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HomeMy WebLinkAboutElaiho 22-01-25 IN THE MATTER OF AN ARBITRATION BETWEEN: CENTRAL WEST SPECIALIZED DEVELOPMENTAL SERVICES (The “Employer”) - and - ONTARIO PUBLIC SERVICE EMPLOYEES UNION, Local 249 (The “Union”) AND in the matter of an individual grievance. ARBITRATOR: William A. Marcotte APPEARANCES: FOR THE EMPLOYER: P. Pengelly, counsel C. Lee, HR consultant J. Tella, stu.-in-law M. Rolston, CWSDS D. Batson, CWSDS T. Britton-Kennedy, CWSDS D. Price, RSW J. Currie, CWSDS P. Meghnath, physiotherapist FOR THE UNION: M. Singh, counsel J. Letton, counsel E. Elaiho, grievor Hearings held in Oakville on March 11, 2020, and by videoconference on October 21 and November 30, 2020, January 13, July 16, October 18 and December 13, 2021. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 2 AWARD In its grievance dated December 18, 2017, the Union claims that Mr. E. Elaiho (the “grievor”) was unjustly discharged. The Employer contends it had just cause to dismiss the grievor as indicated in the December 15, 2017 letter of dismissal under the signature of the grievor’s area manager, Ms. Dede Batson, as follows: You have been on a paid suspension since September 22, 2017 while the police conducted their own investigation. CWSDS was unable to commence our internal processes and investigation until the completion of the police investigation and we subsequently met with you on November 27, 2017. Our investigation has now been completed and our findings were as follows: 1. The individual “AR” can be seen on camera throughout the morning, and just prior to the outing with no visible markings on his inner thigh. 2. Multiple fresh bruises that appear to be caused by pinching, can be seen on AR’s inner left thigh upon return from the outing. 3. You were the only employee that [sic] was alone with AR during the time that the bruising could have occurred. 4. You were sitting on the right side of AR in the van, which would give you the opportunity to reach over and pinch the inside of his left thigh. 5. We can observe your co-workers on camera having a discussion about the fact that you were confronted about the bruising and admitted that you “did some of it, but not all of it”. When questioned about this during our investigation, you did not deny that this conversation had occurred by stated that you “could not recall”. Based on a balance of probabilities, we believe that you are responsible for the bruises found on AR. This amounts to abuse of a client and violates several of CWSDS [policies] including but not limited to: Abuse of Individuals, Code of Ethics, Standard of Conduct, Rights of individuals Receiving Supports/Services through CWSDS and Health and Safety Responsibilities. Based on all of the above there has been an irreparable breach of trust and as such, we wish to inform you that your employment with CWSDS is terminated for just cause effective immediately. The relevant provision of the collective agreement under which the grievance arises is as follows: Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 3 12.01 The Union recognizes that the management of the Organization and the direction of the working force are fixed exclusively in the Organization and shall remain solely with the Organization. Without restricting the generality of the foregoing, the Union acknowledges that it is the exclusive function of the Employer to: … (b) Hire, discharge… and suspend or otherwise discipline Employees for cause, provided that … a claim that an Employee has been unduly discharged or disciplined may be the subject of a grievance and dealt with in accordance with the Grievance Procedure; The parties submitted the following Agreed Statement of Facts: 1. Central West Specialized Developmental Services (hereinafter “CWSDS” or the “Company”) and OPSEU, Local 249 (hereinafter the “Union"; together the “Parties”) have agreed to stipulate to facts and documents in relation to the disposition of certain aspects of the dispute between the Parties concerning the termination of Edobor “Eddy” Elaiho (the “Grievor”) employment effective December 15, 2017 (the “Termination Date”). 2. The facts stipulated below and the documents attached hereto are deemed true subject to any submissions the Parties wish to make with respect to relevance or weight. 3. Although the Parties have agreed to the facts set out below and the documents attached hereto, they do not agree that all facts set out below and documents attached hereto are rel evant to the issues in dispute. 4. Notwithstanding the foregoing, the Parties are permitted to call viva voce evidence to add, clarify or supplement any facts or documents. The Grievance 5. CWSDS and the Union are party to a collective agreement with an effectiv e date of April 1, 2018 (the “Collective Agreement”). 6. On December 18, 2017, the Union filed Grievance No. 2017 -0249-0025 (the “Grievance”) with CWSDS in relation to the termination of the Grievor’s employment. (See Book of Documents at Tab 2). Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 4 7. Specifically, the Grievance states as follows in respect of the issue in dispute: “I am grieving that the Employer is in violation of Article 3 or any other Article of the Collective Agreement or Legislation that may pertain to this matter." 8. The Grievance seeks the following remedy “that I be reinstated into my position and all money lost be reimbursed. I be made whole." The Grievor 9. The Grievor commenced his employment with CWSDS on or about January 30, 2017. As of the Termination Date, the Grievor had 10.5 months’ service with CWSDS and was 28 years old. 10. At CWSDS, individuals with extremely complex needs and high behaviour challenges, including some with medical and aging needs, live in residential houses and receive care and support in their daily living activities. 11. CWSDS has policies and procedures in place to ensure the safety and wellbeing of individuals and all employees are expected to uphold these policies. Upon hire, CWSDS employees are required to review and sign an acknowledgment of the expectations and policies, including the Code of Ethics, Standards of Conduct, Abuse of Individuals, and Respectful Intervention. These policies are attached hereto (see Book of Documents Tabs 3 – 7). 12. At all relevant times during his employment, the Grievor was subject to and aware of CWSDS’ policies and procedures. During the course of his employment with CWSDS, the Grievor signed off on CWSDS’ Policies and Procedures manual, confirming that he read and understood the same. Copies of these signed acknowledgements dated January 30, 2017 are attached hereto (see Book of Documents Tab 8). 13. As of the Termination Date, the Grievor was employed by CWSDS in the full-time bargaining unit position of Residential Support Worker II in House 6. A copy of the job description for Residential Support Worker (RCII) is attached hereto (see Book of Documents Tab 10). 14. House 6 is one of CWSDS’ residential homes located at 53 Bond Street, Oakville. House 6 is considered a behavioural home where individuals require a higher degree of care and supervision by staff. At the time of the Grievance, House 6 housed individuals who received 24-hour supervision based on their individual care needs. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 5 15. Each individual who resides in House 6 has a Behaviour Support Plan (“BSP”) which is developed by CWSDS’ clinical team which can include physicians, behavioural therapists, clinicians and other medical professionals, and includes information about target behaviours related to the individual and the corresponding reaction that staff should demonstrate. A copy of the BSP related to one individual identified by the initials “A.R.” who resides in House 6 is attached hereto (see Book of Documents Tab 21). 16. A.R. has been supported by CWSDS since on or about April 2014 and has resided in House 6 since this time. Before coming to CWSDS, A.R. resided at another organization. A.R. has both intellectual and physical disabilities and relies heavily on CWSDS staff for daily living activities. 17. All employees who work in House 6 are required to complete a general orientation of the house, including a review of policies and procedures related to House 6 and the BSPs of each individual who resides therein. In this regard, the Grievor completed his orientation of House 6 during the week of February 3, 2017 (see Book of Documents Tab 11). Incident Leading to Termination 18. On September 21, 2017, the Grievor was working in House 6 with four (4) other employees: Deneka Price (“Price”), Kevin Muzangaza (“Muzangaza”), Tania Guthrie (“Guthrie”) and Alicia Popali (“Popali”). A copy of the shift report from September 21, 2017 is attached hereto (see Book of Documents Tab 12). 19. At approximately 11:30 am, CWSDS staff prepared the individuals for an outing to pick up supplies for the home. Before leaving for the outing, Popali showered A.R. and changed him from pants to shorts. Price provided assistance to Popali during this process. There were no marks observed on A.R.’s legs at this time. 20. Two vehicles were used for this outing. The Grievor, Popali, Muzangaza and three (3) of the individuals including A.R., rode in the first vehicle. Muzangaza was the driver, Popali sat in the passenger seat, and the Grievor sat in the middle seat beside A.R.. The two other individuals sat in the back row behind the Grievor. Price and Guthrie rode in the second van along with the other two individuals. 