HomeMy WebLinkAboutTERRASSE-1996-16-04
IN THE MATTER OF AN ARBITRATION
BETWEEN:
EASTERN ONTARIO HEALTH UNIT
The Employer
- and -
ASSOCIATION OF ALLIED HEALTH PROFESSIONALS:
ONTARIO
The Association
AND IN THE MATTER of the grievance of Sophie Terrasse and a policy grievance, both
relating to placement on the salary grid.
Board of Arbitration:
I.G. Thome, Chairman
Robert M. Whittaker, Employer Nominee
Joe Herbert, Association Nominee
Appearances for the Employer:
Carole Piette, Counsel
David Marshall, Director, Corporate and Support Services
Jeanne Lamarche, Director, Home Care Program
Apoearances for the Association:
Sue McCulloch, Labour Relations Officer
Maureen Fraser, Labour Relations Officer
Sophie Terrasse, Grievor
A hearing in this matter commenced on January 26th, 1996, at Ottawa, Ontario.
2
PRELIMINARY AWARD
There are two grievances before us, a policy grievance dated January 12th, 1994, and the
individual grievance of Sophie Terrasse dated January 28th, 1994. Both grievances are stated in
the same way:
The Employer is not providing placement on the salary grid in accordance with related
experience. Without limiting the generality of the foregoing, the employer is not
recognizing related experience which is gained outside Canada.
Both grievances allege a violation of Article 20.01 of the collective agreement, of which
the following portions are relevant to the present matter:
Article 20 - Salaries
20.01(a) Salaries to be paid to employees and the classification of employees shall be
contained in Schedule "A" attached hereto and forming part of this Agreement;
(b) Starting salaries - Placement on the Grid:
(i) The Employer shall recognize related experience to the extent of one (1) increment
for two (2) years experience to a maximum of two (2) increments above the start rate...
The essence of the grievance of Ms. Terrasse is that, when she was hired by the Employer
in Apri11993 as a Speech Language Pathologist (non-accredited), she was placed at the starting
salary rate on the salary grid and thus no account was taken of her several years of experience as a
speech language pathologist in France. It is our understanding that the Association intends to call
3
evidence and to argue that the grievor's experience was "related experience" within the meaning
of Article 20.01(b) of the collective agreement.
At the opening of the hearing counsel for the Employer advised that the Employer took
the position that the interpretation and application of Article 20.0 1 (b), as it related to recognition
of experience gained outside Cansda, had been fully and :finally litigated in an arbitration between
these parties before a board of which Mr. Howard Brown was chairman. The award of that board
was dated November 22nd, 1994, and adjudicated the grievance of Pierette Guilbault, who had
been hired as an Occupational Therapist. Mr. Whittaker and Mr. Herbert were the Employer and
Union nominees then, as they are in the present case. After hearing from the parties'
representatives, we asked that they provide us with written submissions with respect to the issue
raised by the Employer. A tentative date was set for the continuation of the hearing in the event
that we should decide that the hearing should proceed.
Some additional facts, which appear not to be in dispute, should be set out before the
parties' submissions are considered. Following the grievor's hiring and placement on the salary
grid and the filing of her grievance, as noted above, the grievance of Ms. Guilbault came on for
hearing at arbitration. (It appears from the award in Ms. Guilbault's case that she had been hired
in July of 1991, and had filed a grievance in September 1992.) On February 9th, 1994, Sue
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McCulloch, Labour Relations Officer for the Association, wrote to the Employer's Director of
Corporate and Support Services in the following terms:
RE: Experience Recognition - Policy Grievance and Terrasse Grievance
Further to your letter of 1994 01 25 and our telephone conversation of February 7, 1994
this letter will confrrm the agreement of the Parties to hold these issues in abeyance until
the Guilbeault grievance is determined. You have indicated that the only reason Ms.
Terrasse was not given recognition for her experience for the purpose of placement on
the salary scale was because her experience was from outside Canada. This issue,
therefore, is exactly the same issue which forms the basis of the Guilbeault grievance.
I trust that I have presented our discussion accurately.
It appears, again from the facts as set out in the award in Ms. Guilbault's case, that Ms.
Guilbault had been employed before 1991 as an occupational therapist for eight years in Europe.
From January through April of 1991 she had been employed in Ontario, apparently in the same
capacity. The Employer had declined to recognize her previous experience outside Canada but
had recognized her experience in Ontario. At the time of her hiring Ms. Guilbault held a
certificate from the Canadian Association of Occupational Therapists.
In the Association's submissions to this board, Ms. McCulloch explained the writing of the
letter of February 9th, 1994, as follows:
Prior to the position that the Employer took at the Brown arbitration hearing, the issue in
dispute was clear and simple. Ms. Guilbault believed she should have been placed at
Step 3 on the grid because she had more than 8 years of experience as an occupational
therapist. The Employer's position prior to the hearing both verbally and in writing (page
5
2 Brown award) was that the reason for denying the credit for experience under the
collective agreement was a result of the fact that the experience was gained outside
Canada.
The position that the Employer's lawyer took at the hearing was totally different than the
employer's position taken prior to the hearing. At the hearing the reason for the denial of
credit was as a result of her not having been accredited in Canada prior to gaining the 8
years of experience in France.
The award of the Brown board concluded that the Employer had correctly applied the
terms of Article 20.01(b) in placing Ms. Guilbault on the salary grid. The following excerpts from
page 5 of the award indicate the board's reasoning:
... "related experience" as set out in Article 21.01(b) must be considered in relation to
that experience which is connected to the classification for the purposes of applying the
contractual requirements in a reasonable context. In so doing that must in the context of
this article, refer to the classification of Occupational Therapist set out in the salary scale
in Schedule A of the Agreement. To hold that classification requires accreditation in
Canada and presently in Ontario, but at the time of this grievance a certificate was issued
by the Canadian Association of Therapists which the grievor obtained prior to her hire by
the Employer.
