HomeMy WebLinkAbout2018-1830.Porteous.19-11-25 DecisionCrown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB# 2018-1830; 2018-2870; 2018-2871; 2019-0272; 2019-0346
UNION# 2018-0271-0010; 2018-0271-0012; 2018-0271-0013; 2019-0271-0003;
2019-0271-0004
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Porteous) Union
- and -
The Crown in Right of Ontario
(Ministry of the Attorney General) Employer
BEFORE
Ian Anderson
Arbitrator
FOR THE UNION
Ed Holmes
Ryder Wright Blair & Holmes LLP
Counsel
FOR THE EMPLOYER Felix Lau
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING November 21, 2019
-2-
DECISION
[1] The Grievor filed the five grievances noted in the style of cause which the parties
have agreed will be consolidated. Mediation efforts on an earlier date
established an allegation the Employer breached its duty to accommodate a
disability of the Grievor was common to several of the grievances and was the
sole issue in GSB File No. 2019-0272 (“the accommodation issue”). It also
became apparent that the determination of the accommodation issue turned on
whether the information which the Employer had on file was sufficient to trigger
the duty.
[2] Given the narrowness of this dispute, the parties agreed the Employer would
produce all medical information in its file related to the Grievor’s accommodation
request and a hearing would then take place for the purposes of determining the
accommodation issue pursuant to Article 22.16 of the collective agreement.
Article 22.16 provides for expeditious resolution of disputes. Decisions are to be
succinct. They are of no precedential value unless the parties agree otherwise.
[3] This decision determines the accommodation issue.
[4] The material facts may be briefly stated. In February, 2016 the Grievor provided
the Employer with a letter from her doctor, Dr. Cooney, which stated that she was
being seen for “ongoing medical issues” and due to these medical issues she
was “unable to regularly make it into work prior to 9 a.m.”. The doctor
recommended that she be scheduled accordingly. The Employer complied with
this scheduling recommendation, but sought additional information as to the
nature of the Grievor’s medical restrictions. Repeated requests by the Employer
resulted in essence the same information being provided by the doctor, except at
some point Dr. Cooney indicated the Griever would be unable to regularly make
it to work before 9:15 a.m. and recommended she be scheduled accordingly.
Subsequent letters from Dr. Cooney also included the following statement (or a
variant of it): “Due to confidentiality, the nature of her medical issues will only be
released with a signed consent and for the appropriate reasons.” Ultimately,
after almost two years of attempting unsuccessfully to obtain additional medical
information, the Employer advised the Grievor that she would be required to
attend at work at her regularly scheduled time. The grievance which is the
subject of GSB File No. 2019-0272 followed.
[5] Having considered the representations of the parties, I provided the following
decision orally at the hearing:
I am satisfied the Grievor had a disability within the meaning of the Ontario
Human Rights Code. It does not necessarily follow, however, that she required
accommodation in her employment: not all disabilities require such
accommodation.
-3-
The duty to accommodate gives rise to mutual obligations. In order to fulfill its
duty to accommodate, an employer needs the cooperation of the employee, and
the employee is in turn required to cooperate. In order to be able to consider the
possibility of accommodation of a disability on a long term basis, an employer
requires sufficient information from an employee. That typically will take the form
of medical information about the nature of the restrictions the employee has as a
result of her disability. An employer is then obliged to provide reasonable
accommodation of those restrictions, if it can do so without undue hardship. This
determination lies with the employer, not the medical practitioner. Reasonable
accommodation is not necessarily the same as an employee’s preferred
accommodation.
In this case, the information provided to the Employer by the Grievor from Dr.
Cooney was insufficient. The recommendation that the Grievor be permitted to
commence work after 9 AM, without more, appeared to be a suggestion of a
specific form of accommodation or a statement of a preference on behalf of the
Grievor. The characterization of this recommendation as a “medical restriction”
does not make it so. The Employer’s follow up questions, for example with
respect to whether the recommended start time was in any way related to
commuting time, were entirely reasonable attempts by the Employer to
understand the nature of the Grievor’s medical restrictions, if any, so that it could
determine if and how the duty to accommodate was engaged. No material
additional information was provided in response to these questions despite
repeated requests. In these circumstances, I conclude the Employer did not
breach its duty to accommodate when it required the Griever to commence work
at her regularly scheduled time.
[6] Accordingly, the grievance which is the subject of GSB File No. 2019-0272 is
dismissed. The remainder of the matters will continue on dates already
scheduled.
Dated at Toronto, Ontario this 25th day of November, 2019.
“Ian Anderson”
_________________________
Ian Anderson, Arbitrator