HomeMy WebLinkAbout2569 Crown & ALOC, AMAPCEO, OCAA, OPSEU & PEGO, award on National Day for Truth and Reconciliation2569/C
IN THE MATTER OF ARBITRATION
BETWEEN:
Association of Law Officers of the Crown
(ALOC)
Association of Management, Administrative and
Professional Crown Employees of Ontario
(AMAPCEO)
Ontario Crown Attorney’s Association
(OCAA)
Ontario Public Service Employees’ Union
(OPSEU)
Professional Engineers Government of Ontario
(PEGO)
AND
His Majesty the King as represented by the Treasury Board Secretariat
(TBS)
Grievances by ALOC, AMAPCEO, OCAA, OPSEU and PEGO concerning
the National Day for Truth and Reconciliation
Grievance Settlement Board File No. 2022-8790
(OPSEU Grievances 2022-0999-0013, -0014, -0018, -0019)
Christopher Albertyn - Sole Arbitrator
APPEARANCES
2569/C
Counsel for ALOC, AMAPCEO and PEGO:
Marisa Pollock
Karin Galldin
GOLDBLATT PARTNERS LLP
Counsel for OCAA:
Paul Cavalluzzo
Balraj Dosanjh
CAVALLUZZO LLP
Counsel for OPSEU:
Jorge Hurtado
Leila Gaind
MORRISON WATTS
Counsel for the Crown in Right of Ontario:
Lisa Compagnone
Maria-Kristina Ascenzi
MINISTRY OF THE ATTORNEY GENERAL
TREASURY BOARD SECRETARIAT
Legal Services Branch
Hearing held by videoconference on February 27, April 12, 28 and 30, May 8 and
19, June 7 and 29, 2023.
Award issued on July 13, 2023.
1
AWARD
The Issue
1. The trade union parties, described more fully below, represent public sector
employees of the Crown in Right of Ontario. They have filed grievances that raise
a common question: “whether the National Day for Truth and Reconciliation on
September 30 falls within the holiday entitlements set out in their respective
collective agreements” [para. 9 of the Agreed Statement of Facts].
2. The grievances were filed in response to the Employer’s decision not to
recognize the National Day for Truth and Reconciliation (NDTR) as a holiday for
the purpose of the holiday provisions under the unions’ respective collective
agreements in 2022 and likely ongoing [para. 42 of the Agreed Statement of Facts].
3. The parties agree that the issue to be determined first – “the common issue”
– is “the interpretive issue of whether the National Day for Truth and Reconciliation
is a holiday for purposes of the holiday provisions of the collective agreements in
issue” [para. 44 of the Agreed Statement of Facts].
4. A previous decision was issued in this matter on May 2, 2023, rejecting the
Employer’s motion to present evidence of its reasons for treating the National Day
for Truth and Reconciliation as a day of learning, reflection, and reconciliation,
rather than as a paid holiday under the unions’ collective agreements.
Agreed Statement of Facts
5. The parties have an Agreed Statement of Facts, as follows.
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Agreed Statement of Facts
The Parties
1. The Ontario Public Service Employees Union/ Syndicat des
employés de la fonction publique de l’Ontario (“OPSEU/SEFPO”) is
the exclusive bargaining agent for Crown Employees who work in
various provincial ministries and agencies for the government of
Ontario, and who are employed within two OPSEU/SEFPO
bargaining units (Unified and Correctional) as set out in Article 1-
Recognition of the Unified Bargaining Unit Collective Agreement and
Correctional Bargaining Unit Collective Agreement.
2. AMAPCEO is the exclusive bargaining agent of, inter alia,
professional employees who work directly for the government of
Ontario.
3. The Professional Engineers Government of Ontario (“PEGO”) is the
exclusive bargaining agent of professional engineers and Ontario
Land Surveyors, engineers in training, and surveyors in training, who
work directly for the government of Ontario.
4. The Association of Law Officers of the Crown (“ALOC”) is the
exclusive bargaining agent of “lawyers and articling students
employed by the government of Ontario to provide civil legal
services” (ALOC/OCAA Collective Agreement Article 1.4, see
Documents, Tab A).
5. The Ontario Crown Attorney’s Association (“OCAA”) is the exclusive
bargaining agent of “lawyers and articling students employed in their
professional capacity in the Criminal Law Division including fee-for-
service lawyers who are either employees or dependent contractors
as defined by the Labour Relations Act” (ALOC/OCAA Collective
Agreement Article 1.3, Tab A).
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6. The labour relations of OPSEU, AMAPCEO and PEGO are governed
by the Crown Employees Collective Bargaining Act and through that
Act, the Labour Relations Act.
7. The labour relations of ALOC and OCAA are governed by collectively
bargained Framework Agreements and the Arbitrations Act.
8. The Crown in Right of Ontario (the “Employer”) is the employer of all
of the employees covered by the collective agreements referred to
above. The Employer is party to separate collective agreements with
each of AMAPCEO, OPSEU, and PEGO. The collective agreement
of ALOC and OCAA is a separate agreement that is jointly bargained.
The Grievances
9. Each of the bargaining agents has filed a grievance which raises a
common question, namely, whether the National Day for Truth and
Reconciliation on September 30 falls within the holiday entitlements
set out in their respective collective agreements. The parties’
grievances are found at Tab B.
Bargaining History
OPSEU/ SEFPO
10. OPSEU/SEFPO was formed as the successor to the Civil Service
Association of Ontario.
11. The first Collective Agreement between the Employer and
OPSEU/SEFPO was ratified in 1978. The employee benefits applied
from October 1, 1977 to September 30, 1978.
12. The collective agreement language at that time stated:
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Article 9 – Holidays:
9.1 An employee shall be entitled to the following holidays
each year:
New Year’s Day Labour Day
Good Friday Thanksgiving Day
Easter Monday Remembrance Day
Victoria Day Christmas Day
Dominion Day Boxing Day
Civic Holiday
Any special holiday as proclaimed by the Governor-General
or Lieutenant Governor.
13. The holiday entitlement under the relevant Unified and Corrections
collective agreements currently read as follows:
An employee shall be entitled to the following paid holidays
each year:
New Year's Day Remembrance Day Civic Holiday
Easter Monday Boxing Day Thanksgiving Day
Canada Day Good Friday Christmas Day
Labour Day Victoria Day Family Day
Any special holiday as proclaimed by the Governor General
or Lieutenant Governor.
14. The holiday language has remained largely unchanged since 1977.
AMAPCEO
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15. The first full Collective Agreement between the Employer and
AMAPCEO was ratified in 1998.
16. The holiday language under the relevant AMAPCEO collective
agreement reads as follows:
29.1 An employee shall be entitled to the following paid
holidays each year:
New Year's Day Victoria Day Thanksgiving Day
Family Day Canada Day Remembrance Day
Good Friday Civic Holiday Christmas Day
Easter Monday Labour Day Boxing Day
An employee shall also be entitled to any special holiday as
proclaimed by the Governor General or Lieutenant Governor.
17. The relevant special holiday “as proclaimed by the Governor General
or Lieutenant Governor” language has remained unchanged since
the parties’ first collective agreement, and the enumerated holiday
entitlements have remained unchanged with the exception of the
addition of Family Day.
PEGO
18. The first Collective Agreement between the Employer and PEGO
was ratified in 1996 with respect to professional engineers. Since
2001, the bargaining unit expanded to include land surveyors.
