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accordance with the pre-existing language in the collective agreement expiring March 31, 2003.
6. There is no dispute that the employer misapplied these provisions over three successive
collective agreements and that this misapplication was as a result of a mistake by the employer.
7. By letter dated November 18, 2008 from the Director of Compensation, the employer
confirmed to Ms. Phillips-Scott that it was correcting her payment in lieu of benefits to the
maximum of 52 weeks taken for her most recent leaves. It also confirmed that, during her prior
two pregnancy and parental leaves, she had been paid for a total of 35 weeks rather than 52
weeks. The Director further advised that, as the hospital was unaware of the issue and as it had
been "a considerable period of time since those previous leaves, and the issue was not brought
forward until now, I regret to inform you that we are not obligated to go back that far to make
further adjustments." Ms. Phillips-Scott's first period of leaves was from June 2003 to June 2004.
Her second period of leaves began in July 2005 and ended in June 2006.
8. As a result of the issue being raised by Ms. Phillips-Scott, the employer corrected its
practice. The employer also reimbursed part-time employees who were on pregnancy and
parental leave on or after January 4, 2008. The employer took the position that reimbursing
affected employees back to January 4, 2008 was appropriate and sufficient in the circumstances.
Following further discussions between the parties, the grievance was filed on May 19,2009.
9. Ms. Phillips-Smith had previously been overpaid. The employer was recouping that
amount over time from her pay. She was therefore paying particularly close attention to her pay
stubs while on leave. She noticed that the percentage-in-lieu amount had stopped forming part of
her itemized pay, inquired why, and so began the process leading to this arbitration.
10. Between the summer of2006 and April 2008, the employer paid employees on pregnancy
and parental leaves on a biweekly basis. A copy of a letter dated November 22, 2006 to a Ms.
Critch, a part-time employee then taking both leaves (according to Exhibit 11), enclosed a
breakdown of calculations and payments. That breakdown states "Benefit/vacation top up - 35
weeks". Prior to the summer of 2006, the employer paid the percentage-in-lieu amounts as a
3
lump sum. A copy of a breakdown dated December 3, 2003 to a Ms. Sparks, another part-time
employee then taking leave, references a weekly percentage "benefit top up" multiplied by 35
weeks. In both cases, the reference to 35 weeks should have been 52 weeks. I have no evidence
that these employees did not receive these documents.
11. Ms. Phillips-Smith appears to have been provided with a copy of a chart (Exhibit 6) dated
July 2002, prior to her first leave, which she may have relied on in her earlier leaves. At worst,
the chart is ambiguous. At best, it indicates that percentage-in-lieu may continue for 52 weeks
(17 plus 35). It sets out entitlements and appears to appropriately identify pregnancy (referred to
as 'maternity') leave provisions to a maximum of 17 weeks. Under parental leave it identifies
income provisions for part-time/casual employees as including "E.!. Benefits plus SUB to 84%
for 10 weeks (to greater of average ofFTE hrs.) plus % in lieu of benefits and vacation." Under a
separate heading titled "Benefits/Premium Payments" it states, "Average of % in lieu continued"
with no indication of time span except an accurate title reference to "Parental Leave (up to 35
weeks)". There is also a column referring to extended leave, "beyond 52 weeks (Personal
Leave)" wherein it indicates no income provisions for part-time employees and identifies that
benefits/premium payments are not applicable to part-time employees during an extended leave.
12. The current collective agreement came into effect on September 10, 2007 covering the
period April 1, 2007 to March 31, 2009. The two preceding collective agreements had terms of
April 1, 2004 to March 31, 2007 and April 1, 2003 to March 31, 2004. Those three collective
agreements contain the same language in respect of time limits for the filing of grievances:
9.02 A complaint shall not be considered as a grievance unless the aggrieved employee has
first given an opportunity for her Supervisor to adjust the complaint. Such complaint
shall not be considered after five (5) working days of the origin of the complaint or from
the date upon which the subject matter of the complaint may reasonably be deemed to
have come to the attention of the employee so affected. Failing satisfactory resolve
within five (5) working days after the complaint is made, the matter may then be
processed as a grievance.
9.05 A complaint or grievance ansmg directly between the Hospital and the Union
concerning the interpretation, application or alleged violation of the Agreement, shall be
originated under Step No.2. Failing settlement under Step No.2 within fifteen (15) days
it may be submitted to arbitration in accordance with Article 9.10. However, it is
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expressly understood that the provisions of this paragraph may not be used by the Union
to institute a complaint or grievance directly affecting an employee which such
employee could herself institute and the regular Grievance Procedure shall not be
thereby bypassed.
