HomeMy WebLinkAboutUNION-1994-07-06
JON 1 6 1994 I~
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IN THE MATTER OF AN ARBITRATION
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BETWEEN:
THE EASTERN ONTARIO HEALTH UNIT
-and-
THE ASSOCIATION OF ALLIED HEALTH
PROFESSIONALS: ONTARIO
RE:
POLICY GRIEVANCE - JOB POSTING
BEFORE:
HUGH R. JAMIESON, Sole Arbitrator
APPEARANCES:
MR. THOMAS A. STEFANIK, for the Employer
MS. SUE McCULLOCH, for the Association
HEARD:
At Cornwall, on May 31, 1994
DECISION:
June 7, 1994
(2)
This award deals with a policy grievance dated April 14, 1994
over an alleged improper job posting which was taken by the
Association of Allied Health Professionals: ontario (the
Association), against the Eastern ontario Health unit (the
Employer). The issue in dispute was set out in the grievance as
follows:
" The Employer has improperly posted a Health
Educator/Promoter position which provides for two(2)
offices."
The job posting in question, which was dated March 17, 1994,
called for the successful candidate to work three days a week at
Casselman and two days a week at Winchester. The Employer
apparently operates an office at each of these towns which are
located in Eastern ontario approximately 65 kilometers apart.
At the hearing into this matter which was held at Cornwall on May
31, 1994, it became readily apparent that the Association's
concern was the possible negative impact on benefits under the
current collective agreement which it claimed could result from
the Employer specifying two office locations on a single job
posting. While hours of work were mentioned as a possible problem
area, travel allowances were clearly the primary concern for the
Association. While the Association conceded that employees do
(3)
presently operate from more than one office and they do service
clients in more than one area, it took the position that the
collective agreement contemplates that each employee in the
bargaining unit be assigned a single work location or a "home
office". Any requirement to work at locations away from that
"home office" is compensated for under the hours of work and
transportation allowance provisions in the collective agreement.
According to the Association, if the Employer was permitted to
name two "home offices", complications could arise in calculating
the remuneration to which the employees were properly entitled.
To this end, the Association was prepared to provide me with
certain documents which purportedly set out some of the
Employer's policies pertaining to transportation allowances.
However, it decided to rely solely on the wording of the
collective agreement to make its point after the Employer raised
the issue of relevance considering that the instant grievance was
limited to the job posting. The Employer pointed out, correctly
in my view, that the single narrow issue before me was the
Employer's right or lack thereof to specify more than one office
as an employment location on a job posting. Depending on my
ruling on that issue, the Association would be free to bring
another grievance on any other alleged breach of the collective
agreement if and when the circumstances arise.
(4)
On the specific question of the job posting, the Association went
on to refer to several provisions of the collective agreement
where it claimed the wording clearly called for an interpretation
that a single employment location was intended. These included
Articles 3.02, 9.06(b), 9.07 and 16.01. For my purposes, I need
not reproduce all of those articles here, suffice it to say, with
the utmost respect, that I cannot read into these provisions what
the Association asks me to.
To begin with, there are no references to be found anywhere in
the collective agreement to a "home office". Further, while there
is no specific definition of "employment location" in the
agreement, it seems to me that the use of this term in Article
3.02 for example, cannot be read strictly in the singular as the
Association urges:
"3.02 An employee shall, at the time of hiring, be
provided with written notification of her job
classification, salary rate, and employment location as
well as any other conditions which may apply to her
employment together with a copy of the collective
agreement."
Emphasis added
In my view, in the absence of anything more definitive in the
collective agreement and, given that it is common practice for
employees in this bargaining unit to operate from offices in more
(5)
than one town as evidenced by the Association's own witness, Ms.
Leslee Brown, a Drug and Alcohol Addiction Worker, who spends
four days at Cornwall and one day at Alexandria on a regular
weekly basis, "employment location" in the context of this
collective agreement must taken to include a geographic area. At
the very least, it must surely mean the towns where the offices
are located from which employees are required to work.
with that in mind, the job posting requirements under this
collective agreement are set out in Article 9.06(a) :
"9.06(a) A job vacancy that occurs within the
bargaining unit shall be posted on designated bulletin
boards for a period of seven(7) working days for the
benefit of interested employees which shall occur prior
to external advertising. Applications received from
members of the bargaining unit shall be given due
consideration before the processing of other
applications."
Unlike many other collective agreements, there is nothing in this
agreement setting out what information a job posting must
contain. Nor is there anything that determines the source of the
information to be used in job postings, like approved job
descriptions for example. More importantly, there is nothing in
this collective agreement that can even vaguely be construed as
restricting management's right to determine the "employment
location" for the purposes of job postings. In short, I can see
(6)
nothing to support the Association's contention that for a job
posting, the "employment location" is somehow restricted to a
single office location.
In fact, I would go further and suggest that the Employer is
probably obligated to do what it did here, i.e., be up-front
about the geographic scope of the job in question. I base this on
the premise that notwithstanding the silence of the collective
agreement regarding the contents of a job posting, the process of
filling any vacancy must in any event be conducted in good faith
and within the accepted standards of fairness. This would include
in my view, a fundamental requirement that job po stings contain
ample accurate information regarding the applicable conditions of
employment and the necessary qualifications to allow prospective
candidates to rationally consider their options and to provide a
meaningful opportunity for them to apply for the job.
In the circumstances here, where the successful candidate would
be required to operate from more than one office as a condition
of employment, it seems to me that the Employer could be found to
be failing to meet its obligations vis-a-vis fair process if it
did not disclose this requirement on the job posting.
In light of these considerations and, taking into account the
aforementioned lack of restrictions in the collective agreement
(7)
on the Employer's right to determine the "employment location"
for the purposes of job postings, I am compelled to find that the
grievance must fail. It is therefore dismissed accordingly.
Dated this 7th day of June, 1994.