Loading...
HomeMy WebLinkAboutGagliardi et al 18-12-06IN THE MATTER OF AN ARBITRATION BETWEEN: ONTARIO PUBLIC SERVICE EMPLOYEES UNION (the "Union") - AND - MUNICIPAL PROPERTY ,ASSEWMENT CORPORATION (the "Employer") AND IN THE MATTER OF GRIRVANCES REGARDING SPECIAL COMPENSATION ENTITLEMENT UNDER LETTER OF UNDERSTANnING ##1 SOLE ARBITRATOR Robert D. Howe APPEARANCES For the Union Ed Holmes, Counsel David Lynch David Taylor John Paul Gagliardi Danny TQma i Tony Racioppo Mary Stiliadis Kelly Blakely Leo Ferreira Mack McLachlan Jeff Leedale John Odoom For the Employer John Saunders, Counsel Grant Nuttall Natalie Slake Edward Broderick A hearing in the above Matter was held in 'Toronto, Ontario, on November 15, 2018 A_W A R D This award pertains to issues regarding entitlement to "special compensation" under Letter of [understanding #1 (the "LOU") appended to the January 1, 2016 to December 81, 018 collective agreement (the "Agreement") bctween the Union (also referred to in this award as "OPSEU"} and the Employer. That LOU provides This will confirm that full-time employees who accepted employment with MPAC at the time of the transfer, December 31, 1998, or who acQepted positions with MPAC as a result of job postings for approximately "29 Corporate Services positions" posted on or before Decerfber 31, 1999 will receive a special compensation entitlement equal to one (1) week per year of combined service with the OPS and MPAC to a maximum of twenty- six ( 6) weeks ending January 1, 2016 less one (1) week per year of OPS service for which termination or severance pay has been paid at the time of the transfer, multiplied by the M2AC salary as of January 1, 2016. This includes any severance pair under the Employment Standards Act. The payment of this money shall satisfy MPAC"s obligations pursuant to LOU #1 notwithstanding the fact that the eligible employees have not died or peen tex:minated. The money shall be paid out pursuant to the options in the Memorandum of Settlement dated June 17, 2016. This entitlement also applies to full-time Ministry of Finance employees who were on long-term disability prior to December 31, 1998 who have returned to work and comme-aced full-time employment with MPAC in the bargaining unit on or before December 31, 1999 or who were able to return to work on or before December 31, 1999 under a medically -approved rehabilitauion }grogram which will lead to full-time employment shortly thereafter. Counsel agreed to argue the issues on the haeis of facts stipulated during the course of their submissions, and exhibits entered into evidence on the agreement of counsel. Those facts pertain to examples provided by certain grievances selected from the 21 grievances that are currently before me 1 in these proceedings, The Ontario Property Assessment Corporation, {110PAC"} was created by statute on December 31, 1995 to perform property assessment functions which had previously been performed by the Ontario Ministry of Finance (the ,MOF,,). It was subsequently renamed the Municipal Property Assessment Corporation (r'MPAC"). Most if not all of the classified and unclassified empioyccs who had been performing those functions at the MOF were offered jobs with pPAc. Unclassified employees were employed at the MOF through individual contracts that ran from one specified date to another specified date. Unlike classified employees, they had no job security and their rights under the January 1, 1994 to December 31, 1998 Ontario Public Service ("ops"} Collective Agreement between OPSEU and the Management Board of Cabinet (the "OPS Agreement") were very limited_ The 381 unclassified employees who accepted employment with OPAL were hired as temporary employees through individual contracts effective from one specified date to another specified date, or for a period of 'yup to one year's duration" from a specified starting date. The approximately 1200 classified employees who accepted employment with OPAC/MPAC were hired into nontemporary positions. Under the OPS Agreement, classified amplc�yees were entitled to receive "termination pay", which was a severance payment of one week per year of service for each year that they work(�d beyond five years of service. Unclassified 2 cmployces had no entitlement to that payment. The CAPS Agreement also contained provisions regarding the Conversion of unclassified positions to classified pos tions, including Article 31.15.1.1, which provided as follows: Effective upon the date of ratification, wh.erG the same work has been performed by an employee in the Unclassified, Service for a period of at least two () consecutive years, except for situations where the unclassified employee is replacing a classified employee on a leave of absence authorized by the Employer or as provided for uDder the Collective Agreement, and where the ministry has determined that there is a continuing need for that work to be performed on a full-time basis, the ministry shall establish a position within the Classified Service to perfoxm that work_ To facilitate an orderly transfer of the duties and responsibilities of property assessment functions, the MOF and OPAC entered into a Memorandum of Understanding which included the following items - ITEM 6: TRANSFER OF ASSETS 6.1 The Ministry shall transfer all assets ownc-d by the Government of Ontario at the time of transfer, located in regional assessment office locations occupied by the Property Assessment Division (PARI at no charge to OPAL. The Ministry shall transfer to OPAL all office supplies and cquiprn(�nt owned by the Govcrnment of Ontaxio at the time of transfer and used by PAD at the head office in Oshawa except the desks, tables, chairs, filing cabinets, bookcases and phones. ITEM 16: SPECIAL PROVISION FOR CORPORATE SERVICES STAFF 16.1 OPAL recognizes that up to 29 positions (F.T.E.$) in the Mirlistry's Corporate Services Division (Human Resources, Information Technology, Corporate Planning and Finance, Audit Services) and Freedom of Info=ation and 3 Privacy Office (collectively referrers to as "Corporate Services positions") may he impacted by the transfer of the PAD_ Therefore, if, between the date of the signing of this memprandum and December 31, 1999, OPAC establishes the need for and conducts initial corapetitions to fill such Corporate Services positions, it will include i -a its search area for the initial competitions, those employees who were employed in the Corporate Services Division on the date of the transfer (12:01 a.m. Dacc�mber 31, 1998) and who remain similarly employed at the date of the initial competition. If Ministry Corporate Services staff are hired by OPAL directly as a result of the foregoing paragraph, such employees will be offered employment on the teams and conditions and employee benefits as if they had leen PAD Employees who became OPAL employees on the transfer date. This applies only to the initial competition and to no more than 29 positions. OPAC's search obligation is satisfied by providing the Ministry with a copy of the appropriate job posting. Nothing herein obligates OPAL to hire anyone or use any particular selection criteria. A letter of understanding providing for 'Special compensation entitlement on termination" was included in the first collective agreement entered into by OPAL and OPSEU, and has formed part of each of the collective agreements which OPAL/MPAC and OPSEU have entered into since that time. The letter of