19. The holiday language under the relevant PEGO collective agreement
reads as follows:
40.1 a) Each full-time employee is entitled to the following paid
holidays:
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New Year’s Day Family Day Good Friday
Easter Monday Victoria Day Canada Day
Civic Holiday Labour Day Thanksgiving Day
Remembrance Day Christmas Day Boxing Day
Any special holiday proclaimed by the Governor General or the
Lieutenant Governor.
20. The relevant special holiday “as proclaimed by the Governor General
or Lieutenant Governor” language has remained unchanged since
the parties’ first collective agreement, and the enumerated holiday
entitlements have remained unchanged.
ALOC/OCAA
21. The Employer, ALOC and the OCAA agreed on their first Framework
Agreement in July 1989. The first collective agreement between the
Employer, ALOC and the OCAA was ratified in January 1990.
22. Prior to the 2009-2013 ALOC/OCAA collective agreement, there was
no provision dealing with holidays. Since that agreement, the
relevant special holiday language has remained unchanged, and the
enumerated holiday entitlements have remained unchanged. It
reads as follows:
27.1 A full-time regular or fixed-term lawyer is entitled to a
holiday in each year on each of the following days:
New Year’s Day Victoria Day Thanksgiving Day
Family Day Canada Day Remembrance Day
Good Friday Civic Holiday Christmas Day
Easter Monday Labour Day Boxing Day
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Any special holiday proclaimed by the Governor General or
the Lieutenant Governor.
Existing Holiday Entitlements in the Collective Agreements
23. With slight variations in introductory wording, the collective
agreements at issue all identify a prospective entitlement to “any
special holiday as proclaimed by the Governor General or Lieutenant
Governor” and all refer to the same holidays.
24. Since the first Public Service Act in 1878, various regulations have
set out the terms and conditions of all public servants in the province
of Ontario.1 The phrase “special holiday proclaimed by the Governor
General or the Lieutenant Governor” entered the Ontario public
service workplace in 1970 via regulation.2 Most recently, Ontario
Regulation 977, established under the Public Service Act of Ontario,
S.O. 2006, prescribed holiday entitlements for public servants in
Ontario until its revocation in December 2007.3
25. Some of the holidays are found in federal statutes: The Canada
Labour Code refers to New Year’s Day, Good Friday, Victoria Day,
Canada Day, Labour Day, Thanksgiving Day, Remembrance Day,
Christmas Day and Boxing Day as “general holidays”. The federal
Holidays Act also establishes Victoria Day, Canada Day, and
Remembrance Day as legal holidays to be observed throughout
Canada.
26. Some of the holidays are also identified as such in provincial
statutes. The province of Ontario’s Employment Standards Act
1 An Act Respecting the Public Service of Ontario, 41 Vict., c. 2, 1878, assented to 7 March 1878,
s. 1.
2 O. Reg. 215/70.
3 R.R.O. 1990, Reg. 977.
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enumerates New Year’s Day, Family Day, Good Friday, Victoria Day,
Canada Day, Labour Day, Thanksgiving Day, Christmas Day and
Boxing Day as public holidays.
27. These holidays originate from different varieties of legislative and
executive acts and instruments.
Victoria Day
28. In 1845, the Legislature of the Province of Canada declared May 24
to be a holiday for Queen Victoria’s birthday. After Queen Victoria’s
death in 1901, Parliament passed an Act that established Victoria
Day as a legal holiday on May 24. In 1952, the Statutes of Canada
were amended to establish Victoria Day as the Monday preceding
May 25.4
Canada Day
29. On June 20, 1868, Dominion Day was established by Royal
Proclamation, signed by Governor General Lord Monck. In 1879,
Parliament passed a federal law that established July 1 as a statutory
holiday to celebrate the “anniversary of Confederation.” 5 On October
27, 1982, the name “Dominion Day” was changed to “Canada Day.”6
Labour Day
4 Canada, “Victoria Day”, online: Government of Canada <https://www.canada.ca/en/canadian-
heritage/services/important-commemorative-days/victoria-day.html>; An Act respecting Victoria
Day, 23 May 1901, (1901) C Gaz, vol 34, ch 12.
5 Canada, “Dominion Day – Origin and special observance”, online: Government of Canada
<https://www.canada.ca/en/canadian-heritage/services/canada-day-history/dominion
day/newspaper-extracts.html>; Monck, Proclamation, 20 June 1868, C Gaz; An Act to make the first
day of July a Public Holiday by the name of Dominion Day, House of Commons Debates, vol II
(assented to 15 May 1879) at 2047.
6 Canada, “History of Canada Day”, online: Government of Canada
<https://www.canada.ca/en/canadian-heritage/services/canada-day-history.html>.
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30. On July 23, 1894, a bill sponsored by Prime Minister John Thompson
to establish Labour Day received Royal Assent.7
Remembrance Day
31. Remembrance Day, which was previously known as Armistice Day,
was first proclaimed as a holiday in 1918.8 In 1921, Remembrance
Day was recognized as a holiday observed on the first Monday of the
week of November 11.9 In 1931, the date of the holiday was amended
to be November 11.10
Thanksgiving Day
32. On January 31, 1957, Thanksgiving Day was proclaimed by the
Governor General of Canada Vincent Massey as an annual holiday
to be celebrated on the second Monday of October.11 Prior to 1957,
Thanksgiving had been celebrated most years since proclaimed by
Sir John A. MacDonald in 1859 and was recognized as a holiday in
legislation as early as 1845.12
Family Day
7 An Act further to amend the law relating to Holidays, 4th Sess, 7th Parl, 1894 (assented to 23 July
1894).
8 Mulvey T, Proclamation, 23 November 1918, (1918) C Gaz, vol 52, no 21, 1739.
9 An Act respecting Armistice Day, 4 June 1921, (1921) C Gaz, vol 54, no 50, 5395.
10 An Act to amend the Armistice Day Act, 11 June 1931, (1931) C Gaz, vol 64.
11 Massey V, Proclamation, 31 January 1957, (1957) C Gaz, vol 91, no 4, 1.
12 Macdonald J, Proclamation, 1 October 1859, C Gaz, vol 18, no 39, 1; An Act to provide for the
Management of the Customs and of matters relative to the Collection of the Provincial Revenue, 1st
Sess, 2nd Parl, 1845 (assented to 17 March 1845).
10
33. On October 12, 2007, the Family Day Proclamation was declared by
the Lieutenant Governor.13 The Proclamation established Family Day
as a holiday pursuant to the Retail Business Holidays Act, R.S.O.
1990, Chapter R. 30 and of the Legislation Act, 2006, S.O. 2006 c.
21 Sched. F. The government issued O. Reg 547/07, also on
October 12, 2007, which amended O. Reg 285/01 of the Employment
Standards Act to prescribe Family Day as a public holiday.14 O. Reg
547/07 was later revoked when the Employment Standards Act was
amended. AMAPCEO and the employer signed agreements on
December 12, 2007, and on January 31, 2008, confirming that
Family Day is a holiday under the collective agreement (Tab C).
OPSEU similarly signed an agreement with the employer on
December 23, 2008 adding Family Day as a holiday under the
collective agreement (Tab D).
