HomeMy WebLinkAbout2020-1933.Jackson.2023-04-13 Decision
Crown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
GSB# 2020-1933
Union# 2020-0623-0005
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Jackson) Union
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The Crown in Right of Ontario
(Ministry of Natural Resources and Forestry) Employer
BEFORE Dale Hewat Arbitrator
FOR THE UNION Alex Zamfir
Ontario Public Service Employees Union
Grievance Officer
FOR THE EMPLOYER Erika Montisano
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING February 2, April 28, September 19,
2022, and March 8, 2023
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Decision
[1] This case involves a grievance, about whether certain duties performed by the
Grievor, after the end of various shifts scheduled between August 3 and October
12, 2020, during the 2020 active fire season, accrued compensating time off or
overtime in accordance with Articles UN 8.71, UN 13.7, and UN 8.75 of the
Collective Agreement. The specific dates in question involve work performed on
August 3, 5, 13, 14, 15, 17, September 16 and October 12, 2020.
[2] The Grievor is employed in a Schedule 6 position, in the classification of
Resource Technician, and holds the permanent position of Fire Response
Specialist. During the active fire season, which typically falls between April 1st
and October 31st each year, the Grievor fulfills the function of a Regional Duty
Officer (“RDO”) in the Regional Emergency Operations Centre (“REOC”). Within
Ontario there are two REOC centres; one in Sudbury and one in Dryden. Both
REOCS are governed by the Provincial Duty Officer who works at the Ministry
Emergency Operations Centre (“MEOC”).
[3] While the facts in this case are not in dispute, the interpretation of the functions
that the Grievor performed is disputed requiring a decision of whether the
functions were fire related or not. The Employer is of the view that all of the
functions performed by the Grievor on the days in question were fire related
deserving of overtime payments. The Union maintains that, other than work
done on August 14, 2020, the functions performed by the Grievor were not fire
related, and therefore, should have been accrued as compensating time off.
[4] Having considered the thorough testimony of all of the witnesses and Counsels’
detailed arguments and analysis, I have determined that the functions performed
by the Grievor on the days in question were fire related work and therefore
compensable as overtime hours. I have reached this conclusion on the basis
that the concept of fire fighting or related duties encompasses a broader scope
than simply performing duties only in response to an existing fire that requires
active suppression. As a result, I have decided that all of the functions that the
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Grievor performed directly stemmed from various incidents of fire or reports of
fire activity, and therefore, were deserving of overtime compensation under UN
8.7.5.
Applicable Collective Agreement Sections
[5] Overtime
UN 8.7.1
Effective August 15, 2005 employees in Schedule 6 who perform authorized
work in excess of 7.25 hours on a regularly scheduled work day shall receive:
(a) compensating leave of one (1) hour for each hour worked between 36.25 and
44 hours per work week, in respect of the total hours worked during the week on
regularly scheduled work days; and
(b) compensating leave of one and one-half (1.5) hours for each hour worked in
excess of 44 hours per work week, in respect of the total hours worked during the
week on regularly scheduled work days.
(c) The compensating leave shall be taken at a time mutually agreed upon.
Failing agreement, the ministry shall reasonably determine the time of the
compensating leave.
UN 8.7.4 Effective August 15, 2005 employees who are in classifications
assigned to Schedule 6 and who are required to work on a day off shall receive
compensating leave of one and one-half (1.5) hours for each hour worked.
UN 8.7.5
Notwithstanding Article UN 8.7.1 and Article UN 13.7 (Holiday Payment),
employees who are in classifications assigned to Schedule 6 and who are
assigned to forest fire fighting or related duties, shall be paid one and one half
(1½) times the employee’s basic hourly rate, to be calculated on the basis of
thirty-six and one-quarter (36¼) hours per week, for all such work after eight (8)
hours in a 24-hour period.
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[6] Holiday Payment
UN13.7
Notwithstanding anything in Article UN13, employees who are in classifications
assigned to schedule 6 and who are authorized by the Employer to work on a
holiday included in Article 47 (Holidays) of the Central Agreement shall receive
compensating leave of one and one-half (1.5) hours for each hour worked.
The Facts
[7] During the active fire season, the Grievor participates in a Compressed Work
Week program in which he is scheduled 10-hour days for 7 consecutive days
followed by 4 days off with a 2.5-hour shift overlap with the other RDO at the
REOC. Longer hours of work are required during the active fire season, in part,
because many fires start burning late in the afternoon or early evening. Like all
other Schedule 6 staff, the Grievor fills out a time-sheet called a data assistant
chart, for each day of work and indicates whether any overtime hours or the last
2 hours on a statutory holiday are fire related or not. The data assistant chart is
reviewed by management before finalizing the payment. If the hours are fire
related, they are labelled FIR indicating that an overtime payment is due. If the
hours are not fire related, they are labelled OV2 indicating that compensating
time off is due. In this case, the Grievor filled out his time-sheets for the days in
question noting that all of the hours were not fire related. Initially the time sheets
were approved by the Grievor’s manager, but were then changed to FIR because
management determined that the time sheets had been filled out in error. The
Grievor brought this grievance after his time sheets were changed claiming that
the duties he performed on the days in question were not fire related and
therefore deserving of compensating time off.
