HomeMy WebLinkAboutUNION-1988-03-10
IN THE MATTER OF AN ARBITRATION
BET WEE N:
THE OTTAWA CIVIC HOSPITAll
The Hospital,
- and -
THE ASSOCIATION OF AllUIED HEAUTH PROFESSIONAliS:
ONTARIO
The Association.
And in the matter of policy grievances with respect to
certain non-registered pharmacists and physiotherapy residents.
BOARD OF ARBITRATION
I. G. Thorne, Chairman
Ronald leBlanc, Hospital Nominee
Sandra Nicholson, Association Nominee
APPEARANCES FOR THE EMPliOYER
Jacques A. Emond, Counsel
Pat Steward, labour Relations Officer
Ron Mills, Director, labour Relations
APPEARANCES FOR THE ASSOCIATION
Diane Nicholas, Counsel
Sue McCulloch, labour Relations Officer
Barbara Jovaisis, Pharmacy Representative
A hearing in this matter took place on March 21st, April
28th, May 9th, June 2nd and June 28th, 1988 at Ottawa.
r
(2 )
A WAR D
The association and the hospital are parties to a
collective agreement which governs the terms and conditions of
employment of pharmacists and physiotherapists, among others at
the hospital. This relationship has existed for some years and
through several renewals of the collective agreement. The two
renewals which concern us in this case are the agreement covering
the periOd from April 1st, 1983 to March 31st, 1984,and the one
relating to the period immediately following, April 1st 1984 to
March 31st, 1987. The association represented full-time
employees during the former term; part-time employees were
brought within the scope of the agreement during negotiations for
the 1984 to 1987 term.
The association has filed two grievances alleging that
the hospital has failed to apply the provisions of the
collective agreement to certain non-registered pharmacists and to
certain physiotherapists who were qualified but not licenced,
all of whom were said to fall within the bargaining unit. While
the grievances were framed as policy grievances, relief was also
asked for the individuals affected. The hospital objected at the
opening of the hearing that relief for individuals should not be
considered in the context qf a policy grievance. The hospital
also objected that the grievances were filed beyond the time
limits specified in the agreement. It then appeared that the
parties disagreed as to whether the timeliness provisions of the
1983-4 or the 1984-87 agreement applied to the grievances, these
provisions having been amended as the result of negotiations for
the more recent agreement. A further potential issue was whether
(3)
we should exercise our discretion to extend the time permitted
for the filing of the grievances if they should be found to have
been untimely.
The hospital's position that the grievances were untimely
came as a surprise to the association, which was not prepared to
deal with that issue or to call evidence in connection with it.
It was apparent from the parti es' open ing statements that the
issue would be an important one and the association then
requested an adjournment.
The board was of the view that,
although the objection might well have been anticipated, the
association was in fact taken by surprise.
As the situations
complained of in the grievances had all come to an end, and since
the evidence would still be available at an adjourned hearing, we
granted the requested adjournment.
When the hearing resumed
(from which point the association was represented by counsel)
e v ide n c e was he a r d bot h 0 n th e p r e,l i m i n a r y mat t e r san don the
merits,
the issues being somewhat interconnected and the
evidence on the preliminary matters being lengthy.
The fi rst of the two grl evances was dated November 3rd,
1986.
It alleged that two pharmacists who worked more than 24
hours per week had not been paid salary or
benefits, that the
employer did not remit union dues for them and that the posting
procedure
was
not
complied
with.
The
grievance
sought
compensation for the affected employees, compensation to the
association ~or dues, and declaratory relief. While the evidence
of the surrounding circumstances will be summarized later in this
award,
for the purposes of clarity the names of two non-
registered pharmacists and the periods during which they were at
(4 )
the hospital can be mentioned now. One was Ho luu, who worked at
the hospital on terms to be described more fully later, from May
26th, 1983 to June 14th, 1984.
From May 26th, 1983 until
February 15th, 1984 he worked less than 22.5
hours per week,
placing him outside the bargaining unit which
at the ti me
included only those working 22.5 hours or more per week. From
March 5th, 1984 onward he was paid.
The period over which the
association grieved was that between February 16th and March 4th,
1984, during which Mr. Luu worked more than 22.5 hours per week.
The other non-registered pharmacist was Sangeeta Srivastava, who
worked full-time without pay from June 17th until September 30th,
1985, after which time she was paid.
She bec ame a permanent
employee in June 1986. No posting was made for the position,
which she still holds.
The second grievance was dated May 20th, 1987. It
claimed that physiotherapists who 'were qualified but not licensed
had not been included in the bargaining unit, that the
association had not been provided with a job description or an
opportunity to negotiate salary, that the individuals involved
had not received salary or benefits and that the employer had not
remitted union dues. The grievance asked for complete redress,
including compensation for the individuals. affected and for the
association for dues. Again, the circumstances are important and
will be set out in due course.
Briefly, four physiotherapists
were said to be involved, all of whom had worked full-time for
certain periods:
Bozena Oleszkiewicz from June 10th to July
29th, 1985 and again from September 30th to November 8th, 1985;
Vera Forster from June 30th to October 31st, 1986;
Andrea
Labelle from January 5th to May 9th, 1987; and Catherine Webster
(5 )
from April 21st to August 14th, 1987.
The dispute over the timeliness of these grievances
centred on the wording of Article 23.4 as it stood in the 1983-84
agreement and as it was revised in the 1984-87 agreement:
(1) 1983-84:
Grievance - First Step
If an employee believes he has a grievance he must submit
it in writing and sign it and present it to his immediate
supervisor within ten (10) working days of the occurrence
otherwise all parties recognize that no formal grievance
exists. The immediate supervisor must convey his
decision in writing to the employee within five (5) days
of the receipt of the grievance.
(2) 1984-87
Grievanc - First Step
If an employee believes he has a grievance he must submit
it in writing and sign it and present it to his immediate
supervisor within ten (10) working days of the occurrence
giving rise to the complaint or from the date upon which
the subject matter of the complaint may reasonably be
deemed to have come to the attention of the employee so
affected, otherwise all parties recognize that no formal
grievance exists. The immediate supervisor must convey
his decision in writing to the employee within five (5)
days of the receipt of the grievance.
As will be seen, alternative submissions were made about
the applicability of other provisions in Article 23 and about the
applicability of Article 23.4 to policy grievances,
but the
provisions
set
out above are central
to the hospital's
preliminary objection. The hospital's position was that, at the
time of the filing of both grievances, the collective agreement
in effect was the 1983-84 agreement.
