HomeMy WebLinkAboutP-2010-0702.Lee et al.11-07-21 DecisionPublic Service Commission des
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P-2010-0702, P-2010-1055
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Complainants
Mike Lee et al and Jim Allen
- and -
The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services)
Employer
BEFORE.DWKOHHQ*2¶1HLOVice-Chair
FOR THE COMPLAINANTSMike Lee, Jim Allen and Al White
FOR THE EMPLOYERJennifer Richards
Ministry of Government Services
Labour Practice Group
Counsel
HEARING
May 26, 2011.
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Decision
[1] This decision deals with preliminary objections raised by the employer in regards to the
complaints of a group of Operational Managers at Elgin Middlesex Detention Centre
(EMDC). The complaints relate to a blog said to be associated with Correctional Officers
who are represented by the Ontario Public Service Employees Union (OPSEU), Local
108. The allegations are in essence that the employer has failed to provide a workplace
free from harassment and discrimination by failing to take sufficient action in regards to
the blog, which is said to have contained offensive and defamatory material directed at
managers, in breach of several Ministry policies and the Occupational Health and Safety
Act as well as to have created a poisoned work environment.
[2] The employer takes the position that the complaints, as grievances are now called under
should be dismissed without
Regulation 378/07 of the Public Service of Ontario Act,
further hearing, as they are untimely and do not make out a prima facie casefor a
breach of the terms and conditions of the DSSOLFDQWV¶HPSOR\PHQWE\WKHHPSOR\HU
Factual/procedural background
[3] An individual complaint filed by Operational Manager James Allen and a group complaint
filed by several other Operational Managers were listed for hearing together as they deal
with the same subject matter and are very similar in wording and remedial request, in
accordance with s. 13(1) of Regulation 378/07.
[4] For the purpose of preliminary motions such as those raised by the employer, the facts
asserted in the complaints are assumed true and provable. Findings concerning any
disputed facts would only be made on evidence at a hearing on the merits of the matter.
Many of the facts relevant to this case are in fact not in dispute and a number of
documents were entered into evidence on consent. What follows is an overview of the
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[5] Leading up to the signing of the most recent collective agreement between the employer
and OPSEU, Correctional Officers, who are supervised by the Operational Managers,
engaged in various forms of organized efforts to make their collective strength felt and to
support their position in collective bargaining. In May, 2009, a group of Operational
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Managers wrote to the Superintendent describing some of that conduct as including
harassment of the Operational Managers and senior management in the form of graffiti
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XQLRQLVVXHV´GLGQRWHQGZLWKWKHVLJQLQJRIWKHFROOHFWLYHDJUHHPHQWDQGFRQWLQXHGWR
affect the working relationship between the managers and the staff, but does not
mention the blog here in issue.
[6] At some point, individuals thought to be associated with OPSEU Local 108, the local
encompassing the Correctional Officers at EMDC, created a blog available to the public
on the internet. The exact date when this occurred is not in evidence, but by August 28,
2009 it had come to the attention of at least one of the Operational Managers who wrote
an occurrence report detailing remarks contained in the blog that were critical of
Operational Managers and management in general. When no response was received
from senior management, follow-up letters were sent to the Superintendent on October 2
and November 20, 2009. These letters acknowledged that the Superintendent had said
that the blog had been shut down, but stated that this did not address the complaints in
terms of the offensive material that had been available to the public on the website for a
considerable period of time. In the November letter, it is noted that the blog is back up
and running.
[7] In February and March 2010 a group of Operational Managers contacted the Deputy
Superintendent by e-mail further quoting from the blog, pointing out remarks that the
Operational Managers considered to be slanderous of management at all levels and
stating that the Ministry was condoning the blog by inaction. On February 22, 2010 the
Operational Managers met with Steven Small, Assistant Deputy Minister, who said that
the blog had gone "underground", apparently meaning that it was now password-
protected. According to the Operational Managers, he also promised a restoration team
for the institution, which has not yet been provided. Mr. Small apparently also met with
senior management and representatives of the union, a meeting to which the
Operational Managers were not privy. The Operational Managers allege that the letter
was ignored and that the blog continued with negative content accessible at least to a
large proportion of the employees working in the institution and likely beyond, continuing
to poison their work environment.