[8] As an RDO, the Grievor fulfills a number of response functions as outlined in the
Annual Fire and Emergency Response Operations plan with the overall
responsibility of developing the Strategic Operating Plan (“SOP”) and managing
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fire response. The RDO is the decision maker responding to inputs in relation to
prior planning and must be designated and contactable 24 hour per day. While
not an exhaustive list, the RDO leads the REOC planning team, approves the
daily strategic plan, sets priorities for resource allocation and dispatch, monitors
situations to ensure appropriate fire response, changes and adjusts the daily
plan, relocates crews, dispatches forest fire suppression equipment and aircraft
as fires develop or situations change and ensures system requirements are
satisfied including incident and fire status reports and ensures logs are kept by all
key staff. In his testimony, the Grievor explained that the SOP is prepared twice
daily to outline and provide guidance to the field of available resources, current
fires, weather conditions, logistical information, fire behaviour forecasting and
what the RDO sees as materializing in terms of expected hazard deployment.
When a fire is reported, the Grievor explained that he tries to ascertain as much
information as possible, including the type of smoke which may provide
information about the type and intensity of the fire, the proximity to populated
areas and water in order to determine the resources that may need to be
deployed. In addition, the REOC team ascertains the approximate position of the
fire and the values on the landscape with a higher value attributed, for example,
to a fire or report of a fire in close proximity to a highly populated area,
infrastructure, or an ecologically protected zone. In terms of tracking fires, the
regions are divided into sectors with numbers of fires or predictions of fires
assigned to each sector. Fires are also categorized as being, being observed
under control, out of control, or out. Fire crew availability and alerts are coded
either Red meaning that the crew is immediately available on a moment’s notice;
Yellow meaning crews must be ready within 30 minutes and Blue meaning the
crew might be working on other tasks but are available to respond within a longer
time-frame.
[9] The Grievor also explained that there are jurisdictional areas not within the
REOC’s responsibility, such as National Parks and the Georgian Bay Islands and
municipalities; however, the REOC may assist with a response to a fire situation
if requested by a municipality under a cost sharing arrangement. The REOC
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might also assist with emergencies through border agreements with the
Provinces of Manitoba and Quebec or when requested to assist by Federal
jurisdictions. The Grievor also explained that there are some instances when the
REOC will not issue a direct fire response, such as when it receives a report of a
fire that is remote and far from any communities and has a low value. In this type
of situation, the Grievor commented that a decision might be made to let the fire
run its course and burn out or arrangements might be made to have an aircraft
go out a number of days later to check on the status of the fire.
[10] Before reviewing the Grievor’s work activities for the days in question in this
matter, it is helpful to review the history of how work in the REOC during the
active fire season has been interpreted over the years. On May 7, 2004,
following a decision of this Board in OPSEU (Hollstedt) v. Ontario Ministry of
Natural Resource, GSB 0226/01 (Fisher), a memo was issued to all East Fire
Region Schedule 6 staff, by Ken Gibbons, Fire Program Manager East Fire
Region in an effort to clarify and provide guiding principles for the compensation
calculation for hours worked after a scheduled day during the fire season (‘the
Gibbons Memo”). In 2004, the Fire Response Centre (now REOC) Schedule 6
employees included a Duty Officer, Intelligence Officer, Air Operations and
Logistics Officer, who were scheduled on a variety of schedules, compressed
and non-compressed. The memo notes that compensation for Schedule 6
employees involved in fire response operations will be according to the Collective
Agreement and that hours worked after a scheduled shift will either be non fire
related or fire related. In the memo Mr. Gibbons wrote:
“Hours worked after an individual’s scheduled shift will be considered fire related
if the following applies:
- Ongoing fires which are exhibiting control problems or requiring sustained
action and require response centre support;
- Fires or incidents including Municipal fires that occurred prior to or after
the end of the day scheduled shift that require direct response centre
involvement after the end of the shift;
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- After the end of their scheduled shift, response centre staff is required to
assist in the support of a fire situation in another Region or acting on
CIFFC requests resulting from fire activity in another jurisdiction.
Fires that would not normally be considered for “fire related” would be fires
being observed and pose no threat to human life or property or those
under control which do not require ongoing support.
The decision for all other Schedule 6 employees regarding whether or not
fire related compensation for premium hours worked is applicable will be
made by the individual’s manager based upon the question – “If it was not
for the existence of a particular fire or support for fires that require the
individual’s direct involvement, would the duties be performed by the
employee?”
[11] The Grievor testified that since he began working in the REOC in 2010, the
Gibbons Memo applied to his duties. He stated that his understanding of the
Memo was that hours worked after a regularly scheduled workday would be
considered fire related if the REOC was directly involved in responding to a fire
that had been assigned a fire number and was deploying assistance and
resources. In contrast, the Grievor explained that if duties involved normal
functions like extending crews in case their assistance was required or waiting for
crews to return then such duties would not be considered fire related and the
time spent after hours would be calculated as compensating by time off.
