HomeMy WebLinkAboutUnion 01-04-30
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IN THE MATTER OF AN ARBITRATION
BETWEEN:
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(the "Unionl1)
-AND-
ONTARIO PROPERTY ASSESSMENT CORPORATION
(the "Employer")
AND IN THE MATTER OF GRIEVANCES REGARDING TEMPORARY EMPLOYEES'
ELIGIBILITY TO RECEIVE SPECIAL TERMINATION PAYMENTS
BOARD OF ARBITRATION
Robert D. Howe, Chair
Pamela Munt-Madill, Union Nominee
Robert Gallivan, Employer Nominee
APPEARANCES
For the Union
Ed J, Holmes, Counsel
Jennifer Reid
For the Employer
D.K. Gray, Counsel
G, Volkes
A hearing in the above matter was held in Toronto, Ontario on
March 7, 2001,
AWARD
The issue to be decided in this award is whether
temporary employees of the Ontario Property Assessment
Corporation (also referred to in this award as 1I0PAC" and the
"Employer" for ease of exposition), whose employment contracts
expire through the effluxion of time, are entitled to receive
compensation under the following letter of understanding (the
"Letter of Understandingll) which forms part of the parties'
collective agreement (the "Agreement"):
LETTER OF UNDERSTANDING
RE: Special compensation entitlement on termination
Dear Madam:
This will confirm that full-time employees who accepted
employment with OPAC at the time of the transfer,
December 31, 1998, or who accepted positions with OPAC
as a result of competitions for approximately "29
Corporate Services positions" posted on or before
December 31, 1999 will receive a special compensation
entitlement on termination or death equal to one week
per year of combined service with the OPS and OPAC to a
maximum of 26 weeks less one week per year of OPS
service for which termination or severance pay has been
paid at the time of the transfer, multiplied by the
OPAC salary at the time of the employee's termination.
This includes any severance pay under the Employment
Standards Act.
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 commenced full-time employment with OPAC 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 rehabilitation program
which will lead to full-time employment shortly
thereafter.
Yours truly,
Eric Preston Vice-President
(:UJ1/uLdLe diHl HUlIlcill Service::"
1
At the commencement of the hearing, counsel advised
the Board that they had agreed to argue the case as a matter
of principle, and to leave for possible future determination
other issues; including the timeliness of the grievances and
the question of whether the grievances are properly before the
Board.
Facts
Counsel agreed to argue the case on the basis of
the facts which were stipulated during the course of their
submissions, and the exhibits which were entered into evidence
on the agreement of counsel.
OPAC was created by statute on December 31, 1998 to
perform property assessment functions previously performed by
the Ontario Ministry of Finance. OPAC has a monopoly on those
functions until 2004; after which the performance of those
functions will be open to competition. When OPAC was created,
most if not all the members of the workforce employed by the
Ministry of Finance were offered jobs with OPAC; including
classified employees and unclassified employees. The latter
were employees who had no job security; and whose rights under
the collective agreement between OPSEU and the Crown were very
limited. They were employed under contracts that ran from one
specified date to another specified date.
When OPAC was created, the classified employees were
given notice or severance pay to complete the ternlination of
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2
.'
were given notice but no severance payor any other payment.
Unclassified employees who accepted employment with OPAC were
hired as temporary employees. As was the case with the
Ministry of Finance1s unclassified employees, OPAC's temporary
employees were given contracts effective from one specified
date to another specified date. When the latter date arrived,
the contract expired and the employment relationship ended.
All but one of the grievances involve temporary
employees whose contracts expired through the effluxion of
time. Although the remaining grievance involves a temporary
employee whose contract ended prior to its expiry date,
counsel agreed to argue this phase of the case on the basis
that it involves temporary employees whose contracts expired
through the effluxion of time.
The specimen temporary employment letter entered as
Exhibit 4 in these proceedings is on OPAC letterhead and reads
as follows:
January 2, 2001
Subject:
Temporary Employment
I am pleased to offer you temporary employment with the
Ontario Property Assessment Corporation, Office,
effective to
Your job title is
the rate of $
assignment.
and you will be paid at
per hour for the duration of this
The terms and conditions of your employment are
detailed in Article 5 of the Collective Agreement
between OPSEU and OPACj this document is available on
the OPAC Intranet site.
