HomeMy WebLinkAbout2008-2793.Pilger et al.11-09-02 DecisionCommission de
Crown Employees
Grievance
UqJOHPHQWGHVJULHIV
Settlement Board
GHVHPSOR\pVGHOD
Couronne
Suite 600 Bureau 600
180 Dundas St. West 180, rue Dundas Ouest
Toronto, Ontario M5G 1Z8 Toronto (Ontario) M5G 1Z8
Tel. (416) 326-1388 7pO
Fax (416) 326-1396 7pOpF
GSB#2008-2793, 2008-2794, 2008-2828, 2008-3084, 2008-3085, 2008-3155, 2008-3156,
2008-3157, 2008-3158
UNION#2008-0369-0368, 2008-0369-0369, 2008-0369-0375, 2008-0369-0399,
2008-0369-0400, 2008-0369-0403, 2008-0369-0404, 2008-0369-0405, 2008-0369-0406
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
èÏÔÎÏ
(Pilger et al)
- and -
The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFOREVice-Chair
Randi H. Abramsky
FOR THE UNION
David Wright
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
FOR THE EMPLOYER
Suneel Bahal
Ministry of Government Services
Labour Practice Group
Counsel
HEARING
October 15, 2010, March 2,
May 4 & May 30, July 20, 2011.
- 2 -
DECISION
[1]There are nine individual grievances before me, although the parties elected to proceed
solely with the evidence of two grievors at this time. The grievances assert that the Employer
has violated Articles 2 (Management Rights) and 3 (Discrimination) of the collective agreement
and the Ontario Human Rights Code. It is undisputed that the grievances also involve an
allegation that the Employer has violated ArticleDVZHOODVWKH³MXVWFDXVH´UHTXLUHPHQWRI
the collective agreement. Essentially, the grievances contend that the Employer improperly
UHYLHZHGWKHJULHYRUV¶DWWHQGDQFHIRUSDWWHUQDEVHQWHHLVPKHOG³GLVFLSOLQDU\´PHHWLQJV
concerning their attendance, and, in certain cases, improperly required the grievors to submit
medical certificates for any absence for a thirty day period.
Facts
[2]All of the grievors are Correctional Officers at Central North Correctional Centre
(CNCC). That facility, from 2000 to 2006, had been involved in a public-private partnership
whereby correctional services and management of CNCC were provided by a private entity.
That arrangement ended in November 2006, and the Ministry of Community Safety and
Correctional Services once again resumed management of the facility. The majority of
employees remained throughout this time period.
[3]In the Spring of 2008, it was noted that absenteeism had increased significantly after the
Ministry resumed management of the facility. From an average absenteeism rate of between 9
and 10 days per employee per year while under private sector management, the level of
absenteeism had significantly increased afterward. This led the Northern Region to request a
- 3 -
review of pattern absences, EDVHGRQDGRFXPHQWHQWLWOHG³&ulpable Absenteeism/Suspected
$EXVHRI6LFN/HDYH%HVW3UDFWLFHV´7KDW document provides a secWLRQHQWLWOHG³5HDVRQDEOH
*URXQGVWR6XVSHFW$EXVH´ZKLFKSURYLGHs, in relevant part, as follows:
Reasonable Grounds to Suspect Abuse
In order to require an employee to provide a medical certificate before the required number of
GD\VKDVH[SLUHGILYHIRU236(8«
WKHHPSOR\HUmust have reasonable grounds to suspect that
the employee is not sick or injured.
There are a number of circumstances that may reasonably raise the suspicion of the employer:
(1)An employee requests and is denied leave for a specific day and later calls in sick on/for
that day.
(2)$UHYLHZRIDQLQGLYLGXDO¶VDWWHQGDQFHUecord indicates a pattern of absences. The
stronger the pattern the more legitimate the suspicion. It is imperative that accurate
records have been kept if considering pattern absences. Patterns of absence that may
cause suspicion are, for example:
where an employee regularly calls in sick on a certain day of the week or at a certain
time of the year;
where an employee takes excessive sick time combined with excessive overtime or
overtime for shifts that immediately follow the absence due to illness;
where spouses of co-workers call in sick such that they are off at the same time; or
other patterns.
(3)A special event is occurring in the community that the employee or a group of employees
is or are likely to attend, for example a hockey tournament.