Any grievance by the Hospital or the Union as provided in this paragraph shall be
commenced within ten (10) days after the circumstances giving rise to the complaint
occurred or from the date upon which the subject matter of the complaint may
reasonably be deemed to have come to the attention of the Hospital or the Union.
9.06 Where two or more employees have identical grievances and each employee would be
entitled to grieve separately, they may present a group grievance in writing identifying
each employee who is grieving within ten (10) days after the circumstances giving rise
to the grievance have occurred or a reasonably to have come to the attention of the
employees so affected. The grievance shall be originated at Step No. 1.
9.07 Failing settlement under the foregoing procedure of any grievance between the parties
arising from the interpretation or alleged violation of this Agreement, such grievance
may be submitted to arbitration as set forth in Article 9.10. If no written request for
arbitration is received within fifteen (15) days after the decision under Step No.2 is
given, it shall be deemed to have been settled and not eligible for arbitration.
9.09 No matter may be submitted to arbitration which has not been carried through all the
requisite steps of the Grievance Procedure. Where no answer is given within the time
limits specified in the Grievance Procedure, the grieving party shall be entitled to submit
the grievance to the next step of the Grievance Procedure.
9.12 The Arbitration Board shall not have jurisdiction to amend or add to any of the
provisions of the Agreement, or to substitute any new provisions in lieu thereof, nor to
give any decision inconsistent with the terms and provisions of this Agreement.
9.14 The time limits fixed in both the grievance and arbitration procedures may be extended
by written consent of the parties to this Agreement.
13. Article 1.01 of those three collective agreements is also identical and provides:
1.01 It is the intent and purpose of this Agreement to establish and maintain an harmonious
collective bargaining relationship and to provide a method for the prompt and equitable
adjustment of grievances of employees in the employ of the Hospital, or of disputes
between the parties without unnecessary delay or expense, ...
14. A preliminary list and approximate calculation compiled by the employer indicates a
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potential liability to the employer of approximately $65,000 in order to make whole those part-
time employees who have taken pregnancy and parental leaves longer than 35 weeks in the
period April 1, 2003 to January 4,2008.
*
*
*
15. It was the position of the union that the grievance was expressly filed under three collective
agreements and that I therefore have the jurisdiction to remedy the employer's mistake to April
1, 2003. The union further argued that the claim involves an entitlement in the nature of a wage
payment, and that this entitlement is in the nature of a vested or accrued right. It relied on the
Supreme Court of Canada's decision in Dayco, infra, to argue that, although the right to the
percentage-in-lieu payment may have arisen under prior collective agreements, those rights could
not be expunged by the expiry of those agreements. Not to take jurisdiction, argued the union
would result in significant prejudice; a right without a remedy. The union argued that since
Dayco it was clear that an arbitrator has the jurisdiction to hear, determine and provide a remedy
for a right accrued under a prior collective agreement. It argued that this was a continuing breach
affecting an identifiable group and that as a complaint could be brought within one year after the
last incident in the series under the Human Rights Code (the "Code"), authority existed to
provide a remedy back to 2003.
16. The union also argued that the employer could not rely on its mistake to found an argument
that the union failed to act in a timely way. The union argued that there was no way for the union
or its members through normal diligence to know of the mistake until it came to the attention of
one employee who was actively and beyond normal expectations scrutinizing her pay.
17. The employer argued that there was a distinction in the nature of the right being claimed by
the union from that in Dayco. Dayco and later cases, argued the employer, referred to rights and
a status accruing over time or service in employment, and over different collective agreements,
such as pension or seniority entitlements. Each claim made in this case, argued the employer, did
not continue beyond the expiry of the particular leave and is a claim for compensation.
6
18. The employer argued that my jurisdiction was limited to considering the matter under the
terms of the current collective agreement. In the alternative, the employer argued that, even
assuming jurisdiction to interpret and apply the three collective agreements, the claim was
simply too late. The employer argued that the doctrine of delay/laches applied. The employer
noted that it was not taking issue with any delay in the filing of the grievance in May 2009 given
that the matter had been raised in August 2008. The issue, argued the employer, was that the
union could not claim relief prior to the time limits contemplated by the collective agreement and
could not claim relief under predecessor collective agreements. It noted that the timeliness
concern was raised as early as November 2008 in its letter to Ms. Phillips-Scott.