New Year’s Day, Good Friday, Christmas Day and Boxing Day
34. The origins of New Year’s Day, Good Friday and Christmas Day pre-
date Confederation, and are found in early legal definitions of holiday
from at least 1800 (for Christmas Day)15, 1801 (for Good Friday),16
13 Onley D, Proclamation, 27 October 2007, (2007) O Gaz, vol. 140-43.
14 O Reg 547/07, s 1.
15 An Act to amend part of Act passed in the thirty-fourth year of the Reign of His Majesty, intitled,
“An Act to establish a SUPERIOR COURT of CIVIL and CRIMINAL JURISDICTION, and to
regulate the COURT OF APPEALS,” and also to amend and repeal part of an Act passed in the
thirty-seventh year of the Reign of His Majesty, intitled, “An Act for Regulating the Practice of the
COURT of KING’S BENCH,” and to make further Provision respecting the same”, 3rd Sess, 2nd
Parl, 1798 (assented to 1 January 1800).
16 An Act for granting to his Majesty, his heirs and successors, to and for the uses of this Province
the like Duties on goods and merchandize brought into this Province from the United States of
America as are now paid on goods and merchandize imported from Great Britain and other places,
1st Sess, 3rd Parl, 1801 (assented to 9 July 1801).
11
and 1845 (for New Year’s Day)17. Similarly, Boxing Day has been a
holiday in Canada since at least 1872.18
Easter Monday
35. Easter Monday is a municipal enactment and has not been
designated as a provincial or federal statutory holiday.
Civic Holiday
36. The Civic Holiday is a municipal enactment and has not been
designated as a provincial or federal statutory holiday.
The National Day of Truth and Reconciliation
37. A new holiday, known as the National Day of Truth and
Reconciliation, was created by the federal government in 2021
through An Act to amend the Bills of Exchange Act, the Interpretation
Act and the Canada Labour Code (National Day for Truth and
Reconciliation) (“Bill C-5”). Bill C-5 took effect on June 3, 2021, when
it received Royal Assent. It amended three federal statutes, namely
the Bills of Exchange Act, the Interpretation Act and the Canada
Labour Code, to add a new holiday – the National Day for Truth and
Reconciliation – to be observed on September 30 every year
thereafter.
38. The purpose of Bill C-5 is to respond to the Truth and Reconciliation
Commission of Canada’s call to action number 80 by creating a
holiday called the National Day for Truth and Reconciliation to
honour First Nations, Inuit and Métis Survivors and their families and
communities and to ensure that public commemoration of their
17 An Act to provide for the Management of the Customs and of matters relative to the Collection of
the Provincial Revenue, 1st Sess, 2nd Parl, 1845 (assented to 17 March 1845).
18 An Act to amend the Act relating to Banks and Banking, 34 Vict, c 5 (assented to 14 June 1872).
12
history and the legacy of residential schools remains a vital
component of the reconciliation process.
39. On September 3, 2021, Deputy Minister of the Treasury Board
Secretariat, Deborah Richardson, issued a memorandum to all OPS
staff informing them of how the National Day for Truth and
Reconciliation would be treated on September 30, 2021 (Tab E).
Further, on September 20, 2021, she sent a reminder memo to all
OPS Staff regarding September 30, 2021 (Tab F). On September
20, 2021, the Bargaining Agents were informed, on a without
precedent and prejudice basis, that the National Day for Truth and
Reconciliation was treated as a holiday under the various collective
agreements discussed above. (Tab G). The Bargaining Agents were
provided notice of the employer’s intentions on or about August 31,
2022 through a letter from Kevin Wilson on behalf of Jennifer Price,
Director Employee Relations Branch (Tab H). A memorandum to all
OPS staff from Deborah Richardson was also sent out on August 31,
2022 (Tab I).
40. The employer sent out a memo and Q&A entitled “September 30 –
National day for Truth & Reconciliation & Orange Shirt Day” to all
OPS Staff on August 31, 2022 (Tab J).
41. A Ministry Guide for Learning and reflection was developed and
distributed to management within the OPS for use on September 31,
2021 (Tab K).
The Grievances
42. AMAPCEO PEGO, ALOC, OCAA and OPSEU all filed grievances in
response to the Employer’s decision not to recognize the National
Day for Truth and Reconciliation as a holiday under their respective
collective agreements.
13
43. AMAPCEO, ALOC, PEGO, OCAA and OPSEU have since joined
their grievances together, to be heard and determined by Arbitrator
Chris Albertyn.
44. The common issue between the parties, and the issue to be
determined first (“the common issue”), is the interpretive issue of
whether the National Day for Truth and Reconciliation is a holiday for
purposes of the holiday provisions of the collective agreements in
issue.
6. Counsel to the parties provided most helpful written summaries of their
principal arguments, which I will summarize further below, with their books of
authorities. The written briefs of the argument were: the unions’ submissions on
the merits of the grievances, the Employer’s submissions in response, the unions’
reply submissions, and the Employer’s surreply submissions. These submissions
were amplified in argument at the hearing.
7. The key issue is the proper interpretation of the words in the holidays’
language of the different collective agreements, which reads: an employee shall
also be entitled to any special holiday as proclaimed by the Governor General
or Lieutenant Governor.
8. The unions contend that the National Day for Truth and Reconciliation is a
special holiday that was proclaimed by the Governor General. The Employer
asserts that there never was such a proclamation by the Governor General. As will
be seen in the elaboration of the arguments below, the Employer’s submission is
that the Governor General giving royal assent to a statute is not a “proclamation”
or “proclaiming”. For the Governor General to proclaim a holiday, the Employer
submits, the Governor General must exercise an executive (rather than a legislative)
function, acting on the authority of the Cabinet of the Government of Canada.
14
Union Submissions
9. The unions rely on several recent arbitral decisions, on similar language,
affirming the National Day for Truth and Reconciliation as a holiday under the
collective agreements concerned (Caps Canada Corporation v United Food and
Commercial Workers, Local 175, 2023 CanLII 440 (Randazzo); Vaughan Public
Library Board v Canadian Union of Public Employees, Locals 90517 (Part-time
and Casual) and 90518 (Full-time), 2022 CanLII 79947 (Knopf); Olympic Motors
(WC1) Corp and IAMAW, Local 1857 (National Day for Truth and Reconciliation),
Re (2021), 334 LAC (4th) 434 (Saunders); PIPSC and New Brunswick (Department
of Finance and Treasury Board) (2021-110-152), Re (2022), 342 LAC (4th) 240
(Filliter); LIUNA, Local 1059 and London & District Concrete Formwork
Contractors’ Assn (Statutory Holiday), Re (2021), 333 LAC (4th) 318 (Beatty);
Alberta Union of Provincial Employees v Alberta Health Services, 2022 CanLII
22226 (Bartel); Sodexo Canada Ltd v Labourers’ International Union of North
America, Local 1059, 2021 CanLII 145655 (White); Windsor (Corporation of the
City) v Canadian Union of Public Employees, Local 543, 2022 CanLII 4641
(Steinberg); Corporation of the City of Belleville v Canadian Union of Public
Employees, Local 907, 2022 CanLII 62779 (Hayes); Kenora (City) and CUPE,
Local 19101 (National Day), Re, 2023 CLAS 33 (Sheehan); CUPE, Local 1750
and Ontario (Workplace Safety and Insurance Board) (Policy), Re, 2023 CLAS 36
(Sheehan); UFCW, Local 1006A and National Grocers Co. (GR0148), Re, 2021
CarswellOnt 14694, 150 C.L.A.S. 42, 334 L.A.C. (4th) 216 (Jesin); Pacific Honda
and IAMAW, Local 1857 (National Day for Truth and Reconciliation), Re, 2022
CarswellBC 1343, [2022] B.C.C.A.A.A. No. 47, 2022 C.L.A.S. 1 (Saunders);
Davis Wire Industries Ltd. v United Steelworkers Union, Local 2009, Re, 2022
CarswellBC 2060 at para 1 (Devine); CUPE, Local 1750.01 and Infrastructure
15
Health and Safety Assn., Re, 2022 CarswellOnt 15477, 2022 C.L.A.S. 457, 345
L.A.C. (4th) 225 (Mitchnick); BC General Employees’ Union v PRT Growing
Services Ltd. (National Truth and Reconciliation Day Policy), Re, 2022
CarswellBC 3351, 2022 C.L.A.S. 586, 345 L.A.C. (4th) 255 (Rusen); Wuis
Brothers Concrete Pumping and LIUNA Local 183, 2021 CanLII 135982
(Mitchell); George Vale Golf Club v CUPE Local 50, Re, 2022 CarswellBC 3385,
2022 C.L.A.S. 62 (Love); Johnson Controls and IBEW, Local 213 (National Day
of Truth and Reconciliation), Re, 2022 CarswellBC 1649, [2022] B.C.C.A.A.A.