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[8] On February 24, 2010, the then acting Superintendent wrote to Mr. Allen saying that the
institution had no control over the content of the union blog and stating that the material
that Mr. Allen had provided him did not appear to warrant any further investigation, but
indicating that if any of the blog content did violate policy he would review it and take
action if necessary.
[9] On February 26, 2010 Mr. Steven Small, Assistant Deputy Minister, wrote to the
executive members of the union local, as well DVWKH%ORJ:ULWHUV´H[SUHVVLQJKLVJUDYH
concerns about the highly inappropriate features and comments recently posted on the
blog, as well as acknowledging that OPSEU itself had requested that any comments or
posts that might be perceived as attacks on individuals be removed. In the view of the
group of Operational Managers, nothing changed after that, and these grievances
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March 5, 2010.
Excerpts - Regulation
[10] Relevant statutory provisions are as follows:
From Regulation 378/07 under The Public Service Of Ontario Act -
4. (1) Subject to subsection (2), a public servant who is aggrieved about a working
condition or about a term of his or her employment may file a complaint about the
working condition or the term of employment with the Public Service Grievance Board,
«
Filing a Complaint
Notice of proposal to file a complaint
8. (1) A person who proposes to file a complaint shall give notice of the proposal to
the following person or entity:
1. A complainant who, at the material time, worked in a ministry shall give the notice
to his or her deputy minister.
«
(4) The notice must be given within the following period:
«
3. For a complaint about a working condition or a term of employment, within 14 days
after the complainant becomes aware of the working condition or term of
employment giving rise to the complaint. O. Reg. 378/07, s. 8 (4).
- 5 -
- from Regulation 977, under the Public Service Act,now superseded
54. The Board or a Classification Rating committee may, of its own motion,
(a) abridge the procedure set out in this Part and hear the grievance at any time under
section 48: or
(b) extend the time limits specified in this Part, RO 1980, Reg, 881, s. 61.
Submissions and Conclusions
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employer's position that the grievances are untimely and should be dismissed. In the
HPSOR\HU¶VVXEPLVVLRQWKH2SHUDWLRQDO0anagers were clearly aware of the union blog
by the fall of 2009 and did not grieve until 2010, in breach of the14 day time lines set out
in Regulation 378/07 under The Public Service Of Ontario Act.
[12] Further, counsel for the employer argues that the timelines in section 8 (1) of Regulation
378/07 are mandatory timelines that are not able to be extended by the Board. Counsel
refers to Section 54 of the former regulation 977, no longer in effect, which provided the
Board with jurisdiction to extend time limits. Counsel argues that when the new
regulation 378/07 was implemented, it contained no similar provision, and thus any
jurisdiction the Board had to extend time limits is no longer applicable.
>@,QVXSSRUWRIWKHHPSOR\HU¶VDUJXPHQWVRQWLPHOLQHVVFRXQVHOUHOLHVRQWKHIROORZLQJ
case law: Daniel Beauchamp 2010 Can LII 6691 and 11287, (ON L.R.B.), Service
Employees International Union, Local 204 v. Leisureworld Nursing Homes Ltd., [1997]
O.J. No. 1469, 99 O.A.C. (Divisional Court), affirmed by the Court of Appeal with brief
reasons reported at [1997] O.J. No. 4815, 75 A.C.W.S. (3d) 854 (Ont. C. A.) and Kris
Persad v. TTC et. al., 2009 HRTO 325 (Can LII). In the Daniel Beauchamp decisions,
the Ontario Labour Relations Board (OLRB) found that in dealing with its jurisdiction over
,there was no language allowing
appeals under theOccupational Health and Safety Act
for the extension of the timelines. In the result, despite sympathetic facts, which
included a one day delay caused by solicitor inadvertence, the appeal was dismissed as
untimely. In doing so, the OLRB also found that its broad power to control its own
procedure did not give it jurisdiction to amend the timelines set by statute.