19. The employer argued that no reason for the delay had been asserted other than that
employees were pre-occupied. It noted that there was no suggestion other than that the mistake
was inadvertent on the hospital's part and that, although not previously raised by the union, there
was nothing in the evidence to support a claim under the Code. The employer argued that the
mistake was not hidden and could have been ascertained through normal diligence. It argued that
the employer's response to remedy the matter back to January 4,2008 was more than appropriate
in the circumstances. The employer argued it was necessary to consider the prejudice to the
hospital represented by the potential unbudgeted liability represented by the claim in a time of
broader public sector fiscal restraint, and given the time limits in the collective agreements.
20. In reply, the union argued that the appropriate assessment was what had been negotiated. It
argued that the percentage-in-lieu payment flowed from an accrued right as employees had to
meet certain service requirements before becoming eligible for the leaves. The cases relied on by
the employer, argued the union, either pre-dated Dayco, or did not refer to it. It argued that the
payment of money was not prejudice. Rather, it argued, prejudice arose in the ability or not to
respond to the claim and present a case; not an issue here, as the claim was acknowledged on the
merits. The collective agreement did not contain mandatory time limits, such as the deemed
abandonment of grievances, argued the union. If there are competing equities, argued the union,
they should be resolved in favour of the part-time employees affected.
*
*
*
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21. The union referred me to and I have reviewed the following cases: Dayco (Canada) Ltd. v.
CAW-Canada [1993] 2 S.c.R. 230; Red River School Division v. Red River Division Assn. No.
17 of the Manitoba Teachers Society, (1972) 25 D.L.R. (3d) 106 (Q.B.); Algonquin and
Lakeshore Catholic District School Board v. OECTA [1999] O.L.A.A. No. 475 (Roach); Air
Canada v. lAM (Graham), (1999) 80 L.A.c. (4th) 224 (O'Neil); and Huntsville District Nursing
Home and Ontario Nurses' Association, (2001) 106 L.A.c. (4th) 312 (Lynk).
22. The employer referred me to and I have reviewed the following cases: Canadian General
Electric Co. (Davenport Works), (1952) 3 L.A.C. 980 (Laskin); Auto Screw Machine Products
Ltd. v. USWA, Local 7105, (1972) 23 L.A.c. 396 (D.L. Johnson); Alexander Marine & General
Hospital and Ontario Nurses' Association, unreported decision of Arbitrator Burkett dated
October 13, 1989; Atlantic Packaging Products Ltd. and c.P.U, (1993) 34 L.A.c. (4th) 59
(Starkman); FPC Flexible Packaging Corp. v. Graphic Communications International Union,
Local 500-M (Annette Grievance), (1998) 77 L.A.c. (4th) 198 (Bendel); and Cambridge
Memorial Hospital v. Ontario Nurses' Assn. [2006] O.L.A.A. No. 745 (Herlich).
23. I note at the outset that, although the union stated that the employer's actions affected an
identifiable group under the Code, it did not otherwise assert or rely on any violation of the Code
in support of its position.
24. What is the scope of my jurisdiction? I start with the principle that an arbitrator has no
jurisdiction beyond the collective agreement under which he/she is constituted. Arbitrators are
creatures of statute and derive their authority from the collective agreement. Additionally, since
the Supreme Court of Canada's decision is Dayco, supra, there can be no doubt that an arbitrator
can acquire and exercise jurisdiction in respect of rights set out in a collective agreement even
though the term of that collective agreement has otherwise expired. However, these statements
mayor may not reflect the same question. The decision in Dayco does not specifically address
the question of whether an arbitrator may be constituted under more than one collective
agreement at once.
25. However, that issue was discussed in the decision in Huntsville District Nursing Home,
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supra, which qualifies the starting principle noted above. After reviewing Dayco, Air Canada,
supra, and other cases, the arbitrator concluded:
35 I am satisfied that the accumulated weight of judicial and arbitral caselaw has
established that an arbitration board may have the jurisdiction to hear, decide and remedy a
claim respecting an employment right or entitlement that had crystallized or accrued or vested
under a prior collective agreement, notwithstanding the rule in Re Goodyear. However, for
jurisdiction to be acquired under this second variance, each of the following three pre-
conditions must be met.