If that was the case, the
grievance with respect to the pharmacists was long out of time,
while the grievance with respect to the physiotherapists could be
timely only insofar as it concerned the situation of Catherine
Webster.
(We would think that that grievance was timely also
\ 0)
with respect to Andrea Labelle, given that Article 23.3 excludes
Saturdays and Sundays from the calculation of the time limit.)
If the wording of the 1984-87 agreement was in effect, however,
it might be that the grievances might be timely if they had been
filed within ten working days from the date on which the
complaint might reasonably be deemed to have come to the
association's attention.
It should be noted that no individual
has filed a grievance about the situations of which the
association has complained so that it is the state of knowledge
of those acting on behalf of the association which is material to
this issue.
At this point, therefore, we shall summarize the
evidence relating to the question of which collective agreement
was in effect and what was known by representatives of the
association from time to time.
Following
the expiry of the 1983-84 agreement on March
31st, 1984, the parties negotiated for a renewal.
The process
was lengthy, but by December, 1985 agreement had been reached on
all issues except salaries and vacation entitlement.
Those
issues were referred to a board of arbitration, chaired by
Maureen Saltman, pursuant to the Hospital Labour Disputes
Arbitration Act. An initial hearing was held on July 22nd, 1986
but the parties' submissions were not completed on that date.
Because of the time it would take to complete the hearing, the
board made an interim award on August 27th, 1986 under which
employees would receive rates of pay in accordance with the
hospital's final offer, expressly without prejudice to the final
disposition of the salary issue.
Earlier that summer there had been a discussion between
(7)
Sue McCulloch, the Executive Assistant of the association at
Ottawa, and Jeanett2 May, a Labour Relations Officer at the
hospital, about the proposed implementation of the 1984-87
agreement.
Specifically, Ms. May indicated to Mrs. McCulloch
that the hospital was planning to implement the new collective
agreement to the extent that agreement had been reached. A draft
of the agreement had been provided to the association in March,
1986 and on July 29th, Ms. May wrote to Mrs. McCulloch as
follows:
Enclosed please find the newly revised A.A.H.P:O
Collective Agreement for the term April 1, 1984 to March
31, 1987.
In order to expedite matters, if you would kindly sign
the document and, forward it back to Human Resources at
your earliest convenience. At that point, it will be
signed by the Hospital.
The agreement provided by Ms. May was signed on behalf of
the Association on or about August 5th, 1986 and was returned to
the hospital.
However it was not si gned by the hospital.
The
former Director of labour Relations had left the hospital at the
beginning of August and his successor, Ron Mills
joined the
hospital on October 1st.
Shortly after he arrived, Mrs.
McCulloch raised with him the question of the signing of the
co 11 ec t i ve agreemen t.
He discussed the matter with the Vice-
President, Human Resources. They decided that the hospital was
not prepared to sign a partly completed agreement and he advised
Mrs. McCulloch of this. Nonetheless, she continued to understand
that the collective agreement was to be implemented (except with
respect to the two issues which were before the Saltman board);
the hospital had not indicated that it would not implement the
agreement and she observed that the interim salary arrangement
(8 )
had been implemented even before the board had made its interim
award. From her point of view, therefore, the revised version of
Article 23.4 was in effect at the time of the filing of the two
grievances.
As it happened, the new agreement was not signed for
quite some time after the final award of the Saltman board was
issued on February 17th, 1987. Mr. Mills found himself virtually
alone
in
the
Labour
Relations
Department
following
the
resignation of Ms. May and the serious illness of his secretary.
He was not able to provide a draft of the new agreement to Mrs.
McCulloch until May, and it then turned out,that the parties were
not in agreement on the wording of provisions dealing with
vacation entitlement and retroactivity on vacations. The
disagreement was not resolved until October and
the agreement
was then signed.
We now turn to the facts surrounding the filing of the
two grievances.
Mrs. McCulloch testified that she became aware
on October 24th, 1986 of the situation giving rise to the
"pharmacy" grievance. Mrs. Srivastava had raised a question on
seeing a seniority list which had been prepared at some time
following the point
at
which she became a registered
pharmacist: a pharmacist who had started working at the hospital
after her starting date
had been pl aced ahead of her on the
seniority list. Her question had led
to a meeti ng with Mrs.
McCulloch and others at which the details of her situation came
out. Mr. l.:uu was also at the meeting and Mrs. McCulloch then
learned of his situation as well. The grievance was then filed.
Mr. Mills then asked for an extension of the time allowed for a
(9 )
response ln order that the hospital could investigate the
allegations. Shortly after that, Mr. Mills wrote to ask for the
names of the pharmacists and the time frame involved, observing
that the grievance did not provide these details.
In hi s 1 etter
he remarked, "I am assuming that the situations you are referring
to must have occurred fairly recently in view of the date of your
grievance."
A meeting to discuss the grievance took place in
February, 1987, when Mr. Mills asked Mrs. McCulloch why the
grievance was coming forward now as one of the situations
complained of dated back to 1984.
Mrs. McCulloch replied that
she had learned of it only recently.
In her testimony she
acknowledged that Mr. Mills had raised the question of timeliness
but she had not felt that the hospital was indicating that it
would deny the grievance on that basis.
There had been communications between the hospital and
the association in the past about both Mr. luu and Mrs.
Srivastava.
On May 20th, 1983 the manager of Industrial
Relations wrote to the then business representative of the
association (in part):
2. Pharmacy Intern. The hospital has made arrangement
with a Mr. Ho Luu for him to come on staff as a voluntary
Pharmacy Intern. Mr. Luu is a Registered Pharmacist in
Vietnam. He arrived here four years ago and became a
Canadian citizen. In order to qualify as a Registered
Pharmacist in the Province of Ontario, he must, get one
year's practical experience under the supervision of a
Registered Pharmacist in addition to supervision of a
Registered Pharmacist in addition to passing his written
requirements. His period of supervision must total one
year and Mr. Luu will be spending four hours a day at the
Civic Hospital and four hours a day at the Royal Ottawa
getting his training. It is hoped that Mr. Uuu will
start on Tuesday, May 24.
Mrs. McCulloch acknowledged that the association had been
(10 )
aware then that Mr. luu was working at the hospital without pay,
but she noted that he was initially working less than 22.5 hours
per week, placing him outside the bargaining unit, so that the
association could take no action.