We :find that it is the experience which relates to that classification which must be
considered by the Employer and that classification does not exist for the purposes of this
collective agreement without the certification required in this country. ...
***
In the foregoing circumstances, counsel for the Employer argued, as noted above, that the
interpretation and application of Article 20.01(b) as it related to the recognition of experience
gained outside Canada, had been fully and :finally litigated in the Guilbault matter. Counsel argued
6
that res judicata applied to arbitration proceedings, while observing that boards of arbitration had
talcen somewhat different approaches to the question. In that respect, counsel reviewed the
approaches taken in Re Pharma Plus Drugtnarts Ltd. and United Food & Commercial Workers.
Local 175 (1991), 20 LAC.(4th) 251 (Barton) and Re Victorian Order of Nurses CLanark
Branch) and Ontario Nurses' Association (unreported, June 10th, 1993, Emrich). Arguing that a
party should not be pennitted to reopen an earlier grievance by trying to bring a subsequent one
to argue the same issue on new facts, but facts which were essentially the same as those resolved
in the previous grievance, the Employer suggested that a party which believed that a decision was
wrong should more appropriately take the matter to judicial review - as the Association had
chosen not to do in the present case. Emphasizing that the parties were the Employer and the
Association, counsel referred to Re Loeb IGA Southside and United Food & Commercial
Workers International Union (1994), 39 LAC.(4th) 353 (Kilgour). With respect to the policy
grievance, the Employer asserted that the issue raised was identical to the issue considered in the
Guilbault grievance and argued that the Association should not have an opportunity to re-litigate
the same issue. With respect to the grievance of Ms. Terrasse, the Employer took the position
that the Association had agreed in its letter of February 9th, 1994, that the issue in the Guilbault
and Terrasse grievances was identical. Further, the Employer argued that the fact that Ms.
Guilbault was hired as an accredited Occupational Therapist while Ms. Terrasse was hired as a
non-accredited Speech Language Pathologist was a difference which was not substantial or
7
material.
The Association took the position that the grievance of Ms. Terrasse arose out off acts
and issues which were substantially and significantly different from those in Ms. Guilbault's case.
As will be apparent from the portion of the Association's submission reproduced above, the
Association considered that it had not agreed that the issue in the Terrasse and Guilbault cases
was identical, given the way it had been characterized by the Employer's counsel at the hearing of
the Guilbault matter. The Association also laid some stress on the fact that Ms. Terrasse had been
hired as a non-accredited employee, and argued that the award in Ms. Guilbault's case appeared
to turn on experience for the purpose of the classification in which the individual was placed;
since accreditation in Canada was not required for placement on the non-accredited scale, the
Association considered that Ms. Terrasse's experience outside Canada would qualify as "related"
for compensation purposes. The Association also argued that judicial review was not the
exclusive method of dealing with an award that a party believed was wrong, and further that the
Brown award resulted in a breach of the Human Rights Code in that it did not result in equal
treatment with respect to employment for foreign employees.
So far as the policy grievance was concerned, the Association asserted that that grievance
involved all classifications, some of which did not require accreditation.
8
***
It is fair to say that boards of arbitration have taken differing approaches to the extent to
which the doctrine of res judicata should be applied in arbitration proceedings. Taking the view
that we do of the individual grievance of Ms. Terrasse - that the nature of the dispute it raises is
different from that raised in the Guilbault case - it is not necessary to consider the doctrine as it
might apply to the grievance of Ms. Terrasse. However, we will have certain comments to make
about the doctrine in its application to the policy grievance, the nature of which is not entirely
clear to us at this stage.
The Terrasse grievance, of course, involves the same Employer and Union and requires an
interpretation of the same clause of the collective agreement as was in issue in the Guilbault case.
Ms. Terrasse, as did Ms. Guilbault, is seeking to have her years of working experience outside
Canada recognized for the purposes of placement on the salary grid, and has been denied that
recognition. What is different about this case - apart from the fact that a different grievor with a
different professional background is involved - is that the nature of the dispute raised in the
grievance appears to be a different one. The Guilbault case involved an occupational therapist
who held the necessary accreditation at the time she was hired. In placing her on the salary grid,
9
the Employer recognized only experience which she had gained as an occupational therapist
accredited in Canada. In :finding that the Employer had correctly applied the terms of Article
20.01(b), the board was of the view that only experience which related to the grievor's
classification need be considered and that the classification did not exist for the purposes of the
collective agreement without the certification required in Canada. The Terrasse grievance
involves a speech pathologist, who can be hired on one scale if accredited and on another scale if
not accredited. Ms. Terrasse was hired on the non-accredited scale. When account is taken of
this distinction between the two grievors' situations, it appears that there is scope for the
Association to argue that the experience which must be considered by the Employer, when
placing a non-accredited speech pathologist on the grid, should not be restricted to experience
following accreditation in Cansda. On this issue at least, we are not being asked to say that the
award in Guilbault was wrong, but that it did not adjudicate how a non-accredited person should
be placed on the grid.
We must consider whether the Association's letter of February 9th, 1994, should preclude
consideration of the Terrasse grievance. It seems clear from the text of the letter that the
Association understood, at the time the letter was written, that the Employer was denying
recognition for her experience only because her experience was gained outside Cansda, and that
Ms. Guilbault had been denied recognition for her experience on the same basis. The position
10
taken by the Employer at the Guilbault hearing was that Ms. Guilbault had been denied
recognition for some of her experience because she had not been accredited in Canada before
gaining it. As we have indicated, it is at least arguable that the same reasoning might not apply to
the placement of a non-accredited employee on the grid. In these circumstances we do not thinlc
it reasonable that the Association should be foreclosed by its statement that the two grievances
involved" exactly the same issue", based upon its understanding at the time the letter was written.