36 First, the employment right or entitlement that is being claimed must have accrued or
vested under the prior collective agreement(s). To put it another way, an employment right
found in a collective agreement expires with the termination of the collective agreement,
unless the right or entitlement can be said to have crystallized or vested or accrued prior to the
end of the agreement. Having crystallized, these rights remain grievable and are capable of
arbitral remedy, unless the parties have extinguished these rights by some subsequent
agreement. Mr. Justice La Forest, at page 641 of the Dayco ruling, stated that:
As a simple principle of contract law, the enforcement of a contract can take place
well after the contract itself has expired. What is at issue in these cases is exactly
that - the enforcement of the collective agreement to rectify damage appearing after
the expiration of the agreement... It is not the survival of the term per se that allows
for arbitrability - no one disputes that the term is extinguished in the sense that it
has no prospective application. Rather it is that the rights created by that term vest
or accrue.
37 Whether a right or entitlement can be said to have vested or accrued prior to the expiry
of a collective agreement is to be judged on the circumstances of each case. However, it
appears clear from Dayco that crystallization or accrual would have an ordinary contractual
meaning (vesting would appear to have a more specific, pension-related meaning), such that
the fulfillment of a promise, or the satisfaction by one party of its side of a mutual obligation,
would be ordinarily sufficient to acquire that status.
38 Second, the arbitration board must determine whether the grievance before it has been
filed under the previous collective agreement or agreements where the claim in question has
been said to have crystallized. This is ordinarily determined by examining whether the
grievance has made any specific references in its language to an earlier date when the claim in
question could be said to have accrued: Re Air Canada, supra; Re Canadian Broadcasting
Corp., supra. For example, in Re Beachville Lime Ltd., supra, the grievance was filed in
December 1999, and specifically referred to incidents that occurred in 1994 and 1995. These
references were sufficient to imply:
... that the grievance is filed under the collective agreements in effect at those
times. Accordingly, it must be found that the arbitrator has jurisdiction to hear
and consider this grievance as it relates to rights that may have accrued to the
grievor under the collective agreements in place in 1994 and 1995. [At p. 359.]
39 And third, the grievance must satisfy any procedural or timeliness provisions in the
collective agreement, subject to their modification by statute: Re Beachville Lime Ltd., supra.
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26. The reference in paragraph 38 of the quote to collective agreements in the plural, focuses
on the nature of the claim and a determination of under which collective agreement that claim
can be said to have crystallized. I digress briefly, therefore, from the question of one's
jurisdiction under multiple collective agreements in order to initially consider the first pre-
condition set out in Huntsville District Nursing Home. The union relied heavily on this decision
and the decision in Dayco in support of its position.
27. Firstly then, has the entitlement claimed 'accrued' or 'crystallized' under a prior collective
agreement? The union asserted that the entitlement to the percentage-in-lieu payment for up to
52 weeks was in the nature of an accrued or vested entitlement. In so asserting, the union relied
on the following comments in Dayco:
46 Counsel for the company submitted that the concept of "vested rights" has no place in a
collective bargaining context, where every collective agreement is viewed as a fresh start,
revoking the agreement that came before. This view, commonly stated by labour lawyers,
must be restricted to the context of the prospective relationship between the parties. Terms
such as "revoking" or "displacing" the prior collective agreement should be taken to mean
simply that the old agreement ceases to have prospective effect. An example of the use of the
terminology in its proper context is found in an early arbitral decision of Gale J. (as he then
was), writing for an arbitration panel in In re De Havilland Aircraft of Canada Ltd. and
U.A. w., Local II 2 (1950), 2 L.A.C. 465, at p. 468:
The very purpose of the new Agreement was to set up the Contract between the
Company, the Union and the individual employees and it is perfectly apparent
that it was intended to displace any Contract or Contracts which had theretofore
existed. If it were otherwise, all parties would be constantly in doubt as to
whether they were bound by the terms of Contracts apparently no longer in force.
It is our view that the whole theory of collective bargaining demands that the
current Collective Agreement is to contain and represent the whole Agreement
between the parties.
The new agreement "displaces" the old one, which is no longer in force. But this is with
respect to the current employment relationship, and says nothing about the previously accrued
rights of the parties... Another example of the importance of context is seen in Brown &
Beatty, supra, where the authors speak of a new agreement "extinguishing" the terms of the
old agreement. This may be an unfortunate term, which suggests some retroactive rescission of
contractual obligations between the parties. However, it is clear from the cases cited by the
authors that any extinguishment has prospective effect only. Other cases on this point are
reviewed below, and I have found no case that suggests that accrued rights are expunged once
a new collective agreement is negotiated. Moreover, I see nothing differentiating the promise
to pay retirement health benefits from promises to pay regular wages or vacation pay. All of
these can be enforced after the termination of the agreement. Any other conclusion would
render meaningless a wide range of promises to employees that might extend beyond the
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expiration of a collective agreement. In addition to unpaid wages and retirement benefits,
disability benefits owing to former employees and pension benefits to retired workers would
also be placed in jeopardy. (emphasis added)
28. This description of an accrued or crystallized right is extremely broad and ought to be read
in context with the Court's later statement that enforcement is available "to rectify damage
appearing after the expiration of the agreement" (see the excerpt quoted in Huntsville District
Nursing Home above).