21. During the outing, they stopped at Walmart, TD Bank and IKEA. When they arrived at IKEA, the vans were parked. Guthrie and Popali went inside. The Grievor, Muzangaza and Price remained with the individuals. While parked, Muzangaza exited the vehicle to speak with Price. During this time, the Grievor remained alone in the vehicle with the three (3) individuals. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 6 22. At approximately 1:30 pm, they returned to House 6 and A.R. stayed in the kitchen and subsequently went to the washroom. Shortly thereafter, Price went into the washroom and observed red marks on A.R.’s inner left thigh. An incident report and body check form was completed by Popali to document these markings (see Book of Documents Tabs 13 - 14). 23. At approximately 3:00 pm, Jackie Currie (“Currie”), Residential Services Manager, arrived at House 6. Currie spoke to Price and Muzangaza, took pictures of A.R.’s leg and notified senior manager, Dede Batson (“Batson”), about the incident (see Book of Documents Tab 16 – 18). 24. On September 22, 2017, Price met with Currie in the morning and discussed the incident (see Book of Documents Tab 19). 25. Batson subsequently contacted the Halton Police Department regarding the suspicion of abuse of an individual in accordance with CWSDS’ statutory duties. 26. The Grievor was place on a paid suspension effective September 22, 2017 while the Halton Police conducted its investigation. 27. On or about November 23, 2017, the Halton Police advised CWSDS that charges had been laid on the Grievor in relation the September 21, 2017 incident. 28. Once the Halton Police concluded their investigation, CWSDS resumed its internal investigation into the September 21, 2017 incident. The investigation was conducted by Rolston and Batson. (see Book of Documents Tabs 21 – 22). CWSDS arranged individual meetings on November 27, 2017 with Currie, Price, Muzangaza, Guthrie and the Grievor in the course of its investigation. 29. On November 27, 2017, Rolston and Batson met with Currie regarding the incident on September 21, 2017. During this meeting, Currie confirmed she was advised of the markings on A.R.s’ legs and observed them on September 21, 2017 when she attended House 6. Currie described these marks as “bright red”, “recent – broken blood vessels – not bruised yet”. A copy of Rolston’s notes from this meeting are attached hereto (see Book of Documents Tab 23) 30. On November 27, 2017, Rolston and Batson met with Price and a union representative (Kim McGuiness) regarding the incident on September 21, 2017. Price stated that Popali showered and changed A.R. before the outing on September 21, 2017 and did not see any markings on A.R.’s body at that time. Price confirmed that during the outing, the Grievor was the only person left alone in the vehicle with A.R.. Price noted that when they returned to House 6, she observed the bruising on A.R.’s leg Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 7 and described that it was “purple, looked like a squeeze, disgusting bruise, couldn’t be missed”. A copy of Rolston’s notes from this meeting are attached hereto (see Book of Documents Tab 24). 31. On November 27, 2017, Rolston and Batson met with Muzangaza and a union representative (Kim McGuiness) regarding the incident on September 21, 2017. Muzangaza confirmed that the Grievor was the only person left alone in the vehicle with A.R. during the outing. Muzangaza noted that during the outing, A.R. was making his usual noises and the Grievor kept saying “stop making those noises”. Muzangaza advised that when they returned to House 6, Price called him over to look at markings on A.R.’s leg and described them as “massive, horrific…big red bruise, swollen, raised. Covered 4 inches of his leg” and indicated that he thought it looked like pinching. A copy of Rolston’s notes from this meeting are attached hereto (see Book of Documents Tab 25). 32. On November 27, 2017, Rolston and Batson met with Guthrie and a union representative (Kim McGuiness) regarding the incident on September 21, 2017. Guthrie confirmed that the Grievor was the only person left alone in the vehicle with A.R. during the outing. Guthrie noted that when they returned to House 6, Price called her over to the washroom to look at markings on A.R.’s leg and described them as “swollen, welt on the inner thigh, very red”. A copy of Rolston’s notes from this meeting are attached hereto (see Book of Documents Tab 26). 33. On November 27, 2017, Rolston and Batson met with the Grievor and a union representative (Terry Kirkelos) regarding the incident on September 21, 2017. The Grievor confirmed that he was alone in the vehicle with A.R. and the other individuals during the outing. The Grievor could not describe the markings on A.R.’s leg in much detail and simply said they were bruises. The Grievor reported not being aware of how A.R. got the bruises. A copy of Rolston and Batson’s notes from this meeting are attached hereto (see Book of Documents Tab 27 – 28). 34. On December 15, 2017, CWSDS arranged a meeting with the Grievor related to its internal investigation. During this meeting, the Grievor was advised that as a result of the investigation, CWSDS determined that on a balance of probabilities he was responsible for the bruises found on AR and that this amounted to abuse of a client. As such, the Grievor’s employment was terminated effective immediately. 35. On December 15, 2017, the Grievor was issued a letter regarding his termination for just cause for abuse of a client, breach of trust and a violation of CWSDS’ policies. A copy of the termination letter is attached hereto (see Book of Documents Tab 29). Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 8 Ms. Deneka Price was a Residential Support Worker (“RSW”) at material times assigned to House 6. In the morning of September 21, 2017, she observed a fellow RSW, Ms. Popali, bathing AR and noticed no unusual marking on his legs. During the outing, AR wore shorts. When they arrived back at House 6, Ms. Price went to the washroom to check her resident for that day, ML. AR was in the next stall. “I saw the bruises and questioned him. He was rubbing that area. I asked what happened and he said, ‘hurt’. I was shocked because it was a large marking, I never saw marks like that before. I called in each staff member on-by-one and asked how did this happen. Everyone was shocked and didn’t know. They hadn’t seen this before. [The grievor] was the last one I spoke with. He said he didn’t know what happened and was nonchalant. I said, I know you did it, he said ‘part of it’ and left. I said pretty much like, stay away from AR.” Ms. Price said that she had worked with ML previously. In the washroom he was smiling and had never been aggressive with AR. In his interactions with staff, AR vocalized by yelling and “pulls staff hard to where he wants to go.” When asked how AR expresses pain, Ms. Price said, “Unless you ask him if he is okay, he won’t say anything, his pain tolerance is very high.” When asked if AR engages in self-injury, she said that “after showering he’ll dry hard behind his neck.” When Ms. Currie arrived in the House, Ms. Price asked her to look at AR’s thigh; “It wasn’t sitting well with me, it did not look like what AR would do to himself.” The next day, September 22, 2017, she again spoke to Ms. Currie; “I wanted to give her more details because it was still not sitting well with me. I told her [the grievor] told me he did part of it [i.e., the bruising], I told her I questioned everyone else, they were not sure how it happened.” Ms. Price is familiar with AR’s BSP and noted he is “hands off, it could be medical and for AR, you never put on physical restraints, you do verbal re-directions, he usually follows them.” She said the physiotherapist who deals with AR does not provide advice as to techniques for interaction with AR, including physical interaction, in that Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 9 it is not part of a physiotherapist’s functions. Only verbal prompts are to be used with AR. In cross-examination, Ms. Price said AR’s behavioural challenges are “vocalization, yelling and pulling you” where he wants to go. She did not know if any of these behaviours were occurring during the outing on September 21, 2017. Ms. Price said AR went for physiotherapy sessions two or three times a week. AR has a long history of entwining his legs when sitting. All who worked with him were aware of this behaviour. No specific techniques have been suggested by the physiotherapist for dealing with this behaviour. Ms. Price had observed the grievor and AR interacting. She said the grievor plays “with residents and being friendly, it is how you build rapport.” Prior to the September 21, 2017 incident, there were no complaints concerning the grievor’s interactions with residents. Ms. Price was certain she had called the grievor into the washroom on their return to the House. She was certain the grievor had said that he “did part of it” in reference to AR’s bruising. She did not mention the grievor’s remark when first speaking with Ms. Currie that day but mentioned his remark the next day, September 22, 2017; “it wasn’t sitting well with me, not telling the whole conversation” with the grievor on the previous day. She agreed the Incident Report indicates “unknown” in regard to the “Possible Contributing Factors”. Ms. Price said that outside of