Similarly, the Grievor interpreted the Memo as listing situations which would not
be considered fire related where, for example, fires are deemed to be under
control or where they are being observed because they might self-extinguish or
where the fire is located in an area valued as a low risk of spread or damage.
When asked what fire related meant to him, the Grievor pointed to the Memo
referring to when a fire becomes out of control, requiring sustained action of
crews and resources and planning, or where the REOC is called to assist with a
municipal fire or where the REOC is called to assist by deploying water bombers
to another region in the province or contacted by the Canadian Interagency
Forest Fire Centre to assist with a fire on a national scale. According to the
Grievor, he submitted time-sheets for compensating time off and was regularly
paid accordingly for work that he viewed as not fire related until August 2019.
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[12] On August 19, 2019 Bruce Duncan, the REOC manager at the time, sent an
email to Schedule 6 staff indicating that they had been filling out the time sheets
incorrectly and referred staff to an email that he had received from Tammie
Thibault, Business Management Coordinator. That memo indicated that on a
normal day during the active fire season an RDO would not accrue compensating
time off know as OV2 (banked overtime) or OV3 (banked overtime in excess of
44 hours per week). In her testimony, Ms. Thibault explained that during the
active fire season, an RDO would be entitled to receive compensating time off as
per the Collective Agreement for the first 8 hours worked on a scheduled day off
or for the first 8 hours worked on a statutory holiday. According to Ms. Thibault,
any additional hours would be coded as FIR or fire related as the RDO would be
engaging in fire response functions in the REOC. This interpretation was also
reiterated by Mr. Duncan in his response to the Union in an email dated
September 9, 2019 in which he explained that from Management’s perspective,
the REOC response roles are considered fire related. He also distinguished fire
response roles from fire training roles and indicated that the Hollstedt decision
did not apply to Management’s interpretation of fire related duties and the
consequent accrual of overtime rather than compensating time off. During her
testimony, Ms. Thibault explained that the Grievor had entered the hours in
question as OV2, which had been approved by Mr. Duncan but that she changed
the entries once she was advised that they should have been entered as fire
related. When questioned why she made the changes despite Mr. Duncan’s
prior approval, Ms. Thibault stated that she believed that Mr. Duncan might not
have known what Schedule 6 staff were entitled to. She admitted that she did
not review the work that the Grievor performed on the days in question before
changing the entries to fire related hours. However, she stated that the
interpretation of how hours are defined must be based on the function being
performed at the time and that the functions performed during the active fire
season by the Grievor in the REOC were fire related. She also agreed that the
Grievor would not stay at work beyond his regularly scheduled hours to update
manuals or policies. The Employer agreed that prior to Ms. Thibault’s email in
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2019, during prior fire seasons the Grievor routinely requested that hours worked
after the end of his shift, on a regular day, would be compensated as
compensating leave, and such compensating leave was granted routinely while
fulfilling the function of Regional Duty Officer.
[13] Paul Riopel, the current Fire Regional Response Co-ordinator and Manager of
the REOC, also testified about his interpretation of what functions are fire related.
According to Mr. Riopel, he understood that the Gibbons memo was issued to
clarify fire related and non fire related work that applies to REOC staff and other
Schedule 6 employees. He testified that the Gibbons memo is no longer being
followed and has been superseded by the 2019 memo from Mr. Duncan which
clarifies that all fire response functions in the REOC are fire related. He
explained that the REOC has evolved over time and that there are other non-fire
related incidents that REOC might be asked to assist with such as tornado relief,
search and rescue and flooding. He also indicated that for some time staff are
no longer required to list a fire number when inputting hours on time sheets. He
also explained that on a slow day during the active fire season, an RDO might
work on projects that belong to the home position, such as updating manuals or
policies. However, he explained that the function of anticipating fire activity and
being ready to respond to an incident are fire related functions. For example, in
Mr. Riopel’s view waiting for a helicopter and crew to return is fire related
because the crew and helicopter were dispatched to a fire assignment. While he
agreed on cross-examination that there could be situations that are not fire
related as outlined in the Gibbons memo, he remained steadfast that if it was not
for the existence of fire activity, the Grievor would not have stayed past his
regularly scheduled hours on August 5, 13, 14, 15, 17 and September 16 or
fulfilled fire related functions during the last 2 hours of his shifts on August 3 and
October 12, 2020 which were statutory holidays.