Different considerations may apply to the policy grievance. On the basis of the material
before us it appears that the situations of Ms. Guilbault and Ms. Terrasse were what gave rise to
the policy grievance. So far as Ms. Guilbault's grievance is concerned, it seems to us that the
parties have had their opportunity to litigate the issues raised in that grievance. The policy
reasons for declining to, in effect, rehear a grievance were summarized in Re Pharma Plus
Drugmarts (supra) in which Arbitrator Barton considered several meanings of the concept of res
judicata in civil proceedings. The following comments, at p. 253, are relevant to the Guilbault
grievance - if it is the Association's intention to seek a different outcome in Ms. Guilbault's case:
All of these doctrines have a number of different purposes. One of the major purposes of
them is to force parties to put their full attention to proper presentation of the first case.
They are not allowed to split up the case and have two tries at it. Another reason for the
doctrines is to prevent the possibility of inconsistent results in consecutive proceedings
involving essentially the same issues. Because a subsequent tribunal might hear
somewhat different evidence than the first, where the same issue is litigated twice there is
a possibility that the second result might not be the same as the first. This would make
the whole system look bad.
11
A further reason for the doctrines of res judicata is that people should be allowed to
forget about the past and get on with the future. They are entitled to know where they
stand with respect to a particular problem and once it has been resolved are entitled to
go on and use the resolution of it as a guide to how to conduct their affairs in the future.
It is worthwhile to bear in mind, however, that Arbitrator Barton considered that the area
of res judicata was one in which a board of arbitration had a discretion whether to hear a given
grievance or not.
Re Rainy River Val1ev Health Care and Ontario Nurses' Association (1985),20
L.A.C.(3d) 331 (Devlin), cited in Re Victorian Order of Nurses (supra), contains a most helpful
examination of authorities relevant to this area. Re Rainv River was quoted at some length in Re
Victorian Order of Nurses and it is unnecessary to do so here. It is sufficient to say that
Arbitrator Devlin's review identified and reconciled two arbitral approaches to res judicata. On
the one hand, " ... it would appear that where boards of arbitration have declined jurisdiction on
the basis of a prior award, this has resulted from a determination that the second grievance is in
substance the same grievance as previously advanced. In such cases, the board had pierced the
form in which the grievance has been presented and precluded one of the parties from
rearbitrating the initial grievance ..." (at p. 337). On the other hand are " ... situations which do
not involve one or other of the parties endeavouring to rearbitrate precisely the same grievance
but rather in circumstances where the second grievance may involve the same or a similar issue as
raised in an earlier grievance. In such cases the grievors may be different, the specific
12
circumstances giving rise to the grievance may vary or the grievances may have arisen at different
points in time ..." (also at p. 337). In the latter type of case, it seemed more appropriate that a
board of arbitration hearing a subsequent grievance should take the prior award into account and
regard it as highly persuasive unless convinced that the prior award was wrong.
Weare uncertain at this stage what may be involved in the policy grievance. If the
Association's purpose in bringing it forward is to obtain another adjudication on Ms. Guilbault's
placement on the grid as considered in the Brown award, we would respectfully decline to hear it.
If the Association's purpose is simply to ensure that the issues raised in the Terrasse grievance are
dealt with, we cannot see that the policy grievance will add anything to the situation. It may be
that there are circumstances of which we are not aware and we will therefore await what is said
about the matter at the hearing, but we would expect that any representations in that regard
should not delay the hearing of the Terrasse grievance.
With respect to the Terrasse grievance, we should briefly address certain submissions
made by the Association and not mentioned in this preliminary award up to this point. One such
question is the issue of movement from the non-accredited to the accredited grid, which the
Association has identified as an issue in the T errasse grievance. The Employer has responded that
that was not an issue when the grievor filed her grievance and thus is not a matter before us. It is
13
evident that the Association has certain submissions to make regarding the effect of the Regulated
Health Professions Act and regarding the effect which the Ontario Human Rights Code may have
on our decision. We mention these matters now simply to indicate that it has not been necessary
to .determine them in the course of this preliminary award and that, if they are raised at the
hearing, we will hear what the parties have to say about them.
Dated at Kingston, Ontario, this 16th day of April1996.
~.~-
LG. Thome, Chairman
I dissent in part
"R.M. Whittaker"
Robert M. Whittaker, Employer Nominee
I concur
"J. Herbert"
Joe Herbert, Association Nominee
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IN THE MATTER OF AN ARBITRATION
Between:
EASTERN ONTARIO HEALTH UNIT
"Employer"
- and -
ASSOCIATION OF ALLIED HEALTH PROFESSIONALS: ONTARIO
"Association"
Grievance of Sophie Terrasse and Association Grievance
BOARD OF ARBITRATION
Guy Thorne
Robert Whittaker -
Joe Herbert
Chairperson
Employer Nominee
Association Nominee
ASSOCIATION SUBMISSIONS
February 23, 1996
2
In "THE FACTS" the Employer states in
1. that the Grievor was placed on Step 1 in accordance with Article 20.01 (a)
and Schedule A of the Collective Agreement. The Association disputes this
aspect of the sentence as "a fact" as the position of the Association is that
her placement was not in accordance with the Collective Agreement, Health
Educator Promoter is also included on that salary scale.
2. "and any other relevant article" should be included
ADDITIONAL FACTS
1, The policy grievance was filed January 12, 1994. The period for which the
grievance, as a continuing grievance relates is from December, 1993
onward,
2. Prior to January 1, 1994, Speech Language Pathologists were not licensed in
Ontario. The Ontario Speech and Language Association was the provincial
body which was recognized (on a voluntary basis) as the body responsible
for accreditation and setting the standards of practise in Ontario.