work, she and the grievor went on a “group outing one time” and they all went to her house afterward. She agreed they had a relationship that “fizzled out” about one week prior to September 21, 2017. In re-examination, Ms. Price said the two vans had been facing each other and she could not see into the one where the grievor and AR were sitting. Rough play with residents is discouraged. Ms. Jackie Currie is a casual shift supervisor and has known and worked with AR for some seventeen years and has daily contact with him. She has been assigned to AR’s Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 10 house with the current Employer since 1999. She setup the grievor’s orientation and schedule when he was hired in January/February 2017. As his direct manager, she had no issues with how he performed his work. On September 21, 2017, Ms. Price approached her and said there was an Incident Report for AR for “possible injury”. She reviewed the report and AR’s body chart, the latter having been prepared by Ms. Popali. She then met with AR and noticed the bruising on his left thigh. She had never seen this sort of injury on AR. She then spoke with Mr. Muzangaza and inquired as to who was in the vans on the outing and was informed that the grievor had been left alone with AR. Later, she asked for written statements from Ms. Price and Mr. Muzangaza. Given the injury to AR, she was of the belief there had occurred possible abuse and sent all the information she had to Ms. Batson. The next day, September 22, 2017, Ms. Price came to Ms. Currie’s office and informed her that the events of the day before were “not sitting well with her, she was quite upset and told me the further steps she had taken [the previous day].” She informed Ms. Currie that when she noticed AR’s injury while in the bathroom she had called the other staff members one-by-one into the bathroom. She told Ms. Currie that they seemed quite shocked and had confronted the grievor, stating, “‘I know you did this [and the grievor] was very calm’.” She told Ms. Currie that the grievor had said. “‘I did it but not all’ and quietly walked away.” Ms. Currie then contacted Ms. Batson who instructed her to notify the police “as per our policy when we suspect staff had harmed a client”. After providing the police with her statement, she had no further involvement in the matter. Once the police had completed their investigation, the Employer commenced its investigation and Ms. Currie was interviewed by Ms. Rolston and Ms. Batson. In her statement, she had noted that staff are “not comfortable telling on each other.” In her testimony, Ms. Currie said this was due to “possible retribution, bullying, accusing someone of something whether it was true or not, retaliation from others.” Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 11 Ms. Currie confirmed that all staff are familiar with the clients’ BSPs and all are provided appropriate training so that all staff know how to deal with every client. There was no report from staff on September 21, 2017of AR acting in a way that would have caused his injuries, which is required of them if an injury occurs. She said that based on her experiences with him, AR had never before injured himself in the fashion she observed on September 21, 2017. Ms. Currie said that staff are not trained by physiotherapists in physiotherapy techniques and do not engage in physiotherapy with the clients. Staff are to give AR verbal directions to have him uncross his legs or not to sit on his fingers. There was no direction from physiotherapists to take a hands-on approach with AR. In cross-examination, Ms. Currie’s evidence is that the grievor is more hands-on with clients than other staff; “high fives, shakes hands.” Ms. Price was the first to inform her of the incident. It was only the next morning, September 22nd, when Ms. Price informed her of what the grievor had said to her on September 21st. She could not recall if she was concerned that Ms. Price waited until the next day to tell her what the grievor had told her, Ms. Price, the day before. “I don’t know her reasons for not telling me on September twenty-first.” Ms. Currie said that it was after her discussion with Mr. Muzangaza on September 21st that she suspected the grievor had injured AR “because he said only [the grievor] had been alone with AR during that day”. She did not initially think AR’s injuries resulted from abuse. When asked if it was Ms. Price’s information that had turned the matter into suspected client abuse, Ms. Currie said, “I believe it was all the facts and [Ms. Price’s] information caused the start of an investigation of whether or not it was physical abuse.” She did not ask the grievor to respond to the information she had received from Mr. Muzangaza and Ms. Price because he had been suspended pending investigation. She agreed that directing AR to stand up in order to uncross his legs would not be possible in a moving vehicle. Suggestions to staff from physiotherapists about clients would sometimes, but not always, be documented. There is no formal direction from physiotherapists for a hands-on approach to have AR uncross his legs. “Any direction would be communicated to the whole team [and] added to the client’s BSP.” She could not Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 12 confirm if AR was on any medication that would cause him to bruise more easily. She agreed AR is mostly non-verbal in his communications. Ms. Dede Batson’s managerial duties include supervision of House 6. She has known AR form some sixteen years, beginning as a RSW in another facility similar to that of the Employer. She had AR transferred to the Employer some six years ago and she has continued her relationship with him. In AR’s Individual Program, it indicates “No Restraint”, which Ms. Batson said “… means you are not able to put hands on him. He has a medical condition, brittle bones, which could cause injury to him.” On September 21, 2017, Ms. Batson received a call from Ms. Currie who informed her of an incident that day involving AR where he had unexplained bruising on his left thigh. Ms. Batson’s evidence is that there is nothing in AR’s BSP that would explain the injury. Ms. Currie took photographs of AR’s left thigh and forwarded them to Ms. Batson along with the Incident Report completed by Ms. Popali. She also included the “Body Check” diagram indicating where the bruising was located. Ms. Currie forwarded to her what Ms. Price and Mr. Muzangaza had told her on September 22, 2017. Ms. Batson contacted the director of human resources, Ms. Michelle Rolston. Since the incident involved suspected resident abuse based on the information they had received, the Employer’s procedures required that the police be contacted. Once the police began investigating the matter, the Employer suspended its own investigation until the police had concluded their work, again, as per Employer procedures. Because initial inquiries implicated the grievor, he was suspended with pay pending the Employer’s completion of its investigation. Once informed that the police had concluded their investigation and criminal charges were laid against the grievor, the Employer resumed its own investigation. Ms. Batson and Ms. Rolston conducted the investigation of the September 21, 2017 incident which included review of all documentation, staff statements, house logs and videos. They held interviews with staff who participated in the September 21st outing, and also with Ms. Currie. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 13 Ms. Batson said that based on all the information that had been gathered in their investigation, the Employer concluded that the grievor had caused the bruising on AR’s thigh on September 21, 2017, that it was an incident of resident abuse, and determined to terminate the grievor’s employment. She said the outcome of the police investigation did not affect the Employer’s decision. “Absolutely not. Their lens is different from our lens. They use the Criminal Code, we have a different focus. We didn’t know the outcome of the charges laid [against the grievor]. We moved forward with our investigation.” In cross-examination. Ms. Batson agreed that from time-to-time staff have to use intrusive measures, for example restraint or confinement, to interrupt challenging behaviours, which measures are in compliance with Employer policies. “They are used to support an individual through a difficult or challenging [event].” Every physical contact with a resident is documented. Responses to a resident’s behaviour are governed by his or her BSP. “NO RESTRAINT” for AR, “means just that.” A physiotherapist is not part of AR’s clinical team; “The BSP speaks to his behaviour needs and a physiotherapist is not part of that. The physiotherapist does not impact his behaviour.” Staff are expected to follow physiotherapy directions. Those instructions and their carrying out are to be documented. Ms. Batson said, “It is not something physiotherapists would say”, when asked if the instruction was to physically uncross AR’s legs and, “in my experience no, there is no direction to physically uncross AR’s legs.” Ms. Batson’s evidence is that the physiotherapist who worked with AR was not interviewed as part of the Employer’s investigation. In re-examination, Ms. Batson said there was nothing unusual about their investigation of the events of September 21, 2017; “all we did is pretty well standard, and we have a significant amount of experience