[14] In the Divisional Court's decision in Leisureworld, affirmed on appeal, cited above, the
Court found it to be unambiguous that when words relating to the power to extend time
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limits in provisions of collective agreements related to arbitration procedures were
dropped from the Labour Relations Act,arbitrators lost jurisdiction to grant relief from
time limits for referral to arbitration, as opposed to steps within the grievance procedure
leading to the referral to arbitration. Counsel argues that the amendment to the
regulation resulting in the absence of the provisions providing for the extension of time
OLPLWVLQ5HJXODWLRQ
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when they first heard about the blog, which I am asked to infer was around the same
time that Mr. Allen became aware of it in the summer of 2009.
[19] As to the issue of whether the matter is a continuing grievance, counsel says that
despite the fact that the grievance refers to the idea that the employer was continuing to
fail to take appropriate action, there are no particulars to show a continuing breach.
[20] The second part of the employer's motion relates to the submission that the union blog
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employment. Stressing that it was not an employer blog and that the employer did not in
any way control its content or comments, nor promote or agree with anything there,
counsel argues that the employer never failed to provide a workplace free of
harassment, nor did the employer create a poisoned work environment. The blog was
created and broadcast by the union and is therefore the responsibility of the union.
Essentially the employer's position is that any recourse should be against OPSEU, who
is not a party to this matter, rather than the employer.
[21] Moreover, the employer made it clear that it did not agree with the contents and wrote
letters to that effect and did take steps to deal with the negative effects of the union blog.
For instance, the Assistant Deputy Minister wrote to the union executive and the
contributors to the blog and the Superintendent of the institution had conversations with
the local executive and co-chairs of the provincial Management and Employee Relations
Committee [MERC]. In any event, counsel submits that it is not the role of this board to
go back in time and determine how the employer could have or should have dealt with
the bargaining agent.
>@&RXQVHOUHOLHVRQSDUDJUDSKRIWKH%RDUG¶VGHFLVLRQLQAllen et. al. v. Ontario
(Ministry Of Community Safety And Correctional Services), 2009 CanLII 43639 (ON
PSGB), 98 C.L.A.S. 181 for its formulation of what is required to make out a prima facie
case, i.e. a viable case with three elements: an existing term or condition of employment,
a breach of that term or condition of employment and a connection between the alleged
breach and some remedy within the board's jurisdiction.
[23] Counsel submits that the Operational Managers have not demonstrated any provision
that was violated by the employer. Although the comments on the blog were
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inappropriate, they are not contraventions of the Public Service Of Ontario Act or any
RWKHUWHUPDQGFRQGLWLRQRIWKHHPSOR\HHRIWKH2SHUDWLRQDO0DQDJHUV¶HPSOR\PHQWLQ
WKHHPSOR\HU¶VYLHZ6KHQRWHVWKDWDWWKHWLPHRIWKHFRPSODLQWWKH:RUNSODFH
Discrimination and Harassment Prevention policy (WDHP) did not contain a provision for
complaints that did not refer to grounds such as race, gender or disability. Further,
although the employer acknowledges the concerns and submits that they responded
appropriately in the circumstances, counsel submits that it is unclear what remedy could
be given. Noting that the blog has been password-protected since approximately March
2010, counsel says that only OPSEU members should be accessing the site and that it
is no longer fully accessible to the public. The employer asserts that the complainants
have not identified anything that the employer could have done that they failed to do.