Prior to January 1, 1994, Dietitians were not licensed in Ontario, The
Ontario Dietetics Association was the provincial body which was recognized
(on a voluntary basis) as the body responsible for accreditation and setting
the standards of practise in Ontario.
Prior to January 1, 1994, Occupational Therapists were not licensed in
Ontario. The Canadian Association of Occupational Therapists was the
federal body which was recognized (on a voluntary basis) as the body
responsible for accreditation and setting the standards of practise in Ontario.
3
Prior to January 1, 1994, Physiotherapists were licensed to practise in
Ontario under the Drugless Practitioners Act.
As of January 1, 1994 the Regulated Health Professions Act came into
effect. Schedule 1 of this Act lists the various self governing health
professions and names of the individual Health Profession Acts. .The
following Regulated Health Professions are currently in the EOHU - AAHP:O
bargaining unit:
Speech-Language Pathology
Dietetics
Occupational Therapy
Physiotherapy
The following are also included in the bargaining unit and are not included
under the Regulated Health Professions Act:
Addiction Workers
Prevention Workers
Speech-Language Pathologist (non-accredited) [pre 1994 term]
Social Worker (SSW & MSW)
Health Educator Promoters
The Ontario Association of Professional Social Workers is the provincial body
which is recognized (on a voluntary basis) as the body responsible for
accreditation and setting the standards of practise in Ontario. There is also a
voluntary College of Social Workers,
4
ASSOCIATION RESPONSE AND RESPONSE TO EMPLOYER'S SUBMISSION
The Employer's submission indicates that the Brown award:
as it relates to recognition of experience gained outside Canada has been
fully and finally litigated before the Board in the Guilbault matter. (p4)
The issue of recognition of out of country experience was fully dealt with in
the Brown award. (p8)
We believe this difference is not substantial or material and does not take
away from the arbitrator's findings that related experience arises where the
experience is gained in Canada. (p9)
Unfortunately, the Employer did not understand the award, Mr. Brown did not say
anything about experience gained outside Canada in a general sense. The fact is
he dealt exclusively with experience which was gained prior to accreditation in
Canada and presentlv in Ontario, In the Guilbault case, that experience happened
to be outside Canada. However, if someone were accredited in Ontario and
subsequently gained experience outside Canada, presumably that experience would
be credited. Likewise, where the classification had two scales, one of which did
not require accreditation (Terrasse) there is no suggestion in the award that the
experience outside Canada should be denied for credit, Furthermore the award,
because it was based on an individual grievance and individual facts, spoke not at
all to classifications for which there are no accreditations. It did also not deal with
classifications in the salary scale which do not require accreditation but where
positions in that job classification do (one of the Health Educator/Promoter
positions, Le, "nutrition field" requires a dietitian. Although a "Dietitian" is required
to be licensed, the classification of Health Educator Promoter on the salary scale is
not.)
Clearly the Employer thinks the issue is about experience outside Canada because
that is the only issue which was ever discussed between the Parties. The issue of
accreditation was a creation of counsel for the employer at the hearing before the
5
Brown Board and unfortunately it was the issue on which Mr. Brown based his
decision.
The Association submits that the Thorne Board should use its discretion not to
apply the doctrine of Res Judicata for the following reasons:
1. The facts giving rise to the prior case and the issues to be determined in the
Terrasse and Policy grievances are substantially and significantly different.
2. The issue of movement from the "non-accredited" to the "accredited" grid is
an issue in the Terrasse grievance which was not an issue in the Guilbault
grievance,
3. The grievances arose prior to and post the Regulated Health Professions Act
which fundamentally affects the application of the award.
4. The Association was not obligated to judicially review the Brown Award if it
felt it was wrong.
5. The Brown award violates of the Human Rights Code.
Based on the foregoing and supporting case law, the Association requests that the
Thorne Board hear the merits of the Terrasse and Policy grievances.
6
DIFFERENCES BETWEEN GUILBAULT AND TERRASSE GRIEVANCES
I Accredited vs Non-accredited Salarv Scale
In support of the res judicata, the Employer appears to rely heavily on the fact that
in February 1994 the Association wrote to the employer indicating that the issue in
the Guilbault grievance and the Terrasse and Policy grievance were exactly the
same.
Prior to the position that the Employer took at the Brown arbitration hearing, the
issue in dispute was clear and simple. Ms. Guilbault believed she should have been
placed at step 3 on the grid because she had more than 8 years of experience as
an occupational therapist. The Employer's position prior to the hearing both
verbally and in writing (page 2 Brown award) was that the reason for denying the
credit for experience under the collective agreement was a result of the fact that
the experience was gained outside Canada.
The position that the Employer's lawyer took at the hearing was totally different
than the employer's position taken prior to the hearing. At the hearing the reason
for the denial of credit was as a result of her not having been accredited in Canada
prior to gaining the 8 years of experience in France.
The Brown award on p 7 states:
We find that the Employer correctly applied the terms of Article 20,01 (b) in the
placement of the Grievor on the salary grid by properly crediting the grievor with her
experience at Paramed in Ontario prior to her employ at this Health Unit, We find
that is the extent of consideration required to be given by the Employer which need
not under these terms investigate experience prior to the grievor obtaining the
designation of Occupational Therapist and certified in Canada, "Whether that
experience contributed to or was the basis for the Canadian certification does not bear
on the Employer's responsibility to place employees on the salary grid under Article
20,01.
7
The Association expected the Board to answer the question "is experience gained
outside Canada related experience?"
The Brown Board did not answer that question. The Brown Board stated that
experience gained prior to Canadian certification is not related experience for
classifications requiring certification in Canada.