conducting investigations.” Ms. Michelle Rolston is the director of human resources and in that capacity is involved in investigations of alleged client abuse. In those instances, the Employer is obligated to follow legislative measures including notification to the police to conduct an investigation. As per policy, at that juncture, the Employer suspends its initial Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 14 efforts and only resumes its investigation once the police have completed their inquiry. The employee or employees involved in the alleged incident are placed on paid leave pending investigation, as was the grievor in the instant case. Once the Employer was advised the police had concluded their investigation and that charges had been laid against the grievor, the Employer resumed its investigation. Ms. Rolston’s evidence is that as part of the investigation all relevant documentation was reviewed. Interviews were then conducted with the employees involved in the events of September 21st. Questions to be posed to interviewees in separate interviews were based in the information that had been received. The grievor was the last employee interviewed in part because the interview had to be arranged to occur off- site. All bargaining unit members were interviewed by Ms. Batson and Ms. Rolston in the presence of a Union representative. Ms. Rolston’s evidence is that when the interviews were completed, she and Ms. Batson compared all interviewee’s responses to the questions. She noted that the interviewees, other than the grievor, who had participated in the September 21, 2017 outing were consistent in their description of the outing activities, the client and staff locations in the two vans, and that the grievor had been the only staff member in the van with AR for a period of time. They were also consistent in describing the bruising on AR’s left thigh. In comparison, the grievor did not accurately recall the activities during the outing. He could not recall if anyone else had been alone in the van with AR, or, if he had left the vehicle. He was not able to recall other than that AR had “‘bruises but can’t describe what it looked like’.” He was only able to state that he had “a very brief [conversation]” in the washroom about AR’s bruises. When he was referred to Ms. Price’s statement, that in response to her remarks he had said, “‘not all of it’”, the grievor had said he did not recall that conversation with her. Ms. Rolston testified that she was concerned about the inconsistency between the grievor’s version of the events and those of the other interviewees and, also, with the brevity of his information about events. What also stood out in her mind was that while the pictures of AR’s left thigh showed significant bruising, the grievor had but Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 15 a vague recollection of the bruising. Ms. Rolston said that on review of all the information they had before them, she and Ms. Batson recommended that the grievor’s employment be terminated for suspected abuse of AR, that the grievor “could no longer work for us.” Ms. Rolston said that the police investigation had no impact on their recommendation; “we rely on our own… We have fired people even though no criminal charges have been laid.” The grievor’s discharge letter identifies the reasons for their decision. The decision to discharge him was based on finding, on a balance of probabilities, that the grievor was responsible for the bruising on AR’s left thigh on September 21, 2017. In cross-examination, Ms. Rolston confirmed she had not met the grievor until his interview on November 27, 2017. When asked if she recalled the grievor mentioning to her that on the advice of his lawyer, he could not speak with her on November 27, 2017, Ms. Rolston told him “The criminal charges have nothing to do with the workplace and we have to rely on the information you provide.” She knew Ms. Price from previous investigations. She determined Ms. Price’s information was credible because “what she told us was consistent with the other witnesses.” Ms. Rolston said the grievor was advised his interview on November 27, 2017 was confidential; “that’s always told to people.” Ms. Rolston concluded the grievor had “pinched” AR in reviewing the bruises on his left thigh. Ms. Rolston was not concerned that Ms. Price had spoken with other staff on an individual basis on September 21, 2017 because “she was advocating for [AR].” At that point, Ms. Rolston said there was no suspected abuse. In re-examination, Ms. Rolston said it is the Employer’s standard practice to advise employees their interviews are confidential. Mr. Prem Meghnath was the Employer’s physiotherapist at material times. He assessed the residents in order to determine their physical functional levels and developed programs for them to maintain their functional abilities. His assistant, Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 16 under his direction, would conduct exercises with the residents, for example walking with them, but those exercises did not involve hands-on treatments. No one else was permitted to have physical contact with AR. Mr. Meghnath would instruct the caregiver who accompanied AR to encourage him to stand with both legs. He provided no training to staff and did not direct them to take a hands-on approach with AR, but told them to use verbal cues. In particular, he did not instruct staff to physically engage with AR to uncross his legs. There is nothing in his physiotherapy assessment that indicates for staff to use a hands-on approach with AR. If Mr. Meghnath delegated physiotherapy to his assistant that would be recorded in AR’s assessment. The assistant could not delegate that treatment to anyone else as provided for in Regulations of the College of Physiotherapists. He has so delegated to his assistant for other residents but not for AR, which delegations are recorded in those residents’ files that are accessible by staff. Mr. Meghnath has seen the Body Check report and photographs of AR’s injuries to his left thigh which he identified as pressure marks. His evidence is that there is noting in AR’s physiotherapy plan that would have caused the bruising. In cross-examination, Mr. Meghnath indicated he is the only therapist to treat AR since AR became a resident of the Employer in March, 2017. He started treating AR onsite in or around 2018 rather than in Mr. Meghnath’s offices. His assistant was not involved with AR. He said AR could have been reminded to uncross his legs every few minutes when in that position and would frequently have to be directed to uncross his legs. There was to be no hands-on approach with AR, rather, verbal cues were to be used to get his attention. Staff were not permitted to tap AR’s knee in order to get hm to uncross his legs. He recalled AR to cross his legs when he was sitting but he was not concerned with that, but only with AR doing so while standing in that he had a previous history of hip dislocation. He gave no direction about AR uncrossing his legs when sitting. He denied having given instruction to the grievor to uncross AR’s legs if a verbal cue did not have effect; “The instruction was to use verbal instructions.” He disagreed that there could have been a verbal instruction given to Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 17 uncross AR’s legs. He did not direct staff to tap AR’s knee to get him to uncross his legs. No one asked him to provide a written statement. The grievor was employed as a RSW in November, 2016 and went through training and orientation. He had a clean discipline record over his some 10 months of employment. His manager, Ms. Currie, expressed no concerns during his 6-month performance review. He got along with his co-workers in House 6, where he was assigned for the most part. Staff had relationships outside of work when they socialized on a few occasions. In particular, he and Ms. Price had a relationship outside of work which ended prior to September 21, 2017. Their relationship at work did not continue well; “We wouldn’t talk and when we did it felt like resentment from her… We just kind of ignored each other.” The grievor’s evidence was that he was assigned AR twice a week, sometimes three times. He “took care of his needs” according to AR’s BSP. Some of his behaviours required intervention and at times, he saw AR self-harm; “Hitting his head, throwing stuff, using a towel after being in the bathroom and rubbing his body with it.” He was aware of and familiar with AR’s BSP. The grievor said that AR had a tendency to tightly entwine his legs. He took AR to physiotherapy roughly twice a week and the assistant therapist said, “to uncross his legs. It deteriorated his posture… so she said that in order to slow it down, uncross his legs.” The grievor was not given direction on how to uncross AR’s legs. The grievor acknowledged that AR’s BSP included no restraints, meaning no hands on, “just not touch him at all… you can’t do anything physical with him.” On September 21, 2017, the residents and staff rode in two vans for the outing. The grievor sat beside AR in the middle row of seats. The grievor said that during the ride, “AR would cross his legs. Sometimes he did uncross them [when verbally instructed to] and sometimes I would throughout the whole ride.” The grievor would “spread [AR’s] legs apart and uncross them for him [with] just a firm grip. He wasn’t fighting to cross them. I did it numerous times during the ride.” The grievor was not Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 18 frustrated with AR and said that in retrospect, “I should have just let him, but I wanted to help.” On their return to House 6, Ms. Price called the grievor into the washroom and asked if he knew what had happened to AR. “I said no, I didn’t know. That was the last I heard [about the matter].” He said that afterwards, “Ms. Batson called me into her office, said the police were investigating [the incident] and everything went downhill from there.” In further regard to his conversation with Ms. Price in the washroom on September 21, 2017, the grievor said, “She called me into the washroom, pointed to AR’s bruises and she said, “‘I know how they got there.’ I said no, I don’t know how they got there.” He said he replied, “no” for reason that “I really didn’t. I didn’t think it came from me. I did not know or recall how they got there.” He disagreed he had admitted to Ms. Price that he had bruised AR. The grievor was referred to the testimony of Mr. Meghnath in which he said he did not instruct staff to uncross AR’s legs. The grievor said, “Other staff told me to uncross his legs. I was told by the physiotherapist.” The grievor said that he was suspended on September 22, 2017 pending police investigation. On November 27, 2017 following that investigation (in which charges were laid against him but later dismissed at trial) he met with Ms. Rolston and Ms. Batson away from the work site. The grievor said, “I felt the meeting was very biased. They came with a pre-conceived notion from what they heard from Ms. Price. I told them I couldn’t talk about my case. It was very unfair. There was much more I wanted to say but couldn’t.” When asked in that meeting if he was ever alone with AR in the van, the grievor is reported to have said, “Can’t recall.” In his testimony, the grievor said, “Yes, but for a brief moment, a minute or two, the only time I was left alone with AR.” When asked “When and how did you become aware of the bruises on AR”, the grievor is reported to have indicated Ms. Price had called him into the washroom, asked if he knew how the bruises got on AR’s thigh and had said, “I don’t know.” He told Ms. Batson and Ms. Rolston he could not describe the bruises and it is noted that he “(can’t recall the colour).” In his testimony, he said, “To be honest, I Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 19 didn’t want to go into details because of my [court] case.” He agreed he had said he could not recall the bruises. “Maybe I should have used better words but the court case was proceeding, I didn’t really want to talk about the situation. I had been advised by my lawyer not to talk, give information until the criminal proceeding was completed.” He agreed he could recall events but chose not to say anything.” “Maybe I should have given a different answer.” The grievor’s evidence is that he was “quite disappointed” when he received his termination of employment letter. “It was not what I expected, it was hurtful.” He had expected the Employer to “have more patience, to wait until [the charges had been resolved] and I could give a more detailed response.” The discharge has resulted in significant personal consequences for the grievor. He is currently working in another field. The grievor said that if his actions had caused AR’s bruises on his thighs, “It was not my intention to inflict harm on AR. I’m not an aggressive person, it’s not my behaviour… I’m very sorry this [whole] thing happened.” In cross-examination, the grievor’s evidence is that he is aware of all the Employer’s policies and procedures relevant to the case at hand, including the Code of Ethics, Client Rights, Abuse of Individuals, Standards of Conduct and Respectful Intervention. He noted that the definition of client abuse includes “any behaviour likely to cause personal injury.” He agreed that under the Abuse of Individuals policy there is zero tolerance for client abuse and that suspected abuse must be reported. That policy, under “Suspected Abuse”, includes evidence of “Certain areas are highly suspicious such as inner thighs.” He agreed that under the Standards of Conduct policy use of excessive force is unacceptable conduct. He agreed that as a RSW it is critical for him to follow policies and procedures and that the clients, who are vulnerable, receive proper care. The grievor had reviewed and understood AR’s BSP. He agreed it indicates “No restraints” and that it calls for a “hands off” approach with AR. He agreed he met with Mr. Meghnath with AR roughly twice a week. When it was put to him that Mr. Meghnath’s evidence was he gave no direction to him for AR’s range of motion Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 20 exercises, the grievor said, “Yes, but he actually did give instructions as per exercise and stretches with AR including to uncross his legs.” When it was pointed out Mr. Meghnath had testified that he never instructed a hands-on approach with AR, the grievor said, “He did state the need to keep his legs uncrossed but gave no directions on how to do it. … He verbally instructed to make sure he keeps his legs uncrossed, but he never said how to do it.” He said Mr. Meghnath’s instruction was “verbal, it was not placed on [AR’s] BSP… something new less than a month prior to the [September 21, 2017] incident, not something serious enough to put on the BSP.” On the September 21, 2017 outing, the grievor said he sat beside AR the whole time and AR was crossing his legs. When AR did not listen to him, the grievor uncrossed his legs. In regard to the bruising on AR’s thigh, “I can only assume it was because I uncrossed his legs multiple times.” He agreed that in the washroom on September 21, 2017, Ms. Price had spoken one-on-one with him. His recollection of their conversation is that he did not say, in regard to AR’s bruising, “I did part of it” and did not recall her having put to him that she knew he did it. His evidence is that Ms. Price’s evidence is not true. He iterated that he had had a personal relationship with Ms. Price. In regard to the notes of Ms. Rolston and Ms. Batson of his meeting with them on November 27, 2017, he said they were “not exactly what happened, they don’t do me any favours.” He agreed that at that time, he had been charged by the police. “At the beginning, I said I can’t speak about [the incident] but we had a conversation.” In regard to his response about being asked about the bruising, i.e., “Can’t recall” and the suggestion that his response is different from saying that his lawyer advised him not to speak about the matter, “But they kept pushing. I should have ended the interview.” As to his “not recall” responses to their questions, he said, “I could have used better wording.” The Employer submitted that the grievor was governed by a high standard of conduct given that he was responsible for residents who are vulnerable and dependent upon him for their daily care and activities. The grievor was aware of the Employer’s policies Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 21 and procedures to be followed in the performance of his duties, including those regarding abuse of residents as that term is defined in those policies, and which policies are in response to the public’s trust in him in the performance of his duties. In the instant case, the grievor was aware that AR’s BSP identified him as a “no hands on” resident. The grievor testified that is was a physiotherapist instruction or direction that he was to physically uncross AR’s legs. However, there is nothing in AR’s BSP that indicates this instruction and if it had been given, it would be indicated in AR’s BSP and all RSWs would have been made aware of that instruction. Further, Mr. Meghnath testified that he did not instruct the grievor or anyone else to physically uncross AR’s legs. Also, Ms. Batson and Ms. Currie, who both had long experience with AR, testified he was not a hands-on client and that his status had never changed. In light of the evidence of Mr. Meghnath, Ms. Batson and Ms. Currie, the grievor’s evidence is not credible. The Employer submitted that the grievor, during its investigation, was given the opportunity to provide information concerning the bruising on AR’s left thigh. Ms. Rolston and Ms. Batson testified that in response to their queries, the grievor’s answers were vague, lacking in detail, or, he had responded “I don’t recall.” Moreover, in comparison with the responses of other House 6 RSWs, the grievor’s responses were starkly different, particularly in regard to the bruising on AR’s left thigh and Ms. Batson’s recollection of it. The grievor attributes his responses in his interview, at least in part, to having been instructed by his lawyer for his criminal trial not to say anything to the Employer about the events of September 21, 2017. Given his admission in his testimony here, that he did physically uncross AR’s legs during the van ride, he was neither forthright nor honest in responding to the questions put to him in his interview and, in particular, his interview responses when compared to Ms. Price’s version of their discussion on September 21, 2017. The Employer submitted that it made the correct decision when it terminated the grievor’s employment. He did physically abuse AR. The Employer has no confidence that he will not engage in that sort of behaviour again and it cannot trust the grievor, Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 