[24] Counsel for the employer asserts that it is not a proper basis for complaint to say that the
VLWXDWLRQZDVKXUWIXOVWUHVVIXORULQDSSURSULDWH7KH%RDUG¶VMXULVGLFWLRQLVURRWHGLQ
violations of terms and conditions of employment. The broad statement that comments
does not amount to a prima
on the blog violate the Occupational Health and Safety Act
facie case, in counsel's submission. Counsel for the employer states that the Board has
no jurisdiction to award anything against OPSEU, such as an apology or dismantling of
the blog. As to the remedies claimed of reclassification and compensating time, the
employer reserved its rights to argue further on those issues if necessary.
[25] For their part, the Operational Managers argue that both the WDHP policy and the
Occupational Health and Safety Act have been violated. They refer to the March 25,
1998 version of the WDHP policy which refers to problems of harassment that are not
based on grounds that can be found in the Human Rights Code as well as the 2001
JXLGHZLWKZKLFKWKH\ZHUHIXUQLVKHGWRWKHHIIHFWWKDWLWLVPDQDJHPHQW¶VUROHWRHQVXUH
a healthy workplace. They submit that the anonymity of many of the comments on the
blog makes the situation more dangerous, because it is not known who is making the
remarks which are in breach of policy and statute, and when one is or is not working with
the authors of the offensive material.
>@7KH2SHUDWLRQDO0DQDJHUVDUJXHIURPWKHVWDWHPHQWLQ0U6PDOO¶VPHPRWRWKHORFDO
union and the bloggers that "further breaches" would not be tolerated that the employer
has already acknowledged that the blog does violate the policies in question, and
contributes to a work environment which is poisoned. They take the position that it does
- 9 -
not matter that the bargaining unit is the source; it remains a breach of the Operational
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that by doing nothing, the Ministry is condoning the remarks on the blog. It is noted that
the previous Superintendent and the union had agreed that there would be zero
tolerance for such breaches of policy, and that all necessary steps up to and including
dismissal would be taken.
>
- 10 -
The fact that the blog was still up, still allegedly generating material which poisoned their
work environment, at the time the complainants filed their complaint, is sufficient to make
these grievances timely.
[30] In these circumstances, it is not necessary to deal with the employer's argument that the
Board has no jurisdiction to extend time limits, because I do not find that the time limits
were breached. If the complaints are ultimately successful, the employer may make
submissions about how far back in time any remedy that would be granted can extend.
However this does not determine whether the complaints are timely.
[31] Employer counsel made several remarks about particulars, referring to the details of the
complaint, suggesting that there were insufficient particulars of a continuing situation. It
is true that the complaint is not particularized in detail. Nonetheless, the basic
proposition that the blog, which is the central focus of the complaints, was still operating,
and that the Ministry was condoning it by inaction, is clearly stated. Further, there is no
suggestion that the employer requested further particulars and that they were not
forthcoming. In the circumstances, any lack of particularity is something that can be
dealt with by a request from the employer and direction from the Board if necessary, but
it is not enough to change the fact that the complaint relates to an allegedly continuing
situation.
Should the complaint be dismissed for failing to set out a prima facie case?
[32] As for the portion of the motion relating to whether a prima facie case has been
described by the Operational Managers, it is convenient to discuss the matter by looking
at what terms and conditions of employment the complainants identify, what breach they
allege, and what remedies they request. If the combination of those three elements
makes up a viable complaint, the matter should not be dismissed at this stage. On a
preliminary motion such as this, the issue is not whether the complainants will surely
succeed, but whether they have an arguable case. The difficulty of the issues raised or
the strength of the employer's proposed defense are not the criteria. Rather, the
v. Carey Canada Inc., [1990] 2
standard set by the Supreme Court of Canada in Hunt
S.C.R. 959, for dismissing a matter on a preliminary motion such as this is whether it is
plain and obvious that the complaint cannot succeed or raises no reasonable or
- 11 -
arguable case for a remedy. The novelty of a complaint or the difficulty of the issues
involved was held not to be sufficient reason to dismiss on a preliminary basis.