29. However, accepting for the moment the characterization in Huntsville District Nursing
Home, 'crystallization' of an entitlement appears to encompass the circumstance of the
satisfaction by one party of its side of a mutual obligation. In that context, the affected
employees in this case have fulfilled their part in taking pregnancy and parental leaves so as to
'crystallize' their entitlement to payment for the percentage-in-lieu for the period of their leaves,
to a maximum of 52 weeks, thereby fulfilling the first pre-condition set out in Huntsville District
Nursing Home.
30. It is also the case that the gnevance before me "has been filed under the collective
agreement or agreements where the claim in question has been said to have crystallized". The
claims for the percentage-in-lieu payment arose as employees took pregnancy and parental
leaves at various times over the course of the three collective agreements in operation since April
1, 2003. The grievance before me makes specific reference to three collective agreements and the
same provision in all three agreements is alleged to have been violated. The grievance expressly
seeks relief to April 1, 2003. Having regard to the comments at paragraph 38 of Huntsville
District Nursing Home, I find that the grievance was filed under all three collective agreements
and, as such, I have the jurisdiction to hear and consider the grievance as it relates to alleged
entitlements arising under those collective agreements.
31. Taking jurisdiction over this allegation of a breach over successive collective agreements
also makes sense from a labour relations perspective, in that it avoids the necessity of multiple
proceedings with the associated delay and additional costs to the parties. See Alexander Marine
& General Hospital, supra. As the Divisional Court also held in OPSEU and The Queen, cited at
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paragraph 82 of Air Canada, supra:
To deny jurisdiction without inquiry into the merits of the dispute would produce a dangerous
and far-reaching result whose consequences could not be predicted. The delay in launching the
grievances and the policy considerations submitted by the employer may all be relevant to the
determination of the dispute. In my opinion, it is more appropriate that these matters be
considered in the context of the grievance procedure rather than a threshold question of
jurisdiction. I, therefore, conclude that the Board was wrong in finding that it had no
jurisdiction to consider a grievance under an expired agreement. (emphasis added)
32. I move then to the third pre-condition; that the grievance must satisfY any procedural or
timeliness provisions in the collective agreement, subject to their modification by statute. As
noted in Air Canada, supra, at paragraph 74:
. . . the question of jurisdiction to inquire into a grievance at all, is different from the question of
the arbitrability of such a grievance having regard to the provisions of the collective
agreement, for example, as to timeliness, delay and other procedural matters.
33. Also, in Red River School Division, supra, the Manitoba Court of Queen's Bench noted:
24 To close, then, expiry of the contract out of which the claim arises does not, without
more, put an end to the right of either of the parties to the agreement to call for settlement of a
dispute arising thereunder in accordance with the arbitration procedure to that end established
by their contract, when the dispute concerns the existence of a benefit allegedly vested during
the term of the agreement in question, and is within the terms of reference of the arbitration
clause. (emphasis added)
34. Notwithstanding that the grievance was not filed until May 2009, the employer conceded
that the issue was raised as of August 2008. It made its arguments regarding time limits and
delay based on the August 2008 date rather than the date of the actual filing of the grievance.
35. Article 9.02 of each of the collective agreements stipulates that a complaint shall not be
considered after five working days of the origin of the complaint or from the date upon which the
subject matter of the complaint may reasonably be deemed to have come to the attention of the
employee so affected. In Article 9.05, a policy grievance shall be commenced within ten days
after the circumstances giving rise to the complaint occurred or from the date upon which the
subject matter of the complaint may reasonably be deemed to have come to the attention of the
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union. Finally, a group grievance may be filed within ten days after the circumstances giving rise
to the grievance have occurred or ought reasonably to have come to the attention of the
employees so affected.
36. The union asserted that the grievance was not out of time in that it alleged a violation of a
continuing nature. I have difficulty with that characterization in light of the collective agreement
language. The claims presented by the grievance are fundamentally of an individual nature. Each
employee taking these leaves was entitled to file a grievance seeking appropriate payment of the
percentage-in-lieu at the time of their leaves. To the extent that one might refer to this as a
continuing breach, the breach continued for the duration of that employee's pregnancy and
parental leaves. Once that employee returned to work, not only had their entitlement crystallized,
so too had their responsibility to raise any concern about that entitlement pursuant to the terms of
the collective agreement.