Should circumstances change within the Corporation and
it lS necessary to terminate your f~rnployrnent you will
"1
be given notice in accordance with the notice
provisions specified under the Employment Standards
Act.
Please sign and return the enclosed copy of this letter
acknowledging your acceptance of the offer of temporary
employment.
Sincerely,
Employee Signature
Although the parties were not in a position to
stipulate that the grievors received that particular letter,
it is common ground between them that all of OPAC's temporary
employees received something similar to it.
Collective Agreement Provisions
During the course of their able submissions, counsel
referred to a number of provisions of the Agreement, including
the following:
ARTICLE 2 - RECOGNITION
2.01
The Employer recognizes the Union as the sole
and exclusive bargaining agent of all employees
of the Employer in the Province of Ontario, save
and except supervisors (other than Manager
Mapping Services and Manager Data Services),
managers, those above the rank of supervisors
and managers, those employed in a confidential
capacity in matters relating to labour relations
and those in the office of the President and
CAO.
2,02
For greater certainty, such employees include
regular and temporary employees, students, and
such other employees as may be mutually agreed
upon.
ARTleL,E 5 - TEMPORARY EMPLOYEES AND STUDENTS
S.Ul The following articles shall apply to temporary
emp~oyees; l, 2, 3, 4, 6, 7, 8, 9, 10 (except
4
10.05), 12 (except 12.06 and 12.07), 15, 16, 17,
18, 20, 27 and 28. No other articles apply.
5.02 Temporary employees shall receive 10 percent of
base wages in lieu of holidays, vacations and
benefits and in lieu of pay therefor.
5.03 Temporary employees shall accrue attendance
credits at the rate of one and one-quarter days
after each month of full attendance. Attendance
credits are for sick leave purposes only, and
for no other purpose. Use of these credits is
subject to such medical evidence, if any, as the
Employer may require.
5.06 Where the same work has been performed by a
temporary employee for any period of at least
two (2) consecutive years after the date of
ratification (except for situations ,.,here 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.
5.07 Where the Employer has determined that it will
convert a position in accordance with 5.06 the
status of the incumbent in the position will be
converted from temporary to regular, provided
that the incumbent has been in the position in
question for at least two years.
Summary of SubJnissions by Counsel for the Employer
On the agreement of the parties, counsel for OPAC
proceeded first with his submissions (without conceding that
the Employer bears any onus in these proceedings), He
presented three alternative submissions in support of his
clientts contention that the grievances should be dismissed.
His first submission was that OPAC's temporary employees whose
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not entitled to receive special termination payments under the
Letter of Understanding because Article 5 of the Agreement
specifically spells out those portions of the Agreement that
apply to temporary employees, and the Letter of Understanding
is not one of them. Although he acknowledged that two of the
Agreementrs letters of understanding (the lILump-Sum paymentH
letter, and the "Seniority - Temporary Employees" letter)
would apply to temporary employees because those two letters
specifically mention temporary employees, he submitted that
none of the other letters of understanding apply to them.
In support of that submission, he noted that although
temporary employees are included in the bargaining unit, many
significant provisions of the Agreement do not apply to them
by virtue of Article 5.01, including the unjust discharge
clause (Article 10.05), the seniority provisions (Article 11),
the provisions regarding job vacancies (Article 12), and the
layoff and recall provisions (Article 13).
Employer counsel's second argument was that the
special compensation entitlement referred to in the Letter of
Understanding is a benefit within the meaning of Article 5,02,
under which temporary employees receive "10 percent of base
wages in lieu of holidays, vacation and benefits and in lieu
of pay therefor." In support of that contention, he submitted
that "benefits" is a word of large import including all
monetary advantage to employees, and referred the Board to the
following authorities: IorontQ__g_l;m~J;gl..HQf:lpit919n~::LQntg,J::Jo
NllrSf'~'?~_lh?J30ci~_U-=-ioll_fE~our Tour NursesgdevanceL unreported
6
award dated June 29, 1990 (H.D. Brown); Family Services of
Hamilton Wentworth and OPSEU. Local 216 (holiday pay grievance
of Terry Schwendinan) i unreported award dated December 5, 1989
(Barton) i Regional Municipality of Ottawa-Carleton and
Ottawa-Carleton Public Employees Union. CUPE Local 503 (OHIP
payroll tax grievance), unreported award dated May 15, 1990
(Stanley); Re Alexandra Marine & General Hospital and O.N.A.
