace. (Emphasis in the original.)
The court in Metro Toronto, at pp.257-8, also noted the
existance of authority: "... that all company rules with
disciplinary consequences must be reasonable."
In the case before us, it can be seen that an employee,
who has been deprived of a training or development opportunity,
may be placed at a disadvatage in a competition held pursuant to
art.4 where an applicant must have had certain training or
development in order to pass a threshold for consideration.
However, the underlying basis for permiting the board to assume
jurisdiction on the issue of discipline in Metro Toronto was
based on the board's holding (referred to at p. 253 of the Metro
Toronto case) that "it would be 'hypocritical, and transparently
so, to deny employees the promise of the rule having exposed them
to its command. '" In other words, if the purpose of the rule is
to avoid insubordination and anarchy in the workplace, the
obvious trade-off is that employees in a unionized envoirnment
will have the right to grieve rules, the breach of which would
50
likely have led to discipline, even if they continue to obey
them. In the case before us, the basis for permitting a grievance
with respect to "discipline in the abstract" does not apply to an
abstract breach of article 4. There are not the same reasons for
hearing the issue ielating tti the denial of training and
develoopment as part of a grievance claiming a violation of art.
4 where no competition has been advertised. As in Brick and Roth,
above, the primary thrust of the grievance is with respect to the
denial of training and development opportunities and not the
failure of the Employer to adhere to its responsibilities under
art. 4. 3 .
Furthermore, in the case before us, there is also the
important additional consideration that article 18(1) of the Act
is specific in prohibiting collective bargaining with respect to
the subject of training and development. In this regard, the
court in Metro Toronto referred to ontario v. O.P.S.E.U. (1986),
570.R. (2d) 404 (Div. ct.). That case involved a Crown employee
who grieved against "a ministry policy" prohibiting certain
political activity by Crown employees. The grievance was based on
a breach of the "just cause for discipline" provision in the Act
(s.18(2)(c).
The ministry policy was based on a statutory
prohibition, contained in the Public Service Act, R.S.O. 1980,
c.418, as ammended, against the kind of political activity
51
engaged in by the employee. (O.P.S.E.U. at p.408.) At p.251 of
the Metro Toronto case, the court indicated its view of the basis
for ~he finding in O.P.S.E.U. :
... a closer examination o~ the judgment of White J.
[in O.P.S.E.U.] reveals that he was motivated by the
fact that the "ministry policy" complaind of merely
reflected the Legislature's will, as expressed in the
Public Service Act, R.S.O. 1980, c.418, ss.11 to 16.
This led White J. to conclude, ... at p. 409 O.R.:
what the grievor is really seeking to
challenge is the wisdom of the Legislature in
enacting the statute and the Grievance
Settlement Board is not the appropriate forum
in which to engage in that effort.
In other words, the Board in the O.P.S.E.U. case had no
jurisdiction to hear a grievance based on legislative
policy. The result would therefore have been the same
whether or not discipline had been meted out. ...
In the case before us, the Employer argued that the
grievance is inarbitrable because it, too, amounts to an attempt
on the part of the Grievor to challenge the "wisdom of the
Legislature in enacting [a] statute" which deprives the Grievance
Settlement Board of jurisdiction to, deal with grievances
involving t~e functions set out in s.18(1) of the Act, which
include the subjects of training and development. The Employer's
position is that the provisions of s.18(1) of the Act which
remove the subjects of training and development from the sphere
of permissable bargaining and, it was argued, from the
jurisdiction of the Board, amount to a grant to it of the sole
and unfettered discretion to decide which employees obtain
52
training and devolopment opportunities.
It is significant the the board, in Council of printinq
Industries, whose reasoning (at pp. 408-411) was approved of by
the court in that case (at pp. 411), in finding an implication
that the employer must exercise its power under the relevant
article "on a reasonable basis, without bad faith, discrimination
or arbitrariness," noted that the article did "not provide that
employees are to be permanently classified 'in the sole
discretion of management'." (At p.409.) The board also noted (at
p. 409) that the management rights clause made "no explicit
reference to the employer's right to permanently classify
employees, explicitly consigning this right to the unfettered
discretion of managemnent."