understanding initially provided that the special compensation would be received "on termination or death". ''hat resulted in employees who had not reached the 26 week maximum continuing to accumulate additional weeks of entitlement. Powcever, during the course of bargaining the January 1, 2016 to December 31, 2018 collective agreement, the parties agrc�,-d to delete that phrase and to add the words 4 "ending January 1, 201611 after the phrase "to a maximum of twenty-six (26) weeks". That charge was made because the Employer had an interest in stopping that accumulation and because the Union had an interest iii having that compensation paid prior to the death or termination of its members, some of whom had already reached the 26 week maximum. To implement those changes, MPAC calculated and paid out special compensation to the employees whom it determined to be entitled to receive it_ However, forty employees filed grievances because they were of the view that MPAC had erred. Although only 21 of those grievances are currently before rye, the parties hope that the other 19 grievances can also be resolved through these proceedings. In a previous case between OPSEU and OPAL regarding temporax employee's eligibility to receive special termination payments under the LOU, the majority of a Board of ,Arbitration which I chaired Qonc:luded in an award dated April 30, 2001 (the 112001 Award"), that OPAC's temporary employees were not entitled to receive compensation under the LIQU because the "Special compensation entitlement" for which it provided fell within the ambit of the term "benefits" in Article 5.02 of the collective agreement between OPSEU and OP,AC, which provided: Temporary employees shall receive 10 percent of base wages in lieu of holidays, vacations and benefits and in lieu of pay therefor. Article 6.02 of the parties' January 1, 2016 to December 31, 2018 collective agreement contains identical language. 5 Since that award was issued, OFAC/MPAO has administered the LOU in a manner that is consistent with it. Any classified employee of the MOF who carne over to a nontemporary position at OPAC/MPAC at the time of the transfer continued to accumulate service for purposes of special compenoation entitlement under the LOU. Any unclassified employee of the MOF who came over to OPAO/MPAC: as a temporary employee and subsequently left the employ OPAC/MPAC did not rcccive any special compensation under the LOU_ There have been at least 205 employees to whom this applied. Grievance of David Taylor Mr. Taylor was a classified employee of the MCF from 1986 until August 31, 1989, when he resigned to pursue a university education_ While pursuing that education, he worked for the MOF during the Summers as an unclassified employee working full-time hours. His employment contracts for those periods of unclassified employment provided for "Elay in lieu of employee benefits [in] an amount equal to 2t of basic hourly rate for all hours worked exclusive of overtime". He completed his university education in 1995 and -qubsequentl returned to work for the MOF, initially as an unclassified employee and thea as a classified employee with an OPS continuous service date of June 3, 1995. He remained a classified employee of the MOF until December 31, 1998, when he accepted employment with OPAC/MPAC as a nontemporary employee. At the time of transfer, he did not receive any termination or severance pay for the period between his 6 continuous service date of June 3, 1996 and his separation date of December 30, 1998, because that period of two years and seven months constituted less than the five years of service as a classified employee required for entitlement to it under the OPS Agreement_ The previous periods that he had worked as an unclassified employee were not included in the MOF's calculation, nor were they included in MPAC's calculation of hie special compensation enti.tl.c-rneat under the MQF_ In calculating that entitlement, MPAC also used the June 3, 1996 dale, in accordance wiuh its consistent practice (over the last nineteen years) of using employees' OPS continuous rervlce date at the time of transfer in calculating special compensation entitlement under the LOU, and of not including any unclassified service time in that calculation. Through his grievance, Mx. Taylor claims that his entitlement tv special compensation under the LOU should have been calculated from Febxuary 17, 1992, which is the start date of his membership in the Ontario Public Service Employees Union Pension Plan (the "OPSEU Pension Plan")f as specified in the Special Deferred Pension Certificate that was provided to him by the OPSEU Pension Trust after he left the OPS and became an employec of OPA /MPAC. Thus, he claims that the calculation should have included an additional four years and three months of service. The February 17, 1992 start date of Mr. Taylor's membership in the OP EU Pension Trust is earlier than his CPS continuous service date of June 3, 1996 because Mr. Tayloz 7 purchased for pension entitlement purposes all of the time that was eligible for pension, entitlement service credit during the period that he was a university student. Grievance of Jeff Lecda3,�, Mr. Leedale's grievance is similar to that of Mr_ Taylor. The compensation that he received under the LOU was calculated on the basis of 19.5 years of combined service with the MOF and. OPA.0/MPAC- He claiRts that it should have included the periods in 1992 and 1993 duxirig which he worked for OPAL/MPAC on a contract, basis as a temporary employee. Accordingly, be seeks to have it calculated on the basis of 20.917 years of combined service. Grievance of Steven ,thea Mr. Shea was an unclassified employee with the MOF in 1998. At the Decernbex 31, 1998 time of transfer, he accepted employment with OPAL/MPAC as a temporary employee. As a result of being the successful candidate in a job competition, he was appointed to a nontemporary position on a probationary basis, effective June 30, 1999. He resigned later that yeax but subsequently returned to the employ of OPAL/MPAC ten years later. He claims entitlement to special compensation based on his accumulated years of service with the MOF azid OPAC/MPA+C. Grievance of John Gagliardi Mr. Gagliardi commenced employment with the MOF ori May 5, 1997 as an unclassified employee and worked full-time hours iri that capacity until December 31, 1998, when he became a temporary employee of OPAiCIMPAC working full-time hours as a 8 result of his acceptance of a temporary employment contract with OPAL/MPAC offered to him on Decembex' 15, 1998. His grievance is an example of a group of grievaznces through which persons who worked full-time hours for the MOF as unclassified employees and then became temporary employees working full -tire hours for OPAL/MPAC as of December 31, 1998, claim special compensation entitlement under the MOU on the basis of their combined sez:vice with the MOF and OPAC/MPAC. xzevance of Jennifer Bouchard Ms. Bouchard was employed by the MOF as an uriclassifled employee working full-time hours f-rom August 6, 1996, until December 31, 1998, under a series of consecutive employment contracts. On December 31, 1998, she became a temporary employee of OPAL/MPAC working full-time hours as a result of her acceptance of an "cuployment contract of up to one year's duration" that wa8 offered to her on December 15, 1998. In the spring of 1999, she obtained a ncntn