(4)A number of employees call in sick at the same time in a concerted manner (an illegal
VWULNHRU³EOXHIOX´
[4] At the time of this directive Robyn Kasha was Assistant Deputy Superintendent of
Administration. She was subsequently promoted to Acting Superintendent and has since become
Superintendent. At the direction of the Superintendent at the time, Ms. Kasha and Manager of
Administration-Staff Services Doug Houghton developed criteria to review the attendance
records of all staff. CNCC has over 400 full-time staff, including 330 full-time Correctional
- 4 -
Offices, 35 Operational Managers, and approximately 60 support staff, plus unclassified
Correctional Officers. The attendance of all staff and management was reviewed, with the focus
H[FOXVLYHO\RQVLFNGD\VXVHG±QRWWSIB or other types of absences.
[5] The first review dealt with the employees¶
- 5 -
two could be a coincidence, but by five or more, it seemed to be a reasonable basis for assessing
a potential pattern. The patterns reviewed were absences which extended time off between
shifts, absences in conjunction with vacation or lieu time, absences on weekends, and absences
coinciding with overtime shifts.
>@(PSOR\HHVDW&1&&ZRUND³FRPSUHVVHGZRUN´ZHHNVFKHGXOH)RU0V0LMDWRYLFRQH
of the grievors, that meant 4 days on, 2 off, 4 on, 2 off, 3 on, 3 off, 3 on, 4 off, 3 on, 3 off, 3 on, 2
off, 4 on, 2 off, 4 on, 10 off. The shifts shHZRUNHG±GD\VDIWHUQRRQQLJKWVDOVRYDULHG
[9] In all, 14 OPSEU employees (and two non-OPSEU employees) were identified as
potentially having suspicious patterns of absence, and the Employer elected to meet with those
HPSOR\HHV±DV0V.DVKDSKUDVHGLW±³WRGLVFXVVRXUFRQFHUQVDQGFODULI\H[SHFWDWLRQV´±DV
ZHOODVWRKHDUWKHHPSOR\HHV¶H[SODQDWLRQV Ms. Kasha was clear that these were not
disciplinary meetings, but potentially could lead to discipline.7KH\ZHUHQRW³DOOHJDWLRQ´
meetings, as that term is used in the Ministry.
>@%RWKRIWKHJULHYRUVZKRWHVWLILHG±0V=GHQND0LMDWRYLFDQG0U-DPHV/DQGULDXOW±
received such letters, which were nearly identical, dated October 16, 2008. The letters, from
Acting Superintendent Kasha, note WKDW³>D@UHYLHZRISDWWHUQHGDEVHQFHVIURPZRUNKDVEHHQ
XQGHUWDNHQIRUDOOVWDII´DGYLVHGWKDWDPHHWLng with her and another manager would be taking
place and when that would be. It fuUWKHUVWDWHV³7KHSXUSRVHRIWKis meeting is for us to discuss
WKH(PSOR\HU¶VFRQFHUQVUHJDUGLQJ\RXU\HDUWRGDte Short Term Sickness absences. A calendar
documenting your absences, from January 1, 2008 through August 31, 2008 has been attached
- 6 -
IRU\RXUUHIHUHQFH´,WIXUWKHUVWDWHVWKDW³>\@ou are entitled to bring a union representative to the
PHHWLQJ´7KHDWWDFKHGFDOHQGDUV actually covered the time period from October 2007 to August
±DSHULRGRIPRQWKV7KHVHOHWWHUVZHUHKDnd-delivered to the individual recipients in a
VHDOHGHQYHORSHPDUNHG³FRQILGHQWLDO´DQGIRUZKich they had to sign that they had received.
[11] Ms. Mijatovic has been a Correctional Officer since April 2003, and a full-time officer
since October 2007. From January 25, 2008 to July 2008, she was in the Attendance Support
Program. She successfully exited that program in July 2008. When she received the October 16,
OHWWHUVKHIHOW³DOLWWOHVKRFNHGVFDUHGDQGXSVHW´6KHKDGWKRXJKWWKDWVLQFHVKHKDG
successfully exited the ASP, she had addressed her attendance issues, yet now the same absences
were being reviewed for potential culpability. She was not aware of the difference between
culpable and non-culpable absenteeism, or that the ASP covered only non-culpable absences.
[12] By both her account and that of Ms. Kasha, Ms. Mijatovic was very emotionally upset
during the attendance meeting, which took place on November 12, 2008. Ms. Mijatovic testified
that she was upset and had a hard time talking and lost her composure. A number of breaks were
taken to provide Ms. Mijatovic with an opportunity to compose herself. She felt upset,
embarrassed, nervous and scared.