22 a short-term employee, to act properly towards its clients in accordance with its policies and procedures in circumstances where there is not a lot of direct supervision of RSWs. If it is found, however, that the Employer did not have just cause to discharge the grievor it is not tenable for him to be reinstated to his employment. In support of its position on the merits of the grievance, the Employer submitted Re St. Josephs at Fleming Long-Term Care Facility v Canadian Union of Public Employees, Local 2280, 2015 CanLII 2811 (ON LA) (Stout); Re St. Joseph's Health Care Centre and London & District Service Workers' Union, Local 220 (Ruyter), 2000 CarswellOnt 9052, [2000] O.L.A.A. No. 103, 59 C.L.A.S. (Kirkwood); Re Toronto (City) and TCEU, Local 416 (Calitri), 2015 CarswellOnt 4987 [2015] O.L.A.A. No. 131, 123 C.L.A.S. 43, 252, L.A.C. (4th) 211 (Marcotte); Re City of Toronto and Canadian Union of Public Employees, Local 79, 2016 CanLII 50783 (ON LA) (Goodfellow); Re Toronto District School Board v. Canadian Union of Public Employees, Local 4400, 2009 CanLII 1363 (ON LA)(Luborsky); Re Cassellholme Home for the Aged for the District of Nipissing and Canadian Union of Public Employees Local 146 (July 31, 2006) unreported version (Slotnick); Re Fairview Nursing Home Co. and S.E.I.U. Local 204, 1995 CarswellOnt 6731, 39 C.L.A.S. (Brent); Re Kennedy Lodge Nursing Home v. S.E.I.U. Local 204, Re 191 CarswellOnt 6445, [1991] O.L.A.A. No. 14, 18 L.A.C. (4th) 38, 21 C.L.A.S. 243 (Davis); Re Versa-Care Centre of Brantford v. C.L.A.C., 2005, CarswellOnt 11047 [2005] O.L.A.A. No. 742, 84 C.L.A.S. 44 (Levinson), and, Brown & Beatty, Canadian Labour Arbitration, 4th ed, para. 7:3312; 5th ed., paras. 7:31, 7:32. The Union submitted there is no dispute that in the health care setting there is a higher standard of care when dealing with vulnerable people. An employer, however, must have clear, cogent and convincing evidence of abuse, and, must establish that the level of discipline imposed on an employee is appropriate. In the instant case, the question is not did the grievor abuse AR, rather, the question is did the grievor’s actions constitute abuse. While not conceding that abuse Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 23 occurred, it must be borne in mind that where some form of abuse has occurred, discharge is not the only disciplinary response. The Union submitted that the grievor was not acting out of frustration nor were his actions a momentary aberration. Rather, he misunderstood AR’s care needs, has explained why he behaved as he did, and, has expressed his remorse for having physically uncrossed AR’s legs in misapprending AR’s care needs. Perfection cannot be the standard to which health care employees are held, and, in any event, the grievor was not uncaring or abusive, or rough in his dealings with AR on September 21, 2017, rather, he misunderstood the instruction he had been given by the physiotherapist and now recognizes he should not have physically uncrossed AR’s legs. As to the grievor’s conduct in his interview with Ms. Rolston and Ms. Batson, it must be appreciated he was facing criminal charges at that time and had been cautioned by his lawyer about speaking of the incident involving AR. This circumstance affected his ability to provide the Employer with full answers and it is only now that he is able to do so, including expressing his regrets about this mis- guided physical intervention with AR on September 21, 2017. Moreover, he did not know for certain in the interview that his actions would have caused the bruising and did not think his actions had that result. The Union submitted there is no contemporaneous evidence as to what happened in the van and the investigative notes made by the management are hearsay comments made by staff who did not testify. In regard to Ms. Price’s evidence, the Union noted there is conflicting evidence concerning the extent of her relationship with the grievor. For his part, the grievor continues to deny he mentioned ‘part of it” in response to a query from Ms. Price about AR’s bruising. His evidence ought to be preferred because once able to fully testify about the events of September 21, 2017, he has been forthright about other matters and there is no reason for him to deny his involvement. The opportunity this arbitration process presents for the grievor to Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 24 have a fair hearing is of significance in the circumstances at hand in contrast to his following his lawyer’s advice in the Employer’s investigation in November, 2017. In support of its position on the merits of the grievance the Union submitted Re Tuxedo Villa Nursing Home and C.U.P.E., Loc. 2180, 1989 CarswellMan 562, 13 C.L.A.S. 50, 4 L.A.C. (4th) 366 (Sigurdson); Re Revera Retirement v. U.S.W., Local 8300, 2012 CarswellOnt 5523 [2012] L.V.I. 4001-1, [2012] O.L.A.A. No. 230, 111 C.L.A.S. 48, 220 L.A.C. (4th) 165 (Bendel), and, Re Riverside Health Care Facilities Inc. v. C.U.P.E., Local 65, 2009 CarswellOnt 8679, 98 C.L.A.S. 138 (Surdykowski). The issue to be determined in this award is whether or not the Employer had just cause to discharge the grievor on December 15, 2017. I find the merits of the grievance, on the evidence and submissions before me, require determination of whether or not the grievor, on September 21, 2017, physically abused AR. If I find he did not, the grievance will be upheld. If I find he did, it must be determined whether or not the level of discipline imposed by the Employer, discharge, is warranted in all of the circumstances. If I find it is not, it must be determined what level of discipline is appropriate in all those same circumstances. In Re St. Joseph’s at Fleming, supra, the union grieved the employer’s decision to dismiss the grievor for conduct that was “… abusive, demonstrating a fundamental lack of judgement and disregard for the physical and emotional well-being of the resident” (para. 2). The union contended that when the videotape of the grievor’s conduct is “… viewed in context, [her behaviour] is not abusive and does not provide just cause to terminate her employment [but] that some form of discipline is warranted” (para. 3). Arbitrator Stout found that the grievor’s conduct fell within the definition of abuse and that her explanation for her actions was unsatisfactory (para. 163). In determining whether or not the disciplinary response of discharge was warranted in the circumstances, the arbitrator, at para. 164, cites Re Baptist Housing Society (Grandview Towers) and Hospital Employees Union, Local 180, (1982) 6 L.A.C. (3rd) 430 (Grayall) p. 437: Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 25 … A much higher standard of conduct is expected from employees in the healthcare field than in other occupational fields. In this industry arbitrators are required to have regard not only to the interests of the grievor and of the employer, but also must have regard to the public interest. Both employer and employee are reposed with a public trust for which they are held accountable. The public trust is onerous. In broad terms it is a charge of responsibility for the physical and emotional comfort of a member of our society who is unable to live independently. The institution and no less its employees, in addition to regular duties assume a role which may best be described as similar to that of a “surrogate” family. This is particularly so in a facility such as Grandview which strives to be a “home” for elderly residents. Because of the public trust reposed in him, when an employee enters the health care field he must do so with considerable ability to understand human frailty and with a gargantuan tolerance of aberrant and unpredictable behaviour that often attends the infirm or elderly. Arbitrator Stout acknowledged that the employer had a zero-tolerance policy where an employer engaged in abusive conduct such that discharge resulted, but noted he was not bound by it rather, “… there is nothing in the collective agreement between the parties that restricts my jurisdiction to substitute such other penalty that I may find to be just and reasonable in all the circumstances” (para. 167). In exercising his jurisdiction, he noted the arbitral approach reflects that patient abuse is very serious misconduct but that termination of employment “is not automatic in every case of abuse” (para. 170), and, that the “Appropriate penalty can vary, depending on the nature of the abuse and the context of the misconduct” (para. 171). In that case, arbitrator Stout found the employer had just cause to discharge the grievor. He found the grievor was a short-term employee (para. 177); he was not confident the grievor would not engage in similar conduct in the future; that her explanation for her conduct was unsatisfactory (paras. 