There are certain significant differences between the
management rights' provisions in the Metro police, C.P.I. and
Metro Toronto cases and the provisions of s. 18(1) of the Act.
While it is clear that the provisions of s. 18(1) of the Act are
incorporated into every collective agreement, the "management
rights" created by s. 18(1) are statutory in nature. In
addition, the Act reinforces the nature of the exclusive
functions reserved to management by providing:" such matters
will not be the subject of collective bargaining nor co~e within
the jurisdiction of a board."
53
Counsel for the parties differed in their
interpretation of the jurisdictional limitations imposed on the
Board by the provisions of s. 18(1) of the Act immediately above
quoted. The meaning of the word "board" in s. 18(1) was
considered by the Board in Dickie, 314/85 (Palmer). In that
case, the Board was dealing with a grievance which alleged the
improper denial of a merit increase. The majority of the Board,
after setting out the provisions of article 18(1) of the Act,
stated at pp. 5-6:
Clearly, the foregoing indicates that the "merit
system" is something which is an "exclusive function of
the employer to manage." Further, the final words of
that section appear dispositive of the present matter,
i.e., that "such matters will not be the subject of
collective bargaining nor come within the jurisdiction
of a board." In this regard, reference must had to
section 1(1) (c), which clearly indicates that the word
"board" covers the present board of arbitration which
is established' pursuant to this Act. Obviously, the
request of the Union asks us to determine the way in
which the Employer has managed the merit system which
is established. This, in our opinion is something we
cannot do. All the rights the Union has with respect
to this system is to have the ability to review "the
governing principles" of this plan with the Employer.
While it is true that the Grievance Settlement Board
is: "a board of arbitration established under this Act," in
context, we conclude that in using the word "board" in article
18(1), the intention was to refer to the "board or arbitration"
referred to in s. 11(1) of the Act, which is as follows:
Upon written notification by the Tribunal, each of the
54
parties shall, within ten days of the notification,
appoint to a board of arbitration a member who has
indicated his willingness to act and shall each notify
in writing the other party and the Tribunal of the name
and address of the member so appointed.
The Legislture, in linking the words II subject of collective
bargaining" with "jurisdiction of a board" was concerned with
what matters might be included in a collective agreement, whether
arrived at by agreement, or as a result of a decision of a board
of arbitration appointed under s.ll(l) of the Act.
The Legislature provided, in s. 18(1) of the Act, that
the matters there set out were outside the realm of collective
bargaining and could not be included in a collective agreement.
Where, notwithstanding the statutory prohibition, agreement is
reached by the parties pursuant to s. 13(1) of the Act, or the
board of arbitration referred to in s. 11(1), pursuant to s.
13(2), s. 18(1) renders such a decision of the parties or the
board of arbitration without legal effect. Similairly, any
collective agreement arising from such action would be invalid to
the extent that it dealt with the prohibited subjects.
What the Legislature intended was a prohibition against
the parties or a board established under s. 11(1) of the Act
dealing with the matters listed in s. 18(1) and, in any event,
preventing any agreement or decision of the Board from having any
55
legal effect.
Nevertheless, for other reaons, we agree with Professor
Palmer's conclusion that the Grievance Settlement Board is
precluded from assuming jurisdiction to deal with the matters
listed s. 18(1). In precluding collective bargaining with respect
to the matters listed in s. 18(1) of the Act, and hence, the
valid inclusion in a collectiv~ agreement of provisions dealing
with them, the Legislature has gone beyond the kind of management
rights' provisions as are found in the Metro Police, C.P.I. and
Metro Toronto cases. In the latter cases, the management rights'
clauses do not prohibit the parties from agreeing to provisions
which would otherwise fall within the exclusive functions
reserved to management. The limitations placed on the Board's
jurisdiction are reinforced by the provisions of s. 18(2) of the
Act which create jurisdiction in the Board to consider three
types of grievances which would otherwise be outside its
jurisdiction. The application of the jurisprudence found in the
private sector cases referred to must take into consideration the
statutory restrictions on the jurisdiction of the Board as set
out in s.18 of the Act.