[13] The meeting was attended by Ms. Kasha, Assistant Deputy Superintendent Cadwell, a
Union Representative and Ms. Mijatovic. During the meeting, Ms. Kasha described the two
different types of absenteeism - culpable and non-culpable, and assured Ms. Mijatovic that the
meeting was not disciplinary and would not be on her personnel file. Ms. Kasha reviewed Ms.
- 7 -
0LMDWRYLF¶VFDOHQGDUDQGH[SUHVVHGWKH(PSOR\HU¶VFRQFHUQVDERXWWKHQXPEHURIVLFNGD\V
taken which extended her time off between sets of shifts (16) and the number of weekend sick
days (11) taken. At the hearing, Ms. Mijatovic testified that heUDEVHQFHVZHUHGXHWR³VRPH
PLJUDLQHV´D³VHQVLWLYHVWRPDFK´DQG³RWKHUUHDVRQV´6KHFRXOGQRWUHFDOOKRZHYHULIVKH
mentioned that at the meeting, nor could she recall if she had raised these medical issues during
KHU$63PHHWLQJV,WZDVWKH(PSOR\HU¶VHYLGHQce that she did not. She acknowledged that she
had the opportunity to explain her absences and provide information at the meeting, and that
management, throughout the meeting, acted professionally and supportive. Due to her emotional
upset, management allowed Ms. Mijatovic to leave her shift for the rest of the day with pay,
based on compassionate grounds. At no time when these absences occurred was Ms. Mijatovic
asked to submit a medical note, nor has she ever been disciplined for her absenteeism.
[14] On November 12, 2008, the date of the meeting, Ms. Mijatovic filed her grievance in this
matter. On November 14, 2008, Superintendent Kasha wrote a letter to heUHQWLWOHG³3DWWHUQ
$EVHQFH0HHWLQJ&RQILUPDWLRQ/HWWHU´7KHOHWWHUVWDWHVLQSHUWLQHQWSDUWDVIROORZV
On November 12, 2008, you and your representative met with me to discuss concerns
regarding your year-to-date short-term sick absences. At this meeting, you were advised that
PDQDJHPHQW¶VFRQFHUQZDVEDVHGXSRQDSDWWHUn of absences. You were shown documents
that demonstrated a reasonable basis for this concern.
The information that you provided at the meeWLQJDGGUHVVHGWKHHPSOR\HU¶VFRQFHUQDWWKLV
time.
A further review of short-term sick absence patterns will be conducted during the first quarter
of 2009. Staff identified as exhibiting a pattern of sick absences that cause concern will be
contacted and a meeting arranged.
As discussed, you are encouraged to utilize the various support systems available to ensure
your attendance at work.
- 8 -
Ms. Kasha testified that she decided that she would not require Ms. Mijatovic to submit medical
notes for future absences because she felt, baVHGRQWKHPHHWLQJWKDW0V0LMDWRYLF³XQGHUVWRRG
RXUFRQFHUQV´6KHGHFLGHGWRWDNHD³ZDLWDQGVHH´DSSURDFK,QDGGLWLRQE\WKHWLPHRIWKH
PHHWLQJ0V0LMDWRYLFGLGQRWKDYH³WRRPDQ\DEVHQFHV´
[15] On November 21, 2008, Ms. Mijatovic wrote to Ms. Kasha, identifying matters that were
discussed during the meeting of November 12 but were not included in her letter, such as her
successful exit from the ASP, nor a clear statement that the meeting was not a disciplinary
meeting. It also did not include that she did noWQHHGWREULQJLQDGRFWRU¶VQRWHIRUDQ\VLFN
absences in the next thirty days. Ms. Kasha did not respond to this letter. Ms. Kasha explained
that she did not because the grievance concerning the meeting had already been filed.
[16] Ms. Mijatovic testified that after the meeting, two managers mentioned their surprise that
VKHZDV³SDUWRIWKDWJURXS´referring to the pattern absence meetings. She acknowledged,
however, that she had showed her calendar to other employees to compare and confided to a few
employees that she was called to a meeting about it. She could not recall if she discussed it with
the managers
[17] Mr. Landriault met with Ms. Kasha, Assistant Deputy Superintendent Caldwell, and a
Union Representative on November 12, 2008. He, too, had been in the ASP program but had
successfully exited the program in April 2008. He testified that he received a letter informing
him about a meeting to discuss pattern absences, along with a calendar of his absences attached.