On July 11th, 1986 the Director of Labour Relations wrote
to Mrs. McCulloch about Mrs. Srivastavas as follows:
"As per our conversation this will confirm that the
above-named employee will, on a without prejudice basis,
be placed on the second step of the Registered
Pharmacists salary scale retroactive to her obtaining
her license from the province. This action is being
taken due to the fact that she completed a year of
practical experience at the Civic in order to qualify
for her license and, the department feels this could be
analogous to the agreement we have reached re the
Pharmacy Resident."
While this letter was not in her files, Mrs. McCulloch
assumed that she had received it and noted that the letter gave
no indication that Mrs. Srivastava had worked without being paid.
Finally, with respect to the pharmacists, Mrs. McCulloch
agreed that the association had a staff representative in the
pharmacy department at all times and that the representatives
would likely know that Mr. Luu and Mrs. Srivastava were working
in the department without pay.
However no staff representative
had brought the situation to her attention and the hospital had
not advised the association when these individuals came on staff
within the bargaining unit.
Mrs. McCulloch sought to alert the members of the
bargaining unit to the issue raised in the pharmacy grievance.
In early December, 1986 she circulated an information package to
(11 )
them. Its purpose was primarily to inform them of the results of
negotiations for the incorporation into the bargaining unit of
employees who worked less than 22.5 hours per week and to advise
them of a meeting to hold a ratification vote.
However the
package also included a memo informing the members of the policy
grievance filed in connection with the Pharmacy Department. The
memo explained that "The department has hired non-registered
pharmacists on a "volunteer" basis to perform the complete job
duties of non-registered pharmacists. These pharmacists accepted
these working conditions in order to get the experience necessary
to write their jurisprudence exams." The memo went on to explain
why it was considered important to challenge the practice and it
concluded:
Although the Association is aware of this practice
occurlng in the Pharmacy, it is possible that similar
situations could be happening in other departments as
well. If you are aware of voluneers performing
professional services in your department (either past or
present) could you please inform your Staff
Representative.
With respect to the physiotherapists, Mrs. McCulloch's
evidence was that she became aware on May 12th, 1987 that
physiotherapists had worked at the hospital without receiving pay
or benefits.
She learned of this in a telephone conversation
with Mrs. Srivastava on that date. (She had called her to ensure
that she was aware that a meeting with management in connection
with the pharmacy grievance had been cancelled).
Following a
contact with the Canadian Physiotherapy Association, from which
she learned something of the terms on which some physiotherapists
must undergo a period of hospital residency, Mrs. McCulloch filed
the grievance with respect to the physiotherapists on May 20th,
1987.
As in the case of the non-registered pharmacists, the
(12 )
association had a staff representative in the Physiotherapy
Department at all times.
While Mrs. McCulloch did not know of
the presence of resident physiotherapists who received no payor
benefits, she acknowledged that the staff representatives would
know. The practice had never been reported to her even after the
memo of December, 1986 to her members.
The final factual circumstance to set out concerns the
terms on which the two pharmacists and the four physiotherapists
worked at the hospital.
There was one common factor in all of
the cases:
the requirement that a person who had attained some
degree of professional qualification outside Canada must
spend
some time at a hospital in Canada in order to obtain professional
status here.
In the case of the two pharmacists, while their
situations were not identical, it was a matter of spending a year
under the supervision of a registered pharmacist in a hospital
and to pass an examination in order to become registered
pharmacists in Ontario. In the case of the physiotherapists, all
of whom had qualified in other countries and some of whom had
considerable professional experience, it was necessary for each
to spend a period of time as a resident in a hospital under the
supervision of a licensed physiotherapist.
Essentially the
purpose of the residency was to permit the resident to
demonstrate her
skills to the standar-ds of
the Canadian
Physiotherapy Association in order to become licensed.
All of the individuals involved gave evidence, with the
exception of Mr. l.:uu. In each case the individual had approached
the hospital, or an approach had been made on her behalf, to
determi ne if the person coul d work at the hospital for the
required period.
(13 )
Applicants were told that there was no money
budgeted to pay them, with the variation that in the Pharmacy
Department it was indicated that payment would be possible after
a period of time.
The individuals agreed to work on this basis
(and in most cases at the hearing expressed their gratitude for
being enabled to do so).
It appeared that there was a mixed
practice at hospitals accepting residents in such circumstances,
some hospitals always paying such residents and others paying if
finances permitted. When Mr. luu and Mrs. Srivastava were later
paid,
it was at the rate established on a scale in the
collective agreement for non-registered pharmicists.
The pharmacy residents generally did not work alone,
until they became registered, but otherwise did much the same
work as those supervising them and worked
the same hours as
other pharmaci sts.
There was an element of training in their
work. The physiotherapy residents were less closely supervised,
although each was assigned to a licensed physiotherapist who
would review and co-sign her reports, and some were taught
procedures with which they had not previously been familiar. The
physiotherapy residents acquired their own caseloads of patients
and indeed were expected to handle at least 80% of the caseload
of , licensed physiotherapist in order to meet the requirements
of the Canadian Physiotherapy Association.
In dealing with
patients they were expected to identify themselves as clinical
residents and' they wore identification tags to this effect;
however we would not think that the meaning of the distinction
would be apparent to most patients.
The physiotherapy residents
generally conformed
to
the
Department's
dress
code
for
physiotherapists. The residents were expected to work the hours
(14 )
in effect in the areas in which they were placed, but from the
Department's poi nt of view they were free to take time off for
illness or for personal reasons. However residents who testified
on the point felt obliged to attend work work regularly and to
make up any days they missed. It was not the Department's policy
to use them to cover for staff who were absent, and the
Department
sought
to
cover
absences
and
vacations
with
temporaries or part-timers.
However there were occasions on
which residents replaced physiotherapists who were absent.
The Issue of Timeliness
As indicated at the outset, the timeliness of the
grievances was in issue. A fundamental issue, and one to which a
good deal of testimony was directed, was whether the version of
Article 23 which governed the situation was the one in the 1983-
84 or that
the 1984-86 collective agreement.
It was the
hospital's contention that the former agreement was the one which
was in effect when the grievances were filed in November, 1986
and May, 1987,
for the simple reason
that no new collective
agreement had replaced it. The union's view was that the parties
had decided that the provisions of the new agreement on which
they had reached agreement would be brought into effect leaving
open only the
two issues on which they disagreed.
It was. of
course open to them to enter into a new collective agreement in
respect of certain matters and to leave the items in dispute to
be governed by the provisions of the former agreement (or by the
terms of the interim award of the Saltman board) The question is
whether they did so. Mrs. McCulloch was no doubt led to believe
by the hospital's letter of July 29th, 1986, and by her
(15 )
conversation with Ms. May, that the hospital was prepared to
implement all of the items which had been settled:
that is the
only conclusion one can draw from the text of the agreement
provided by Ms. May in conjunction with her statements to r'irs.