In O.P.S.E.U. and Anderson et ale v. The Queen in riqht
of ontario as represnted by the Ministry of Natural Resources and
the Crown Employees Grievance Settlement Board (1990), 750.R.
(2d) 212 (Div.ct.), in considering the remedial jurisdiction of
56
the Board in a classification grievance, once it decided that a
classification was wrong, the court had to deal with the
jurisdiction of the Board in the light of SSe 18(1) and (2) of
the Act, as well as SSe 7 and 19(1). At p. 219, the court noted
that:
It is not necessary to determine whether or not the
board erred in its interpretation of the word "board"
in s. 18(1). The board based its jurisdictional
decision on the content of the management rights
clause. That clause in the context of the statutory
scheme as a whole including S. 7 and S. 19 [am. 1984,
C. 55, s. 214] does impose limits on the jurisdiction
of the rights arbitrator in relation to functions
reserved by statute exclusively to management and the
question is whether the board in the result correctly
interpreted those limits.
We conclude that our jurisdictional decision can, as
well, be based on the content of the management rights clause, in
the context of the statutory scheme as a whole, including S. 7
and S. 19.
In the Anderson case, the court considered the
questions: "Does
management's right to classify positions
under s. 18(1) (a) and the corresponding restrictions on the
board's jurisdiction, require the defeat of the employee's right
to grieve classification and the board's duty to effect final
settlement of all grievances?" (at p. 221). It was the existence
of an employee's statutory right to grieve classification
established by s.18(2) (a), along with the Board's statutory duty
57
to effect a final settlement of classification grievances "and
the narrow ambit of necessarily incidental board activity around
the outer edge of management's protected classification zone,"
that enabled the court to find -(at p. 223) that the Board "was
entitled to review the content of a class standard established by
management pursuant to a Berry - type direction from the board
and instruct management to alter or amend the standard in order
to reflect properly the duties, responsibility, etc. of the
grievors."
At p. 222, the court stated that: "the jurisdiction
contended for does not involve any significant inroad of
management's right to classify." The court made this statement
in the context of a case where management's exclusive statutory
right to classify was required ~o be accommodated by a statutory
right granted to an employee to grieve classification. In the
case before us, the Act does not contain any provisions requiring
such accommodation. Also, even if the word "board" in s. 18(1) of
the Act does not include the Grievance Settlement Board, the
subject of training and development is still outside of its
jurisdiction. If the subject of training and development cannot
directly be the subject of collective bargaining, it cannot
indirectly insinuate itself into the collective agreement, as can
a subject reserved to management in a collective agreement
without such a restriction as is found in s. 18(1). If such a
restrictive provision is to be ~imited in the scope of its
58
application, there will have to be legislative intervention. Cf.
the Manitoba Labour Relations Act, 1987 R.S.M. c. L10, s.80(2).
This does not mean that the Employer has carte blanche
to do what it wishes under the purported exercise of an exclusive
management function with respect to training and development.
The greater part of this Decision is concerned with the
requirement that the Employer exercise its exclusive functions
with respect to training and development bona fide; as that term
is explained in this Decision.
since Metro police, many words have been used to
describe the possible ways of breaching fairness obligations that
may be imposed on an employer in administering rights granted
under a collective agreement: arbitrary, discriminatory, unfair,
bad faith, unreasonable. The board in council of printinq
Industries employed a number of the terms associated with
fairness. In finding that the interpretation placed on art. 22 by
the board in council of printinq Industries was not "patently
unreasonable," the court stated, while commenting on the board's
deliniation of the fairness requirements imposed on management
(at p.411): "The majority concluded, although many words were
used, that the mandatory obligation to permanently classify
[pursuant to art. 22] must be done in a bona fide fashion."