[33] The sources of terms and conditions of employment identified by the Operational
Managers include the WDHP policy and an accompanying guide entitled Workplace
'LVFULPLQDWLRQDQG+DUDVVPHQW3UHYHQWLRQLQWKH236±D0DQDJHU¶V*XLGH, a 2001
SXEOLFDWLRQRIWKHHPSOR\HU¶V0DQDJHPHQWBoard Secretariat. It notes that managers
are accountable and have the authority to ensure that the workplace is free from
discrimination and harassment no matter what the source or who is involved, as well as
working in a proactive way to create a positive healthy working environment. Although
the guide acknowledges that the WDHP operating policy mirrors the legal framework of
The Human Rights Code, it also contains a section dealing with violations which fall
outside that framework. This section gives an example of employees who continually
make negative public comments about the effectiveness of the work unit and says that a
manager in that situation has a responsibility for effectively resolving these issues and
restoring the workplace to health. This is somewhat analogous to what this complaint
represents - middle managers alleging that senior management is responsible to restore
the workplace to health after the publication of the blog which they say poisoned their
work environment.
[34] The following quote from the guide for managers tends to support the Operational
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amendments to the WDHP which apparently make this explicit, that it is management's
responsibility to deal with harassment whether or not it is based on grounds which
appear in The Human Rights Code. The following instructions to managers appear at
page 15:
Determine whether the WDHP Operating Policy or another policy framework covers
the issue.
Generally, this means assessing whether behaviour exhibited by employees is
covered by the definitions of discrimination and harassment and whether it is related to
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SRVLWLYHDQGUHVSHFWIXOZRUNHQYLURQPHQW´"$SURKLELWHGJURXQGGRHVQRWQHHGWREH
the only reason for the issue or conflict, but it must play some part for a resolution to
occur within the framework of the WDHP Operating Policy. However, you must act to
resolve the issue even if it is not related to the policy. In these cases, other OPS
policies and procedures may provide guidance (e.g. Staff Relations Policy). Contact
your WDHP specialist for more information. (pg. 15)
- 12 -
And further on in the guide:
The organization has the right to insist that all employees treat each other with dignity
and respect. (pg. 29)
[35] It is notable as well that the version of the WDHP policy dated March 25, 1998, most
recently revised in 2007, which predates these complaints, says in a footnote at page
12:
Management must not condone any kind of discrimination and harassment and must
also take appropriate and timely action even if the discrimination or harassment falls
outside of the application and scope of this policy. Processes used to address
complaints under the WDHP policy may also be used to resolve disputes falling
outside of the scope of this policy, for example, personal harassment.
[36] The complainants also rely on the Occupational Health and Safety Act, although they
were not specific about which portions they were relying on. I note that Bill 168 which
added provisions in respect of personal harassment had not come into force at the time
RIWKHFRPSODLQWV0HQWLRQZDVDOVRPDGHRIWKHHPSOR\HU¶V6WDWHPHQWRI(WKLFDO
Principles, but specific provisions of that policy were not referenced.
[37] The employer did not argue that the above policies did not constitute part of the terms
and conditions of employment of the complainants. In my view, the complainants have
an arguable case that the policy standards they are to uphold as managers also apply to
them, and form part of their terms and conditions of employment. This is quite apart
from the any relevant sections of the Occupational Health and Safety Act, or any other
provisions which may form a term or condition of their employment, on which it is not
necessary to comment for the purposes of this preliminary motion.
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essence, the Operational Managers are arguing that their right to a healthy workplace
and freedom from personal harassment was infringed when senior management failed to
effectively address the negative daily work situation created by some of the blog content.