37. The union's argument is based on the fact that the employer mistakenly applied the terms
of the collective agreement over various employees' leaves. That is arguably the 'policy' issue.
However, Article 9.05 stipulates that a policy grievance may not be used to initiate a claim
directly affecting an employee where such employee could herself institute the claim. There is
often an underlying policy aspect to an individual grievance. The distinction may be seen in the
request for remedial relief. The union is not asking me to only address the 'policy' issue; that is,
to declare a violation as having occurred and to direct the employer to correct its mistake
prospectively. It is asking me to order that the employer reimburse all employees affected over a
period of almost five years, notwithstanding that none of those employees (with the exception of
Ms. Phillips-Scott) grieved the issue.
38. The policy issue has been resolved between the parties. The employer acknowledged its
breach and has since complied with the requirement to pay percentage-in-lieu to a maximum of
52 weeks to part-time employees taking pregnancy and parental leaves. The employer also
retroactively remedied individual claims to employees on leave as of January 4, 2008. The
grievance was brought forward to arbitration for the purpose of claiming individual relief for
those employees who took pregnancy and parental prior to January 2008. The grievance reflects
13
separate individual claims that could have been brought, as noted above, at any time during a
leave or shortly following the completion of the leaves when it might reasonably be deemed to
have come to the attention of the employee affected. That is, in applying Article 9.02 of the
collective agreements, an arbitrator might reasonably conclude that an employee only realized
that they had been 'short-changed' once the leaves were over.
39. The circumstances in the case before me are unlike those in Air Canada, supra. In that
case, the collective agreement allowed for the filing of a grievance "within ten calendar days
of.. . [the employee's] knowledge of the event". It was not disputed in that case that the grievor's
name had been erroneously left off a list of employees who had been granted certain seniority
credit pursuant to an agreement between the union and the employer, and about which the
grievor was not told. It was also not disputed that the grievor only learned of the agreement some
five years later and only through happenstance. While arguments were made to limit the
employer's liability, they did not rely on the timeliness of the filing of the grievance.
40. I have no evidence from which to conclude that employees were unable through normal
diligence to ascertain that they had not been appropriately compensated for the percentage-in-
lieu over the course of their leaves. The evidence, in the form of the documentary material
described earlier, suggests otherwise. August 2008 is well beyond a date that any employee on
leave prior to January 4,2008 may reasonably be deemed to have learned of the shortfall in pay.
Thus, I find that the remaining claims raised by the grievance have been brought well beyond the
time limits set out in each collective agreement and the grievance is, in respect of those claims,
untimely. Should I exercise the discretion under section 48(16) of the Labour Relations Act,
1995 as amended (the "Act"), to extend those time limits?
41. The decision in Alexander Marine & General Hospital, supra, provides, in my view, a very
helpful analysis. In that case the union alleged that the employer had failed to pay shift premium
to each of four grievors over five successive collective agreements between 1981 and 1988. Two
of the grievors worked full-time permanent evening shifts and two worked full-time permanent
night shifts. A grievance had been filed in respect of each of the five collective agreements.
There was no dispute that the grievors were entitled to be paid shift premium for their hours
14
worked between 1981 and 1988 and that a 'mutual mistake' had resulted in their not receiving
those entitlements. In fact, part-time employees on permanent evening and night shifts had been
paid the premium from 1983. Similarly to the case before me, the employer commenced paying
the shift premium from the date that the grievances were filed. Although considered prior to the
decision in Dayco, the parties agreed to confer jurisdiction on the arbitration board to consider
the five grievances.
42. As in the case before me, the grievors had satisfied their side of the mutual obligation; they
had worked the hours, although for less pay than their entitlement. In the post-Dayco
characterization, their entitlement had 'crystallized'. The issue of the arbitration board's
jurisdiction to entertain both multiple grievances and successive collective agreements was not
challenged. That effectively left the third pre-condition for that arbitration board to consider;
whether the grievances were timely, subject to any modification by statute. The arbitration board
noted that the failure to pay the shift premium was a continuing breach in that it was repeated
with the issuance of each pay cheque to each grievor. It therefore found the grievance filed under
the then current collective agreement to be timely in respect of the most recent period prior to the
filing of the grievance, but found that the grievances were otherwise untimely. The arbitration
board went on to consider whether or not to exercise the discretion under what is now section
48(16) of the Act to extend time limits.