poraxy position with DPAC/MPAC as an Assessment Field officer, effective May 3, 1999, as a result of being the successful applicant in a competition for that position. Grievazxce of Bornadette Macri On November 1, 1998 Ms. Macri (whose name at that time was Bernadette Zenko) commenced employment with the MOF as a quality assurance clerk working full-time hours in its Property Assessment Division urnder a contract of employment, which specified that she was "appointed to the unclassified service", effective from November 1, 1998 and to December 31, V 1998. Her duties and responsibilities were to perform a quality control assessment function by checking the evaluations clone by other property asse88ment employees. Although there was initially a dispute regarding whether she was workirig in the MOF's Property Assessment Division or in its Corporate Services Division, during the course of his reply submissions Union counsel advised that the Union does riot dispute that she was working in its Property Services Division at the time of transfer_ She then accepted a position as a temporary employee under a contract with OPAOfMPAC. As a result of her completion of heic probationary period while on contract, her employee status was subsecentl changed to that of a nontemporary assessment field officer, with May 17, 1999 as the date of her ",Appointment to Clas8ified Staff" (as indicated by the OPAL "CHANGE IN EMPLOYEE STATUS" form included in Tab 10 of the exhibit book). Grievance of John Odoom Prior to December 31, 1998, Mr. Odoom was an employee of Gear Canada Limited {"Geac""} who performed information technology services for the MOF. He was impacted by the aforc-mentioned transfer of property assessment furnctions from the MOF and OPAL because following that transfer there was no longer any need for those services to be provided to the MOF. He applied for a position with OPAL through a job posting and was hired by it as a Technology Infrastructure Analyst on February 1, 1999 through a temporary contract with a termination date of July 30, 1999. He worked full-time hours 10 in that temporary position_ Grievance of Christian .Stoeken Prior to December 31, 2018, Mr. Stoeken was employed by the MOF as a full-time unclassified employee. He was hired by OPAO as a full-time temporary employee and subsequently bcc'ame a full-time nontemporary employee. Re claimG entitlement to special compensation under the LOU because it stipulatcs that the special compensation for which it provides llincludes any severance pay under the Employment Standards Act". In support of that claim, he relies upon section 65(2) of the Act, which provides: All time spent by an employce in the employer's employ, whether or not continuous and whether or not active, shall be included in determining whether he or she is eligible for severance pay under subsection 64{1} azad in calculating his or her sevearaace pay under sub5ection(1). Collective Agreement Excerpts In addition to the above -quoted LOU, during the course of argument reference was also made to the following provisions of the Agroomcnt: ARTICLE 6 - TEMPORARY EMPLOYEES AND STUDENTS 6.06 Whore the same work has been porfc}rrnUd by a temporary employee for arty period of at least eighteen (18) consecutive months (except for situations where the employee is replacing a regular employee on a leave of absence authorized by the Employer or as provided for under the Collective Agreement) and where the Employer has determined that there is a continuing need for that work to be performed on a full-time basis, the Employer shall establish a regular position to perform that work. 11 5.08 Where a temporary employee has been released from their contract betorc thcir eighteen (18) months and rehired as a temporary employee within four (4) weeks of their last day worked, the period of absence in between shall not be con8idercd a break in services. That is, the period of the first temporary employment and the period of absence shall be included when determining the li�iigth of continuous service. ARTICLE 12 - OUTSIDE BARGAINING UNIT POSITION AND SENIORITY 12.01 Seniority, as referred tc) in this Agreement, shall mean length of ccntiinueus scrv'ice. All employees, seniority dates shall be the earliest of: a) the seniority date recognized by the ov<�rnmcnt of Ontario for employees who were employed by the Ministry of Financc immediately prior to becoming employees of the -Employer on December 31, 1998; or h) the date the employee was last hired by MPAC. For greater certainty this shall include all continuous temporary and permanent service. Reference was also made to Letter of_ Understanding 47, which provides as follows regarding "Seniority - temporary employees": This will confirm certain understandings regarding the seniority of persons who were classified as temporary employees by MFAC ori Decsmbex 31, 1998, and who had unclassified service with the Ministry of Finance immediately prior to and contiguous with that date_ Subject to the provisions of this letter, it is agreed that such persons will he credited with seniority, for the cele purpose of vacation., layoff, recall and Lbe filling of vacancies, for continuous service with the Ministry of Finance immediately prior to and contiguous with Decembe.r 31, 1998_ It is understood that this will only be done once the employees arrange for the provision of records from the Ministry of Finance that confirm the dates of such service_ The employee will have until December 01 [sic], 2006 to furnish the 12 records. The effective date of any change iri the seniority date will be January 15, 2007, it is understood that there will be no retroactive impact of the recognition of serxi.ori.ty pursuant to this letter, and the provisions of this letter are otherwise subject to the provisions of Article 12.01(b). Summary of Union Counsel's Submissions The LOU io unambiguous; it contains plain words that are used in their ordinary sense, so there is no need for extrinsic evidence. It specifies that full-time employees with the MOF who accepted employment with MPAC at the time of transfer, c)r who accepted positions with MPAC as a result of job postings for approximately 29 Corporate Services Positions posted on or before December 31, 1989, are entitled to receive the payment for which it provides. There is no diapute that Mr. Taylor and Mr. Leedale were full-time employees entitled to receive special cpmpensation under the LOU. The dispute regarding those two grievors is what is to he included in the calculation of that compensation. The LOU provides for patent of compensation equal to one week per year of combined service with OPS and MPAC, to a maximum of twenty-six weeks. it does not require that the servioo he continuous or unbroken; the only qualifier i recombined ervice'r. MPAC calculated their entitlement on the basis of their continuous or unbroken service, and dict not loaf at their entire period of employment. when the parties meant continuous servicer they used language such as "consecutive months", as exemplified by Article 6.06r or "continuous service", as exemplified by the 13 first sentence in Article 12.01 and the last sentence in 12.01(b). Given that they used such language in various places in the Agreement, their use of the phrase "combined aervice" in the LOU indicates that they intended some other entitlement or outcome; "combined" must mean something different that 11continuous". The