59
Bona fides may have a broad or narrow meaning depending
on the context. See, Manon Schiralian, 914/86 (Roberts), referred
...
to in Shaw, 410/88 (Watters), where the Board stated, at p.6:
"Reasonableness in this context is a species of good faith."
The Shaw case was concerned with a grievance which asked the
Board to find that a purported release of a probationary employee
under the authority of section 22(5) of the Public Service Act
for ostensibly having failed to meet the reqirements of his
position amounted to a dismissal without just cause which the
Board had jurisdiction to deal with under s.18(2) (c) of the Act.
In an earlier case decided by t~e Board, Leslie (1978), 22 L.A.C.
(2d) 126 (Adams), at p. 134, the majority of the Board stated:
... this Board is of the opinion that the employer
cannot camouflage either the discipline or the
termination of an employee for a reason other than the
employee's failure to meet the requirements of his
position ... by the guise of a 'release' under the
Public Service Act. This Board therefore, has
jurisdiction to review a contested release to insure
that is is what it purports to be. But in the
adjudication of such 'a grievance, this board is without
jurisdiction to evaluate and weigh the reasons of the
employer unless the Collective Agreement provides
otherwise. The Board must only be satisfied that the
employer, in good faith, released the employee for a
failure to meet the requirements of his position. As
long as the Board can be satisfied that the employer
has made an evaluation of that kind, it has no
jurisdiction to review the fairness or correctness of
that termination under [what is now s. 18(2) (c) of the
Act] .
In commenting on the use of the term "unreasonable," in
some earlier decisions of the Board dealing with the good faith
60
exercise of the statutory right to "release" a probationary
employee, the Board stated, in Shaw, at pp. 5-6:
While this term [unreasonable] is utilized in the
earlier decisions we do not take it to mean that we can
review the merits of the employee's job performance and
reinstate him if we find that assessment was
"unreasonable" that the employee had not met the job
reqirements. Reasonableness in this context is a
species of good faith. Whereas the phrase "bad faith"
could encompass a release improperly motivated or
maliciously intended, "unreasonableness" speaks more to
an objective assessment that the release did not flow
logically or rationally from the facts. If, for
example, there was simply no evidence that a
probationary employee had not fulfilled or could not
fulfill the job requirements, then no matter how well
meanihg were the actions o~ his superiors, the release
would have been an unreasonable exercise of authority.
The Board in Shaw also dealt with the the fairness
requirement that there be a rational relationship between the
facts and the release (at p.6). This factor was found to be
"nearly synonomous with 'reasonableness'." In holding that
(ibid.) the release can be reviewed as a discharge if the
employ~r's "assessment th~t a certain set of facts justifies
release is 'irrational' on any half-intelligent view of the
matter," the Board cautioned (ibid.) that the rational
relationship test should not be placed too high, as:
It is easy to brand as "irrational" any thought process
or decision with which one does not agree. The Deputy
Minister must be free to make decisions, without being
found to have acted irrationally merely because a board
of arbitration might have come to a different decision.
61
That is, the test of good faith, in this context is not one of
correctness.
Although the Leslie and Shaw cases were concerned with
certain rights given to a deputy minister by s. 22(5), of the
Public Sevice Act, they have some relevance in the case before
us. We, too, are faced with the provisions of a statute which
removes the subjects of training and development from collective
bargaining between the parties. The requirement that the exercise
of the exclusive function of management with respect to training
and development be caried out in good faith is the same as the
obligation imposed on a deputy minister under s. 22(5) of the
Public Service Act, and for the same reasons. In order to be
carried out in good faith, an employer must have had a genuine
intention to carry out a legitimate government purpose which has
the effect of denying an employee a training or development
opportunity.