No. 54, 2022 C.L.A.S. 423 (Kandola).
10. Referring to Alberta Health Services, Sodexo, and Olympic Motors, above,
and to Manalta Coal Co and Alberta Strip Miners Union, Local 1595, Re (1990),
17 CLAS 37 (Elliott), Ms. Pollock, counsel for ALOC, AMAPCEO and PEGO,
submits that arbitrators have taken a broad and liberal approach to the meaning of
“proclaim” and “proclamation” within the collective agreement holiday provisions.
Those cases suggest that “proclamation” refers to a government officially
declaring, announcing, or publishing an action of the government. In Malton
Village of the Peel (Regional Municipality) and CUPE, Local 966 (Arya), 2023
CLAS 101 (McNamee), the arbitrator suggested, at paragraph 41, that “proclaim”
requires “a considerable degree of formality” and provides “a clear statement of
government policy and intent”.
11. The Unions give law dictionary definitions of the meaning of “proclaim”
and “proclamation”.
• “Proclamation” – Promulgation, the official announcement or formal
declaration. The act of causing some state matters to be published or
made generally known. It is a publication by authority. A notice to the
public of anything or a public declaration of the sovereign’s will made
to his subjects. A written or printed document in which are contained
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such matters issued by proper authority. No particular form is necessary
to qualify a document as a proclamation (Attorney General of Canada
v Ryan, (1888) 5 Man. R. 81).19
• Proclamation. n. 1. Authorized publication. 2. A proclamation under
the Great Seal.20
• Proclamation. A formal public announcement made by the
government.21
12. The unions claim that the National Day for Truth and Reconciliation
(September 30th) was proclaimed as a holiday when, on June 3, 2021, the federal
Bill C-5 received Royal Assent because it was “declared” or “announced” or
“published” as a legal holiday on that date. The unions submit that the words,
“Governor General”, simply refer to the federal government, as distinct from the
provincial government. So, “promulgated by the Governor General”, is a reference
to a legislative act by the federal government.
13. Bill C-5 amended three federal statutes, namely the Bills of Exchange Act,
the Interpretation Act, and the Canada Labour Code, to add a new holiday – the
National Day for Truth and Reconciliation – to be observed on September 30 every
year thereafter (subject to observance on alternate days as permitted by law).
14. The unions made submissions on the meaning of the words, “special
holiday”, in the language of the holidays’ provision in the collective agreements.
19 The Canadian Law Dictionary, by R S Vasan (Don Mills, ON: Law and Business Publications
(Canada) Inc, 1980) at p 297.
20 “Proclamation” in The Dictionary of Canadian Law by Daphne Dukelow and Betsy Nuse
(Scarborough, ON: Carswell, 1991) at p 822.
21 “Proclamation” in Black’s Law Dictionary, 3rd ed by Bryan A Garner (St Paul, MN: Thomson
Reuters, 2009) at p 1326.
17
The issue was addressed in Ontario (WSIB), above, at paragraph 26 in response to
the WSIB’s argument that “special holiday” meant a one-time event. Arbitrator
Sheehan dismissed this argument, finding that “special” included the meaning,
“designed for a particular purpose or occasion”, which he found applied particularly
to the National Day for Truth and Reconciliation.
15. As counsel for the OCAA submit, the National Day for Truth and
Reconciliation is a “special holiday” because it is “readily distinguishable from
others of the same category” or “designed for a particular purpose or occasion”22.
The clear purpose of the enactment was stated in Bill C-5, at para. 38 of the Agreed
Statement of Facts:
The purpose of this Act is to respond to the Truth and Reconciliation
Commission of Canada’s call to action number 80 by creating a holiday
called the National Day for Truth and Reconciliation, which seeks to honour
First Nations, Inuit and Métis Survivors and their families and communities
and to ensure that public commemoration of their history and the legacy of
residential schools remains a vital component of the reconciliation process.
16. In the arbitral jurisprudence cited by the unions, arbitrators have looked at
how already recognized holidays came to be included as paid holidays. The origins
of the holidays differ, as is clear from paragraphs 25 and 26 of the Agreed Statement
of Facts, above. Some are from federal or provincial enactments, some are from
provincial proclamation (Family Day), and some (Easter Monday and the Civic
Holiday) are from municipal enactments. The variety of sources of the holidays has
persuaded arbitrators to accept holidays from different levels of government and
from different forms of enactment.
22 “Special.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-
webster.com/dictionary/special cited in CUPE, Local 1750 and Ontario (WSIB), above, at para 26.
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17. The unions submit that a common-sense, non-technical, approach is needed,
as the parties to the collective agreements would themselves have done. The unions
stress that the main consideration is “to discern the intention of the parties from the
language in the collective agreement”23. Counsel for the OCAA submit that this is
to be done by applying the fundamental rules of collective agreement
interpretation24. Counsel for OPSEU stress the importance of giving the language
its plain and ordinary meaning.25 They submit that any new statutory holiday,
whether from the federal or provincial government, is what the parties intended to
be covered by the relevant language, “any special holiday as proclaimed by the
Governor General or Lieutenant Governor”.
18. Counsel for the OCAA submit that the unions’ interpretation of the key
23 LIUNA, Local 1059 and London & District Concrete Formwork Contractors' Assn. (Statutory
Holiday), above, at para 23.
24 The “fundamental rule of collective agreement interpretation” is that the “words used must be
given their plain and ordinary meaning unless it is apparent from structure of the provision or the
collective agreement read as a whole that a different or special meaning is intended”. “All words
must be given meaning, and different words are presumed to have different meaning, unless this
would lead to a result that is absurd or inconsistent with the overall scheme and structure of the
agreement”. (Ontario Power Generation Inc. v Society of Energy Professionals, 2011 CanLII 8963
(Surdykowski) para. 27).