The award did not answer the question vis a vis the claim for experience of Sophie
Terrasse. She was hired as a "non-accredited" Speech Language Pathologist
which would appear to be exempt from the Brown decision. Although her
experience was also gained outside of Canada the operative part of the Brown
award appears to pivot on experience for the purpose of the classification as per
the salary scale. Since accreditation in Canada is clearly not required for placement
on the non-accredited scale, it would appear that her experience outside Canada
would qualify as "related" for compensation purposes. Despite 11 Y, years of
experience in France as a Speech-Language Pathologist, the employer placed her
on Step 1 of the Non-Accredited Speech Language Pathologist scale. Although
this action is consistent with the employer's previous reason for denying the
grievance, i.e, "it has been the practice of the Eastern Ontario Health Unit when
hiring personnel from outside Canada not to recognize previous experience that
may not meet the established Canadian standards", it is totally inconsistent with
the position it took at arbitration. At the arbitration hearing the Employer
specifically differentiated between salary scales where creditation is not required,
...such as for the Speech Language Pathologist (Non-Accredited) (p3 of award).
The Brown award echos this position,
II Occuoational Theraoist vs French Soeech Lanauaae Patholoaist
Another significant distinction between the Guilbault grievance and the Terrasse
grievance is the profession of each grievor. Ms. Guilbault is an Occupational
Therapist and Ms. Terrasse is a French Speech Language Pathologist.
8
The Eastern Ontario Health Unit provides services in the Counties of Stormont,
Dundas, Prescott, Russell, and Glengarry. The level of French as a first language is
significant in this region and in fact Ell of four of the 5 counties are designated
under the French Language Services Act as having a right to service in French (only
the Township of Winchester is designated in the County of Dundas). For all of the
professional services which are provided by the Health Unit, there is a level of
French competency which is required in order to deliver service to the French
population, The level of such competency differs in accordance with the nature of
the service.
The very essence of the French Speech Language Pathologist's position is the
French language. Whereas an Occupational Therapist may require competency in
French to communicate with the client, the Speech Language Pathologist has to be
able to deal with the mechanics of French speech. Ability to communicate in
French is not sufficient,
In Canada, the only places which provide Speech Language Pathology education in
French are Universite de Montreal, and the University of Ottawa. The University of
Ottawa graduated its first very small class last year (Ie 1 Y, years post the date of
the grievance), Besides Canada, French Speech Language Pathologists are
educated in France, Belgium and Switzerland. Of the 4 current French Speech
Language Pathologists at the Eastern Ontario Health Unit, 2 are from France and 2
are from Belgium.
If the Board is to consider whether experience from outside Canada, or experience
prior to certification in Canada or in Ontario is related, it must be done within a
context. When the job, by virtue of its very nature (the French language) is such
that it does not exist to a large extent in Canada as a whole, or in Ontario, surely
that restriction must impact on a decision as to what is "related". The Health
Unit's entire complement of French Speech Language Pathologists were educated
9
and had experience outside of Canada prior to their hire. The Association submits
that even if the Thorne Board upholds the Brown Award vis a vis Occupational
Therapists (and the Association does not suggest it should), the Board should not
apply the Brown award to French Speech Language Pathologists.
MOVEMENT FROM THE "NON-ACCREDITED" TO THE "ACCREDITED" GRID
Besides the issue of the differences between the Guilbault and Terrasse awards,
there are further issues as regards the Terrasse grievance, itself, The movement
from the "non-accredited" to the "accredited" Speech Language Pathologist scale
is also an issue.
As previously indicated Ms. Terrasse was hired as a non-accredited SLP and was
paid at Step 1 of that salary scale which continued beyond the date at which she
filed her grievance. In the fall of 1993, Ms. Terrasse filed her documents in order
to meet the requirements of the Regulated Health Professions Act and College of
Audiologists and Speech Language Pathologists of Ontario (CASLPO). In October
1994 the Employer received confirmation that she was certified by the CASLPO for
the year 1993-1994 and placed her on Step 1 of the Accredited Speech Language
Pathologist scale retroactively to January 1, 1994. It is the Association's position
that Ms. Terrasse should have been placed on the third step of the Speech
Language Pathologist (accredited) scale as opposed to the initial step where she
was placed.
REGULATED HEALTH PROFESSIONS ACT
At the time of the Guilbault grievance, the standard for accreditation as an
Occupational Therapist was eligibility for membership in the Canadian Association
of Occupational Therapists (CAOT).
10
Brown wrote (p5)
In so doing that must in the context of this article, refer to the classification of
Occupational Therapist set out in the salary scale in Schedule A of the Agreement.
To hold that classification. requires accreditation in Canada and oresently in Ontario.
but at the time of this grievance a certificate was issued by the Canadian Association
of Therapists which the grieyor obtained prior to her hire by the Employer.
(underlining added)
For the purposes of the Guilbault grievance an Occupational Therapist needed to be
eligible for membership in the CAOT in order to be an "Occupational Therapist"
under the terms of the collective agreement.
Since January 1, 1994, as a result of the Regulated Health Professions Act, in
order to be an "Occupational Therapist" under the terms of the collective
agreement the employee must hold a "certificate" from the College of Occupational
Therapists of Ontario (COTO).
Policv Grievance
The Policy Grievance states:
The Employer is not providing placement on the salary grid in
accordance with related experience. Without limiting the gerality of
the foregoing, the employer is not recognizing related experience
which is gained outside Canada.
As previously stated, at the time of filing the grievance, the Association believed
that the issue was related to credit for experience gained outside Canada. It
appears that the Brown award may have expanded the exclusion of related
experience from outside Canada to outside Ontario, The Association intends to
address these issues in the present hearing in the policy grievance.