11cCul1 och.
There was also evidence that certain of the newly
agreed provisions were implemented. But the hospital was not
bound to the course of action indicated by Ms. May.
It changed
its position and made it clear that it would not sign a new
agreement until all the outstanding issues had been resolved. At
that point it should have been clear that the parties were not in
agreement.
The remaining question on this point is whether, the on
the signing of the agreement in October, 1987, the new version of
Article 23.4 had retroactive effect.
Some provisions of the new
agreement were made retroactive expressly, but Article 23.4 was
not among them.
Nor was there evidence that the parties had
treated it as being in effect before the signing of the
agreement.
In 0 u r view
the general rule should apply that an
agreement takes effect upon executivn, )n the absence of a clear
stipulation to the contrary.
In the case of a provision as to
the
time
limits
for
filing
grievances,
the
retroactive
application of a new provision without any prior understanding
that this would be ~he case, could put in question the
disposition of some grievances already resolved.
We do not of
course say that there have been any such grievances. We simply
make the point that we would ~xpect the parties to consider the
possiole implications of a change of this sort and to agree
expressly that it was to be retroactive if that was their
intention.
(16 )
The union made the alternative submission that, whichever
agreement was in effect, the time limit establi shed in Article
23.4 did not apply to these grievances in any event as they were
pol i cy gri evances.
Counsel noted that Article 23.2 recognized
employee, group and policy grievances and suggested that there
was some latitude available to the union to decide in which form
a grievance should be brought.
In this respect she drew our
attention to the comments of the board in Ottawa Civic Hospital
and Associaiton of Allied Health Professionals:
Ontario
(unreported, May 1st, 1986 Emerich). Only an employee grievance
had to be commenced under Article 23.4 and thus, she argued, only
an employee grievance was subject to the time limits set out in
that article.
A policy grievance was to be launched under
Article 23.6, which imposed no time limit.
Counsel for the
hospital argued that that would be an absurd interpretation of
Article 23, which should be read as a whole.
The scheme of the
article was to establish a multi-stage grievance proce,ss whose
objective was to resolve disputes.
Policy grievances were
commenced at a higher level of official involvement but the whole
process was still to be started within the time limit in Article
23.4,
failing which the article stipulated that "...no formal
grievance exists".
As indicated above, we consider that Article 23 as it
appeared in the 1983-84 agreement is applicable.
The relevant
portions of it are as follows:
23.2 Types of Grievances
Complaints of the Hospital or of employees shall be
adjusted as quickly as possible. It is understood that
( 17)
an employee has no grievance until the matter has been
referred to the employee's immediate supervisor and an
opportunity been given to adjust the complaint. The
fOllt)l1ing types of grievances are recognized:
a) Employee Grievance: which shall be defined as a
complaint of an individual employee and shall commence at
Article 23.4.
b) Group Grievance:
complaint of a group
Article 23.5.
which shall be defined as a
of employees and shall commence at
c) Policy Grievance: which shall be defined as a
complaint of the Hospital or of the Association shall
commence at Article 23.6.
23.3 Time limit
Saturday, Sunday and paid holidays shall not be counted
in determining the time within which any step is to be
taken or completed in any of the steps of the Grievance
or Arbitration procedure. Time limits presently set
forth may be modified by mutual agreement in writing.
23.4 Grievance ~ First ~
If an employee believes he has a grievance he must submit
it in writing and sign it and present it to his immediate
supervisor within ten (10) working days of the occurrence
otherwise all parties recognize that no formal grievance
exists. The immediate supervisor must convey bsi
decision in writing to the employee within five (5) days
of the receipt of the grievance.
23.5 Grievance ~ Second Step
If an employee believes that his complaint has not been
satisfactorily adjusted at the first step level the
employee and the appropriate staff representative are to
request within five (5) working days an appointment with
the Department Head. The Department Head must convey his
decision in writing to the employee within ten (10)
working days of such a meeting.
23.6 ~ Grievance ~ Third i~~~
If the employee believes that his complaint has not been
satisfactorily adjusted by Management he may, together
with the Grievance Committee, submit the matter in
writing to the Assistant Executive Director (Personnel)
for consideration at a meeting of the Grievance Committee
with representatives of the Hospital which shall be held
within ten (10) working days after the written submission
and the Assistant Executive Director (Personnel) shall
render his decision upon the complaint with five (5)
working days after the date of the meeting.
(18 )
As the board observed in the Ottawa Civic Hospital Case
(supra) at page 5:
While the sorts of grievances are identified and a
corresponding procedure is assigned to each, the articles
do not contain any stipulation to the effect that the
procedures are mutually exclusive. There is no
elaboration as to the proper scope of each sort of
grievance. Once a particular format is chosen, the
Article merely dictates at which step of the grievance
procedure that sort of grievance should commence.
After a careful review of cases in the area, the board
found that there was no express limitation in the agreement on
the scope of a policy grievance and that the three types of
grievances recognized in the agreement were not mutually
exclusive. We agree with that analysis, and conclude that the
association has considerable latitude' in choosing the form in
which to bring a grievance.
It is not necessary in the present
case to consider how broad that latitude may be.
It does not follow that the time limit applicable to an
employee's grievance does not apply to a policy grievance. The
structure of Article 23 establishes a progression, starting with
a time limit for launching a grievance and following through a
series of time-limited steps. Each step refers back to the prior
step, which itself is dependent on a time limit, the effect being
to maintain the pressure to meet time limits throughout the
process so that the dispute will either be brought forward to a
resolution or, at some point, abandoned. We must determine what
effect on this process was intended by the stipulation in Article
23.2 (c) that a po1icy grievance was to "commence" at Article
23.6.
In our opinion, the intended effect is indicated by
Article 23.6 itself:
the matter is to be submitted directly to
(19 )
the Assistant Executive Director (Personnel) and there is to be a
meeting between the Grievance Committee and the representatives
of the hospital to consider it.
In other words, a policy
grievance is to be dealt with in the first instance by a senior
official of the hospital, and the involvement of lower levels of
supervision is eliminated. It is understandable that the parties
should wish to deal at a senior level with matters
of more
general interest than the cOlTIplaint of a single employee.
However the requirement that a policy grievance "commence" at
Article 23.6 does not suggest to us an intent to do more than to
raise the level of official involvement in a dispute.
It does
not suggest that the scheme of timely raising and resolution of
disputes was to be set aside.