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[14] Days in Question
The Grievor worked a 10-hour shift on August 3, 2020 which was a statutory
holiday ending his work day at the completion of his shift. He testified that it was
a quiet day in terms of fire activity, with only 15 crews out of 66 having been
deployed throughout the province and with clear weather with little wind. In his
log book the Grievor noted that he attended a weather meeting in the afternoon
and that by he made notations asking if crews, who had been delayed, had
arrived back from at fire in the north west region at 17:44 and 17:46 pm and
confirmed their arrival at 17:50 p.m. He testified that he decided to make sure
they had arrived back and to make a call to confirm their arrival. At 18:40 he was
contacted by a Sector Regional Officer regarding smoke on the west side of Red
Lake near Cochrane. His log book entry noted that he would be discussing the
fire incident in Cochrane with his colleague the following morning. During the last
2 hours of his shift, the Grievor claims that he did not perform any fire related
work as there was not particular fire for the REOC to respond to at that period of
time. He did agree, during cross-examination, that he was fulfilling RDO
functions with respect to his log book entries and noted that he did not always
make a notation of a crew arrival but did in this case because the plane had been
delayed in its return. In contrast, Mr. Riopel testified that the Grievor engaged in
fire related functions because of the crews arriving back from a fire response and
because he logged information about dealing with responding to a smoke report
which would be reviewed the next morning.
[15] On August 5, 2020, the Grievor stayed 1 hour past the end of his shift. He
explained that he made the decision to stay longer because a large brush fire
and white smoke had been reported at 6:28 p.m. near the Municipality of
Sudbury. Given the time of day and the fact the crew had been dispatched and
was in proximity to fire, the Grievor decided to extend crews by asking them to
stay longer in case assistance was needed. The Grievor explained that
sometimes it is more efficient and cost effective to extend crews, like having
“cheap insurance,” than having to call crews back after their shifts have ended.
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The Grievor also agreed that he forgot to make a notation in the August 5, 2020
logbook that he had extended the crews availability from 7 to 8 p.m. that evening,
noting that it was an oversight. He also explained that as the RDO it is his
responsibility to remain at work when crews have been extended and when
awaiting the safe arrival of aircraft or helicopter crews. Despite the decision to
extend crews, the Grievor maintained that this decision did not involve any fire
suppression activity but instead was simply a decision to keep crews available in
case their services were needed by the Municipality, which did not unfold. From
Mr. Riopel’s perspective, all duties that the Grievor engaged in after the report of
the fire were fire related because they involved responding to the Municipality
and making crews available to assist.
[16] On August 13, 2020 the Grievor also stayed 1 hour past his regularly scheduled
shift because he decided to extend crews in response to a report of a fire in the
Timmons area. Earlier that day a helicopter had been dispatched to investigate
the fire but was unable to land due the conditions. Following that landing
attempt, a decision was made to try to access the fire by boat. However, due to
safety reasons it was decided that fire suppression action would not be done
during the night and instead crews would be dispatched the following morning.
The Grievor remained at the workplace an additional hour until the helicopter
crew safely returned. The Grievor explained that since there was not fire
suppression or a direct response taken to deal with the fire beyond an attempted
landing by the helicopter, him remaining at work for the additional hour was not
fire related. When questioned about this day, Mr. Riopel explained that the
REOC responded to the initial fire reports to offer support and that waiting for the
return of the helicopter and crew was an extension of responding to the fire, and
therefore was fire related.
[17] In contrast, the Grievor agreed that what occurred on August 14, 2020 was fire
related and thus the additional 2.5 hours that when he remained at work were
properly classified as overtime hours. On that day, the Grievor explained that
there was a direct response to a fire that had been reported in the Sudbury
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district which required a second fire crew to be dispatched for assistance with fire
suppression, including water-bombing air attacks. Given the nature of the fire, it
was given a fire number. Although, the northeast region had ultimate
responsibility for this fire suppression, the Grievor made the call to extend the
time his crew was on location to assist and remained at work until they returned.
[18] On August 15, 2020 the Grievor stayed past his regular work day because he
needed to remain in the office until the crew returned from investigating a report
of a fire at Lady Evelyn provincial park. A Red crew was dispatched to
investigate the fire and at 5:00 p.m. the Grievor made the decision to extend the
crews’ time there. It turned out that the fire did not require suppression as it was
located at an end of a narrow peninsula with minimal chance of expansion. As a
result, a decision was made to keep observing the fire but that it was not
necessary for the crew to remain at the site. Again, the Grievor explained that
his remaining at the office for the additional hour was not fire related because he
was simply following up on his responsibility as the RDO to ensure the safe
return of a crew. In contrast to the Grievor’s interpretation, Mr. Riopel noted that
crews had been extended to respond to an active fire incident and he viewed the
time spent by the Grievor as engaging in fire related functions.
[19] On August 17, 2020 the Grievor responded to a report of a fire near Stonecliff
Ontario. A helicopter and crew were dispatched at 5:20 p.m. to the Haliburton
region to investigate. Upon arrival the crew reported that there was no smoke or
fire in sight. The Grievor stayed past the end of his shift again to wait for
helicopter and crews’ return, which was delayed because it had to land to refuel
before returning. From the Grievor’s perspective, the additional time that he
remained at work was not fire related because upon investigation it was
determined that a fire did not exist; however, he was required to stay at work to
ensure the safe return of the helicopter and crew. From Mr. Riopel’s perspective,
he viewed the additional time spent by the Grievor as a fire response function
and responsibility associated with the initial call and deployment of the crew,
even though a fire did not materialize.