Prior to the Brown award the employer did not recognize experience which was
gained outside Canada; however, it did recognize experience which was gained
inside Canada, albeit outside Ontario. Physiotherapists have been licensed in
11
Ontario for decades under the Drugless Practitioners Act which was repealed and
replaced by the Regulated Health Disciplines Act and Physiotherapy Act, Despite
the fact that a Physiotherapist who worked in Quebec would not have been
licensed as a Physiotherapist in Ontario, credit for experience would have been
given,
Again this approach is consistent with the employer's reasons for denying the
experience outside Canada but not consistent with their position at the hearing
which restricted credit for experience to experience gained after "accreditation".
"Physiotherapist" on the salary scale prior to 1994 referred only to physiotherapists
licensed in Ontario. If the situation of the Physiotherapists were analogous to the
Occupational Therapist, (who according to the Employer's position and the award
would be granted only credit for experience which was gained after "certification"),
the Physiotherapist should have been eligible for only credit for experience gained
after licensure in Ontario,
Now that the Health Disciplines Act is in force, the application of the Brown award
might limit credit for experience for salary purposes to experience gained after
joining the relevant college for those professions which are covered by the Health
Disciplines Act. It could follow that related experience outside Ontario would not
be given credit, The Employer has never applied credit for experience in this
manner and the Association believes it would be patently wrong to do so. The
concern of the Association; however, is that without further clarification, it is
conceivable that the Brown award could be so applied.
12
JUDICIAL REVIEW
The Employer has indicated that the proper forum is judicial review if a party
believes that an arbitral decision is wrong. The Association contends that judicial
review may be an appropriate forum in some cases; however, it is not the exclusive
method of dealing with an award that a party believes is wrong. The Association
submits that the best body to deal with labour issues is a body which is
constituted by or for labour. Although conceivably the Association could have
judicially reviewed the Brown award, related issues needed to be resolved which
would have required another board of arbitration anyway. The Association,
therefore, chose to use this board to resolve all these issues.
In Re Toronto Transit Commission and Amalgamated Transit Union, Local 113;
Saltman 21 LAC (3d), Ms. Saltman reviews the issue of Res Judicata. She differs
from Mr. Barton in that she supports the position of arbitrator Laskin in Re Brewers'
Warehousing Co, Ltd. and Local 278C, Int'l Union of Brewery, Flour, Cereal, Malt,
Yeast, Soft Drink & Distillery Workers of America (1954), 5 LAC 1797 (Laskin) (the
"Brewers' Warehousing" case) (p 1798) which states:
It is not good policy for one Board of Aroitration to refuse to follow the award of
another Board in a similar dispute between the same parties arising out of the same
Agreement where the dispute involves the intelpretation of the Agreement.
Nonetheless, if the second Board has the clear conviction that the first award is
wrong, it is its duty to detennine the case before it on principles that it believes are
applicable.
She goes on to say on pp 353/4
"the vast majority of cases, however, follow the policy of aroitral deference proposed by
then aroitrator Laskin in the Brewers' Warehousing case, supra, and adopted by Mr.
Justice Monnin in the Canada Safeway case, see Re Philips Cables Ltd. and U.E. W,
Local 510"
"In this board's view, this latter approach is more consistent with the role of labour
aroitration, which is concemed not only with the legal issues but with the practical
effect of the award; see JFW Weatherill, "The Binding Force of Arbitration Awards"
(1958), * LAC 323, Accordingly, although considerable deference ought to be given
to prior aroitration awards dealing with the same issue arising out of the same
13
agreement, arbitrators must be free to depart from prior awards which are clearly
wrong. However, such a departure is not to be taken lightly (particularly in view of
the potential disruption to parties faced with conflicting decisions) and an arbitrator
who embarks on such a route must be prepared to analyze the previous decision and
establish the basis for the departure: see Re Canadian Johns-Manville and Int'l
Chemical Workers, Local 346 supra,"
The Association submits that the Brown award is manifestly wrong.
The Brown Award states on p 5 & 6:
In the Ottawa Civic HOSlJital award the collective agreement specifically provided
consideration of related clinical experience in countries other than Canada as
distinguished from experience in this country,..
To provide that link of experience gained outside of Canada would require specific
language such as found in the Ottawa Civic Hosvital case,
According to Palmer, in Collective Aoreement Arbitration in Canada, clauses should
not be implied into an agreement.
"The implication of a clause into a collective agreement as a matter of law should be
restricted and only done under the clearest of circumstances. This is so, of course,
because the role of an arbitrator is to construe the agreement as it stands, not to
create a new one for the parties,"
The AAHP:O - EOHU collective agreement states:
20,01 (b) "The Employer shall recognize related experience to the extent of one
(1) increment for two (2) years experience to a maximum of two (2)
increments above the start rate,"
7.02
The Arbitration Board shall not have any authority to alter or change
any of the provisions of this Agreement, or to substitute any new
provisions in lieu thereof, or to give any decision contrary to the
express intent or terms and conditions of this Agreement, or in any
way modifY, add to or detract from any provision of this Agreement.
The Association submits that in order for the clause to exclude related experience
outside Canada, or related experience gained prior to certification, the oarties
would be obligated to include words to that effect in the collective agreement.
This type of restriction was apparent in the Ottawa Civic Hospital collective
14
agreement at the time of the Emrich award. If Mr. Brown's reasoning were correct,
that such language was necessary in order for credit to be given for related
experience outside Canada, or related experience gained prior to certification, it
would follow that in order for credit to be given for related experience outside
Ontario, or related experience gained prior to licensure in Ontario, additional
language needed to be incorporated. There was absolutely no dispute t.hat related
Canadian experience outside Ontario prior to certification or licensure in Ontario (as
required by Physiotherapists even at that time) applied. The arbitrator did not
construe the agreement as it stood; instead, in effect he created a new clause for
the parties.