In our view Article 23 does not
exempt policy grievances from the requirement of timeliness
(although it may be of course that some policy grievances will be
of a continuing nature so that they may be raised at any time
while the situation complained of continues).
While Article 23
is not ideally phrased, the applicable time limit must be that
set out in Article 23.4, after which "...an parties recognize
that no formal grievance exists.
It was also argued that these grievances were continuing
grievances and so could not be untimely.
It is sometimes
difficult to determine whether a grievance is truly of a
continuing nature,
the cases which have given particular
difficulty being those in which a single action, long since
passed, has a continuing effect.
That type of situation was
distinguished in Re Port Colborne General Hosoital and Ontario
Nurses' Association
(1986), 23 LA.C. (3d) 323 (Burkett), from
cases in which there are reCUi'"rent acts ilhich give rise to a
(20 )
renewed cause for complaint as long as they continue. The board
there had to consider whether an alleged improper exclusion from
the bargaining unit gave rise to a continuing grievance.
While
observing that the cases were not consistent in their treatment
of such situations the board commented, at p. 327-8:
...It is clear from a reading of the cases that the
question that must be asked is whether or not the conduct
that is complained of gives rise to a series of
separately identifiable breaches, each one capable of
supporting its own cause of action. Allegations
concerning the unjust imposition of discipline, the
improper awarding of a promotion or the failure to
provide any premium or payment required under the
collective agreement on a single occasion, while they may
have ongoing consequences, constitute allegations of
discrete non-continuing violations of the collective
agreement. In contrast an allegation of an ongoing
failure to pay the wage rate or any benefit under the
collective agreement or an ongoing concerted work
stoppage constitute al1egatfons of continuing breaches of
the collective agreement. In these cases the party
against whom the grievance is filed takes a series of
fresh steps each one giving rise to a separate breach.
In this latter type of case the time limits for the
filing of a grievance, apart altogether from any question
as to when damages commence to run, must be found to be
triggered by the breach closest in time to the filing of
the grievance.
The difficulty in this case is that, except for the
physiotherapy grievance which is timely with respect to one or
possibly two individuals, the actions of the hospital
were not
continuing in
their consequences or in the sense that a breach
continued up to the time
of the grievance. Each time a
physiotherapy resident or a non~registered pharmacist worked, it
might have been alleged that a violation of the agreement
continued as long as the individual remained at the hospital. On
the evidence, it is difficult to conclude that the presence of
these individuals had any effect on the status of other members
of the bargaining unit once they had left the hospital.
E ac h
(21 )
time one of them left the hospital any violation of the agreement
ceased. The most that can be said is that there may have been a
series of distinct violations, each of which may have been
continuing in nature but each of which (except the last) had
ceased.
There is a possible exception in the case of Mrs.
Srivastava who, it was alleged, obtained a permanent position
without its bei ng posted but we di d not understand that the
association was now seeking to have her position posted, or to
have the seniority list revised in consequence.
The association
made the further alternative argument
that the hospital had waived any right it may have had to object
to the timeliness of the grievances.
Although Mr. Mills had
questioned the timeliness of the pharmacy grievance when the
parties first discussed it, counsel urged that the hospital's
failure to raise the question again the course of the grievance
procedure must amount to a waiver:
the grievance had been
processed on its merits and the formal reply to both grievances
had dealt with the merits and had made no reference to any
irregularity in the filing of the grievance.
There were more
details which, in counsel's submission, supported the conclusion
that any irregularity had been waived: the hospital's first act
in the grievance process had been to ask for more time to look
into the matter and it was many months before the hospital
finally responded to both grievances;
and the associ ation had
presented evidence to show that the hospital's normal practice
was to object in writing at an early stage if it intended to rely
on an irregularity~ Counsel for the hospital argued that it was
sufficient for the hospital to raise the issue of timeliness in
the way Mr. Mills had at the outset and suggested that it had
(22)
been necessary for the hospital to ask for time to respond to the
pharmacy grievance, which lacked specifics.
Whether a procedural irregularity, such as the late
filing of a grievance, has been waived is a question of fact.
One would also think that waiver can take place at any time
during the course of the grievance procedure. Thus an objection
at the outset may very well be sufficient to put the other party
on notice unless the objecting party changes its position at a
later stage.
In determining this issue we must bear in mind how
the pharmacy grievance came to the hospital's attention. The
grievance which was filed lacked any indication of the time frame
in which the situations complained of had occurred and did not
name the employees invo1ved.
It was hardly surprising that the
hospita1 should ask for time to investigate. When the time frame
involved became apparent, one wou1d have to say that the delay in
filing a grievance - whatever the reason - was striking. One of
the alleged violations had ceased ~ore than more than two years
before the grievance was filed and the other was not recent. Mr.
Mills questioned this aspect and the parties can hardly have been
unaware that it was an issue thereafter.
Did the hospital then
waive its right to object by responding to the grievance on its
merits? We should not be quick to find that it did.
It is not
unreasonable that an employer should discuss the merits of a
grievance which is out of time in the hope of reso1ving it, whi1e
reserving its right to rely on an objection it had already made.
We are inclined to think that the rather slow processing of the
grievance in this case would not reflect anything more than the
pressure of work on Mr. Mi 11 s' department at the time, and
perhaps a feeling that a matter outstanding for so long was not
urgent.
(23)
Whatever the cause may have been we do not think that
the delay says anything about an intention on'the hospital's part
to waive its rights, nor do we find the evidence of the
hospital's usual practice helpful:
it might have been desirable
for the hospital to state its objection in a more formal way, but
its failure to do so does not indicate to us an intention not to
maintain its objection.
We come back to the obviously lengthy
gap between the events which were grieved and the filing of the
grievance. Both parties must have been aware of that problem.
In aTT the circumstances, we do not find that a waiver
has been made out.
This brings us to what we have found to be the most
difficult issue in this case: whether we should extend the time
for the filing of these grievances as permitted by Section 44 (6)
of The ~abour Relations Act. -That section reads:
Except where a collective agreement states that this
subsection does not apply, an arbitrator or arbitration
board may extend the time for the taking of any step in
the grievance procedure under a collective agreement,
notwithstanding the expiration of such time, where the
arbitrator or arbitration board is satisfied that there
are reasonable grounds for the extension and that the
opposite party will not be substantially prejudiced by
the extension.
An extension is necessary if the merits of the pharmacy
grievance are to be considered. It is necessary only with respect
to certain aspects of the physiotherapy grievance as that
grievance was timely so far as the situations of two employees
are concerned.