employees in the group of grievors exemplified by Mr. Gagliardi are all entitled to special compensation under the LOU. They were all full-time employees of the MOF who became fuii-time cmploy4�es of OPAC/MPAC on DeceiTber 31, 1998. The fact that they were unclassified employees with the MOF who became temporary employees with OPAL/MPAC does not deprive them of that entitlement, as the language of the LOU merely requires that they were "full time employees who accepted employment with MPAC at the time of transfer". It does not require them to have been classified employees, nor cions it contain any language which excludes unclassified ErnployeeE from its scope. The Employer is seeking to have ymu modify the LOU by implying qualifiers which do not exist in it. It simply says "full time employees". That phrase is not defined in the LOU or anywhere else in the Agreement. Consequently, it must be given its plain meaning. A full-time employee is commonly understood to mean an employee who works full-time hours. Ms_ Bouchard is also entitled to special compensation under the LOU on the same basis as Mr. Gagliardi. Alternatively, if the argument advanced on his behalf is not 14 accepted, her entitlement to special compensation under the LOU can be found on the ba: is that prjox to December 31, 1998, she should have been eoovex`ted under Article 31.15.1.1 of the OPS Agreement from an unclassified position to a classified position as a result of having worked for more than two consecutive years as an unclassified employee. The grievors' entitlement to special compensation is also supported by the fact that while they were employed by OPAC/MPAC, their seniority was backdated to their start date with the MOF. OPAC/MPAC's recognition of their MOF tart date as their seniority date serves as a legal trigger that supports their• entitlement under the LOU. Ms. Maori and Mr. Odoom are both entitled to special compensation under the LOU because they each accepted positions with OFAC/MPAC as a result of job postings for two of the approximately 29 "Corporate Services positions" that were posted before December 31, 1999. Although Mr. Odoom was not an employee of the MOF, he performed services for it and was impacted by the transfer of property assessment functions from the MOF and OPAC because following that tra.nsfe�7 there was no longcr any need for those services to be provided to the MOF. rix. Stc�eken claims entitlement to special compensation under the LOU on the basis that it stipulates that the special compensation for which it provides "includes any severance pay under the Employment Standards Act"_ His argument is that because he was an employee of the MOF prior 1s to December 31, 1998, for the purposes of the Employment ,Standards Act hi� was art employee and it does not matter whether he was classified or unclasiiicd, nor whether he was full. -time or part -times, because it is all employment under section 65(2) of the Act. He alsc argues that by referring to the pio mcnt Standards Act, the LOU imports those entitlements into it_ This case is different from the case that was dealt with in the 2001 Award because we are focusing specifically on the words "full-time employees". we do not need to look at whether they were classified employees or unclassified employees because the LOU does riot draw that distinction_ The grievors were full-time employees and had their seniority recognized by MPAC. That is different from the previ=ease. Irx addition to the 2001 Award, during the course of his submissions Union counsel referred Co B�Own & Beatty, Canadian Labour Arbitration, paragraphs 4:2000 and 4:2140; Re Nova ,Scotia Department of Transporta tion) 8 n C. U. P.I E. , Loc. 1867 (1990), 12 L.A,C. (4th) 352 (Veniot); Re Cuclph General Hospital and ONA (2012) , 226 L.A.O. (4th) 24 (Stout) , U.P.C'.W., Local 401 v. Richards5on Oilseed Ltd. (2012), 219 L_A_C. (4th) 433 {Wallace) j and OP 'EU and The Crown in bight Of Ontario (Ministry of Finances), decision dated July 29, 2004 re GM ##2002-2394 (Dissana ake). He also referred to the Oxford Dictionary, which defines "full-time" as "occupying or using whole of available work ng time". 16 Summary of Employer Counsel's Subrrrissions Under the OPS Agreement, classified employes were entitled to receive a Peverance payment of one week per year of service for each year that they wo-rked beyond five years of service, but unclassified employees had no entitlement to that payment. The purpose of the LOU was to recognize prior service with the OPS under certain circumstance;. What it and the 2001 Award said was that if employees had such entitlement at the time of the transfer, they could keep it, but if thoy did not have it at the time of the transfer, they could not generate entitlement to it after the transfer. During the last round of bargaining, the only chane that the parties made to the LOU was to provide for it to bE� paid now rather "on tezminatign or death's. The 2001 Award found that the "epecial compensation entitlement" provided by the LOU was one of the "benefits" covered by what gra: then Article 5.02, which is now Article 6.02 of the Agreement, and that temporary employees were therefore not entitled to zeceive it. MPAC's position is that if an employee was not entitled to it at the time of the transfer, they cannot possibly have it now because the language has not r -hanged, the intention has not changed, and the interpretation certainly should not change. Since that award was issued, OPAC/MPAC has applied the LOU in a manner absolutely consistent with what it said. Any classified employee of the MOF who came over to a nontemporary position at OPAC/MPAC aL the time of the tra-nsfer 17 continued to accumulate servicra for purpo8es of special compensation entitlement under the LOU_ ,Any unclassifi.ed employee of the MOF who came over to OPAC/MPAC as a temporary employee and subsequently left the employ OPAC/MPAC did not receive any special compensation_ That has been cleax' and consistent siiRce 1999. There are at 12a2t 205 pooplc to whom this applies, and none of them raised a complaint or filed a grievance. If there is any ambiguity i.n the LOU, the past practice between the parties over nineteen years has been to interpret it ars that manner.. The Employer's position is reinforced by what the parties agreed to in LOU 47. it very specifically deals with the issue of the seniority to be credited to pCrsons whom the Employer hired as ternporaxy employees on December 31, 1998, and who had unclassified service with the MOP immediately prior to and contiguous with that date. It records the parties, understanding that such persons will be credited with seniority "for the sole purpose of vacation, layoff Arid the filling of 'Vacancies". If the parties had also warted to have that seniority credited to those employees for the purposes of Letter of Understanding #1, they could have included a reference to it, but they did not do so. The grievors exemplified by Mr. Gagliardi, who worked full-time hours for the MOF as an unclassified employee and then became a temporary employee working full-time hours for OPAC/MPAC as ot December 31, 1993, are not entitled to special compensation under the MOU because they did not have any 18 entitlement at the time of the transfer and caii-not have it now because there iG nothing that gives it to them. Cir. 