Support for the Association's reasoning can be found in Re Abitibi Price (Fort
William Mill) and Canadian Paperworkers Union, Local 132 (1990), Unreported. On
pp 7 & 8 Arbitrator Burkett refuses to be bound by the previous award of Arbitrator
Phillips because he felt it was manifestly wrong. In the award, Mr. Burkett first
quotes the award of Arbitrator Phillips:
"I agree with the Union's statement that these are sophisticated parties with a lengthy
history of negotiating such articles. However, I would draw a different inference from
this fact than that stated by the Union. The fact that the parties were very careful to
specifY limitations on the application of Article 23.15(a) for sickness would lead one
to expect equal specificity with respect to mill accidents if mill accidents and sickness
were to be treated separately. If I were to accept the Union's interpretation, I would
have to agree that the Employer intended to grant vacation pay to employees on long
term absences due to mill accidents as well as those on shorter term absences, Even
though the matter at hand does not involve a long term absence, the interpretation I
placed on this article must apply consistently to situations of long term as well as
short term absences due to mill accidents.
If the parties had intended this Article to provide such a significant benefit as full
vacation pay for an unlimited period of time while employees are off work due to mill
accidents, it is likely the parties would have conveyed this fact in clear and
unequivocal language analogous to that which appears in Article 23,15 (b)."
l5
Mr, Burkett in addressing the Phillips decision states:
I am not persuaded by the reasoning set out above. Indeed, in my view, it is
manifestly wrong... Finally, the arbitrator reasons that if the parties had intended to
provide vacation pay to employee off work by reason of mill accidents "it is likely the
parties would have conveyed this fact in clear and unequivocal language analogous to
that which appears in article 23,15 (b)". However, there is a clear, unequivocal and
unrestricted exemption in article 23. 15 (a) for time off by reason of "mill accidents",
The language could not be clearer. .Article 23.15 (b) deals with the restriction upon
the exemption for sickness that is made in article 23.15(a). With all due respect; if it
had been the intention of the parties to similarly restrict the exemption for mill
accidents on would expect language "analogous to that which appears in article
23,15(b)", Absent any reference to "mill accidents" in 23,15(b) or absent a similar
clause dealing with "mill accidents" the correct inference is that the parties did not
intend to restrict the exemption for time off by reason of "mill accidents under
23.15(a),
As is the case in the award above, the original clause in the AAHP:O - EOHU collective
agreement is unrestricted. The Parties constructed the clause to clearly indicate what they
meant--if experience is related then credit applies,
HUMAN RIGHTS CODE
The Association alleges that the Brown Award's denial of compensation for related
experience because it was not gained after obtaining Canadian credentials breaches the
Ontario Human Rights Code. The application of the award does not give equal treatment
with respect to employment to foreign employees and the restriction is neither reasonable
nor bona fide in the circumstances. The Human Rights Code states:
Section 5 (1) Every person has a right to equal treatment with respect to employment
without discrimination because of race, ancestry, place of origin, colour, ethnic origin,
citizenship, creed, sex, sexual orientation, age, record of offenses marital status, family
status or handicap,
Section 6 Every person has a right to equal treatment with respect to membership in any
trade union, trade or occupational association or self-governing profession without
discrimination because of race, ancestry, place of origin, colour, ethnic origin, citizenship,
creed, sex, sexual orientation, age, marital status, family status or handicap,
Section 10(1) In Part I and in this Part,
"equal" means subject to all requirements, qualifications and considerations that are not a
prohibited ground of discrimination;
16
Section 11 (1) A right of a person under Part I is infringed where a requirement,
qualification or factor exists that is not discrimination on a prohibited ground but that results
in the exclusion, restriction or preference of a group of persons who are identified by a
prohibited ground of discrimination and of whom the person is a member, except where,
(a) the requirement, qualification or factor is reasonable and bona fide in the
circumstances; or
(b) it is declared in this Act, other than in section 17, that to discriminate because of
such ground is not an infringement of a right, .
(2) The Commission, a board of inquiry or a court shall not find that a requirement,
qualification or factor is reasonable and bona fide in the circumstances unless it is satisfied
that the needs of the group of which the person is a member cannot be accommodated
without undue hardship on the person responsible for accommodating those needs,
considering the cost, outside sources of funding, if any, and health and safety requirements, if
any,
(3) The Commission, a board of inquiry or a court shall consider any standards prescribed
by the regulations for assessing what is undue hardship,
In respect of the Brown Award, the Association alleges the award breaches the
Human Rights Code as a result of its determination that experience is related for
the purposes of compensation under the collective aareement pnlv if it occurs
subsequent to "accreditation in Canada and presently in Ontario",
The award states:
"The grievor claims however, that her past experience as an Occupational Therapist in France
should be considered to allow her progress to Groups 2, Level 3 at the higher salary rate,
There is no doubt on the evidence that the grievor had experience as an Occupational
Therapist in France according to her CV and the other documents which were filed and there
is no doubt as to her qualification for that classification, That however is not the issue which
is restricted to the detennination of what the Employer must consider in placing the grievor on
the salary grid pursuant to the specific tenns of Article 20.01 (b),
"The grievor's experience in France while significant in the grievor's ability to obtain the
Canadian qualification it was gained outside of Canada and was not related to the
classification in this agreement which requires creditation in Canada." (P6)
"We find that the extent of consideration required to be given by the Employer which need not
under these tenns investigate experience prior to the grievor obtaining the designation of
Occupational Therapist and certified in Canada,"(p7)
17
Under Section 5 (1) "Every person has a right to equal treatment with respect to
employment without discrimination because of race, ancestry, place of origin,
ethnic origin, and citizenship. Under the terms of the collective agreement,
employees are entitled to increased compensation of up to 2 steps on the salary
scale if they have related experience. The arbitrator concedes "there is.no
doubt...that the grievor had experience as an Occupational Therapist in France,.."