Specifically, the latter grievance has raised in
a timely way the issue of the status of those employees as
(2-4 )
members of th" bargaining unit. Accordingly we must deal with
that issue and with the parties'
submissions
about the
appropriateness of compensation for those employees. Should the
time limits for the filing of the other grievances be extended?
In approaching a problem of this sort, a number of cases have
relied on the considerations set out in:
Re
Becker Milk Co.
ltd. and Teamsters Union, uocal 647 (1978),19 LA.C. (2d) 217
(Burkett):
The exercise of the equitable discretion vested in an
arbitrator under s. 37 (5) [now s. 44(6)J of the Act
requires a consideration of at least three factors.
These are: (i) the reason for the delay given by the
offending party; (ii) the length of the delay; (iii)
the nature of the grievance. If the offending party
satisfies an arbitrator, notwithstanding the delay, that
it acted with due diligence, then if there has been no
prejudice the arbitrator should exercise his discretion
in favour of extending the time-limits. If, however,
the offending party hds been negligent or is otherwise
to blame for the delay, either in whole or in part, the
arbitrator must nevertheless consider the second and
third factors referred to above in deciding if
reasonable grounds exist for an extension of the time
1 i mi,ts.
It seems to us that the first of these factors wi 11 be
critical in this case. The essence of the union's justification
for the delay was that it did not know about the situations of
the six individuals whose work at the hospital gave rise to the
grievances.
The hospital's view is that if the union did not
know about them it should have known. The salient features of
the evidence in this area can be summarized.
The employees in
question were not advised of the existence of the union or of the
collective agreement. It is understandable that their coming from
outside Canada (apart from Ms. Webster who was returning to
Canada), their acceptance that their work was not to be paid, and
their consciousness that they needed to complete a stipulated
period
of
work
in
order
(25 )
to complete
their
professional
qual ifications, all may have contributed to their not inquiring
into rights they may have had under the agreement. The
association was not directly or formally advised by the hospital
of
the
presence
of
the
six
individuals.
However
staff
representatives of the association knew of their presence and
must have been aware of the type of work they were doing and the
hours they worked.
As well, officials of the association had
been made aware of the presence of Mr. !;uu and Mrs. Srivastava,
though not of the
critical facts which would have indicated to.
the association a possible violation of the collective agreement.
There can be no question that Mrs. McCulloch was prompt in
raising the alleged violation through grievances as soon as she
became personally aware of them.
What this issue seems to come down to is the extent to
which the association Should be affected with the knowledge which
the staff represe:ltatives, and indeed other's u'; it;:; ;;1e,llbers, had
of the presence and the work of the six individuals.
We do not
see this as a legal question, as would be the question of who may
speak for the association. Rather it is a practical one of the
effectiveness of the information-gathering activities of the
association through the various people responsible.
Senior
officials cannot be expected to know of everything that may
affect the association's interests and presumably one function of
the st~ff representatives is to inform the executive officers of
the association of possible violations, as well as to inform
individual employees of their rights.
Yet apparently no one
apart from the most senior officers of the association found
these situations worthy of inquiry.
Even when Mrs. McCulloch
(26 )
drew the nature of the problem, as the association saw it, to the
a:tenti on of all members of the bargai ni ng uni tin December,
1986, no further information was forthcoming about the problem.
One '/lay of viewing the difficulty before us is to observe that
Mrs. McCulloch did not know of the circumstances which prompted
the grievances, but it is also the case that others knew of them
and did not act. In our view that failure is significant.
We should also consider
the length of the extensions
which would be necessary to make these grievances timely. One of
the two situations covered by the pharmacy grievance had ceased
about two and a half years before the grievance was filed, the
other about a year before.
Under the physiotherapy grievance,
the two cases which were not current had been outstanding for
about six months and one and a half years.
We must consider
these delays not only ln the light of the reasons for them put
forward by the associ ati on but al so in rel ati on to the ten day
time limit set out in the collective agreement.
Finally we should remark that an issue the association
considers highly important, that of individuals apparently within
the scope of the bargaining unit working without payor benefits,
must be canvassed within the context of the physiotherapy
grievance.
In all of these circumstances we do not consider that
reasonable grounds have been shown for an extension, quite apart
from any question of any possible prejudice to the hospital. We
are
conscious
that
this
decision
precludes
an
award
of
compensation for certain of the individuals affected by the
grievances.
(27)
However the same time 1 imits appl i ed to them and
presumably the same reasons for the delay;
we say "presumably"
as the only
reasons put forward were for the failure of the
association to grieve.
For these reasons, we find that the pharmacy grievance
was out of time.
The physiotherapy grievance was timely to the
extent that it was raised by the situation of two physiotherapy
residents, Ms. Webster and Ms. Labelle.
(28)
The Merits of the Physiotherapy Grievance
It was the position of the association that the
physiotherapy residents (being for the purposes of this
arbitration Ms. Webster and Ms. ~abel1e) had substantially
performed the duties of physiotherapists at the hospital. The
work they had done was of the sort done within the bargaining
unit. Although they were engaged in meeting the requirements of
the Canadian Physiotherapy Association, the hospital controTTed
the assignment of work and shifts to them. The association also
maintained that the hospital, in making arrangements with
individuals for terms and conditions not authorized by the
collective agreement, had thwarted the union's exclusive authority
to bargain for employees. The hospital's view was that the
physiotherapy residents could not faTT within the scope
provisions of the agreement as they were not employees; they
were simply present in the hospital for work experience and
training. The hospital had not treated them as employees and did
not determine the duration or conditions of the relationship
which was determined by the Canadian Physiotherapy Association,
the hospital's role being to evaluate the residents for the CPA.
The hospital could not terminate a resident - unless perhaps her
evaluation was unfavourable. Counsel noted that this was not an
all-employee unit: Article 2.2 excluded certain employees whose
common characteristic was a lack of full qualification. While
physiotherapy residents were not among those listed, the intent
must have been to include in the bargaining unit only those who
were fully qualified to practise.
The hospital also took the position that, if there had
(29)
been a breach of the agreement, the associaition was estopped by
its conduct from complaining of it.
In failing to act in the
face of alleged breaches over a lengthy period the unit must be
taken to have aquiesced in them.
We can
reviewed the
deal briefly with the latter point.
leading arbitration cases dealing
Counsel
with the
principles on which an estoppel must be founded. One of these is
that there must have been a representation, made by the party
said to be estopped to the other party, and intended to be relied
upon, to the effect that it will not insist on the enforcement of
its
strict legal rights.
Silence in the face of a violation
may amount to a representation.