'Taylor received special compensation under the LOTS in the amount to which he was entitled biased iipon his combined sezvice as a classified employee with the OPS and as a nonternporary employee with OPAL/MPAC. On the Deeamber 31, 1988 date of transfer, Mr_ Taylor had two years and seven months of service, based upon his OPS continuous service date of June 3, 1996. In calculating the amount of special compensation to which Mr. Taylor was entitled tinder the MOU, MPAC quite properly used that date, in accordance with its consistent practice over the last nineteen years of using employees' OPS centin=8 service date at the tirnEt-, of transfer in calculating that special QQmpensation entitlement under the LOU, and not including any unclassified service time in that calculation. Mr. Taylor's purchase of all of the time that was eligible for pensionable service credit under the OPEU Pension Plan during the period when he was a university student gave him additional pensionable service credit for purposes of that Plan, but did not give him any additional service for purposes of the LOU. Those are two different numbers for two different purposes. The phrase "combined service" in the LOU means that OPS service is to be joined together with OPAL/MPAC service. The service that Mr. Taylor had at the time of transfer was the Lime from June 3, 2006, nothing more. 19 As is the case with all of the grievors except Mr. Taylor and Mr. Leedale, Mr. Shca is net entitled to any special compensation under the LOU because he was an unclassified employee of the MOF who came over to OPAL/MPAC on December 31, 1998, as a temporary employee. He subsequently resigned in 1999 and returned ten years later. Consequently, his seniority only gees Lack to the date in 2009 when he was rehired, as that is "the date the employee was last hired b MPAO°, as specified in Article 12.01(b) of the Agreement_ Ms. Bouchard was one of the 381 unclassificcd MOF employees who accepted a temporary employment contract with OPAOfMPAC. OPAC/MPAC took her as she carne to it, namely, as an unclassified employee. She now claims that she should have been converted under Article 31.14.1.1 of the OPS Agreement from an unclassified position to a classified position as a result of having worked for more than two consecutive years as an unclassified employee. However, that is not the test, Article 31.13.1.1 required the MOE-' to establi h a classified position where the came work, had been performed by an unclassified employee a period of at least two consecutive years and where the MOF had determined that there was a c ontiriuing need for that work to be performed on a full-time basis. If Ms. Bouchard wanted to file a grievance alleging that both of those requirements had been met, the time to do so was in 1998. You do not have jurisdiction to decide that matter. Ms, Macri did not hold one of the approximately 29 0 Corporate Services positions referred to in the LOU- She was an unclassified quality assurance clerk working full-time hours in the MCF's Property Assessment Division prior to accepting a temporary ppsitjon with OPAC/MPAC at the time of transfer. [fir. Odoci'fL worked for Gcac and wa; novcr an employ of the MOF. He has no entitlement under the LOU because had no OPS service and was therefore not a full-time employee of the MOP who accepted a position with MPAC as a result of a job posting for one of the apprQximately 29 Corporate Scrv'ices positions posted on or before December 31, 1999. Mr. Stoeken's creative argument regarding the Ehpdoyment Standards Act cannot succeed because that Act did not apply to the Crown at the time of the transfer, and because section 65( ) of that Act applies to blocks of service with an employer; it docs not address service with two employers. During the course of his submissions, counsel for the Employer also referred to Brown & Beatty, Canadian Labour Arbitration, paragraph 2:3220; Re Essar Steel Algoma Inc. v. V& K , Local 2251 (2008), 177 L.A_C_ (4th) 183 (Stout) Re Toronto ,District .School Board and Mkintenance & Canstruction .Skilled Trades Council, 2014 CarowellONT 11113 (Tacon) ; and Re Peel Regional Paramedical Services and OPSEU, Local 277 ( orz nski), 2014 CarswellOnt 11166 fMarcotte). .Summary of anion Counsel's Reply Su mi88inn8 When parties enter into a collective agreement, it is 21 open to them to give employees something new. Through the LOU, the parties agreed to give the special compensation entitlement to "full-time employees who accepted employment with MPAO at the time of the transfer". That is what gives entitlement to the grievors in the group exemplified by Mr. Gagliardi, Mr. Taylor's entitlement goes back further than his continuous service date of June 3, 1995, becau8e the LOU does not require continuous service. It should have been calculated from February 17, 1992, so as to include within hi$ "combined service with the OPS and MPAC" his full-time OPS service during the summers of the years in which he was pursuing his university education. Ms. Bouchard shouidbe found to have been entitled to be converted under Article 31.15.1.1 of the OPS Agreement from an unclassified position to a cia853itied pcnition because her situation satisfies both of the requi7cemerxts of that provision. As an unclassified employee, she performed the same work for the MOF for a period of at least two years. The continuing need for that work to be performed c)n a full-time basis is established by the fact that after she had been employed by the MOF as an unclassified employee for a period of two years, shfit continued to work as an unclassified employee for the duration of her employment with the MOF up the December 31, 1998 transfer date. Deci si ars As indicated above, in the 2001 Award issued in the 22 previous case between OPEU arid OPAL' regarding temporary employee's eligibility to receive special termination payments under the LOU, the majority of a Board of Arbitration which I chaired concluded that OPAC's temporary employees were riot entitled to rec-eive cvmpezisation under the LOU because the „Special compensation entitlement" for which it provided fell within the ambit of the term "benefits" in what was then Article 5.02, which is now Article 6.02 of the Agreement_ The rationale for that conclusion is set forth as follows in the majority award (at pages 11-16): Having duly considered the able submissions of counsel, we have concluded that temporary employees whose employment contracts expire through the effluxion of time arc not entitled to receive compensation under the Letter of Understanding, because the "'special cQmpeT�sation entitlement" provided by the Letter of Undertarnding is a "benefit"" within the meaning of Article 5.0 of, the Agreement, which provides: Temporary employees shall receive 10 percent of base wages in lieu of holidays, vacations and benefits and in lieu of pay therefor_ In Tox7orxto General Hospital and Ontario Nurses' Association (Paur 7'C irr Nu- ,3es g-cievalice) , suipr , arbitrator Brawn found holiday pay to be a "fringe benefit" covered by the e_ctra 14% included in the regular part-time nurses' hourly salary rate as a "percentage in lieu of fringe benefits' In reaching that conclusion, he wrote, in part, as follows (at page 13 ) . There is no mystery as to what is meant by a fringe benefit in the industrial relations corateyct, it is :imply part of ccmpeneatioTx for work which is outside of direct salary or wages paid but attached to such payment by way of additional compensation in the employment relationship directly relating to the hourly salary Qr wades paid for work performed. Pay for statutory holidays arises as a result of that relationship and is a paid benefit in addition to salary.... 