His sole reason for denying equal treatment under the collective agreement was a
result of this experience having been gained outside Canada, prior to her
certification in Canada.
Section 11 of the Human Rights Code makes provisions for constructive
discrimination. The Brown award did not state that the claim for related experience
was not given because of the grievor's race, ancestry, place of origin, ethnic origin,
or citizenship but because the experience was gained prior to Canadian creditation.
The Association contends that the arbitrator's basis for denial "results in the
exclusion of a group of persons who are identified by a prohibited ground of
discrimination and of whom the person is a member". In other words, the Brown
award sets up a qualification for claiming related experience which excludes foreign
employees in general and Ms. Guilbault in particular.
Notwithstanding that a constructive discrimination is prohibited, the HRC makes
exceptions where, the requirement, qualification or factor is reasonable and bona
fide in the circumstances.
Is the denial of experience gained prior to Canadian creditation reasonable and bona
fide in the circumstances? The Association suggests looking at the practices of the
professional bodies who are likewise covered under section 6 of the HRC to
establish whether they categorically deny recoginition of experience from outside
Canada.
18
The practices of the Canadian Association of Occupational Therapists (as an
occupational association) and the College of Occupational Therapists of Ontario (as
a self-governing profession) are covered by Section 6 of the HRC, As a minimum
threshold for determining eligibility for practice in Canada/Ontario, the applicant
must be eligible for membership in the professional organization of the country in
which she is/was practicing. Both these Canadian organizations investigate the
educational systems and experiential requirements for eligibility in occupational
therapy organizations in other countries to determine if such requirements meet
those of the Canadian system. Once the professional body of the country of origin
has passed that threshold, the CAOT and/or COTO further require the successful
completion of a Canadian examination to ensure that the individual meets the
standards of Canada/Ontario.
The Association contends that the professional bodies meet the obligations of the
Human Rights Code. They have established standards for Canada/Ontario and
subsequently investigate and rate the educational and experiential standards of
applicants from other countries as a basis for determining eligibility for professional
status. In the case of Ms. Guilbault, they determined that her educational and
experiential credentials were sufficient to grant her membership in CAOT (and
subsequently COTO).
In contrast the Brown award provides no investigation and evaluation for
determining "related" experience. All experience is arbitrarily quashed for
compensation purposes if it is gained prior to certification.
The Brown award determined that under the terms of the collective agreement an
"occupational therapist" does not exist for the purposes of this collective
agreement without the certification required in this country. In fact the term
"occupational therapist" was not a protected term prior to January 1, 1994
although for the purposes of the salary scale of the Collective Agreement the
19
Association agrees that it implies "eligible for certification by CAOT". The
Occupational Therapy Act which went into effect January 1, 1994, states:
1 In this Act,
"College" means the College of Occupational Therapists of Ontario;
"member" means a member of the College
7 (1 ) No person other than a member shall use the title "occupational therapist, a variation
or abbreviation or an equivalent in another language,
(2) No person other than a member shall hold himself or herself out as a person who is
qualified to practise in Ontario as an occupational therapist or in a specialty of occupational
therapy.
The purpose of the Health Disciplines Act and Occupational Therapy Act is to
protect the members of the public in Ontario; they were not established to protect
the profession, These Acts protect the public served by the Eastern Ontario Health
Unit insofar as they require. Occupational Therapists to be members of their
college, the body which is responsible for the development, establishment and
maintenance of standards for the profession in Ontario. The Association agrees
that in order to be placed on the "occupational therapist" salary scale, a current
incumbent would be required to be a member of the College; however, it is
unreasonable to extrapolate that in order for related experience to be valid, it must
be gained subsequent to such membership,
The responsibility for professional standards and hence "accreditation" is politically
determined, In Canada it is a provincial responsibility. Other countries have other
political boundaries. The practice of Occupational Therapy is similar regardless of
location; however, the jurisdiction of related bodies and laws vary according to
locale. There is clearly no need for an occupational therapist to have a certificate
of competence from the COTO to practice occupational therapy in France. The
public in Ontario is not in the least jeopardized when an occupational therapist is
practicing in France.
20
The experience which Ms. Guilbault gained as an occupational therapist working in
France was relevant for gaining the credentials required to practice in Ontario. It
assisted the Occupational Therapist to be more proficient in her profession. It was
a benefit to the patients whom she treated, It was germane to the amount of
direct supervision the Employer was required to provide. The only purpose for
which the experience had no value, as a result of the Brown award, wa;:; for the
purpose of compensation under the collective agreement.
Was the denial of credit for experience gained prior to Canadian creditation
reasonable and bona fide in the circumstances? The Association submits it was
not.
In the result, foreign employees were not given equal treatment with respect to
employment without discrimination and the Brown award attempts to legitimize this
discrimination.
~;;..
21
CONCLUSION
In summary the Association requests that the Board exercise its discretion not to
apply the doctrine of res judicata,
1. The facts giving rise to the prior case and the issues to be determined in the
Terrasse and Policy grievances are substantially and significantly different.
The Guilbault grievance involved an "accredited" occupational therapist; the
Terrasse grievance involves a "non-accredited" French Speech Language
Pathologist. The policy grievance involves all classifications, some of which
do not require accreditation.
2. The issue of movement from the "non-accredited" to the "accredited" grid is
an issue in the Terrasse grievance which was not an issue in the Guilbault
grievance.
3. The grievances arose prior to and post the Regulated Health Professions Act
which fundamentally affects the application of the award.
4, The Association submits that the Brown award is manifestly wrong;
however, it was not obligated to judicially review the Brown Award. The
Association submits that the best body to deal with labour issues is a body
which is constituted by or for labour.
5. The Brown award violates of the Human Rights Code.
The Association further requests that the Board hear the merits of the Terrasse and
Policy Grievances,
All of which is respectfully submitted.