As held in the Shaw case,at p.6, if there was simply no
evidence as to why a grievor had been denied a training or
development opportunity, this would go to the reasonableness
aspect of the good faith test referred to in Shaw.
If the facts relied upon by an employer in support of
62
its position that it had denied an employee a training and
development opportunity for the purpose of achieving a legitimate
government objective are "'irrational' on any half-intelligent
view of the matter," this would also go to the question of good
faith. As was noted in Shaw, in examining the employer's
rational, the Board should avoid finding the absence of a
rational relationship between the facts and the decision to deny
the requested training or development opportunity unless it
concludes that, on the facts, no such conclusion could have been
reached rationally.
As also noted by the Board in Shaw, the rational
relationship factor is nearly synonymous with reasonableness. And
reasonablene~s, in the conext of the case, is a species of good
faith. In the case before us, in outlining the good faith
obligations of the Employer, we include the further elements of
reasonableness and a rational relationship between the facts
leading to the making of the decision and the decision itself.
Where the Employer cannot be shown to have denied the Grievor's
requests for reasons which are "improperly motivated or
maliciously intended," such as his being a francophone; for
reasons prohibited by s.4 of the Code; or because of a desire to
impose disguised discipline, the Employer will have satisfied the
first aspect of the good faith test identified in Shaw. As stated
in Shaw (at p.5): "Clearly the bad faith, if found, must be
relatively serious."
63
Where there is some evidence permitting an objective
assessment that the decision flowed logically from the facts, the
Employer will have satisfied the second aspect of the good faith
test (reasonableness).
If the conclusion arrived at by an employer is one that
is reasonably possible based on the last mentioned evidence, then
the necessary rational relationship between the facts and the
decision will exist.
The jurisprudence relating to the tests to be used by
the Board in cases involving managerial discretion was recently
reviewed in Selzer, 1928/89 (Keller), in a decision dated
November 15, 1990. The cases referred to were Da Costa, 570/84,
and Kuyntiies, 513/84. Although the test was put somewhat
differently in both cases, the Board, in Selzer (at p.5) found
that the statements were to the same effect~ In both of the
cases referred to, in addition to the requirement of good faith,
the Board added the requirements that the decision must not be
based on : "discrimination" or "arbitrary" conduct (Da Costa),
"discrimination" (Kuyntiies).
The statements made by the Board in those cases, make
it clear that any additional words used were, in context, related
to the subject of good faith as was the case in Shaw. All of the
64
cases emphasize that in cases involving the exercise of
managerial discretion, the Board will hesitate to substitute its
view for that of the employer as long as certain minimum tests
are met. These include the requirement that the decision be a
genuine one related to the management of the undertaking and not
a disguised means of aChieving impermissable ends based on
discrimination or other grounds unrelated to the making of
genuine management decions. The facts considered in making the
decision must be relevant to legitimate government purposes.
Also, in making its decision management, provided it has acted in
'good faith, as above described, need not be correct.
In the case before us, it is difficult to view the
provisions in s. 18(1) of the Act, which remove the subjects of
training and development from collective bargaining as being
other than a statutory direction granting unfettered discretion
to the Employer in making decisions to grant or withhold training
and development opportunities, and, as such, being subject only
to the good faith test described above.
A grievance, such as the one before us, is to be
contrasted with the one which was considered by the court in the
O.P.S.E.U. (Anderson) case (above). In the latter case, the Board
had to deal with its jurisdiction under s. 18(2) (a) of the Act to
adjudicate a grievance that an ~mployee's position had been
improperly classified in the light of management's exclusive
65
right under s. 18(1) to dertirmine the classification of
positions.
The 6ase turned (at pp.213-4):
... on the application of the principle in the Berry
case, O.P.S.E.U. v. ontario (Minister rsic.l of
Community and Social Services) (1985), 15 O.A.C. 15
(Div.ct.), at p. 20, that the Crown Employees. Grievance
Settlement Board in a classification grievance, once it
decides that a classification is wrong, has an
unrestricted remedial jurisdiction to effect a proper
classification.