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[20] On September 16, 2020 the Grievor stayed an additional hour at work because
he was waiting for a crew to return from a fire investigation and response earlier
that day. The crew had been dispatched at 8:30 a.m. to Wawa Ontario in
response to a small fire which was deemed under control by 4:20 p.m. The
Grievor remained at work past his regular scheduled shift because there was a
delay in finding air transportation to bring the crew back to the office. Again, the
Grievor testified that the additional time he spent at work was not fire related
because there was not a response to a fire, no suppression and he was simply
waiting for the crews’ return. In contrast, Mr. Riopel maintained that bringing
crews back from a fire is fire related because it is the fulfilment of a fire response
function in the REOC. Mr. Riopel noted that there was a fire on this day that the
REOC had responded to by dispatching crews, and therefore, waiting for the safe
return of the crew was fire related.
[21] The Grievor worked his regularly scheduled shift on October 12, 2020, which was
a statutory holiday and did not stay past the end of his shift. He testified that
there were reports of small fires in the morning but that no action was required to
deal with them as they had been extinguished earlier in the day. Around 5:00
p.m. that afternoon, there was a report of a small fire on an island in the
Haliburton Ontario region but it was decided that no action was needed to
supress the fire. In addition, the REOC received a call from a member of the
public concerning a tree on fire that had fallen on a power line in a rural area.
The Grievor determined that no one was needed to attend at the fire scene given
the low risk of the fire spreading and because the local hydro unit could deal the
situation. From the Grievor’s viewpoint, during his last 2 hours of work that day,
he was not engaged in fire related work given that there was no response action
or directions given to supress the reported fires. From Mr. Riopel’s perspective
the work that the Grievor completed that day was fire related because the
Grievor was required to deal with an initial report of fire related incidents. The
fact that the fires did not require suppression did not take away from the fire
response function, according to Mr. Riopel.
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Union Submissions
[22] The Union argues that the Employer, in this case, has applied UN 8.7.5 in an
overly broad manner without regard to the actual work performed and treated
routine duties as being fire related when there was not a response to an existing
fire. The Union states that this Board in OPSEU (Hollstedt) v. Ontario Ministry of
Natural Resource, GSB 0226/01 (Fisher) previously held in interpreting
predecessor language to UN 8.7.5., a duty that falls within the ambit of “assigned
to forest fighting or related duties”, requires a determination as to whether: If it
were not for the existence of a particular fire, would these duties have been
performed by the employee? The Union submits that I am bound to follow
Hollstedt in light of the GSB decision in Amalgamated Transit Union (Blake et
al.) v. Ontario (Toronto Area Transit Operating Authority) , GSB No. 123/87
(Shime).
[23] The Hollstedt case involved the question of whether teaching a pre-scheduled
forest fighting training course by a Schedule 6 employee during the fire season
constituted “related duties” under a predecessor version of UN 8.7.5. In that
case the issue was whether the Grievor was entitled to overtime compensation if
the teaching was found to be fire related. The Union submits that Hollstedt
stands for the proposition that in order for duties to be found as fire related an
actual fire must exist and not a theoretical or potential one. While Hollstedt dealt
with training courses, the Union argues that the relevant consideration under UN
8.7.5. is the one posed in Hollstedt that if were not for the existence of a fire,
would the duties have been performed? Applying that test to this case, the Union
states that only where there is a specific response to an existing fire on the
landscape involving sustained action and suppression, does a duty become fire
related.
[24] While acknowledging that the Gibbons memo is not enforceable, the Union
asked that I consider and apply its guidelines and principles. The Union noted
that it was prepared about 1 year after the Hollstedt case and was relied on by
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Management and Staff for a number of years to clarify whether duties were fire
related or not. In addition, the Union pointed to Ms. Thibault’s testimony and the
Employer’s acknowledgement, that up until 2019, the Grievor did receive
compensating time off instead of overtime payments for additional hours worked.
[25] The Union maintains that it cannot be, as suggested by the Employer witnesses,
that all work in the REOC during the fire season, is fire related. Again, the Union
submits that the actual work performed must be assessed and asks me to
consider that Gibbons memo contemplated that there can be both fire related
and non fire related duties occurring during the active fire season.
[26] Turning to the days in question, on the statutory holiday of August 3, 2020, the
Union argues that the evidence shows that it was a quiet day with usual weather
briefings and conference calls with colleagues in other fire regions, crews arriving
back and monitoring of a fire that was labelled under control. While there was a
report of smoke near Cochrane late in the day, the Union states that the Grievor
testified that by 5:00 p.m. that day there were zero incidents to report. From the
Union’s perspective, the Grievor did not perform any fire related duties.