43. The statutory discretion to relieve against time limits requires that an arbitrator be satisfied
that there are reasonable grounds for the extension of the time limits and that the employer will
not be substantially prejudiced by the extension.
44. In Alexander Marine & General Hospital, the majority of the arbitration board exercised
the discretion to extend the time limits for the filing of the grievances under the two most recent
collective agreements. In doing so, the majority stated:
7. The factors to be considered in exercising discretion under section 44 (6) [now section
48(16)] to relieve against time limits can be found in Re Becker Milk Co. Ltd... and Greater
Niagara General Hospital... The reason for the delay, while it is one factor to be considered, is
not dispositive. The nature of the grievance, the length of the delay, whether the union or the
grievor is responsible for the delay, and, most importantly, whether the employer will be
15
prejudiced by granting an extension to the time limits are all factors that must be weighed. We
comment at this juncture that the length of the delay is a factor to be considered because sound
labour relations are promoted by the elements of certainty and finality. Indeed, the parties
incorporate the time limits for the filing of grievances into their collective agreement to
promote these elements. Finally, an employer can reasonably expect that time limits will be
observed and can order its business in the knowledge that grievances will be filed and
processed in a timely fashion. It follows, therefore, that whereas equity considerations usually
weigh in favor of extending time limits any decision to extend must take into account possible
prejudice to the employer.
8. In this case we have a continuing breach that was repeated with the issuance of each pay
cheque.... It is acknowledged... that the breach of the collective agreement arose because of the
inadvertence of the employer and the subsequent inadvertence of the grievors. The grievors
were unaware of their rights. Notwithstanding their inadvertence however, the grievors have a
contractual responsibility to apprise themselves of their rights and to make claims under this
collective agreement in a timely fashion. The delay in the filing of the grievance in this case
extended for some five years; an inordinately long time when measured against the agreed
time limits. Given the policy considerations of certainty and finality exceptional circumstances
would be required to cause us to exercise our discretion to relieve against time limits this long
expired. Indeed, we are not aware of any arbitrator relieving against time limits this long
expired.
9. This is not to say that some relief is not warranted. These full-time employees worked
this whole period of time for considerably less than they were entitled to receive. The
employer received what must be termed a $17,000 (approximate) windfall. Even part-time
employees on non-rotating shifts received the proper shift premium. In these circumstances the
equity considerations weigh strongly in favour of the grievors. The prejudice relied upon by
the employer is the prejudice of not having provided for a $17,000 payment in its current
budget. We accept that the financial burden of an ongoing liability caused by a union's failure
to grieve in a timely fashion is a form of prejudice that must be taken into account. This is
especially so when the amount of the liability is substantial.
10. The length of the delay in this case is inordinate and the union has failed to put forward
a reason for the delay that would support a decision to provide full relief against time limits so
long expired. However, there are compelling equity considerations that weigh in favour of
providing some relief. We refer specifically to the fact that the grievors performed services for
the employer for less remuneration than that to which they were entitled and that part-time
nurses in the same circumstances received full payment. We have been satisfied that
reasonable grounds exist to extend the time limits under the two most recent collective
agreements. The effect is to strike a balance between the equity considerations that weigh in
favour of the grievors and the labour relations policy considerations and prejudicial impact
upon the hospital that weigh in favour of refusing to exercise our discretion. It is to be noted
that by restricting the exercise of our discretion to providing relief against the time limits in
the two most recent collective agreements we have significantly reduced the prejudicial impact
of the ongoing liability against the hospital.
45. Bora Laskin's commentary in Canadian General Electric Co., supra, remains sound:
8 Neither the Agreement under which this gnevance was filed nor the preceding
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Agreement contains any time limitation for the filing of grievances. Is there, then, any basis on
which a grievance can justly be declared "stale" or "out of time," and thus subject to rejection
without consideration of its merits? And if there is such a basis of rejection, is this case within
its limits? In considering this problem it is safe to start with the proposition abstract though it
may be, that a grievance about any alleged violation of a Collective Agreement should be
brought within a reasonable time after the alleged violation has occurred. It should make no
difference to the application of this proposition that the grievors were unaware that they had a
right to complain, unless they were in some way misled by the Company....
10 ... The efficient and expeditious conduct of labour relations or, what is much the same
thing, the proper administration of a Collective Agreement, requires mutual recognition by the
parties of the principle of repose as to all claims under the Agreement not asserted within a
reasonable time and involving matters which have, to all outward appearances, been
satisfactorily settled between the parties. Unless some such policy is admitted, then, having
regard to [the] continuing nature of Collective Agreements, there is wide scope for harassing
activities by each party with consequent danger of damage to present relations by dragging up
ghosts from the past.