Does that unrestricted remedial jurisdiction in the
case of a class standard established by management
pursuant to a Berry type direction from the board to
create a proper classification, include the power to
review the content of the class standard and decide
whether it was properly drafted.
The court, in the Anderson case, at p. 220, stated the
governing principles that must be balanced:
(1) The right'of the employee to grieve
classication.
(2) The duty of the Board to bring about the
final and binding settlement of all
differences between the parties, and to bring
it about fairly, effectively, and efficiently
within a reasonable time.
(3) The right of management to classify
positions and the corresponding restriction's
on the Board's jurisdiction.
Referring to the first principle, the court stated,
ibid. :
t ,
66
Under the first principle, the right to
grieve classification should not be
restricted unless the legislature clearly
intended the restriction;
Where a right to grieve a
particular matter is specifically
recognized by legislation it ought
not to be restricted absent a clear
intention on the part of the
legislature to do so.
OPSEU v. The Oueen (1982), 400.R.
(2d) 142 per Callaghan J.at p.145.
In the case before us, unlike the one before the Board
in Anderson, there is no provision in the Act that specifically
restricts the discretion of management in exercising the
functions which here are "not to be the subject of collective
bargaining." In the Anderson case, the exclusive function of
management to classify positions under s. 18(1) (a) of the Act had
to accomodate the provisions of s.18(2) (a).
In Anderson, the 'court considered (at pp.221-3) whether
the exclusive management function with respect to classification
under s. 18(1) (a) "and the corresponding restriction on the
Board's jurisdiction, require the defeat of the employee's right
to grieve classifications [unde~ s. 18(2) (a)] and the Board's
duty to effect final settlement of all grievances [under s.
19(1)." At p. 222 the court stated:
The statutory restriction on the Board's
jurisdiction [under s. 18(1)] must be read
subject to the employee's statutory right to
grieve classification [under s.18(2) (a)], the
.
67
board's statutory duty to effect a final
settlement of classification grievances
[under s. 19(1)], and the narrow ambit of
necessarily incidental Board activity around
the outer edge of management's protected
classification zone.
Here, the Grievor has no statutpry right to grieve
because he has been denied a training and development
opportunity. He claims that he does have a right under the
collective agreement to certain consideration when he applies for
a position under art. 4 of the collective agreement, and that any
restriction on the Board's jusisdiction to deal with matters
, relating to training and development must be read subject to an
employee's right to fair consideration under art.4. Because of
the statutory limitation imposed by s.18(1), there is no room for
the penumbral activity permitted in Anderson as might arise
through the operation of the statu~ory rights contained in s.
18(2). Here, the right to raise the subjects of training and
development by way of a grievance has been restricted by means of
a clear indication on the part of the Legislature. Cf. Metro
Toronto case, at p.250. The effect of the statutory limitation
placed on the Board's jurisdiction differentiates this case from
council of printinq Industries amd Metro Toronto.
In rejecting the preliminary objections to our
jurisdiction, we have found tha~ the issue of good faith in the
exercise of the Employer's discretion as it relates to the
subjects of training and development opportunities, as explained
'\
68
-above, are properly before the Board, and this includes the
question of whether the Employer, in refusing the Grievor's
requests, did so in violation ot the provisions of s. 4 of the
Code.
It is interesting to note that the majority of the
board in ~hc H~j;;~o Toro.Il~o c::~"c relied on thl:ee IU~jVL YLULlllUti .cUL"
findihg that the rule imposed by the employer was unreasonable:
1. the absence of any consultation with those whose
h,=a.1Ul cm~ Ba.cety were ~lK.e~y ~o De atrec't.8a oy ~ne
directIve;
2. the absence of any employer interest sufficient to
justify the change in policy; and
3. the testimony of several drivers/attendants to the
e.f'f'o<:ot that t.h~y .cl;lll. L.he policy woula De Dotn
counterproductive and dangerous.