(1990), 17 L.A.C. (4th) 270 (Devlin); and Brown and Beatty,
Canadian Labour Arbitration (3rd Ed.), at pages 8-2 to 8-3.
Mr. Gray's third argument was that on the face of the
Letter of Understanding, the special compensation entitlement
for which it provides is payable only lion termination or
deathll, and does not apply to someone whose employment
contract simply expires. He submitted that the word
"termination" implies some act on the part of the Employer to
put an end to the employment relationship, as opposed to
simply allowing the employment contract to run out. In
support of that argument, he referred to Traders Group
v. Stanley Mutual Fire Ins. (1983), 47 N.B.R. (2d) 310
(Q,B.) . .1sl
Summary of Submissions by Counsel for the Union
Union counsel commenced his submissions by referring
the Board to Re Grey County Board of Education and O.S.S.T.F.
(1983) 1 12 L. A. C. (3d) 412 (Tepli tsky), as authority for the
proposition that onus has no role to play in the
interpretation of collective agreements, as the true meaning
'7
of any contract is a question of law and there is no onus
ordinarily applicable in resolving questions of law. He
submitted that it is important to read the Letter of
Understanding in light of what the parties have said in
Article 2.01, which refers to "all employees", and in Article
2.02, which provides that IIsuch employees include regular and
temporary employees, students, and such other employees as may
be mutually agreed. 11 He noted that the only modifier to the
word "employeesll contained in the Letter of Understanding is
"full-time", and submitted that if the parties had wanted the
letter to apply only to regular employees, they could have
said so. He also submitted that acceptance of the Employerts
first argument would require the Board to read out the words
IIfull timell and to read in the word IIregular". He referred
the Board to Re Canadian Red Cross Society and S.E.I.U. (1999)
84 L.A.C. (4th) 314 (Whitaker) in support of his client's
interpretation, and urged us to read Article 2, Article 5, and
the Letter of Understanding together in deciding the case.
Mr. Holmes submitted that Article 5 only talks about
which articles of the Agreement do and do not apply to
temporary employees, and does not talk about letters of
understanding, It was his contention that rather than
inferring from Article 51s silence regarding letters of
understanding that they do not apply to temporary employees,
the Board should conclude that all of those letters apply to
temporary employees in a general sense, and then determine
their particular applicability on the basis of whether
H
temporary employees meet or do not meet the conditions
established in the various letters of understanding. He also
submitted that the letters of understanding are obviously part
of the Agreement because they are listed in the Agreement's
Table of Contents, which first lists its 28 articles and then
lists its 16 letters of understanding. It was his contention
that a number of those letters apply to temporary employees,
including the letters regarding Lump-Sum Payment, Seniority -
Temporary Employees, Special compensation entitlement on
termination, Safety Equipment, Job Descriptions, Harassment
Policy, and Violence in the Workplace.
Counsel for the Union noted that entitlement to
special compensation under the Letter of Understanding arises
"on termination or death", and submitted that the inclusion of
Udeathll as a trigger indicates that entitlement is not
dependent upon some act on the part of the Employer. He
further submitted that the letter must be read in its entirety
in the context provided. He argued that in common parlance
IIterminationl1 occurs where there is an employer-employee
relationship which has been severed. He also referred the
Board to Re Canadian Union of Public Employees, Local 79. and
Municipality of Metropolitan Toronto (1972), 24 L.A.C. 90
(Rayner), which held that the discharge provision in Local
791s collective agreement applied to a temporary employee even
though the employment relationship had been terminated by
lapse of time.
AfLer noLing that the concepts of fuJl-time or
9
part-time employment are not defined in the Agreement, Union
counsel referred the Board to OP8EU (Group Grievance,
Clapperton et all and The Crown in Right of Ontario (Ministry
of the Solicitor General and Correctional Services),
unreported Grievance Settlement Board decision dated March 16,
1999, in support of his contention that if employees are
working full-time hours, they can be considered to be
full-time employees even if they do not have a contract which
says that they are full-time. He also referred to the
approach which has been adopted by the Ontario Labour
Relations Board in determining whether employees are full-time
or part-time, as set forth in Stratford Shakespearean Festival
Foundation of Canada, [1984] OLRB Rep. Dec. 1778, and
submitted that the parties presumably came into the Agreement
with that understanding. In further support of his contention
that temporary employees can be full-time employees under the
Agreement, Mr. Holmes referred to the conversion provisions
contained in Articles 5.06 and 5.07.