He stated that he was at first confused by the meeting, wonderiQJZK\WKHVH³SDWWHUQV´KDGQRW
- 9 -
been noted before while he was in the ASP program, and then he became angry and upset. He
WKRXJKWLWZDV³ULGLFXORXV´EHFDXVe they could find a pattern in anything, and they were treating
all of his absences as culpable. He testified that his high absenteeism in 2007 was because of the
death of his mother in March 2007, after which he could not work for a month. Then, on
October 14, 2007, his grandmother passed away and on October 16 his son was born. His
attendance calendar shows that in October 2007 he took three bereavement days, followed by
WKUHHOLHXGD\VDQGIRXUYDFDWLRQGD\V±QRQHRIZKLFKZHUHFRXQWHGLQWKH(PSOR\HU¶VDQDO\VLV
He also stated that he had headaches, which he believed at the time were migraines. He did not,
KRZHYHUVHHKLVGRFWRUDERXWKLVKHDGDFKHVXQWLO1RYHPEHU±DIWHUWKHDWWHQGDQFH
PHHWLQJ+HWHVWLILHGWKDWKH³GLGQ¶WQHHGWR´XQWLOKHZDVTXHVWLRQHG,Q0DUFKKLV
doctor advised that his headaches were tension headaches, not migraines. Nor did Mr.
Landriault ever mention migraine headaches during his ASP meetings. He explained that he was
QHYHUDVNHGIRUVXFKLQIRUPDWLRQ±WKH0LQLVWU\KDd only wanted to know if it could assist him in
achieving improved attendance.
[18] At the November 12, 2008 meeting, the employer discussed its concerns about Mr.
/DQGULDXOW¶VXVHRIVLFNWLPH±DEVHQFHVLQ2007 and 26 absences through the end of August
in 2008, including 17 instances where it extended time off between scheduled shifts and 9 times
where sick days coincided with overtime worked. Mr. Landriault had never been asked to
produce a medical note in connection with these absences.
[19] Superintendent Kasha testified that she GHWHUPLQHGWKDWWKH(PSOR\HU¶VFRQFHUQVZHUH
not sufficiently addressed and Mr. Landriault would be required to submit medical notes for his
- 10 -
absences during the next thirty (30) days, unless there was a reasonable explanation for why he
could not do so. On November 14, 2008, he received a letter from Superintendent Kasha which
stated, in relevant part, as follows:
On November 12, 2008, you and your representative met with me to discuss concerns
regarding your year-to-date short-term sick absence. At this meeting, you were advised that
PDQDJHPHQW¶VFRQFHUQZDVEDVHGXSRQDSDWWHUQ of absences. You were shown documents
that demonstrated a reasonable basis for this concern. As a result, you were advised that for a
period of one month from the date of our meeting, you would be required to provide a
medical certificate for every absence. If, in this one-month period, a culpable absence is
demonstrated, a further meeting will be arranged and the periods of review may be extended.
In order to be acceptable, a medical certifiFDWHPXVWPHHWWKHIROORZLQJUHTXLUHPHQWV«
Failure to provide medical certificates in accordance with this direction, in the absence of a
reasonable justification, may lead to a loss of pay for the day(s) in question.
As discussed you are encouraged to utilize the various support systems available to ensure
your attendance at work.
[20] Mr. Landriault testified that he was not absent during the following month, and so the
UHTXLUHPHQWEHFDPH³PRRW´%HFDXVHRIWKHQXmber of his absences, however, he was also
placed back into the ASP program. He testified that since then he has tried not to use sick time
even when sick because he did not want to progress in the ASP program. Instead, he was
utilizing other credits, particularly vacation time, to cover his illness as well as the illness of his
children. In his view, it was not easy to go to the doctor since it involved a two hour drive, or
going to the emergency room since there was no walk-in clinic available. Mr. Landriault filed
his grievance on November 12, 2009.
Positions of the Parties
The Union
[21] The Union has raised a number of issues LQUHJDUGWRWKH(PSOR\HU¶VDFWLRQVLQWKLV
matter. First, it asserts that the attendance meetings held in regard to pattern absenteeism were
- 11 -
³GLVFLSOLQDU\´PHHWLQJV7KH(PSOR\HULQHVVHQFHDOOHJHGWKDWWKHJULHYRU¶VZHUH³IDNLQJLW´
Ms. Mijatovic was stressed and distressed by this. In terms of Ms. Mijatovic, it notes that the
OHWWHUVKHUHFHLYHGVWDWHVWKDWWKH(PSOR\HU¶V³FRQFHUQV´ZHUHDGGUHVVHG³DWWKLVWLPH´EXWWKDW
monitoring will continue and further meetings might follow. Further, despite assuring her
verbally that the meeting was not disciplinary, Supt. Kasha did not put that assurance in her
November 14, 2008 letter, nor amend the letter to reflect that when Ms. Mijatovic requested that
the Employer do so. In addition word of her inclXVLRQLQWKHJURXSJRWRXWDQGPDQDJHU¶VPDGH
FRPPHQWVWKDWVKHZDV³SDUWRIWKDWJURXS´LPSDFWLQJKHUUHSXWDWLRQat the facility. In terms of
Mr. Landriault, the Union contends that the November 14, 2008 letter was disciplinary by
demanding he provide medical notes (a punishment) as well as by the tone and terms of the
letter. It submits that the letter and medical note requirement is a punishment or chastisement for
his pattern of absences.