Even though the Metro Toronto case relied on
jurisprudence (C.P.I.) whioh does not apply to a case governed by
s. 18(1) of the Act, we are uncertain as to whether the test to
be applied necessarily produces a different result:
1. Ground one in the Meto Toronto case can be seen to
be another manifestation of bad taith. In the case
before us, if the Employer is shown to have refused to
discuss its reasons tor denying the Grievor the
training and develupment opportunities requested by
him, this might, along with other evidence, represent
,
.
"
6')
a manifestation of unreasonable behaviour which could
disclosed a laek of 900d faith in the exercise of its
discretion.
2. Ground two, referred to in Metro ToroD~O, can also
be seen to be a manifestation of bad faith. If the rule
was changed without a demonstration of any rational
rea con eo do co, . ei~nifican~ quo8~ion would arig~ ag
to the qenuineness of the employers exercise of the
"
management right, and hence as to its good faith.
3. similairly, where the rule appears to have no
%:'CLthmdll 1.II::hlt.iol'llilhip to the purpo1.Ate<1 exercise ot the:
right relied upon, it would not have been exercised in
qood faith, in the sense that it was unreasonable:
unreasonQbleness in ~hia context bQing ~ cpooioc of
go'od faith as explained in the. Shaw case,a.bove). See
ground three, referred to in Metro Toron~9.
We, too, have used many words in arriving at the
conclusion that the Employer must act in good faith in exercising
its rights with respect to training and dAVQlonmAnt as provided
tor in s. 18(1) ot the~. (ct. c~unci1 o~ printing Indu~Lr~e$,
at p. 411.) It must be remembered, however, that words, as is the
\nA~~, ~n~ ~A~~~ n~ ~~~~~h. A~~ ~~n~i~iv~ ~n ~h~ ~nn~~Y~ whp-rA
they a~e tound. A word may, tor example, function as a noun, verb
.03/08{91 15:06
tr416 364 4814
WINKLE~ FILION ~~~ CORNISH
~005
t
,..
70
or modifier. The meaning of words is also affected hy the context
in wh;nh t-h,::ay lIlIrea -f'nnnl"'t. ~n. t-hc t-~'M'n "(7nnn -f'lllIit-h" h.o: "1"1 Unnea_
size-fits-all" meaning. Its meaning is affected by such factors
as the nature of: (1) the manaqement rights provision involved;
\.c::J\,.U. n~""UL"e U1. l;.ne 5pe\,;,LJ;,Lc mani:lgemenl;. L"J.c:JIll;.\SJ .LnVU.Lvec,; ~ne
applicable statute(s)j ana (3) other relevant provisions in the
collective agreement, and the general understanding of parties
engaged in a collective bargining relationship. eel'. Metro
Toronto, at p. 259).
In cUlvl.h~.L ....a.2:)~, lllvulv.l.uy a \ll.c,[.;::;Lent ~vlle~tivc
&9reement. a~~r~r~n~ ~Q~QVQn~ ~~a~u~Q(~Jr Qtc_, a ~inain9 that an
employer is required to administer a particular manaoemene riQht
in good faith may result in a meaning of that term, in its
particular context, that differs from the one found here. Many of
the problems experienced by employers and unions, in agreeing to
the proper standard to be applied to the actions of manaqement in
~hG Q~mini~t.ation oC manQgem~nt .i9ht~ ~1au~e~1 Q.i~e ~.Qm thGi.
failure to appreciate the limitations involved in applying, as
9cnera1 ruleo, ~hc pronounoemcntG ~Qdc in PQrtioul~r OQOco.
~ -r T_
:.
"
f
Oated at Toronto the .1st day of Karch
, 199 1.
-<<.e ~
M. Gorsky - Vice Chairperson
~~er
:? I
~ j /iAU.~1
G.... 1I11lQ:. '.~ ": - Member
71