In responding to the Employer counsel's argument that
the special compensation entitlement referred to in the Letter
of Understanding is a benefit within the meaning of Article
5.02, Union counsel submitted that the instant case is
distinguishable from the authorities relied upon by the
Employer, He contended that Article 5,02 is qualified by the
Letter of Understanding, which he submitted provides for a
payment over and above the standard fringe benefits referred
~o in ~he Agreement. He also contended that this
10
distinguished that payment from the standard fringe benefits
referred to in the authorities relied upon by Employer counsel
in support of that argument.
Summary of Employer Counsel's Reply Submissions
In replying to Union counsel's argument that the
letters of understanding regarding Lump-Sum Payment, Seniority
- Temporary Employees, Special compensation entitlement on
termination, Safety Equipment, Job Descriptions, Harassment
policy, and Violence in the Workplace apply to temporary
employees, Employer counsel submitted that this argument
ignores Article 5.01's list of articles which apply to
temporary employees, and its statement that no other articles
apply. After noting that UArticle 14 - Health & Safety" is
one of the articles which does not apply to temporary
employees, he submitted that the Safety Equipment letter of
understanding is obviously designed to flesh out Article 14
and does not apply to temporary employees. He submitted that
the same is true of the Job Descriptions letter of
understanding (in that the Article 26.12 employee entitlement
to a copy of his/her job description upon request does not
apply to temporary employees), and the Harassment Policy
letter of understanding (in that Article 26.05, by which the
Employer, employees, and the Union agree to conduct their
affairs in accordance with the Ontario Human Rights Code, is
also not one of the provisions which Article 5.01 makes
applicable to temporary employees). Thus he submitted that
11
the letters of understanding cannot be viewed in isolation,
but rather must be considered in the context of the entire
Agreement.
Employer counsel's reply to Union counsel's
"full-time employee" argument \qas that since the Agreement
does not distinguish between full-time and part-time
employees, but rather between regular and temporary employees,
it would be far more consistent with the terms of the
Agreement to conclude as a matter of construction that
"full-time employeesU in the Letter of Understanding was
intended to be a reference to regular employees. He also
argued that the validity of this interpretation is reinforced
by Article 15.01, which provides that the "normal work week
for regular employees shall ordinarily consist of 36 and one
quarter (36 1/4) hours per week", in that this description of
full-time hours, which is the only one included in the
Agreement, specifically applies solely to regular employees.
Thus, he contended that Article 15.01 makes it clear that a
full-time employee is a regular employee. He submitted that
the cases relied upon by counsel for the Union are
distinguishable from the present case, and further submitted
that the manner in which the word "terminate" is used in the
fourth paragraph of the specimen temporary employment letter
makes it clear that the parties regard the termination of
employment as a different thing from the expiry of the
contract due to the effluxion of time.
IYlr, Gray submitted that Union counsel's argument that
12
Article 5.02 is qualified by the Letter of Understanding is
precisely the opposite of the proposition set forth by
arbitrator Brown in Toronto General Hospital and Ontario
Nurses' Association (Four Tour Nurses grievance), supra. He
also took issue with Union counsel's submission that Article
5.02 only applies to "standard fringe benefits", and suggested
that it is obvious from the caselaw, and from the list
included in the aforementioned passage from Brown and Beatty,
Canadian Labour Arbitration, that no such thing exists.
Decision
Having duly considered the able submissions of
counsel, we have concluded that temporary employees whose
employment contracts expire through the effluxion of time are
not entitled to receive compensation under the Letter of
Understanding, because the "special compensation entitlement"
provided by the Letter of Understanding is a "benefitll within
the meaning of Article 5.02 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 Toronto General Hospital and Ontario Nurses'
Association (Four Tour Nurses grievance), supra, arbitrator
Brown found holiday pay to be a IIfringe benefitlt covered by
the extra 14% included in the regular part-time nursesl hourly
salary rate as a "percentage in lieu of fringe benefits". In
reaching that conclusion, he wrote, i.n part, as follows (at
13
page 13)
There is no mystery as to what is meant by a
fringe benefit in the industrial relations context, it
is simply part of compensation 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 or wages paid for worK performed. Pay for
statutory holidays arises as a result of that
relationship and is a paid benefit in addition to
salary....