46. And see FPC Flexible Packaging Corp., supra, and the cases cited therein.
47. The use of such broad words in Dayco to describe the kind of right that can be enforced
following the expiration of a collective agreement inevitably leads to a more careful assessment
of the appropriate application of time limits to ensure that important collective bargaining and
labour relations considerations continue to be taken into account. It would run counter to the very
essence of collective bargaining to create an environment that did not give effect to the adage
"labour relations delayed is labour relations denied". That applies equally to employers, unions,
and employees. Time limits form part of the negotiated rights and obligations in a collective
agreement and exist for a reason. The parties wish to have disputes, at the very least, identified
promptly for the reasons expressed in the quotes above. The opening clause of the collective
agreement between these parties highlights as a key purpose, to provide "a method for the
prompt and equitable adjustment of grievances of employees in the employ of the Hospital, or of
disputes between the parties without unnecessary delay or expense" (emphasis added).
48. Unlike the situation in Alexander Marine & General Hospital, I have no evidence to
suggest that the individual employees affected were not aware of their right to be paid
percentage-in-lieu up to the maximum of 52 weeks. They may have been unaware that they had
been paid incorrectly. However, I am satisfied that the employer did not mislead employees. As
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noted earlier, the chart apparently provided to Ms. Phillips-Scott was, at worst, ambiguous. The
other documentary material filed identifies the employer's mistake. The statements noted that the
employer had calculated the payment on the basis of only 35 weeks. That fact was not hidden by
the employer, had the employee sought to question it. Until Ms. Phillips-Scott, no one did.
49. Fundamentally, and as in Alexander Marine & General Hospital, these claims have merit.
The affected employees were entitled to receive the percentage-in-lieu for the full period of their
pregnancy and parental leaves to a maximum of 52 weeks. The employer received a windfall as a
result of its mistake; a windfall that now exists as a significant potential liability. In Alexander
Marine & General Hospital, the majority of the arbitration board took into account the fact that
part-time employees had received the shift premium throughout the period; an equity
consideration not present here. To the contrary, in this case, it is arguably inequitable to extend
the time limits, thereby allowing for remedial relief for some, when those with an earlier, but
identical claim, would be shut out. On the evidence, no differing considerations apply as between
any of the affected employees. As noted earlier, an employee's claim did not 'continue'
following their return from leave and each affected employee was subject to the time limits set
out in Article 9.02 of the collective agreement.
50. Unlike Alexander Marine & General Hospital, I also have no evidence that affected
employees were unaware of their rights. I am driven to the conclusion that affected employees
simply failed to assert those rights in a timely fashion. I am not persuaded that the fact these
employees were absent on pregnancy and parental leaves and were, according to the union,
focused on those responsibilities, provides an answer to the kind of delay evident here. As noted
in paragraph 36 above, while on leave, each employee's claim would be of a continuing nature
and, as such, might fall within the time limits and/or be amenable to an extension of the time
limits to a reasonable point shortly following that employee's return to work, given the particular
language in Article 9.02 of the collective agreement. That already allows a significant period of
time during which an employee taking pregnancy and parental leaves had the opportunity to
inquire into and/or verify or review her pay.
51. Having regard to all of the above, and where I find the equities for extending the time
18
limits to be less persuasive than those in Alexander Marine & General Hospital, in assessing
whether there are reasonable grounds for the extension without significant prejudice to the
employer, I am persuaded that it is appropriate to, and, I hereby exercise the discretion to extend
the time limits for the filing of this grievance to the effective date of the most recent collective
agreement, that is, September 10, 2007.
52. Turning to the question of remedy, the employer has admitted the breach of the collective
agreement. Part-time employees were entitled to receive percentage-in-lieu payments for the
period of their pregnancy and parental leaves to a maximum of 52 weeks. The employer paid
only to a maximum of 35 weeks. Accordingly, and having regard to my finding with respect to
the extension of time limits, I hereby order the employer to pay part-time employees who were
on pregnancy and parental leaves as of September 10, 2007 the balance of any percentage-in-lieu
amount that the employee was entitled to based on the length of that employee's leaves, to a
maximum of 52 weeks.
53. This grievance is allowed in part. I will remain seized with respect to any issue arising in
respect of the implementation of this award.
Dated at Toronto, Ontario this 31 st day of May, 2010.
Marilyn A. Nairn, Arbitrator.