Mr. Emond relied in particular
on: ~ Consolidated-Bathurst Packaoinq utd. and International
Woodworkers .2.f. America, !'ocal 2-242 (1982), 6 L.A.C. (3d), 30
(MacDowell) and Re Vancouver Police Board and Vancouver Police
Union (1987),32 LA.C. (3d) 214 (Hope).
Common to those cases
was a situation in which union officials knew of an employers
practice contrary to a collectiv,e agreement - in 'the one case
involving the fictional resignation of summer students so that
they did not acquire seniority, in the other, a certain shift
system.
In this case we found that those who could bind the
association,
i.e., those who could make a representation
intending that the hospital rely upon it, did not know of the
hospital's practice of taking on physiotheripy residents without
pay. Other employees knew of it but we cannot find that their
inaction amounted to a representation by the association, for
whom they could not speak. The lack of knowledge of responsible
officers of the association is what distinguishes this case from
those mentioned to us. The association cannot be fixed with a
(30)
representation about a practice which it did not know about.
The next question we must examine is whether the
physiotherapy residents were "in the employ" of the hospital
within the meaning of Article 2.1 of the col1ective agreement.
The question of the status of a person as an employee arises most
often in the context of a suggestion that he may be an
independent or dependent contractor instead of an employee.
Cases which examine the status of a person whose presence in a
workplace has an educational aspect seem quite uncommon. However
one case in particular which was sited to us deals with the
issue: Vancouver General Hospital and Health Sciences Association
of British Columbia
(June 11th, 1981, unreported, ~abour
Relations Board of British Columbia). As it happens the decision
dealt with a situation very similar to the present one, in that
the individual in question was a physiotherapist, professionally
qualified in another country, who was required to work for a
period in a hospital in order to demonstrate her ability and so
meet the requirements of the Canadian Physiotherapy Association.
The
board
approached
the
issue
by
contrasting
the
physiotherapist's situation with that of the student practical
nurses whose status had been con'sidered in Hospital Employees
Union, ~ocal 180 and Cranbrook and District Hospital and Selkirk
Colleqe [1975] 1 Can. uBR 42. The student nurses had been found
not to be employees.
In finding that the physiotherapist at
Vancouver General Hospital was an employee, the board noted that
the direction and control of the individual was in the hands of
the hospital
rather than
an educational
body,
'hat the
physiotherapist did the same work as other physiotherapists at
the hospital (save for the need for her to be supervisee and
(J 1)
that the physiotherapist was working so that her skills could be
evaluated, rather than being trained.
The board found the
situation of the physiotherapist to be more like that of medical
interns, apprentices or articled law students than like that of
the student practical nurses considered in the Cranbrook case.
The board appeared to attach some importance to the fact that
there was a potential benefit to the employer (at page 13):
All of these positions have certain elements in common.
They all perform some useful work for the employer
although, perhaps initially, the work performed may be
unprofitable from the employer's point of view. All of
them involve a certain degree of learning and assessment
of the person in question, but inevitably, there is a
benefit to the employer over and above whatever immediate
work production is obtained. The additional benefit is
the training of future qualified persons who may benefit
this particular Employer or the industry in general.
We did not have evidence on the latter point and would
not assign it as much significance as appears to have been the
case in the Vancouver General Hospital case. In other respect"
however.. we find that decision persuasive. We would think that
the nature of the work done by, the physiotherapists in the
present case should be given considerable weight.
Each of them
spent the greatest part of her time at the hospital carrying a
patient load like any other physiotherapis~s.
The ~ oad was not
as heavy as that of a licensed physiotherapist but the practical
responsibilities were essentially the same. The supervision they
received was largely for the purpose of evaluation and was in any
case not close supervision.
We would attach rather less
significance to the fact that the physiotherapy residents were
not subject to the same absolute requirement to attend work as
the permanent physiotherapists:
as a practical matter and as
responsible individuals the physiotherapy residents were expected
(32)
to report regularly to the shifts to which they were assigned and
to treat the patients assigned to them.
It would be somewhat
artificial to regard them as free not to follow the rules of the
workplace.
The fact was that they di d fo 11 ow the rul es, as was
necessary for the system to function.
In a situation in which
"employee" is not defined in the agreement beyond the following:
1.1 (a)
"Employee" means an employee of the Ottawa Civic Hospital
for whom the Association is the recognized collective
bargaining agent,
we find the decision of the British Columbia Uabour Relations
Board
most
helpful
and
reach
the
conclusion
that
the
physiotherapy residents were "in the employ" of the hospital.
We must now consider whether they are within the scope of
Article 2.1,
2.1 The Ottawa Civic Hospital recognizes the Association
of Allied Health Professionals: Ontario, or its
successors, as the sole collective bargaining agent for
the persons described in the certificate issued by the
Ontario Labour Relations Board, May 18, 1976, which reads
as follows:
"All physiotherapists, occupational therapists,
pharmacists, and therapeutic dietitians in the
employ of the Trustees of the Ottawa Civic
Hospital in Ottawa, save and except supervisors,
persons above the rank of supervisor, persons
regularly employed for not more than 24 hours
per week [since amended by agreement of the
parties to 22.5 hours per week] and persons
covered by subsisting collective agreement,
or whether they are excluded by Article 2.2:
2.2 It is also agreed that persons while classified as
pharmacy residents, dietetic interns, dietitian
(3)
trainees, physiotherapy and occupation therapy junior
and senior interns and graduate students shall not be
included in the bargaining uiit.
On the face of it, "all physiotherapists" are within the
bargaining unit and the only exclusions relevant to physiotherapy
are "physiotherapy
.. .junior and senior interns and graduate
students".
It is not suggested that physiotherapy residents are
expressly excluded but that they should be by analogy as they,
like the other persons excluded,
are not fUlly qualified.
We
are not willing to extend the enumerated exclusions on the basis
of an analogy, at least in the absence of a much clearer
indication of the parties' intentions.
We note that not all of
the classifications included in article 2.1 are of fully-
qualified persons, as the inclusion of a scale in the agreement
for non-registered pharmacists indicates.
One can also observe
that most of the exclusions in Article 2.2 are of persons who are
not only not qualified but also only partly trained, the
evidence was that the physiotherapy residents were already
trained with only minor exceptions.
The result, must be a finding that the two physiotherapy
residents under consideration were within the bargaining unit.
It follows that, in making private arrangements with them with
respect to hiring and compensation, the hospital failed to
recognize the association as the sole collective bargaining agent
of these employees as stipulated by Article 2.1 (we should make
it clear that we do not find any evidence that the hospital was
in bad faith or that it deliberately violated the agreement. The
evidence suggests that the hospital acted at least as much to
assist the phYSiotherapists involved as to benefit the hospital).