186, 187), and, that the public trust and vulnerability of the home residents (para. 190) had to be borne in mind in consideration of the employer’s disciplinary decision. Relevant for our purposes, the St. Joseph’s award indicates that a zero-tolerance policy concerning patient or resident abuse is justified given the public trust granted to health care workers, but that the existence of such a policy ought not result in every case of patient abuse ending in dismissal. Rather, the nature of the Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 26 mis-conduct engaged in and the circumstances in which it occurred inform the appropriateness of the penalty imposed. That approach is exhibited in the St. Joseph’s Health Centre award. In Re St. Joseph’s Health Centre, supra, the union grieved the employer’s decision to discharge the grievor “… for patient abuse for using force and acting against a resident’s wishes” (para. 1). The union argued the employer did not have just cause to discharge the grievor and, alternatively, that it was excessive in all the circumstances (para. 3). Relevant to our purposes, arbitrator Kirkwood found that the grievor did abuse the resident in the above circumstance and in doing so, the grievor “… did not follow the approach set out in the [resident’s] care plan” and had acted contrary to employer polices and Resident’s Bill of Rights (para. 96). Similar to the approach expressed by arbitrator Stout concerning consideration of the appropriateness of an employer’s disciplinary response where resident abuse has been established, the arbitrator noted, at para. 97: “A finding of abuse does not automatically trigger discharge, rather the nature of the abuse has to be looked at in the context of all the circumstances and measured against the high standards required of the health care industry.” Arbitrator Kirkwood found the grievor had not read the resident’s care plan, was not properly aware of the resident’s behaviour in the situation of abuse and had exercised “poor judgement in attempting to care for the resident by looking at the exercise of her duties within the terms of her own time schedule… although the nature of the grievor’s actions fell within the criteria for abuse and her actions were serious, it was not a case of extreme abuse” (para. 98). Also, while the arbitrator noted that a finding of abuse did not require intent, “the grievor’s good intentions do have consideration. Her actions were not out of anger or malice towards the resident and her actions were more in the nature of poor judgement” (para. 99). (See Cassellhome, supra, at p. 13 where arbitrator Slotnick noted the absence of malice, threats, or personal insults towards a resident and that the abuse was in the form of yelling at the resident). While the grievor had a clean disciplinary record over a long employment history, discipline was warranted “… as the hospital has a Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 27 high duty of care and responsibility to the public to ensure those left in their care are treated with respect and dignity” (para. 99). In upholding the discharge, arbitrator Kirkwood found, at para. 101: The grievor after all the days of hearing, did not understand the gravity of her actions, or even the possibility that her actions may have been wrong. She did not admit any wrongdoing and showed no remorse. She lied, and she attempted to deflect any responsibility onto the hospital and its lack of training. She had ignored all training. The arbitrator deemed that reinstatement was not warranted, at para. 109: … the most critical aspect that wipes out any possibility of reinstatement is her failure to answer in a forthright manner and to testify honestly. In a defensive position she would say anything that she believed would help to exculpate her and relieve her from any responsibility. A witness does not have to be sophisticated to answer the questions asked. Arbitrator Kirkwood determined the employer properly had no faith in the grievor that she would not act in similar fashion in the future. (See Re Toronto (City), supra, at para. 150 where the notion of a high standard of conduct in the health field is an onerous obligation on employers and employees; para. 152 where it is noted discharge is not an automatic response to patient or resident abuse; Re City of Toronto, supra, page 24, where re-instatement is an appropriate consideration where there has been an incident of patient abuse. See also Re Versa-Care Centre, supra, at para. 15 where arbitrator Levinson found the grievor’s refusal to acknowledge “any culpability for her actions or to be contrite” militated against reinstatement and cast doubt on her ability to regain the employer’s trust). The St. Joseph’s Health Centre and Casselholme awards indicate that while there is arbitral tolerance for instances of abuse that do not involve physical abuse, threats, insults or malice, in those cases it is appropriate to consider whether or not the employee will continue to engage in non-extreme forms of abuse. In both cases, the arbitrators determine that the employer could not properly have confidence that the employee would not continue in engaging in that form of abuse in the future. (See Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 28 Riverside Health, supra, where poor judgement in physically contacting a resident was viewed as insufficient support for a decision to discharge an employee where two minor incidents of non-physical abuse were found also to have occurred). Where there is an actual incident of physical abuse that is other than accidental physical contact, the nature of the abuse draws considerable arbitral attention as in the Fairview Nursing Home award. In Re Fairview Nursing Home, supra, the union grieved the employer’s decision to discharge the grievor for “abuse of a resident…” (para. 2). The grievor did not deny that she caused “a red mark on [the resident’s] right thigh and the mark was in the shape of a left hand with all five fingers clearly visible” (para. 6). The grievor described her actions as either “a tap” or “a slap” or “a hit” and that she did it in response “to a slap in the face which [the resident] had given her.” (para. 7). The grievor acknowledged she knew what she did was wrong, expressed her regret and if reinstated would “never hit a resident again” (para. 12). Arbitrator Brent found that the grievor’s evidence of having been struck by the resident in the past was not credible. The grievor had a clean disciplinary record. As to the grievor’s actions towards the resident, the arbitrator states at para. 21: … it was a significant slap. It may have been a reflexive action on the part of the grievor, we can see no evidence of pre-meditation or any pattern of abuse, but the very fact that a Health Care Aide working with such residents can be made to react like that to a resident's usual behaviour is of concern… Given the nature of the residents who are cared for in facilities like the [employer’s], there can never be any guarantee that no other resident would never exhibit behaviour at least as abusive as [the resident’s]. The arbitrator similarly found that while the grievor testified she would never hit a resident again. “… there is no guarantee that, given circumstances similar to those [of the date of the incident] she would not behave as she did that day” (para. 22). The arbitrator dismissed the grievance noting the nature of the grievor’s employment at para. 24: Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 29 In most employment situations, it is indeed rare to even consider that a discharge would be justified for a single incident of misbehaviour. In most other employment situations, boards of arbitration are looking at a simple employment relationship where only the interests of the employee and the employer have to be considered. Where there is a public trust involved regarding the care of dependent, vulnerable people, the relationship is not as simple as the usual employer/employee one; the interests which flow from the public trust must also be taken into account. In that context, it is more difficult to regard even one incident of resident abuse as being something that could be treated as an ordinary sort of infraction to which corrective discipline should be applied. As can be seen from the Fairview award, where there is actual physical abuse of a resident, the matter of the public trust becomes significant for arbitral determination purposes. Further, consideration is given to whether or not the employee has exhibited a guarantee or certainty that this sort of behavior will not occur in the future. In that regard, arbitrator Brent found the grievor’s version of her own actions not to be credible. The motivation behind an act that involves physical touching of a resident is dealt with in the Tuxedo Villa award. In Re Tuxedo Villa, supra, the grievor was discharged for striking a resident on the hand (para. 2), contrary to the employer’s standards of conduct and other policies regarding the treatment of residents. Arbitrator Sigurdson found there was just cause to discipline the grievor but that discharge was not an automatic response to every incident of resident/patient abuse. It was found that discharge was an excessive disciplinary response, at paras. 31 and 32: 31 I am not prepared to conclude, on the evidence, that the grievor did not react spontaneously to the situation, with no intent to harm. … A natural reaction to observing somebody pulling at a tablecloth, and particularly someone who does not have the capacity to comprehend fully on their own account, would be to physically intervene to get them to let go … I am not satisfied that it was anything other than spontaneous reaction without malicious intent. 32 In the circumstances, I believe dismissal was excessive. …The grievor does not deny that the incident took place. She acknowledges that she struck the resident and … that it was wrong to have done so. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 30 The arbitrator substituted a three-month suspension for the discharge. As can be seen in the Tuxedo Villa award, where the act of physical abuse occurs as a result of a spontaneous or natural human reaction to the conduct of a resident and results in a minor sort of intervention that intends no malice or ill-will towards a resident (but may have protected the resident, in that case from pulling a tablecloth with eating items on it), the action of abuse is viewed as being moderated by the circumstances of its occurrence. When coupled with the grievor’s acknowledgement of the wrong associated with the abusive action, it was found that discharge was an excessive disciplinary response. The circumstances of the occurrence of physical abuse was also a significant consideration in the Revera Retirement award. In Re Rivera Retirement, supra, arbitrator Bindel found the grievors’ conduct met the definition of abuse under the employer’s standards of conduct (para. 57). He determined that discharge was excessive in all the circumstances and addressed that matter at para. 104 as follows: The conduct … met the employer's definition of resident abuse. However, … it resulted, not from frustration or insensitivity by the grievors towards Ms. B, but rather from their own confused assessments as to what was in the best interests of Ms. B, as they believed that it was less acceptable to leave her in a soiled state than to use some mild physical restraint and to ignore her protests while they cleaned and changed her. The grievors' assessments in this regard were shared, in part at least, by Ms. Rodriguez, who had worked as a PSW. They were described by Ms. James, a fellow PSW summoned to testify by the employer, as caring, good employees. All of this persuades me that, with proper training, there is no reason why the grievors could not resume their work as PSWs. The arbitrator imposed 2-month unpaid suspensions. The Revera and Tuxedo Villa awards seems to indicate, relevant to our purposes, that where the nature of the abuse involves an incident that occurs from a weighing Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 31 of alternatives in a response to a resident’s own actions, the motivation to protect the best interests of the resident - as opposed to the interests of the employee - weighs in favour of the employee in light of all the relevant circumstances. In applying the above arbitral approaches to the case at hand, it is clear that physical abuse of a vulnerable resident is a significant violation of the public trust that has been extended to health care workers, as was the grievor at the time of the September 21, 2017 incident. In assessing the incident of the physical abuse, the context of its occurrence and the reasons for the employee’s actions are considered, but such considerations are made bearing in mind that physical abuse of a resident is essentially an intolerable offence that warrants discharge. In the instant case, the grievor admitted that on September 21, 2017, he did physically uncross AR’s legs while riding in the van and did so on multiple occasions. By the time AR returned to House 6, there was obvious bruising resulting from the grievor’s physical interventions. The grievor’s explanation for his actions is that he was instructed by physiotherapy to uncross the grievor’s legs, which he understood to include physical intervention. As to whether or not the grievor’s explanation is credible, the matter of a witness’s credibility is addressed in Brown and Beatty, supra, para. 3:5110 (4th ed.), citing Re Faryna v. Chorney, [1952] 2 D.L.R. 354 pp.356-7: If a trial Judge’s finding of credibility is to depend solely on which person he thinks made the better appearance of sincerity in the witness box, we are left with a purely arbitrary finding and justice would then depend upon the best actors in the witness box. On reflection, it seems almost axiomatic that the appearance of telling the truth is but one of the elements that enter into the credibility of the evidence of a witness. Opportunities for knowledge, powers of observation, judgment and memory, ability to describe clearly what she has seen and heard, as well as other factors, combine to produce what is called credibility… A witness by his manner may create a very unfavourable impression of his truthfulness upon the trial Judge, and yet the surrounding circumstances in the case may point decisively to the conclusion that he is actually telling the truth…. Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 32 The credibility of interested witnesses, particularly in cases of conflict of evidence, cannot be gauged solely by the test of whether the personal demeanour of the particular witness carried conviction of the truth. The test must reasonably subject his story to an examination of its consistency with the probabilities that surround the currently existing conditions. In short, the real test of the truth of the story of a witness in such a case must be its harmony with the prepondence of the probabilities which a practical and informed person would readily recognize in that place and in those conditions. As can be seen from the above, the credibility of a witness’s version of events is not a simplistic consideration. Rather, credibility is considered against the probabilities and circumstances of the events and as against the versions offered by other witnesses in a case of conflict of evidence. In that regard, a witness’s version may be credible in part but not in other parts. Also, a witness’s evidence may be consistent or inconsistent with the evidence of other witnesses, and, may also be internally consistent or inconsistent when taken on its own. The grievor’s explanation for uncrossing AR’s legs presents an inconsistency when take on its own. In examination-in-chief he testified that the physiotherapist’s assistant, i.e., “she”, instructed him to uncross AR’s legs. In cross-examination, he testified it was the physiotherapist, i.e., Mr. Prem Meghnath, a male, who instructed him to uncross AR’s legs. However, Mr. Meghnath testified that only he, as a member of the College, could give that sort of instruction and not his assistant. Further, Mr. Meghnath’s testimony is that it was him and not his assistant who treated AR in his weekly appointments. Secondly, the grievor’s version is not consistent with the evidence of the other witnesses. Their evidence is that any instruction regarding a resident’s treatment is to be entered into that resident’s plan in order to be communicated to all the RSWs who interact with that resident. There is no evidence before me to establish that an instruction had been given for RSWs to physically uncross AR’s legs. Rather, the instruction regarding AR was “no restraints”, which was said by Ms. Price and Ms. Currie to mean no hands on AR. Nonetheless, while being aware of AR’s BSP, the grievor ignored that it called for no restraints, i.e., no hands on, and physically Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 33 uncrossed his legs. Based on the foregoing, I find the grievor’s evidence that he was instructed to physically uncross AR’s legs is not credible. I find that the grievor failed to follow AR’s treatment plan by physically uncrossing his legs. As to whether or not the grievor’s actions constitute physical abuse, the Employer’s “Abuse of Individuals” policy defines abuse as follows: Any action or behaviour that causes or is likely to cause physical injury or psychological harm or both to a person with a developmental disability…. There are many specific forms of abuse. These are: … Physical Abuse, Physical Abuse is an act of assault, or a threat of an assault, such as hitting, slapping and burning that cause actual physical injury or fear of physical injury. Against the above definition, I find the grievor did physically injure AR resulting in the bruising on his left thigh. I find, therefore, that the grievor physically abused AR on September 21, 2017. I find, therefore, the Employer had just cause to discipline the grievor. As to whether or not discharge is an appropriate response to his misconduct, the grievor had less than one year seniority at the time of the September 21, 2017 incident, which amount of seniority he cannot rely on as an offsetting or mitigating factor to the level of discipline imposed. Secondly, the grievor’s version of the instruction given by the physiotherapist is not credible; there is no record, as required of any physiotherapy instruction to uncross AR’s legs and AR’s case plan specifically identifies there are to be no restraints, in the physical sense, of AR. Also, the grievor’s testimony as to who gave him that instruction is inconsistent. In examination-in-chief he identified a physiotherapy assistant who he said was a female and in cross-examination he identified Mr. Meghnath as the one who gave him the instruction. On that point. Mr. Meghnath’s evidence is that an assistant is prohibited from giving instructions as to a resident’s physiotherapy regime. Further, the grievor expressed remorse for his actions towards AR, but it was Central West Specialized Developmental Services & Ontario Public Service Employees Union, Local 249 January 2022 34 expressed as regret for having mis-apprehended the physiotherapy instruction, but no such instruction was given. Based on all the foregoing considerations I find that the level of discipline imposed on the grievor is warranted in all the circumstances. The grievance, therefore, is denied. Dated at Toronto, this 25th day of January, 2022. William A. Marcotte Arbitrator