[27] With respect to August 5, 2020, the Union states that what caused the Grievor to
stay late was his decision to extend the crew to remain available to assist with a
large brush fire that had been reported near Sudbury. In making the decision to
hold the helicopter and crew, the Union argues, as the Grievor explained, that the
REOC was acting a good neighbour in the form of cheap insurance in case
further support was needed. In the end, the crew’s assistance was not required
as no further response was required by the Municipality. From the Union’s
perspective, the situation on August 5, 2020 fits squarely within the Gibbons
memo characterization that when a fire is under control and does not require on-
going support the situation should be considered as not fire related.
[28] Regarding duties performed on August 13, 2020, the Union submits that while
crews responded to a report of a fire, suppression action was not performed
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because a decision was made, for safety reasons, to let fire burn overnight to be
dealt with the following morning. As a result, the Union submits, that waiting for
the helicopter and crews’ safe return was not fire related because no response
was required at the time.
[29] With respect to August 15, 2020, the Union states that a helicopter and crew
were dispatched to investigate a report of a fire at Lady Evelyn provincial park
and upon investigation the decision was made to observe the fire. From the
Union’s perspective the Grievor did not perform fire related functions in waiting
for the helicopter and crew to return because there was no action of suppression
or response required.
[30] The Union argues that the Grievor did not engage in fire related duties after the
end of his shift on August 17, 2020. On that day, although a helicopter and crew
were dispatched late in the day to investigate a report of a fire near Haliburton,
no fire was found and the Grievor remained at work late because he was waiting
for the crew’s return which was delayed due to refuelling issues. The Union
submits that the investigation of the fire report occurred well before the end of the
Grievor’s shift, and therefore, his decision to remain at work was to ensure the
crew’s safe return and not for fire related reasons.
[31] Similarly, on September 16, 2020, the Union maintains that what kept the Grievor
late at work was due to his need to remain at work to wait for the safe return of a
crew who had been dispatched earlier in the day to investigate a fire in Wawa
that was deemed under control later in the afternoon. The Union states that the
evidence showed that the crew was delayed in returning because they had to
wait for another helicopter to pick them up and that their delay, not fire related
reasons, caused the Grievor to extend his time at work.
[32] Regarding the statutory holiday hours on October 12, 2020, the Union submits
that the evidence shows that the Grievor’s last 2 hours of work did not involve fire
related duties. In this regard, the Union points to the Grievor’s evidence that it
was a quiet day in terms of fire activity. The Grievor testified about a report of a
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small fire in Haliburton in which it was determined that it was not likely to expand
and that no suppression was required that day. Additionally, the Grievor referred
to a report of a tree power line fire near Sudbury in which it was determined that
no suppression action would be required from the REOC.
[33] In contrast to all of the days summarized above, the Union argues that there is a
clear distinction between the duties that the Grievor performed on August 14,
2020 which it agrees were fire related. Compared to time spent waiting for crews
and helicopters to return where a fire is under control, being observed or where
no fire exists, the functions performed on August 14, 2020, involved a specific fire
suppression response with resources deployed and water bombing engaged.
Employer Submissions
[34] The Employer argues that UN 8.7.5 is clear and unambiguous when it refers to
forest firefighting and related duties. In that regard, the Employer emphasizes,
for example, that there is no requirement that a fire has to materialize or that
suppression efforts must exist or that a fire number be assigned in order to
characterize work as forest firefighting or related duties. By including the words
related duties, the Employer suggests that this signals a clear intention to
broaden the scope beyond pure forest firefighting.
[35] The Employer relies on the decision OPSEU (Union Grievance) v. Ontario
(Ministry of Natural Resources) GSB No. 2156/87 (Dissanayake), in support of its
view that fire suppression is irrelevant for the purposes of UN 8.7.5. In that case,
a grievance was brought alleging that the Ministry failed to pay overtime pursuant
to an earlier version of UN 8.7.5 to Schedule 6 employees assigned to forest fire
fighting on prescribed burns. As noted at page 3 of that decision, a “prescribed
burn” is a deliberate application of fire to a specific area of the forest under
predetermined conditions and it most commonly used for silvicultural objectives
to prepare a site for tree planting. When the grievance was filed in that case,
Schedule 6 employees who were assigned to a prescribed burn did not receive
overtime because the Ministry maintained that they were not assigned to forest
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fire fighting or related duties. The Ministry also took the position that Schedule 6
employees were not engaged in fighting a fire or related duties in terms of
offensive suppression of a fire but rather were engaged in the act of monitoring
which would not attract overtime. Arbitrator Dissanayake found in favour of the
Union by concluding that the distinction of suppression did not apply and instead
found that readiness to go into action must fall withing the meaning of fire fighting
or related duties. At page 12 of his decision, he wrote: “Surely an employee who
is monitoring a fire in readiness to go into action if required must come within that
term. The employee is on duty in a fire fighting or related role whether he is in
fact required to go into action.”
[36] The Employer maintains, as explained by Mr. Riopel, that during the active fire
season the Grievor, as RDO, is responsible for the duties of a fire response
function no matter which way his role is examined. During the active fire season,
the REOC runs as a 24/7 operation with staff on standby until midnight and the
Compressed Work Week schedule is in place so that employees at work are
ready to respond to fires that often peak in late afternoon or early evening. In
addition, the completion of the SOP twice daily reviews currents fires, weather
behaviour and forecast and the determination of the deployment of resources in
the event a response is necessary. From Mr. Riopel’s perspective all REOC staff
perform fire related work during the active fire season.