Although I agree with employer counsel that this would be a stronger element of the
FRPSODLQDQW¶VFDVHLIWKH\KDGVSHFLILHGZKDWLWLVWKDWXSSHUPDQDJHPHQWFRXOGKDYH
done which it failed to do, I do not agree that the complaints have not made out an
arguable case in this respect. It is, again, in my view, a question of lack of particulars,
- 13 -
rather than the absence of a critical element of a viable case. In this respect, I note that
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they say they did take action. However, it is clear that the complainants were not privy
to all the actions referred to, and more to the point here, it is their central allegation that
ZKDWHYHUVHQLRUPDQDJHPHQW¶VDFWLRQVZHUHWhey did not protect them from what they
consider the poisoned work environment caused by the content of the blog which they
found to be undermining and defamatory. As well, the complainants argue that Mr.
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ZRUNHQYLURQPHQWZKLFKKDGQRWEHHQUHPHGLHG7KHHPSOR\HU¶VYLHZWKDWWKHIDFWWKDW
LWGLGWDNHDFWLRQPHDQVWKH\GLGQRWEUHDFKWKHFRPSODLQDQWV¶ULJKWVHYHQLIWKHLUDFWLRQV
ZHUHQRWWRWDOO\HIIHFWLYHLQWKHFRPSODLQDQWV¶H\HVZLOOEHDQLPSRUWDQWHOHPHQWLQWKHLU
response to the allegations, and may mean that the complaint is not ultimately
successful, but it does not mean that the allegation of insufficient action is inadequate at
this stage to make out an arguable case. Certainly, it does not meet the standard of
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[39] As noted, counsel stressed that the blog was not an employer blog and that the
employer therefore did not create or fail to provide a healthy workplace. Although the
complainants do not allege that management participated in or controlled the blog, the
central point of their case is their contention that management was responsible to react
to restore the situation to a point where the Operational Managers were not subject to
what they consider harassment and a poisoned or unsafe work environment. In my
view, if, as the policy states, there is a managerial responsibility to ensure that the
workplace is free from harassment no matter what the source or who is involved, it
cannot be an answer to the viability of the case to say that it was bargaining unit
HPSOR\HHVZKRPDNHXSWKHEXONRIWKHLQVWLWXWLRQ¶VZRUNIRUFHRUWKHXQLRQZKR
represents them, who were generating the content that is alleged to be personal
harassment.
[40] As to possible remedy, if the complainants were to be successful in establishing that a
breach of their terms and conditions of employment occurred, I agree that some of the
remedies requested by the complainants raise difficulties. In general, it appears the
complainants wanted the employer to have been more proactive to rein in the
anonymous bloggers. However, neither the union nor any individuals thought to be
responsible for the blog or its content are parties to these complaints, and the
- 14 -
complainants clarified at the hearing that they will not be asking the Board to make any
RUGHUVDJDLQVWWKHXQLRQ7KLVLVDSDUWLDODQVZHUWRWKHHPSOR\HU¶VFRQFHUQVDERXWWKH
%RDUG¶VMXULVGLFWLRQWRSURYLGHDQ\UHPHG\FRQFHUQLQJLWVDSSURDFKWRZDUGVWKHXQLRQRU
the bloggers. In any event, the notion that some of the remedies requested would be
LQDSSURSULDWHRUEH\RQGWKH%RDUG¶VUHDFKLVQRWGHWHUPLQDWLYHLIWKHUHDUHRWKHU
remedies available to remedy any breach that might be found to have occurred.
[41] The range of remedies requested in the complaints is not limited to requests that the
employer take action against the union and the bloggers, including shutting the blog
down. They also ask for an investigation, compensating time for health and wellness,
upwards reclassification and an apology from the employer. If there were to be a
decision in their favour, it would likely include declarations, which may be considered a
remedy of sorts.
[42] Having reviewed all the submissions before me, it is my view that there is an arguable
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complainants, including declarations and compensation, if it were to be found that their
terms and conditions of employment have been breached. Given the limited factual
background currently before me, it is not appropriate to speculate at the moment as to
the type of any other possible remedies, and the parties will have full opportunity to
make their submissions about remedy if the matter proceeds.