[22] In support of its position that the attendanFHPHHWLQJVDQGOHWWHUVZHUH³GLVFLSOLQDU\´WKH
Union cites to Re OPSEU (Fitzgerald) and Ministry of Correctional Services, GSB No. 1489/88
(Samuels); 5H+LOWRQ9LOOD&DUH&HQWUHDQG%ULWLVK&ROXPELD1XUVHV¶$VVRFLDWLRQ'HQHV
th
Grievance) (2003), 115 L.A.C. (4) 154 (Gordon).
>@7KH8QLRQDOVRDVVHUWVWKDWWKH(PSOR\HU¶s use of the same absences for non-culpable
DQGFXOSDEOHUHYLHZFRQVWLWXWHVDIRUPRI³GRXEOHMHRSDUG\´,WVXEPLWVWKDWERWK0V0LMDWRYLF
and Mr. Landriault had successfully exited the ASP program, and so reasonably thought that they
KDGDGGUHVVHGWKHHPSOR\HU¶VFRQFHUQVDERXWWKHLr attendance, only to have the same absences
reviewed in terms of culpable patterned absences. It submits that this is an improper mixing of
- 12 -
culpable and non-culpable absenteeism. In this regard, the Union cites to Re Scarborough Fire
)LJKWHUV¶$VVRFLDWLRQ/RFDO
- 13 -
discretion to be exercised is temporally related to the actual absence and cannot be decided in
advance. In support, the Union cites to Re Municipality of Metropolitan Toronto and CUPE,
Local 79 (1982), 23 L.A.C. (3d) 271 (Burkett); 5H6W-RVHSK¶V*HQHUDO+RVSLWDO(OOLRW/DNHDQG
th
2QWDULR1XUVHV¶$VVRFLDWLRQ2VERUQH0D\*ULHYDQFH)(2008), 170 L.A.C. (4) 115 (Sheehan);
th
5H6W0LFKDHO¶V([WHQGHG&DUHCentre and Canadian Health Guild (1994), 40 L.A.C. (4) 105
(Smith); Re City of Toronto and CUPE, Local 79 ( 1984), 16 L.A.C. (3d) 384 (M. Picher); Re
th
NAV Canada and Canadian Air Traffic Controllers Association (2000), 86 L.A.C. (4) 310
th
(Brault);Re I.U.O.E., Local 951 and Health Sciences Centre (2003) 114 L.A.C. (4) 400
(Spivak);5H0DQLWREDDQG0DQLWRED*RYHUQPHQW(PSOR\HHV¶8QLRQ [2007] M.G.A.D. No. 40
(Jones).
The Employer
[26] The Employer submits that it acted reasonably and in compliance with the collective
DJUHHPHQWZKHQLWUHYLHZHGWKHJULHYRU¶VDWWHndance records and met with them concerning
potential patterns of absence. It submits that neither the meetings, nor the letters were
disciplinary, noting that the letters are not LQWKHHPSOR\HH¶VSHUVRQQHOILOH. It contends that none
of the hallmarks of discipline are present here, nor was the meeting to discuss attendance in and
of itself disciplinary. It could, potentially, lead to discipline, but the meeting to discuss identified
SDWWHUQVRIDEVHQFHZDVQRWE\LWVHOIGLVFLSOLQH1RUGRHV0V0LMDWRYLF¶s emotional reaction to
the meeting indicate that the meeting was disciplinary. The tone of the meeting was at all times
professional. Its purpose was not to punish but WRSXWWKHHPSOR\HHVRQQRWLFHRIWKH(PSOR\HU¶V
FRQFHUQV,QWHUPVRI6XSHULQWHQGHQW.DVKD¶VIDLOXUHWRUHSO\WR0V0LMDWRYLF¶V1RYHPEHU
letter, she did not do so because a grievance concerning the meeting had been filed. In support,
- 14 -
the Employer cites to Re OPSEU (Union Grievance) and Ministry of the Solicitor General and
Correctional Services/Management Board Secretariat, GSB No. 1925/96 (Abramsky); Re
OPSEU (Selkirk) and Ministry of Correctional Services, GSB No. 206/84 (Roberts); Re OPSEU
(Halall) and Ministry of Agriculture, Food & Rural Affairs, GSB No. 2007-1045 (Briggs); Re
OPSEU (Moody) and Ministry of Correctional Services, GSB No. 2446/90 (Kaplan).