A similar conclusion was reached by arbitrator Barton
in Family Services of Hamilton Wentworth and OPSEU, Local 216
(holiday pay grievance of Terry Schwendinan), supra, in which
statutory 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 is evidenced by the arbitral rejection not
only of attempts by employees to obtain benefit payments in
addition to such percentage payments, but also of attempts by
employers to obtain reductions in the applicable percentage
payments to reflect changes in the ambit of benefits covered
by the percentage payments, or the cost of those benefits:
see, for exanwle, Regional Municipality of Ottawa-Carleton and
Ottawa-Carleton Public Employees Union. CUPE Local 503 (OHIP
payroll tax grievance), supra, in which arbitrator Stanley
found that the envloyerls expressed intention to reduce the
amount of the percentage in lieu of benefits (12%) paid to
casual, part-timet and temporary employees, in light of an
uHJ..P payroL.l LdX introduced by the CiovenllneIlC of Ontario,
14
would constitute a violation of 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 employees
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 Brown and Beatty,
Canadian Labour Arbitration (3rd Ed.), includes the following
as examples of benefits: life insurance, prescription plans,
night recovery leave, OH1P premiums, U.1. premiums, indemnity
for home study, Christmas bonuses, pension surpluses,
retirement allowances, meeting allowances, child 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
facilities, 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
Jlbenefitslf in a provision such as Article 5.02, it does
provide examples of the broad range of items which may fall
within the purview of that term.
Article 25 of the Agreement is entitled tllnsured
Benefits", and includes provisions regarding sick pay, life
15
insurance, a supplementary health and hospital plan, a vision
and hearing care plan, a dental care plan, and a long-term
disability plan. Those benefits are undoubtedly included
within the ambit of the term "benefits" in Article 5.01.
However, if the parties had intended to confine that term to
those benefits, 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
2511 (or perhaps more obliquely by using the phrase "insured
benefits" or the phrase "regular fringe benefits" in Article
5.02). However, they did not do so. The term they used is
"benefitsJl, 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.
In view of the foregoing conclusion that we have
reached on the basis of Employer counsel's second argument,
which we find to be determinative of the matter in issue, it
is unnecessary for the Board to deal with the other arguments
presented by counsel.
For the foregoing reasons, the Board has concluded
that OPACrs temporary employees are not entitled to receive
special compensation payments under the Letter of
Understanding.
As agreed by the parties, we shall remain seized of
the grievances for the purpose of deciding any other issues
arising thereunder which the parties are unable La resolve.
16
DATED at Burlington, Ontario, this 30th day of April, 2001.
~~,~J~~
Robert D. Howe
Chair
I dissent [for the reasons
contained in the attached
Dissent]
IIPamela Munt-Madill"
Union Nominee
I concur.
IIRobert Gallivanll
Employer Nominee
17
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DISSENT
With all due respect, I do not concur with the majorily's determination in this
matter. I do not believe that the language of Article 5.02 can reasonably be seen to
contemplate payment in compensation for termination of employment. Although
arbitrators have given the term "benefit" a broad definition in articles like this,
application to a situation of termination pay is distinguishable,
Termination pay is not a benefit of the same nature as those listed in Article 5,
I.e., holiday pay and vacations. Those and the other benefits referred to in the case law
are benefits of employment which an employee enjoys during the term of their
employment. It is these sorts of benefits that the payment referred to in Article 5.02 is
being paid in lieu of. Termination pay Is not a benefit received during the term of
employment. It is compensation for termination of that employment. The theoretical
basis for the calculation of this payment is the amount of loss occasioned due to the
termInation of the employment and the amount notionally required to sustain an
individual until new employment Is found. It Is difficult to view such a payment as a
"benefit" ,
Furthermore, none of the C$SeS referred to us during the course of the hearing
contained any discussion of analysis of termination pay as a "benefit" or a finding that
this type of payment should be so considered. For the above reasons, I would have
found that the terminatIon pay at issue here is not a benefit contemplated by the
language of Article 5.02 and would have allowed the grievance.