An interpretation which leads to an absurdity should be avoided. An “interpretation that renders a
provision redundant is inherently absurd” as it is “unlikely the parties settled upon language
incapable of conveying value, tangible or otherwise”. (LIUNA, Local 1059 and London & District
Concrete Formwork Contractors' Assn. (Statutory Holiday), above, at para 26; Pacific Honda and
IAMAW, Local 1857 (National Day for Truth and Reconciliation), Re, 2022 CarswellBC 1343 at
para 41).
Prior arbitration awards dealing “with the same words or phrases are a significant source of meaning
and are often resorted to as corroborative aids or as aids where the meaning of the words in the
agreement admit of more than one interpretation”. (Brown and Beatty, Canadian Labour Arbitration,
5th Edition, LAXBROWNB § 4:34. Prior Arbitration Awards and Judicial Decisions).
Parties to a collective agreement are presumed to know the relevant context, including
jurisprudence. (AUPE and Alberta Health Services (848846), Re, 2022 CarswellAlta 68 at para 29).
25 Maple Leaf Consumer Foods v. United Food and Commercial Workers Canada, Local 175, 2011
CanLII 6860 (ON LA) (Surdykowski), at paras. 18-19.
19
phrase, “any special holiday as proclaimed by the Governor General or Lieutenant
Governor” is consistent with the climate of collective bargaining and with the
prevailing principles of collective agreement contract interpretation. In particular,
the decision in Johnson Controls and IBEW, Local 213 (National Day of Truth and
Reconciliation), above, is instructive because the language in that collective
agreement, “so declared a holiday by order in council by the Federal or Provincial
Governments”, was found to include the National Day for Truth and Reconciliation.
Arbitrator Kandola effectively found that “order in council” was equivalent to
“declared” or “proclaimed” involving “the exercise of a law-making power” by the
government (paras. 9 and 19).
19. The parties have delegated to the federal and provincial governments to
determine a holiday that is to become part of their collective agreement. The OCAA
submits that the collective agreement language is clear and unambiguous on its
face, and that, on the plain and ordinary meaning of the words used, when the
National Day for Truth and Reconciliation was proclaimed a holiday by the federal
government on June 3, 2021, it became a holiday under the collective agreement.
20. The unions rely particularly on the Ontario (WSIB) decision of Arbitrator
Sheehan (sitting as an arbitrator of the Grievance Settlement Board (GSB)), above,
because he interpreted the same language and found (at para. 26) that the National
Day for Truth and Reconciliation was captured by that language because it was
“proclaimed” by the federal government.
21. Counsel for OPSEU refer to Ontario (WSIB) in the context of the Blake
principle at the GSB26 (this case is being heard, in part, under the aegis of the GSB).
Counsel argue that the GSB jurisprudence should be followed on the same issue.
26 ATU Blake et al v. Ontario (Toronto Area Transit Operating Authority), GSB No. 1276/87
(Shime).
20
In Blake, GSB Chair Shime established the principle that prior GSB decisions
should be followed unless exceptional circumstances warranted an earlier decision
of this board being reviewed.
22. OPSEU counsel argue that there are no “exceptional circumstances” to
distinguish this case from that heard by Arbitrator Sheehan in Ontario (WSIB), and
therefore that decision should be followed.
23. The relief sought by the unions is for the grievances to be upheld; for the
National Day for Truth and Reconciliation to be declared a paid holiday under the
Holidays language of each of the collective agreements; for the affected employees
to made whole for the losses incurred as a result of the failure by the Employer to
recognize the National Day for Truth and Reconciliation as a paid holiday on
September 30, 2022; and that the arbitrator remain seized for the implementation
of these orders.
Employer Submissions
24. The Employer does not take issue with the unions’ argument that the
National Day for Truth and Reconciliation is a “special holiday”. The Employer’s
focus is on the meaning of the words, “proclaimed by the Governor General”.
Employer counsel say there was no proclamation by the Governor General, and
therefore, on the plain meaning of the language agreed by the parties, no holiday
for the purpose of the collective agreements has come into effect.
25. The Employer submits that the source of the language in the collective
agreements – first appearing (among these parties) in the OPSEU agreement in
1978 – is a regulation (Ontario Regulation 977) under the Public Service Act, which
described the holiday entitlements that were later incorporated into the parties’
21
collective agreements. From this, the Employer suggests that “the parties were
negotiating in the shadow of legislation and regulation that set out terms and
conditions of employment in this context, the parties intended the words in the
collective agreement to mean the same as what those words meant under the law”.
26. On this basis, the Employer submits that the phrase, “proclaimed by the
Governor General or Lieutenant Governor” has a specific meaning that is distinct
from assenting to legislation. What is meant, the Employer suggests, is a
proclamation issued under an Order of the Governor General.
27. The National Day for Truth and Reconciliation became law after royal
assent was given by the Governor General27 to Bill C-5 once it was passed in the
House of Commons and the Senate. The role of the Governor General was the final
step in the enactment of the legislation. The Employer argues that what is required
by the language, “proclaimed by the Governor General or Lieutenant Governor”, is
an executive act by the Governor General, not the legislative act of royal assent. In
other words, royal assent is legally distinct from proclamation, and therefore, on
the language of the collective agreement, the Governor General never proclaimed
the holiday.
28. The Employer refers to para. 33 of the Agreed Statement of Facts, which
describes how Family Day came to be included in the collective agreements, to
explain how proclamations are issued. The Lieutenant Governor was empowered
by statute to issue a proclamation and then did so. That was an executive act
authorized by statute.
29. The Employer refers to two cases, Durham (Regional Municipality) and
27 In fact, royal assent was given by the Chief Justice acting as Governor General because the office
of the Governor General was vacant at the time.
22
Ontario Nurses’ Association 2008 CanLII 14936 (ON LA) (Bendel) and Aqua-Pak
Styro Containers Ltd. and I.W.A. Canada, Loc. 1-3567, Re, 1996 CanLII 20377
(BC LA) (Kelleher), to suggest there is a presumption that parties intend, in their
collective agreements, to give words the same meaning as the definition of those
words in a statute.
30. The Employer relies on the SCC decision in Sattva Capital Corp. v. Creston
Moly Corp. 2014 SCC 53 (CanLII), particularly the comments, at para. 47, that the
mutual intention of the parties is ascertained by reading “the contract as a whole,
giving the words used their ordinary and grammatical meaning, consistent with the
surrounding circumstances known to the parties at the time of formation of the
contract.” Employer counsel suggest that the “surrounding circumstances” at the
conclusion of the collective agreements was the statutory framework in existence,
particularly Ontario Regulation 977.
31. The Employer points out that the interpretation of statutes and regulations
is governed by the applicable provincial and federal legislation. Provincially, in
Ontario, successive versions of the Interpretation Act28 applied until July 25, 2007,
and thereafter the Legislation Act, 200629 applied. Federally, the interpretation of
statutes and regulations is governed by the Interpretation Act30.
32. Under both the provincial and the federal statute, a “proclamation” of the
Governor General or of the Lieutenant Governor is understood to mean that it is
issued as the Governor or Lieutenant Governor in Council. In other words, a
proclamation is understood to be issued on the direction of the Cabinet.
28 Interpretation Act, RSO 1970, c 225, Interpretation Act, RSO 1980, c 219, and Interpretation Act,
R.S.O. 1990, c I.11.