(34)
We must consider what remedy, if any, is required beyond
the above declaration. In doing so we must bear in mind the
evidence that the practice ceased following the filing of the
grievance, pending the board's findings. To that extent the
objective of the grievance has been met. However the association
has also asked for compensation for it and the affected
employees. So far as the grievance is timely we consider
ourselves obliged to award compensation to the association for
dues owing and to the empJ'oyees in question for salary and any
applicable benefits (so far as the individual employees affected
by the policy grievance are concerned, we are content to fol1ow
the decision of Chairman Emrich between these parties mentioned
ear 1 i e r i nth i saw a r d) . W'e i nd i cat e d ear 1 i e r 0 u r vie w t hat the
grievance, to the extent that it concerned the situation of Ms.
liabel1e and Ms. Webster, was timely as a continuing grievance.
It was continuing in the sense that a fresh violation of the
agreement arose with every pay period. The matter could have
been grieved immediately after each pay period but was not. What
is appropriate in these circumstances is that there should be
compensation to the association and the two employees affected
from and after the pay period immediately preceding the filing of
the grievance, and we so award. Both employees should be paid at
the only rate applicable to them under the collective agreement,
namely the start rate for staff physiotherapi sts. We are aware
that the association took the position that the hospital should
have advised it of the intention to hire these employees, and
shoul d have proposed a rate of pay for them. However that was
not done. It may well be an appropriate course for the parties
to negotiate a special rate for such employees in the future.
(35)
We remain seized of this matter with respect to any
difficulties of implementation including any issue of the
calculation of compensation.
DATED at Kingston this 27th day of September, 1988.
.-"'
1L-- ~
.~ ~.. . . . . . . . . . . . . . . . . . . . . . . .
I. G. Thorne, Chairman
"Ron !!eBl anc"
I concur
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Ronald LeBlanc, Hospital
Nominee
"Sandra Nicholson"
Partial dissent attached
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Sandra Nicholson, Union
Nominee
IN THE MATI'ER OF AN APBITRATICN
BEl'W"EEN
OITAWA CIVIC H:lSPITAL
AlID
ASSCCIATION OF )'IT.T ;mn HEALTH ProCESSIONALS:
ONTARIO
IN TI-::E MATI'ER OF POLICY GRIEVANCE
-PHAR1Ac.{ & PHYSIOI'HERAPY VOlllNI'EEBS
PARTIAL DISENT
I have read the Award in the matter and find I must dissent
in prrt.
I concur with the findings as they relate to !'.s. Webster and
Ms. Labelle, and to =pa.''1.sation far than iIrlividually plus the
Ass=iation.
'Ihe fu.dings I must dissent from are as follow'S:
1. Timeliness:
a) Firstly, I would have found that the 1984-87
collective agreanent was in place for the pJrp:)se5
of the grievance proce:3.ure. On a review of the
evidence, Ms. McCulloch was in ];Ossession of a
written "promise" from the Hospital (in the p:rson
of Ms. J. May) as early as July 29, 1986 that the
Hospital would sign the revised collective
agreanent for' April 1, 1984 to March 31, 1987 ani
implement it. Further there was clear evidence
that certain clauses, includir.g the interim wage
rates, had already been implemented. 'Ihe
Association relie:3. on this written represe."ltaticn
and the action of implementation, and therefore
proferly COn:l.ucte:3. itself as though the agreanent
was in effect.
- Page 2 -
b) Waiver by the Hospital of its right to raise a
timeliness objection:
Mr. Mills only reference to the issue of
timelir>.ess was incorporated into his conversation,
in February, 1987 at the first meeting about the
grievance (4 rronths after the filing) when he
asked.: "Why are you raising the grievance row Whet,
the incidents go bac.\:. as early as 1984?" Ms.
McCullcch answ'ered that by sayi.."lg the Association
had only just became aware of the matter. Mr.
Mills admitted that was the only reference He made
to the issue of timeliness, ani tbat iran then on
the Parties dealt solely with the merits of the
grievances. On reviewing my notes of the
evidence, Ms. McCulloch did not at any time
ackr:owledge that Mr. Mills had thereby raised time
limits objection.
Therefore, I =uld bave fourrl (had such a finding
been required) tbat the H::>spital had waived its
right to object to the arbitrability of the
grievance based en time limits.
c) Section 44(6) of the Labour Relations Act.
In rrr:r view, the majority's finding, based on
length of delay being the =itical factor, was
wrong because it does not properly balance all the
factors of the case. Firstly, the nature of the
grievance is serious, and of great irn!;or--...ance to
the Parties. (Le.- recognition of the
Association as sole bargaining agent, and denial
of all prClllisions of the collective agreement to
certain individual employees). Secondly, the
delay, alth::lUgh obITiously len:rchy, was rot due to
lack of diligence, nor a cavalier flouting of the
- Page 3 -
c) . . . . . . . . .Continue:i
time limits; rather it was a clear case of the
Ass=iation's officer having absolutely IX) kr:owle:ige of tre
matters until they were raised as a result of CUl:rent
concerns (Le.- the seniority of Ms. Srivastava). Although
Ms. McCulloch acknowle:iged that Staff Reps in the
Department may have been aware of the presence of the
employees in question, the Hospital bad clearly refrained
fran prO\l'idin:l' any infonnation to t.'1.e Ass=iation or its
me:nbers about the status of these employees. The H:lspital
has an obligation under the established bargaining
relationship to inform the Association of relevant
activity, arrl in my opinion, its c:rnissicn in this case
requires it to shoulder as much reS];XJnsibility as the
Ass=iation for the ~ in Ms. McCulloch's knowle:ige of
the situation. Based on that, it is unfairly prejudicial
to the Association the.'l to bar it fran havirg its' FOlicy
grievance heard due to the delay in grieving.
Therefore, I =uld have founi that reasonable grounis to
extend the time limits did exist,and=uld have granted
such extension in light of the absence of any claimed
prejudice to the Hospital.
Therefore, in all the above areas, I =uld have founi the timeliness
cbjection to have faile:i. 'fuus, in my view, both FOlicy grievances
should have been heaJ:d on their merits, not just a FOsition of the
second grievance.
All of Which is resp;ctfully subnitte:i.
Date:i at Toronto on this 3rd day of Octdler, 1988.
),ft/l1~AA' 0tA,.JrMPn (tI/1
Sandra Nicholson, Union Nomin:e 1,