[43] To summarize, it is my view that the complainants have an arguable case, such that the
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timeliness, or for lack of a prima facie case. In ruling in this way, however, the Board
wishes to underline that this is a ruling at a preliminary stage, on a complaint that raises
many difficult issues, both factually and legally. Whether or not there will be any
success for the complainants at the end of the day is not the test at this stage. Rather,
to repeat, the test is whether it is plain and obvious that the complaint cannot succeed.
[44] The Board notes that the arguments thus far in this case were properly aimed at the
issues raised by the motions, and did not extend to further issues that would need to be
dealt with if the matter proceeds to a hearing on the merits. Nonetheless, the complexity
of those issues, and the uncertain outcome might well serve as an incentive for the
parties to revisit the possibility of resolving their issues themselves. In this regard, it is
- 15 -
appropriate to note that social media such as the blog here in question are presenting
challenging problems to employers, and others, around the world. There are both legal
and practical limits to controlling even the most egregious examples of harmful speech
on the internet. In our context, it is worth noting that, although there were a few
examples of the statements made on the blog before me, there was no evidence called
or any suggestion that I had heard all of the content of which the Operational Managers
complain. I have not reproduced the blog content of which I was made aware in this
decision, although if the matter proceeds on the merits it may well be necessary to set it
out in a decision, thus further publishing it, whether or not it has been removed from the
web, and whether or not the complaints succeed. Suffice it to say for present purposes
that there seemed to be consensus that some of the comments were at least
disrespectful, and the characterizations of the content in argument included words such
as inappropriate, demeaning, defamatory and offensive. Nonetheless, it is worth noting
that there is a very broad spectrum of possible characterizations of speech by
employees concerning their managers, and that not all negative commentary, even if it
causes offense, amounts to harassment or a poisoned work environment. There is no
doubt a line between acceptable union or individual advocacy and discontent with
management and the right to express it, and what may amount to harassment,
insubordination, threats or defamation, although in any given situation it may be difficult
to pinpoint exactly when that line has been crossed. And where, when and how such
expressions are made is relevant to how they are properly regarded for the purposes of
a complaint such as this. Venting between employees over the real or perceived
inadequacies of their managers has a different aspect when it is limited to personal
conversations in off-duty or social situations, no matter how widespread, compared to
when it is posted for all to see at any time on the internet. Nonetheless, if, when and
how that translates into workplace harassment or a poisoned work environment worthy
of remedy for their supervisors, and if so, what kind of remedy, are novel questions
without a clearly defined answer at this stage.
[45] As well, it is worth noting that managers at all levels have to exercise judgment as to
how and when to respond to problematic situations in the workplace, particularly where
they are not explicitly covered by the WDHP policy or other detailed policy directives.
There will necessarily be differences of opinion as to the best approach. To the extent
that this complaint represents a difference of opinion between various layers of the
management team as to how to best deal with the challenges of their unionized
- 16 -
environment preceding and following collective bargaining, the complainants may well
be testing the outer limits of what should be included in the notion of a poisoned work
environment, a term which eludes precise definition at the best of times. In any event,
the situation regarding the union blog is definitely not a simple one with a straightforward
solution. There are issues involved which range from those raised by the Operational
Managers and the effect of the blog content on the general health and morale of the
workplace, to free speech and freedom of association, all complicated by the easy
access to the Internet which blurs the boundaries between the workplace and private
activity. The parties are encouraged to take this opportunity to consider their positions,
and the advisability or otherwise of continuing on to litigation, as opposed to pursuing
other alternatives, in light of this decision and whatever the current situation may be in
the institution.
[46] For the reasons set out above, the emSOR\HU¶VPRWLRQWRGLVPLVVLVUHMHFWHG
st
day of July 2011.
Dated at Toronto this 21
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