29 SO 2006, c 21, Sched. F, s 134.
30 Interpretation Act, R.S.C. 1970, c I-23; Interpretation Act, R.S 1993, c I-21.
23
33. The Employer says that Family Day was proclaimed a holiday by the power
given to the Lieutenant Governor of Ontario to do so under the Retail Business
Holidays Act31. Similarly, the Governor General is empowered by create holidays
by proclamation under the Interpretation Act32 and under the Bills of Exchange
Act33.
34. Since the National Day for Truth and Reconciliation was created by statute
(with royal assent by the Governor General), rather than by proclamation by the
Governor General in Council under the Interpretation Act or the Bills of Exchange
Act, the Employer submits that this holiday was not “proclaimed”, as the language
of the collective agreement requires.
35. The Employer points out that there are other cases that use the words,
“proclaim” or “proclamation” or “declared” “by the federal or provincial
government”. The Employer concedes that, had that been the language, then the
holiday was proclaimed by the federal government.
36. It is only in the present case, in the GSB Ontario (WSIB) case, and in the
Province of New Brunswick matter34 that the language involves proclamation by
either the Governor General or the Lieutenant Governor. The Employer’s argument
(of a distinction between Royal Assent and Proclamation) was not made in the
Ontario (WSIB) case. It was made, though, in the Province of New Brunswick
matter. That is the only case among all the others cited by the parties that directly
addressed the Employer’s argument. The language in that case was, “all other days
proclaimed as holidays by the Governor-General of Canada or the Lieutenant-
Governor of the Province of New Brunswick.”
31 RSO 1990, c 30, s. 1(1)(i).
32 s. 35(1).
33 R.S.C. 1985, c B-4, s. 42(b).
34 2022 CanLII 95985 (NB LA) (Breen).
24
37. In Province of New Brunswick, the employer argued, like the Employer does
in this case, that the Governor General declares holidays by making a proclamation
under the federal Holidays Act, and not by giving royal assent to a parliamentary
Bill. That argument was unsuccessful. Arbitrator Breen found that royal assent was
a form of the Governor General proclaiming a holiday into law, and so he declared
the National Day for Truth and Reconciliation to be holiday.
38. The Employer here argues that Province of New Brunswick was wrongly
decided because it blurred the distinction between royal assent and Proclamation.
The Employer suggests that Arbitrator Breen’s decision should not be followed
because it relied on dictionary definitions of “proclaim” and “proclamation” when
those terms are defined in the interpretive statute, the Interpretation Act. The
Employer submits that the only valid definitions of “proclaim” and “proclamation”,
for the purpose of determining what the parties intended, are those contained in the
Interpretation Act.
39. As regards the Blake principle, argued by OPSEU, the Employer makes two
arguments. First, if a new legal argument is made and the GSB has not had occasion
to address that argument previously, then the prior decision need not be followed.35
Second, if the prior decision has a manifest error, or the GSB is “attracted by a new
argument that could have been, but was not made, in the previous case”, the GSB
is not obligated to follow the earlier GSB decision.36
40. The Employer refers to the prior GSB decision of Arbitrator Sheehan in
Ontario (WSIB) and points out that the employer in that case did not contest that
35 Lariviere and Ministry of Community Safety and Correctional Services, GSB No. 2002-2124
(Dissanayake).
36 Monk et al and Ministry of Community Safety and Correctional Services et al, GSB No. 1995-
1694 (Gray).
25
the Governor General had proclaimed the National Day for Truth and
Reconciliation as a holiday.
41. Consequently, the key argument presented by the Employer in this case –
that the Governor General did not proclaim the National Day for Truth and
Reconciliation as a holiday – was not considered in the prior GSB decision. That
issue is therefore open for consideration in this case.
42. The Employer asks, if the unions are successful, that the remedies be
referred to the parties, specifically as they related to September 30, 2022, and that
the arbitrator remain seized if implementation issues arise. The Employer further
suggests that individual relief should not be granted on the strength of the unions’
policy grievances.
The Unions’ Reply
43. All the unions adopt each other’s positions in their original arguments and
in their replies.
44. Counsel for ALOC, AMAPCEO and PEGO challenge the assumptions that
inform the Employer’s main argument that there is a clear legal distinction between
royal assent and Governor General Proclamation. The Employer suggested that
words defined in statute, used in the collective agreement, should be accorded the
meaning they have in the statute when interpreting the collective agreement. The
Employer relied on two cases for this proposition: Aqua-Pak and Durham, above.
45. Counsel point out that the arbitrators concluded in both of these cases that
the words in the collective agreements meant something different from the statute
(despite any presumption of following the definition of a term in a statute in
26
collective agreement interpretation), and that the parties’ intentions were different
from what was contained in the statute. From this, the unions submit that any
presumption in favour of a statutory definition is rebuttable and yields to the
primary principle of collective agreement interpretation, viz., to discern the
intention of the parties, having regard to the context in which the words appear.
46. Moreover, while in Aqua-Pak and Durham, the term referred to in the
collective agreement was actually defined in the statute, there is no definition in the
statutes referred to by the Employer of any of the words used in the collective
agreement. That, the unions suggest, eliminates any presumption, and shows that a
necessarily building block of the Employer’s argument is missing.
47. The unions submit that the better approach is to apply the usual canons for
collective agreement interpretation and to apply them to the provision as the parties
themselves have done, by recognizing their intention to capture new holidays
established by the federal or provincial government.
48. In response to the Employer’s argument that the disputed language was
imported from Ontario Regulation 977, the unions reply that there is no evidence
that the parties imported the disputed language from anywhere. There is also no
evidence that the language used, “proclaimed by the Governor General or the
Lieutenant Governor” has any specific meaning under law. It is not defined in
statute, and there is no evidence that it had the meaning contended for by the
Employer when the collective agreements were concluded.
49. Consequently, counsel for ALOC et al. submit that the Employer has
conjured the notion that “proclaiming” does not include royal assent because that
is not done “under law” or done “in accordance with that established by law”.
Ultimately, counsel suggest that the whole Employer argument is a construct that
lacks a foundation in any definition or principle of law.
27
50. Union counsel contend that the interpretive statute of how the Governor
General exercises their power has nothing to do with the collective agreement and
would never have entered the parties’ thinking when they concluded the collective
agreements. They were not thinking about how the Governor General signifies
approval; only that if such approval were granted and a holiday were declared, it
would then become part of the collective agreement.
51. In summary, because there is no corresponding definition in statute of the
words used in the relevant provision of the collective agreement, the unions say that
there is no basis for the presumption that the parties intended to distinguish between
the Governor General acting by royal assent or by proclamation.
52. Union counsel point to the provisions in their collective agreements where
the parties made direct mention of a statute and where the meaning of a statutory
provision is effectively incorporated into their collective agreements. They contrast
this with the absence of any reference to the interpretive federal and provincial
statutes that define the powers of the Governor General and of the Lieutenant
Governor. Counsel submit that when the parties want to make reference to statutes
and statutory definitions, they do so deliberately.
53. The unions point out that the holidays included in the collective agreements
have come from both proclamation and royal assent, as well as other means.
54. Counsel for OPSEU point out that Bill C-5, which the Governor General
assented to, makes clear that the National Day for Truth and Reconciliation is being
proclaimed. There is a declaration by parliament, of which the Governor General is
part, of this holiday being incorporated in the three federal statutes that were
amended (Bills of Exchange Act, Interpretation Act and Canada Labour Code). In
OPSEU’s submission, this process amounts to the Governor General proclaiming
28
the new holiday.