[27] The Employer further contends that union representatives were allowed to attend the
meetings not because the meeting was imposing discipline, but because it is required by Article
44.13, if the meeting is to be allowed into evidence before the Grievance Settlement Board.
Article 44.13 states:
Attendance Review Meetings
44.13 Where an employee is interviewed by a member or members of management in respect
RIWKHHPSOR\HH¶VUHFRUGRIDWWHQGDQFHDWZRrk, no evidence of that interview or of the
particular aspects of the attendance record upon which that interview was based shall be
admissible before the Grievance Settlement Board in the arbitration of a disciplinary
grievance unless the employee was given reasonable notice of the interview and of the right
to have Union representation at that interview, and the employee either had such Union
representation or declined that representation in writing prior to the interview.
>@7KH(PSOR\HUDOVRUHMHFWVWKH8QLRQ¶VDVVHrtion that the grievors were subject to double-
jeopardy in regard to these attendance meetings. It asserts that³GRXEOHMHRSDUG\´LVZKHUHWKH
same misconduct receives some discipline, then additional discipline is imposed. In the
(PSOR\HU¶VYLHZ±QRGLVFLSOLQHWRRNSODFH±HLWKer under the ASP or the review for absenteeism
patterns. The Employer cites to Re OPSEU (Giraudy et al.) and Ministry of Community Safety
and Correctional Services, GSB No. 2004-3120 (Petryshen); Re Samuel Manu-Tech Inc. and
United Steelworkers of America, Local 8782 (Moodie Grievance)[2004] O.L.A.A. No. 807
- 15 -
(Carrier);Re OPSEU (Sidney) and Ministry of Transportation, GSB No. 1855/90 (McCamus);
Re OBLEU (Drury) and Liquor Control Board of Ontario, GSB No. 1707/84 (Roberts).
[29] The Employer further contends that the grievors successful exit from the ASP did not
mean that the Employer could not review their absences to determine if a pattern existed.
([LWLQJWKH$63GRHVQRWUHQGHUDQHPSOR\HH¶VDttendance record immune to further review.
[30] The Employer also argues that the methodology it used to identify patterns was both
reasonable and fair. First, it notes that the same methodology was used for all employees, so no
one group was singled out. It submits that the (PSOR\HUGLGPRUHWKDQLWKDGWR±ILOWHULQJ
HPSOR\HHVWKURXJKDQXPEHURIWKUHVKROGV±the 2007 attendance record, the 2008 attendance
record, and reviewing any medical explanations for the absences, and only then reviewing for
potential patterns. It further submits that requiULQJRUPRUHLQVWDQFHVEHIRUHD³SDWWHUQ´ZDV
identified was fair and reasonable. It submits that if the methodology used was as flawed as the
Union claims, one would have expected far more than 14-16 employees (out of approximately
400) to have been identified as having potential patterns of absence. The Employer then met
with the employees, providing them an opportunity to explain and provide information, again
ILOWHULQJRXWHPSOR\HHVZKRLQWKHHPSOR\HU¶VYLHZ, did not have to submit medical verification.
In its view, based on the evidence it reviewed and the meetings with employees, it reasonably
determined that there may be an abuse of sick leave, sufficient to require Mr. Landriault to
submit medical notes for his absences for a limited period of time. He had been absent 29 times
in 2007 and 26 times in 2008 (through the end of August); there had been no medical
explanation for his absences; 17 absences had extended his time off, and 9 were in conjunction
- 16 -
with overtime shifts. It submits that it had reasonable and probable grounds to require a medical
note for his absences, citing Re Canada Post Corporation and C.U.P.W. (Sigaty
Grievance)[1992] C.L.A.D. No. 16 (Joliffe); 5H/DEDWW¶V2QWDULR%UHZHULHVDQG%UHZHU\
th
Workers Union (1990), 11 L.A.C. (4) 89 (Brandt); Re Ralph and Ministry of Correctional
Services, GSB No. 364/80 (Gorsky); Re OPSEU (Jarvalt) and Ministry of Citizenship and
Culture, GSB No. 178/83 (Swan); Re Leaside Community Gardens and C.U.P.E., Local 114
[1993] O.L.A.A. No. 708 (Abramsky).