[37] In terms of the Gibbons memo, the Employer notes that Mr. Riopel testified that
the memo no longer applies and that, in any event, it was meant to provide a
non-exhaustive list of guidance to clarify fire related and non fire related duties to
both the REOC and non REOC staff. In addition, Mr. Riopel testified that things
have evolved over time in REOC and noted, for example, that fire numbers are
no longer required to be inputted on time sheets. The Employer asked me to
accept Mr. Riopel’s testimony as evidence of less reliance on duties being tied to
the existence of an on-going fire but rather to a broader set of fire related
incidents requiring a response.
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[38] With respect to the decision in Hollstedt, the Employer states that the
circumstances in this case are distinguishable and that the question raised in
Hollstedt must be looked at more broadly in terms of response to a fire. In his
position as RDO in the active fire season the Grievor’s functions are a fire
response role. In Hollstedt, that Grievor was engaged in teaching pre-scheduled
fire training courses, whereas, the Grievor in this case did not preschedule
overtime but was required to remain at work either because there was a report of
a fire requiring investigation, or crews were extended due to a potential fire
activity, or crews were returning from dealing with a fire activity. Had these
events not occurred, the Grievor would not have stayed past his regularly
scheduled shift. In addition, on the statutory holidays of August 3 and October
16, the Employer states that while those days did not involve overtime hours, the
work performed by the Grievor during the last 2 hours of his shifts involved fire
related response functions.
[39] In terms of the days in question in this case, the Employer maintains that on
August 3, 2020 during the last 2 hours of his shift the Grievor engaged in fire
related duties as evidenced in his testimony and what was written in his log book
that Red crews arrived in Haliburton just before 6:00 p.m. In addition, the
Employer points out that in cross-examination the Grievor clarified that crews
were assisting with fires at that time and that Mr. Riopel testified that the duties
performed were fire related in the Grievor’s capacity as an RDO.
[40] On August 5, 2020, the Employer submits that the functions performed by the
Grievor as RDO were fire related because a decision was made to leave crews
on alert, whether or not their assistance was needed by the Municipality.
Although the Grievor spoke about the decision to extend crews as a form of
“cheap insurance,” the Employer argues that the crews were ready to respond to
a fire and therefore the Grievor’s function and duties must be viewed as fire
related. The Employer also argues that I should take note of the fact that the
Grievor did not log full information about extending crews despite the fact, in its
view, the decision to extend crews was a fire related duty.
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[41] With respect to August 13, 2020 the Employer asserts that the Grievor in his
function of waiting for a crews’ arrival was a direct result of the REOC’s response
to a fire, despite the fact that the helicopter could not land and that a decision
was made to deal with the fire by boat approach the following morning. Similarly,
the Employer maintains that on August 15, 2020 the decision to extend crews
and to wait for their arrival was a fire related response to a report of a fire,
despite the fact that upon investigation a determination was made that
suppression was not warranted at that time.
[42] Regarding August 17, 2020, the Employer argues that the time spent waiting for
the return of helicopter crew was due to an earlier deployment of the crew that
day to deal with a fire. The Employer points to the evidence of Mr. Riopel in
which he explained that the REOC receives many calls daily and is always
required to determine and investigate whether a fire is burning and confirmed
that a crew was deployed that day. Mr. Riopel reiterated a similar viewpoint
about what occurred on September 16, 2020 noting that the Grievor was fulfilling
a fire related function not only in deploying a helicopter earlier to respond to a
fire, but also in waiting for the crew to return once the fire was under control.
[43] With respect to the Grievor’s activities on the statutory holiday of October 12,
2020, the Employer submits that there were 2 reports of fires that were
investigated by crews and it was determined that no suppression was required.
Again, Mr. Riopel maintained that the reports of fire required the REOC to
respond, investigate even if suppression was not needed, and therefore the
duties performed by the Grievor the last 2 hours of that day were fire related.
Decision
[44] The Collective Agreement clearly sets out when Schedule 6 employees are
entitled to compensating time off under UN 8.71. UN 8.7.4 and UN 13.7.
However, an exemption to the accrual of compensating time off is found in UN
8.7.5 which provides for the payment of overtime rates to a Schedule 6 employee
assigned to forest fire fighting and related duties, after 8 hours of work on a
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regularly scheduled day or on a statutory holiday. The question before me is
whether the Grievor performed related duties to forest fighting on the days in
question.
[45] I agree with the Employer’s submissions that the concept of fire suppression is
not required in order for a duty to be related to fire fighting. The Collective
Agreement does not contain language which would suggest that a fire needs to
be active or that suppression activities must be engaged when it uses the words
fire fighting. By adding the words “and related duties,” it follows that there is an
understanding that fire fighting involves a broader range of duties and functions
to support fire response that are related to the activity of fire fighting. Having
listened to the Grievor’s very thorough testimony about all the functions that are
performed by him and the REOC to monitor and respond to fires and reports of
fire activity, it is evident that the activity of fire fighting entails a broad range of
functions both preventative and reactive.