23 A similar conclusion was reached by arbitrator Barton in Family services of Hamilton Wentworth and OPSEI7 Local 216(holiday a rievance of Teri chwendinan), s_.unra, in which statuLory holiday pay was found to be included in the percentage of their wage rate (10) which, in accordance with the provisions of the applicable collective agreement, part-time employees received in lieu of benefits. The double-edged nature of such percentage payments in lieu of benefits io evidenced by the arbitral rejection nqt: only of attempts by employees to obtain benefit payments in addition to such percentage payments, but also of attevipts by employers to obtain reductions in the applicable percentagc payments to reflect changes in the ambit of benefits covered by the percentage payments, or the cost of those benefits: see, for example, Regional Municipality of Ottawa-Car,le('on and Ottawa -Carleton Public E to ees Union, CLYDE.. Local 503 (OHIP payroll tax grievance) , supra, in which arbitrator Stanley found that the employer's expressed intention tv reduce the amount of the percentage in lieu of benefits (12%) paid to casual, part-time, and temporary employees, in light of an OHIP payroll tax introduced by the Government of Ontario, would cofYstitute a violation �)f the collective agreement.; and Re Alexandra Marine & General Hospital and O.N.A., supra, in which arbitrator Devlin found a similar violation where the employer unilaterally reduced the percentage in lieu of fringe benefits (14%) for part-time nurses who enrolled in the Hospitals of Ontario Pension Plan after part-time employes became eligible to participate in certain employer pension plans as a result of amendments to the Pension Benefits Act. Note 3 on pages 8-2 and 8-3 of Brawn and Beatty. Canadian Labour Arbitration (3rd Ed_), includes the following as examples of benefits: life insurance, prescription plans, night recovery leave, OHIP premiums, U.I. premiums, indemnity for home study, Christmas bonuses, pension surpluses, retirement allowances, meeting allowances, f~hild care allowances, layoff allowances, parking privileges, housing buy-back arrangements, railway passes, car allowances, personal leave, religious or special leave for non-traditional holidays, responsibility allowances, legal fees, professional dues, gratuities, moving expenses, locker or storage f=acilities, clothing allowances, tool allowance, and company cars. Although that list does not purport to be exhaustive or definitive regarding what is encompassed within the term "benefits" in a provision such as Article 5.02, it does px-ovide examples of the broad range of items which may fall 24 within the purview of that term. Article 25 of the Agreement is entitied "Insurcd Benefits", and includes provisions regarding sick pay, life insurance, a supplementary health and hospital plan, a vision and hearing care plan, a dental caro plan, and a to-ag-term disability plan. Those benefits aze undoubtedly included within the ambit of the term "bi�ne,fits°' in Articic 5.01. However, if the parties had intended to confine that term to those bcnctits, they could easily have done so by stating that "temporary employees shall receive 10 percent of base wages in lieu of holidays, vacation, and the benefits listed in Article 5" (or perhaps more chlicfuely b using the phrase "insured benefits" or the phrase "regular fringe benefits" in Article 5.02). However, they did Tiot do so. The term they used is "bcnefits", which we construe to be a word of sufficient breadth to include the "special compensation entitlement on termination or death" for which the Letter of Understanding provides. As noted in the foregoing summary of Union counsel's submissions, it is the Unions position that employees in the group of grievors exemplified by Mr. Gagliardi are entitled to special compensation under the LOU because they were all full-time employees of the MOF who became tuli-time empioyees QE OPACfMPAC on December 31, 1998_ In support of that position, Union counsel submitted that the fact that they were unclaeeified employees with the MOF who became temporary employees with OPAC/MFAO does not deprive them of that entitlement, because the LOU refers to "full time employees who accepted employment with MPAC at the time of transfer", and does not include any requirement for them to have been classified employees nor contain any language which excludes unclassified employees from its scope. He further submitted the Employer xc seeking to have it modified through the implying of qualifiers which a -re not contained in it. 5 Although Union counsel did not explicitly submit that the 2001 Award is wrongly decided, accepting the foregoing argument would clearly cgnstitute declining to follow it. The conclusion reached in the majority award did not modify the LOU by implying qualifiers into it. What the award fQun,d was that the Lou does not apply to temporary employees because it is one of the llbenefitsl' in lieu of which temporary employees receive 10 perci�nt of base wages, pursuant to what is now ,Article 6.02 of the Agreement. None of the grievors in the group o ernplified by the grievance of Mr. Gagliardi can be awarded compensation under the LOU unless that interpretation of Article 6.02 is disregarded by declining to follow that award. It is well established in the arbitral iurispr-udence that, in view of the importance of providing finality to the resolution of disputes, a prior decision between the parties dealing with the same issues under the same Collective agreement language should be followed as a matter of principle unless it is clearly wrong. See, for example, the following passage from Arbitrator Tacon's award in Toronto ,District .School Board and MaintEt ianCe & c>nstructioxz Skilled Trades COT-2nCil, supra: 71 Brewers Warehousing [(1954), 5 L.A.C_ 1797 (Buskin)] was the earliest articulation of the proper approach of a subsequent arbitrator to an earlier arbitratic.n award (at page 1798): it is not good policy for ane Board of Arbitration to refuse to follow the award of another Board in a similar dispute between the same parties arising out of the same Agrct--ment where th(c dispute involves the interpretation of 26 the Agreement. Nonetheless, if the second Board has the clear conviction that the first award is wrong, it is its duty to determine the case before it on principles that it believes are applicable. 