[31] The Employer asserts that it did not appl\D³EODQNHW´RU³XQLYHUVDO´UHTXLUHPHQWIRU
employees to submit medical documentation. Instead, it carefully reviewed the facts and
exercised its discretion in determining whether there was a reasonable suspicion that there might
be an abuse of sick leave. In its view, the Employer engaged in a thoughtful, meaningful and
measured response to a legitimate attendance concern. It argues that it fully exercised its
discretion; it did not abdicate it. In addition, the Employer notes that the letter does not
automatically disallow sick pay if no medical certified is submitted. It again allowed for
discretion to be exercised.
[32] In terms of Article 44.10, the Employer submits that it fully complied with its terms. It
notes that by its terms there is no temporal limitation in the provision, and no express
requirement that the Employer determine if it suspects potential abuse on the day of the absence.
It contends that it may do so before the absence, the day of the absence or afterward. To accept
WKH8QLRQ¶VLQWHUSUHWDWLRQWKH(PSOR\HUVXEPLWVwould in effect be adding a temporal limitation
- 17 -
to Article 44.10 which does not exist, and which is expressly prohibited by Article 22.14.6 of the
agreement.
[33] Further, the Employer submits that where there is are reasonable grounds to suspect
abuse, employers have been permitted to request medical notes in advance - not just at the time
of the absence. Indeed, it notes that providing employees notice of this requirement can be
useful to the employee. It asserts that the same conclusion applies here. 5H6W-RVHSK¶V+HDOWK
Care and CUPE, Local 1144 (1988), 34 L.A.C. (3d) 193 (Joyce); 6REH\¶V,QFDQG8)&:
Local 175 (Wight Grievance) [2003] O.L.A.A. No. 215 (Liang); Re Skeena Cellulose Inc. and
Christian Labour Association of Canada [2001] B.C.C.A.A.A. No. 164 (Blasina).
Reasons for Decision
1.:DVWKH(PSOR\HU¶V5HYLHZRI$WWHQGDQFH3DWWHUQV8QUHDVRQDEOH"
[34] The evidence is undisputed that employee absenteeism, after the transfer of CNCC back
to the Ministry, significantly increased even though the workforce remained largely the same.
This fact led to a review of attendance records to determine if some of the absenteeism might be
culpable.
[35] The case law clearly establishes that an employer has a legitimate interest in employee
attendance. As stated by the Board in Re OPSEU (Union Grievance) and Ministry of Health,
*6%1R
- 18 -
th
L.A.C. (4
- 19 -
[39] In terms of overtime combined with a sick day, again I find that the five plus criteria
overcomes any issue with that. While it is true, as the Union asserts, there is no necessary
correlation between a sick day followed by an overtime shift, when such a combination happens
on a frequent basis, it can raise a legitimate question.
[40] Accordingly, I find no fundamental flaw in the methodology used by the Employer in this
matter. It was not an unreasonable exercise of its management rights.
2.Are the attendance meetings and letters discipline?
[41] The GSB has determined thDWWKHHPSOR\HU³KDVWKHULJKWto correct employees through
guidance, counseling or even warning without engaging in diVFLSOLQDU\DFWLRQ´Re OPSEU
(Black) and Ministry of Revenue, GSB No. 885/90 (Dissanayake), cited in Re OPSEU (Halsall)
and Ministry of Agriculture, Food and Rural Affairs, GSB No. 2008-1045 (Briggs) at par 33. In
theBlack case, a letter of counsel was issued in regard to an incident in which the grievor
³UHIXVHGWRIROORZDQLQVWUXFWLRQJLYHQWR\RXE\\RXUPDQDJHU«´7KHOHWWHUWKHQUHYLHZHGWKH
discussion that took place in a meeting to review what had occurred and noted that while
DFFHSWLQJWKHJULHYRU¶VH[SODQDWLRQPDQDJHPHQW³HPSKDVL]HGWKHVHULRXVQHVVRIZKDW\RXKDG
done and that any future incident of this nature will be considered insubordination and
appropriate disciplinary action taNHQ«´:KHQWKHJULHYRUUDLVHGFRQFHUQVDERXWWKHOHWWHU
management responded that it was non-disciplinary and was intended to confirm what had been
discussed. In testimony at the KHDULQJWKHJULHYRU¶VPDQDJHUVWDWHGWKDWKH³ZDQWHGWRHQVXUH
that the grievor understood what was expected ofKLPLQWKHIXWXUH´DQGWKDWWKHPHPRZDV
³LQWHQGHGWRFRQILUPWKHGLVFXVVLRQIRUWKHJULHYRU¶VJXLGDQFH´DQGWKDW³LWZDVQRWLQWHQGHGWR
- 20 -
EHGLVFLSOLQDU\´7KH*6%FRQFOXGHGWKDWWKHmemo was non-disciplinary and did not punish the
grievor for his conduct. InsteaGLW³H[SUHVVHGFRQFHUQVDERXWKLVFRQGXFW´DQG³H[SODLQHGWR
him that he should not engage in similar conduFWLQWKHIXWXUH´(Re OPSEU (Black) at p.7). The
fact that it warned him that any future incident would be considered insubordination subject to
GLVFLSOLQHGLG³QRWPDNHWKHPHHWLQJRUPHPRUDQGXPGLVFLSOLQDU\LQQDWXUH´ It was significant
to the Board that the memo was not placed in thHJULHYRU¶VSHUVRQQHOILOHand was stated to be
non-disciplinary.