55. OPSEU counsel make the point that those negotiating the collective
agreements are not constitutional scholars, but labour relations representatives. He
argues that, when concluding the holidays’ provision, the parties were not
incorporating any statute or any statutory interpretation; they were simply wanting
to incorporate holidays that had become law, either federally or provincially.
56. Counsel for OCAA point out that the Employer’s case is built on the word,
“proclamation”, when the actual word used in the collective agreement is
“proclaimed”, a word that means, simply, “declared”. There is also no definition on
“proclaim” or “proclaimed” in the federal Interpretation Act. “Proclamation” is
defined as “a proclamation under the Great Seal” but “proclaim” is not defined. In
any event, counsel argue that issuing a proclamation under the Great Seal includes
the action of the Governor General in giving finality to the legislative process, by
making a written declaration. A proclamation under the Great Seal can be either the
final step of the legislative process or the executive act of the Governor in Council.
57. OCAA counsel submit that the distinction drawn by the Employer – the
difference between the Governor General’s legislative role in giving royal assent
and their executive role in issuing proclamations as those of the Governor in
Council – is far from clear. The Preamble to the Royal Assent Act, S.C. 2002, C.15,
describes how the Governor General gives royal assent. The form and manner of
royal assent is described in s.2:
Form and manner of royal assent
2 Royal assent to a bill passed by the Houses of Parliament may be signified,
during the session in which both Houses pass the bill,
(a) in Parliament assembled; or
(b) by written declaration.
29
58. The Hansard record states that on June 3, 2021, “I have the honour to inform
you that the Right Honourable Richard Wagner, Administrator of the Government
of Canada, signified royal assent by written declaration to the bills listed in the
Schedule to this letter on the 3rd day of June, 2021, at 6:34 p.m.”
59. So, OCAA counsel submit, there was a “written declaration” by Chief
Justice Wagner – acting as the Governor General – which was the Governor
General “proclaiming” the holiday. The law is effective upon both houses of
parliament being informed that the Governor General has signified assent, in this
case by “written declaration”. The unions submit that is proclaiming the holiday.
60. OCAA counsel refer to the Library of Parliament Publication37 “Designation
of National Days and Observances in Canada”. The publication explains the
difference between observances and legal holidays. Parliament can pass legislation
“proclaiming specific days as holidays or officially recognized days”38.
61. The publication explains that the federal government may establish “a
national day or observance by way of a proclamation or order in council, with or
without Parliament’s approval. An order in council is made by the Governor
General on the advice of the Privy Council. It is usually formulated by Cabinet or
a committee of Cabinet and takes legal effect when signed by the Governor
General”39. This, OCAA counsel submit, is what the Employer refers to as a
Proclamation by the Governor General in Council and claims the parties agreed to
in their collective agreements.
62. Table 1 of the publication lists the national days and observances in Canada.
37 Publication No. 2015-06-E, 6 February 2015, Revised 5 April 2017.
38 Para. 2.1.1.
39 Para. 2.2.
30
Those proclaimed by the Governor General in Council include National Mining
Week, Clean Air Day Canada, National Aboriginal Day, National Day of
Remembrance for Victims of Terrorism, A Day of Commemoration of the Great
Upheaval, Police and Peace Officers’ National Memorial Day and National
UNICEF Day. These are the observances that are declared by proclamation by the
Governor General in Council. OCAA counsel explain that these are not holidays,
they are notational days and observances.
63. OCAA counsel refer also to a statement by the Prime Minister of Canada
declaring September 19, 2022 as a National Day of Mourning in Canada to mark
the passing of Her Majesty Queen Elizabeth II. In that statement an explanation is
given regarding statutory holidays: “Statutory holidays in Canada can only be
granted through legislation, which must pass through the House of Commons and
the Senate and receive Royal Assent”.
64. Counsel further explain that there are different sources for days of
mourning, for observances, and for notational days (the Prime Minister’s office,
Proclamations by the Governor General, resolutions by the Senate or the House of
Commons). However, federal holidays are created only by statute, i.e., by
parliament passing a law ordering the existence of a new holiday, which has royal
assent by the Governor General as its final stage.
65. Consequently, OCAA counsel argue that, if the language in the collective
agreement is interpreted in the manner advanced by the Employer, there can never
be a federal holiday added to the list of holidays. That is because the Governor
General in Council, issuing a proclamation, can declare an observance, but not a
holiday. The only way a holiday can be declared is by royal assent of a bill approved
by the House of Commons and the Senate. Counsel submit that the parties could
not have intended that there would never be a federal holiday added pursuant to the
31
provision. Were that so, the unions would have negotiated something of no value;
enforcing what the Employer contends for would amount to enforcing a nullity.
Employer Surreply
66. The Employer reiterates that there never was a proclamation of the National
Day for Truth and Reconciliation by the Governor General. If the statute creating
the holiday had had a provision that the effective start date of the holiday was to be
declared by the Governor General, then the Governor General could have
proclaimed it. As it was, the date was set in the statute and royal assent did not
amount to proclaiming or a proclamation, which Employer counsel submit are one
and the same.
67. The Employer says that the National Day for Truth and Reconciliation was
created by the government of Canada, but not by proclamation of the Governor
General. The parties chose the language of the Governor General proclaiming, not
the government of Canada proclaiming, therefore the parties never agreed that
legislated holidays, without a proclamation by the Governor General, would
become part of the collective agreements.
68. Employer counsel point out that the source documents introduced by the
OCAA in reply do not form part of the Agreed Statement of Facts and they
constitute secondary sources of the powers of the Governor General, removed from
the factual matrix of the bargaining that concluded the collective agreements, and
from the facts surrounding Bill C-5, which came into force two months after royal
assent.
69. Employer counsel reiterate that the factual context for the negotiation of the
provision was Ontario Regulation 977, which necessarily meant that the distinction
32
between proclamation and royal assent was known to the parties, or ought to have
been known to them, and was imported into the collective agreements. Employer
counsel highlight that the relevant language requires more than mere assent or
approval by the Governor General (as occurs with royal assent). What was needed
was a proclamation, which is absent.
Decision
70. The question to be answered is, what did the parties intend when they agreed
to the language, “any special holiday as proclaimed by the Governor General or
Lieutenant Governor”.
71. Part of this determination is to decide if there is any sound legal basis for
suggesting, as the Employer has, that the parties understood themselves (or should
have understood themselves) to have agreed that they were not including any
special holiday that was the result of legislation (federally or provincially), and that
only those holidays which resulted from a proclamation issued by the Governor
General (or Lieutenant Governor) in Council (acting on the authority of the
Cabinet) were to become part of the collective agreement.
72. For reasons explained below, I find that proposition to be wholly unlikely.
The notion of a difference between royal assent and proclamation is novel and
interesting, but it is hardly the stuff of common knowledge and experience among
those negotiating collective agreements. Even if the parties knew they were taking
the language from Ontario Regulation 977, as the Employer asserts, I doubt very
much that anyone negotiating the agreement had a clear conception that there might
be a nice legal difference between proclamation and royal assent. I have difficulty
believing that all who concluded these agreements understood this and, more
importantly, understood that the one type of declaration would create a holiday and
33
the other would not.