72 That theme has echoed throughout the arbitral jurisprudence, as evidenced in the following excerpt from Essar Steel, supra, at p. 190: One of the most important labour relations principles is the concept of final and binding resolution of differences by arbitration during the term of a collective agreement_ Labour relations peace is built upon this concept and operates on the fundamental premise that the parties will respect and abide by the decisions of arbitrators. The parties must be able to rely on decisions as being final and binding so that they may properly govern themselves in administering, operating under and bargaining the terms of their collective agrooment. If previous decisions are not respected, then there will be no resolution of differences and the relationship between the parties will only worsen. As a result, apart from the doctrine or res judicata, it is rare for an arbitrator to disregard a previous decisions between the parties dealing with the same issue under the same collective agreement.._. As indicated above, since the 2001 Award was issued, OPAL/MPAC has administered the LOU in a manner that is consistent with it. In accordaDce with that award, any classified employee of the NOF who came over to a nontemporar position at OPAL/MPAC at the time of the transfer continued to accumulate service for purposes of special compensation entitlement under the LOU, but any unclassified employee of the MOP who came over to OPAL/MPAC as a temporary employee and subsequently loft the employ OPAL/MPAC did not receive any special compensation under it. There have been at least 205 employees to whom this has applied. Since in reliance upon that award OPAC/MPAC has for 27 over seventeen years applied the LOU in accordance with it, and since I remain satisfied that the 2001 Award correctly determined that OPACfMPAC's temporary employoe8 are not entitled to receive compensation under the LOU because the "Special compensation entitlement" for which it provides falls within the ambit of the term "benefits" in what is noir Article 6.02 of the Agreement, neither Mr. agliardi's grievance nor any of the other grievances in the group which his grievance exemplifies can Eucceed, because those grievors were all unclassified employees of the MOF who became temporary employees of OPAL/MPAC at the time of transfer and consequently have received the aforementioned 1026 paid in lieu of that benefit and the other benefits to which Article 6.02 applies. Unioxx counsel also submitted that the gricvors' entitlement to special compensation is supported by the fact that while they were employed by OPAL/MPAC, their seniority was backdated to their start date with the MOF. It was his contention that OPACfMPAC's recpgnition of their MOF start date as their seniority date serves as a legal trigger that supports their entitlement under the LOU. However, as submitted by Employer counsel in response to that argument, LOU ##7 very specifically deals with the issue of the seniority to be credito[i tc persons whom the Employer hired as temporary employees an December 31, 1998, and who had unclassified service with the MOF immediately prior to and contiguous with that. date. It records the parties' understanding that such 28 persons will be credited with seniority 'for the sole purpose of vacation, layoff and the filling of vacancies". If the parties had also wanted to have that seniority credited to those employees for the purposes of Letter of Understanding #l, they could have included a refereTice to it, but they did not do so. Consequently, I am not that the seniority backdating for which LOU 47 provides gives rise to entitlement to special compensation under LOU #l. Special compensation under the LOU is calculated on the basis of an employee' -9 "combined service with OPS and MPAC". David Taylor's grievance raises the issue of whether only service as a classified employee of the MOF and service as a nontemporary employee of OPACfMPAO should be included in that calculation, or whether it should also include the employee's service as an unclassified or temporary employee. As indicated above, Mr. Taylor was a classified employee of the MOF from 1-985 until August 31, 1989, when he resigned to pursue a university education. While pursuing that education, he worked for the MOF during the summers as an unclassified employee working full-time hours. After completing university, hs returned to work for the MOF, initially as an unclassified employee and then as a classified employee with an OPS continuous service date of June 3, 1996, remaining a classified employee of the MOF until December 31-, 1998, when he accepted employment with OPAC/MPAC as a nontemporary employee. In calculating his entitlement to special compensation under the LOU, the Employer used his OP 29 Continuous service date of June 3, 1996, in accordance with its longstanding consistent practice of usi-ng employees, OPS continuous service date at the time of transfer in calculating special compensation entitlement under the LOU, and of not including any unclassified servica time in that calculation. Through his grievance, Mr_ Taylor socks to have his unc'lassificd service time included in that calculation b having it calculated from February 17, 1992, which is the start date of his membership in the OP EU Pension Plan_ That start date iz earlier than his OPS continuous service date because Mr- Taylor, purchased for pension entitlement purposes all of the time that was eligible for pension entitlement service credit during period that he was a tLaiversity student. When Mr. Taylor lett the employ of the MOF on the December 31, 1995 transfer date to accept employment with OPAL/MPAC as a nontemporary �--rmrplc ee, he did not receive any termination or severance pay for the period between his continuous service date of June 3, 1996 and his separation date of December 30, 1998, because that period of two years and seven months constituted less than the fives years of service as a classified employee required for entitlomcnt to it under the OPS Agreement. The previous periods that Mr. Taylor had worked as yin unclassified employee were not iTicluded in the MOFrs calculation, presumably because his employment contracts for triose periods of unclassified employment provided for "Pay in lieu of employee benefits [in] an amount equal to 2 of basic hourly rate for all hours 30 worked exclusive of overtime". I am not persuaded on the hasis of the material before me in these proceedings that OPAL/MPAC breached the Agreement in applying the same approach in ealculatiay tie E�pfz!cial compensation to which employees are entitled under the LOU. Consequently, z find that Mr. Taylor is not entitled to receive any additional special compensation tinder the LOU. Similar reasoning precludes Mr_ Shea and Ms_ Bouchard from receiving special compensation under the LOU for periods during which they worked for the MOF as unclassified employees and subsequently worked for OPAL'/MPAO -�Ls tempoTary employees, because during those periods they received payment in lieu of that and other "benefits" pursuant to their employment contracts and what is now Article 5.02 of the Agreement. However, the only matter decided in the 2001 Award was that OPAC'.s temporary employees Frere not entitled to Teceive compensation under the LOU because the "Special compensation entitlement's for which it provided fell within the ambit of the term "benefits" in what was then Article 5.02, which is now Article 6.02 of the Agreement. The issue of whether an unclassified MOF employee who came to work for OPAC as a tempoTaxy employee, but who subsequently became a nontemporary employee, is entitled to any special compensation under the LOU for the period between the effective date of that nontemporary employment and the end date of January 1, 2016 specified in the LOU, was not addressed in that award. Sind the rationale for denying temporary employees 31 entitlement to special compensation under the LOU is that it is one of the "benefits'l in lieu of which they receive to percent pf base wages wider what is now Article 6.02 of the Agreement, it follows as a matter of principle that if they cease to be temporary employees and become noTitemporar employees, they