[46] I am persuaded by the reasoning in OPSEU (Union Grievance) v. Ontario
(Ministry of Natural Resources) GSB No. 2156/87 (Dissanayake) that the notion
of readiness to go into action or the monitoring of a fire which does not
materialize falls withing the meaning of “fire fighting and related duties” and that
suppression action is not required. While this case involved a prescribed burn
situation, the response functions of the REOC and of the RDO of being ready to
assist or monitor in the event of a fire’s expansion, or where a fire starts but does
not require further response, equally applies in this case.
[47] Having reviewed the reasoning in Hollstedt, the question asked by Arbitrator
Fisher is appropriate. However, given my reading of the language in UN 8.7.5
together with the reasoning in Arbitrator Dissanayake’s decision, I am not
convinced that the decision stands for the narrow principle that only if there is an
existing fire that requires a direct response and suppression does the language
of “ fire fighting and related duties apply.” In that case Arbitrator Fisher reviews
the Board’s ruling by Arbitrator Dissanayake and then asks the question if it were
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not for the existence of a particular fire, would these duties have been
performed? At p. 3, Arbitrator Fisher states:
“If the answer is no, then the duty is related to fire fighting. For instance, if
one’s duty was to roll up hoses after the fire was extinguished, then one can
say that it is a function that would not have been performed but for the prior
existence of a fire. If the answer is yes, then the duty is not related to fire
fighting. Thus, if the job duty was to check hoses for leaks every month, no
matter what they were used for, one could say that this not related to fire
fighting because the duty would have been performed whether or not there
was a fire.”
[48] The duty of teaching fire fighting courses is very different from the duties that
were performed by this Grievor which in my view were duties that related to fire
fighting activities. Waiting for a helicopter and crew to return after a fire was
deemed under control or where a fire was reported requiring a deployment of a
crew that evolves into circumstances where the municipality no longer requires
assistance, is no different than Arbitrator Fisher’s example of rolling up a hose
after a fire is extinguished. In Hollstedt, it was concluded that the pre-scheduled
course was taught on days without regard to the existence of any particular fire.
In contrast, in this case, the reasons that the Grievor stayed late and worked on
fire response activities on the regularly scheduled days in question and on the 2
statutory holidays was as a direct result of the existence of a fire or report of a
fire that was being investigated or required direct response that could not have
been preplanned.
[49] While the Gibbons memo attempted to clarify fire related and non fire related
duties, it is not a binding document. It provided some guiding principles and a
non-exhaustive list of examples of situations that might be considered fire related
or not. Ultimately the memo indicated that it was up to a manager to make the
determination of whether a duty is fire related, which is further indication that the
memo set out guiding principles. Although there was evidence that the Grievor
had received compensating time off in the past for duties performed after hours
during the active fire season, Schedule 6 staff in the REOC were put on notice by
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Mr. Duncan’s August 19, 2019 memo which clarified that time sheets had been
inputted incorrectly. The fact that Mr. Duncan had approved the Grievor’s time
sheets which were later changed by Ms. Thibault does not persuade me that the
work performed in this case was not fire related. Ms. Thibault testified that she
was following the terms of the Collective Agreement and had advised Mr.
Duncan of the need to make the correction. From her perspective, despite not
reviewing the work performed by the Grievor, all the duties performed were fire
related as part of the Grievor’s functions RDO pursuant to the Collective
Agreement.
[50] Looking at the days in question I am satisfied that the duties performed by the
Grievor were fire related and I accept Mr. Riopel’s explanation that there was a
direct connection between a fire response function underlying the reasons that
Grievor stayed late on August 5, 13, 15, 17 and September 16, 2020 and the
work he performed during the last 2 hours of his shifts on the statutory holidays
of August 3 and October 12, 2020.
[51] Had a fire or report of a fire or fire investigation not occurred, or had crews not
been deployed or extended, there would have been no reason for the Grievor to
remain at work after hours on his regularly scheduled days or for him to fulfill the
fire related function on the two statutory holidays in question. From my
perspective, for example, the fact that a crew was delayed returning from a fire
that was deemed under control or a decision was made to deal with a fire the
following morning because it was both unsafe for a helicopter to land and to
attack the fire during the night, does not detract from the original fire response
reason that a crew and resources were dispatched. Similarly, responding to a
report of fire that does not materialize, does not mean it is not fire fighting and
related duties. The concept of being ready to go into action and monitoring even
if a fire does not materialize has been found by the Arbitrator Dissanayake to fall
withing the meaning of fire fighting and related duties and I apply that reasoning
equally to this case.
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[52] Accordingly, this grievance is dismissed.
Dated at Toronto, Ontario this 13th day of April 2023.
"Dale Hewat”
Dale Hewat, Arbitrator