73. There are several arbitration awards that have looked at the question of what
is meant by “proclaimed” and “proclamation”. Among them are the AUPE40 and
the Province of New Brunswick (above) cases.
74. The AUPE case decided that Royal Assent to Bill C-5 meant that the
National Day for Truth and Reconciliation was “proclaimed” “as that word is
generally understood in legal parlance”:
53. I find that on Royal Assent, given to An Act to Amend the Bills of
Exchange Act, the Interpretation Act and the Canada Labour Code
(National Day for Truth and Reconciliation), the federal government
“declared” “announced” and “published” its intention that the National Day
for Truth and Reconciliation was to be considered as both a “holiday” and a
“general holiday” as those terms are used in federal legislation. As of June
3, 2021, the National Day for Truth and Reconciliation was “proclaimed” as
that word is generally understood in legal parlance. …
75. The union in the Province of New Brunswick relied on the AUPE decision
for the proposition that royal assent is the same as proclaiming into law. Arbitrator
Breen, deciding Province of New Brunswick, said this:
50. To this need, I go then to what is claimed as a distinguishing point
by the Employer in this case; i.e., its claim, as to my referred to second point
of difference found in Article 25.01(m), that a “proclamation” by the
Governor General is different than a “proclamation” by, e.g., an appropriate
federal Government authority, - words in issue in the NB Power case. For a
counter to this contention, I turn to the Royal Assent Act, s.c. 2002, c. 15,
cited by the Union in reply, and the Hansard report of June 3, 2021, both of
which attest that Royal Assent is, to cite directly from the Act, “the
40 AUPE and Alberta Health Services (848846), Re 2022 CarswellAlta 685, 337 LAC (4th) (Bartel).
34
constitutional culmination of the legislative process”; i.e., a confirmation
that when Royal Assent of the Governor General is signified by, as here the
case, “written declaration”, an Act is set to come into force – the final step
taken to a “Coming into Force”41 of federal legislation – a like proclamation
recognition addressed in the NB Power42 and AUPE decisions.
51. Further to a “written declaration”, as is spoken to in the Hansard
report of for the NDTR, in the AUPE case reference for the word “proclaim”
was made to Black’s Law Dictionary – there shown, at para 50, to include
the following definitions: to promulgate; to announce; to publish; by
governmental authority. I note too the award in Olympic Motors, where the
arbitrator there, addressing the question of “any other day proclaimed” by a
Federal or Provincial Government stated, at para. 20, that the word
“proclaimed” was read to mean “officially declared”. Also instructive, in
the Manalta case, too cited by the Union, the word “proclaimed” at para 20
was given the following meaning: “established”.
52. As follows from the above, and to close on this point of difference,
I cite once more from AUPE, at para. 53, and a statement offered taken as
applicable to be said here: “As of June 3, 2021, the NDTR was ‘proclaimed’,
as that word is generally understood in legal parlance”.
53. In summary then, I confirm: I find support for the Union’s
proclamation position offered in this case – I accept that a Bill becomes an
Act by proceeding through Parliament, the Senate, and upon receiving Royal
Assent – proclaimed or officially declared – set to come into force. As also
follows here, with Royal Assent given and a coming into force of an “all
other days” holiday, the members of the bargaining unit here can be expected
to enjoy another paid holiday. Once again, this by a choice by the parties of
41 Footnote in original: See Bill C-5, s. 6, which provides, in part, for the NDTR to come “into force
on the day that, in the second month after the month in which it receives royal assent, has the same
calendar number as the day on which it receives royal assent…
42 BEW Local 37 v. NB Power Corporation, date of decision January 26, 2022, referred to in para.
22 of Province of New Brunswick.
35
official language proclaiming a holiday – marking the completion of a
legislative enactment process – words chosen, I find, that go to the same
purpose and intent as those found in the NB Power and AUPE decisions.
76. I agree with Arbitrator Sheehan’s conclusions in the GSB decision Ontario
(WSIB). I adopt his reasoning.
77. As the unions have argued, the critical question is what the parties intended
when they entered into their collective agreements and adopted the language,
“proclaimed by the Governor General or Lieutenant Governor”. I find that they are
most unlikely to have understood that they were agreeing to the interpretation the
Employer suggests.
78. The distinction between assent to a statute and proclamation is not
manifestly apparent from the Interpretation Act, from which the Employer tries to
build the distinction. There is no definition of “proclaim”, and there is no
description that makes clear that it cannot mean royal assent. On the contrary, the
“written declaration” as a defined form of the manner of royal assent under the
Royal Assent Act makes clear that royal assent is a form of proclamation.
79. What really matters, though, is what the parties themselves thought when
they entered into the agreements. They were labour relations representatives
entering into an agreement to cover what would happen if a new holiday were
declared by the government. In my view, their focus was not on the mechanism of
promulgation or declaration of the holiday into the law, but on the outcome. They
were focused on what would be the consequence for their agreement if a new
holiday became law, not on how that law was brought about.
80. I suspect the parties chose the particular language they did, because of what
36
had been in the Public Service Act or its regulations, as the Employer argues. But
that does not entail that they themselves thought that such holidays were to become
part of the agreement only if they were proclaimed other than by the passing of a
statute. I find it unlikely that the method of promulgation would have entered their
minds, let alone have been a common intention. The most likely thought in their
minds was that, when a holiday becomes law, then that holiday will be included in
the collective agreement.
81. As the unions argue, there is no reference to any statute, such as the Public
Service Act or Ontario Regulation 977, in the holidays’ provisions of the collective
agreements. That is because the parties never intended to incorporate any statutory
reference in that provision. When they want to refer to a statute, they tend to do so
expressly.
82. In my view, the specific language used in the collective agreements by the
parties to include new holidays created by government does not particularly matter
(whether it be “promulgated by the federal or provincial government” or
“proclaimed by the Governor General or Lieutenant Governor” or other similar
wording), so long as that intention is clear. What is manifest in the phrase, “an
employee shall also be entitled to any special holiday as proclaimed by the
Governor General or Lieutenant Governor”, is that when a new holiday has
become the law of the land, either by federal or provincial legislation or executive
order, then it is to be included in their collective agreements. That is the plain and
ordinary meaning of the provision.
83. For this reason, I adopt what Arbitrator White said in Sodexo Canada Ltd.,
at para.16:
Turning to the term “proclaimed” as it is used in Article 8.03, it is clearly
intended to be understood as a reference to an action taken by a
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“government”. Accordingly, should a “government”, as referenced by
Article 8.03, publicly declare that it has enacted a new holiday, it may be
said that the holiday has been “proclaimed”.
84. I also adopt the broad approach taken by Arbitrator Breen in Province of
New Brunswick, including for the reasons he advanced (paras. 50-53). The
culmination of the legislative process was the Governor General signifying a
“written declaration”, that being the Governor General proclaiming the new
holiday.
85. For these reasons, I find for the unions.
86. The grievances are upheld. The National Day for Truth and Reconciliation
is a holiday within each of the Holidays’ provisions of the collective agreements. It
ought to have been granted as a paid holiday in 2022. The remedy is referred to the
parties for resolution.
87. I remain seized if the parties cannot agree on the remedy.
DATED at TORONTO on July 13, 2023.
_____________________
Christopher J. Albertyn
Arbitrator