are no longer precluded from receiving special compensation under the LOU in respect of periods of full-time employment during which they were not receiving payment under that provision in lieu of henefits_ Accordingly, Ms. Bouchard is entitled to receive special compensation and(-r the LOU for the period from May 3, 1999, which is the date upon which her aforementioned appointment to a nontemporary position with OPAL/MPAC became effective, to January 1, 2016, which is the end date specified in the LOU. As indicated above, the alternative argument advanced on behalf of Ms. Bouchard was that she can be found to be entitled to special compensation under the LOU for the time that she was employed by the MOF, and also for the time that she was employed by OPAO/MPAC up to January 1, 2016 on the basis that prior to December 31, 1998, she should have been converted undex` Article 31.15.1.1 i�)f the OPS Agreement from an unclassified position to a classified position. However, as submitted by Employer counsel, I do not have jurisdiction to decide whether or not Ms. Bouchard was entitled to such conversion. If Ms. Bouchard was of the view that she was entitled to conversion under that Article, it was incumbent upon her to have filed a grievance under the OPS Agreement so 32 that it could be decided by the Grievance Settlement Board if it could not he resolved by OPS2U and the MOP. Thus, Ms. Bouchard's entitlement to special compensa.tiori undex, the MOF is not enhanced by that alternative argument. Mr. Shea is similarly entitled tQ receive special compensation under the LOU for the period from ,lune 30, 1999, when his appointment to a nontemporary position became effective, to the date on which his resignation from that position became effective. As indicated above, he retu,rrned to the employ of OPAC'fMPAC in 2009. However, it is unclear from the stipulated facts and the exhibits entered into evidence on the agreement of counsel whether he was employed as a temporary employee or a nontemporary employee theTeaftex. 1E he either returned as a nantcmporary employee or returned az, a temporary employee but subsequently became a nontemporary employee prior to January 1, 2015, he would also be entitled to receive special compensation udder the LOLY for the period during the interval in which he was employed as a =temporary employee on a full-time basis. In concluding that Mr. Shea's entitlement to special c-ompensation could include both of those periods, I respectfully agree with and adapt Union counsel's contention that the LOU does not require service to be continuous or unbx'oken. As he submitted, when the partiee meant continuous service, they used language suc-h as l'ccn8ecutive months", as exemplified by Article 6.06 of the Aqreement, or "continuous service", as exemplified by the first sentence in Article 12.01 and the last sentence in 33 Article 12.01(h). Although Article 12.01 defines "seniority" to mean "length of continuous service" in the oontext of determining "employees' seniority dates", in the LOU the only qualifier is "combined" service. 3n the content of detfrmining entitlement to special compensation under the LOU, the phrase «c:ombini�d service" is clearly intended to convcy an intentipn to have aux employee's service with OPS eombiried with his or her service with MPAC. Nothing iT� the LOU requires that service to be continuous. It is common ground between the parties that FIs. Macri was employed by the MOF in its Property Assessment Division, and not in its Corporate Services Division as initially asserted in support of her grievance. She accepted a position as a temporary employee with OPAL/MPAC at the time of transfer, but her employment status was subsequcntly changed to that of a nontemporary assessment field officer, with May 1.7, 1999 as the effective date of that "Appointment to Classified staff"_ Thus, she did not accept a paoition with OPAO/MPAC as a result of a job posting for one of the approximately 29 "Corporate Servioes positions" that were posted before December 31, 1999, as initially submitted by Union counsel in support of her grievance. However, she is entitled to receive special compensation under the LOU for the period fxom May 17, 1999, to the end date of January 1, 2016 specified in the LOU, because durinq that period she was a nontemporary employee of OPAL/MPAC and was accordingly not receiving pay in lieu of that benefit under Article 6.02. 34 Prior to December 31, 1998, Mr, 0doom perLormed information technology services for the MOP a-5 an employee of Oeac. He was impacted by the transfer of property assessment functions from the MOF to OPAO because following that transfer there was no longer any need for those services to be provided to the MOF. He subsequently applied for a position with OPAO through a job posting and was hired by it as a Technology Infrastructure Analyst on Fcbruary 1, 1999 through a temporary contract with a termination date of July 30, 1999. it was contended on his behalf that this was a job posting for one of the "approximately '29 Corporate Services positions, posted on or before December 31, 19991' referred to in the LOU. However, the LOU only gives that entitlement to full-time employees of the MOF who accepted employment with MPAC as a result of those job postings. Although Mr. Odoom perfaxmed information technology services for the MOF, he did so not as an employee of the MOF but as an employee of GEAO. Consequently, he is not entitled to special compensation under the LOU. Mr_ toeken's claim for entitlement to special compensation under the LOU is not advanced by section 65{2} of the Employment Sr-andards Act. That provision stipulates that in calculating an employee's severance pay under section 65(1) of the Act, all time spent by an employee in the employer's employ, whether or not continuous and whether or not active, shall be included in the determination. However, as submitted by Employer counsel, that provision applies to blocks of service with an employer, and does not address service with 35 two employers. Moreover, it is evident from the wording of the LOU that the purpose of includinq a reference to that Act was to make it clear that the "termination or severance pay,- referred ay"referred to in the LOU "includes any severance pay under the Employment Standards Act". Mr. Stoeken is not entitled to any Special compensation under the LOU for the period during which he was employed by the MOF as an unclassified employee nor for the period during which he was employed by OPAC/MPAC as a temporary employee for the reasons set forth above. However, if the date on which he became a nontemporary employee of OPAL/MPAC preceded the end date of January 1, 2016 specified in the LOU, he would be entitled to special compensation for the period between Chose two dates during which he was no longer receiving pay in lieu of that benefit under Article 6.02 of the Agreement. The deter -urinations made in this award will hopefully be of assistance to the parties in resolving the other grievances which have hien fiJ ed regarding entitlement to special compensation under the Lou_ However, I shall remain seised for the purpose of dialing with any unresolved issues arising out of those grievances, and any difficulties which may lie cnc,�)untered in the implementation of those determinations. DATED at Burlington, Ontario, this 6th day of Deceiiber, 2018. Robert. D. Howe Sole Arbitrator 36