[42] In Re OPSEU (Halall), supra at par. 34 and 35, the Vice-Chair quoted two other GSB
GHFLVLRQVFRQFHUQLQJZKDWFRQVWLWXWHV³GLVFLSOLQH´,QRe OPSEU (Barillari) and Ministry of
Community and Social Services, GSB No. 2002-2390 (Dissanayake), the grievor was given two
FRXQVHOLQJOHWWHUVZKLFKVHWRXWWKH(PSOR\HU¶s expectations concerning her behaviour and
criticized certain events in which she was involved. The decision noted that the grievor was
distressed with the information in the letters but that was not the test to be applied. It continued
at par. 62:
Certainly, if the grievor repeats the conduct which was the subject of the letters, the employer
may take disciplinary action, as union counsel suggests. In that event the employer will be
obligated to establish just cause in the event the discipline is grieved. However, that does not
have any relevance to whether the letters are themselves disciplinary. The employer is
entitled to initially attempt to correct an employees conduct in a non-disciplinary way. As the
Board observed in Re Black, that is to be encouraged. If the non-disciplinary approach does
not produce the corrective results, it is open to the employer to initiate a disciplinary response.
The non-disciplinary letters, etc. will not form a step in the progressive discipline system, but
PD\ZHOOVHUYHWRHVWDEOLVKWKDWWKHJULHYRUZDVPDGHDZDUHRIWKHHPSOR\HU¶VH[SHFWDWLRQVRI
the employee should that be an issue.
In regard to the other cited decision, Re OPSEU (Cloutier) and Ministry of Revenue, GSB
No. 108/77 (Swinton), Vice-Chair Briggs stated at par. 35:
- 21 -
It was said in Re Cloutier (supra) that when an employee is advised that they may be
GLVFLSOLQHGLQWKHIXWXUH³LWLVLPSOLFLWLQVXch an admonition that such an appraisal is not
EHLQJPDGHDWWKDWWLPH´)XUWKHULWZDVVDLGWKDW³WKHHPSOR\HHLVsimply being forewarned
that such an appraisal is a distinct possibility if certain conduct about which the employer
FRPSODLQVLVQRWUHFWLILHG´
[43] Similarly, in Re OPSEU (Russell Selkirk) and Ministry of Correctional Services, GSB
No. 206/84 (Roberts), the Board considered a PHPRUHIOHFWLQJD³FRUUHFWLYHLQWHUYLHZ´
concerning attendance. The memo noted that the grievor had been absent on six separate
occasions, five of which were in conjunction with the regular days off or on weekends. It noted
that he was informed that poor attendance was detrimental to an HPSOR\HH¶VUHFRUGDQG
GLVUXSWLYHWRWKHLQVWLWXWLRQ,WDOVRQRWHGWKDW³WKHIDLOXUHWRLPSURYHFRXOGUHVXOWLQIXUWKHU
FRXUVHVRIDFWLRQEHLQJWDNHQ´
[44] The Board, at p. 4, quoted an excerpt from Brown and Beatty, Canadian Labour
nd
Arbitration(2). In part, that quote reads:
It follows from what arbitrators conceive to be the essence of disciplinary sanctions that a
ZULWWHQZDUQLQJZKLFKIRUPVSDUWRIWKHJULHYRU¶VHPSOR\PHQWUHFRUGZKLFKLVLQWHQGHGWR
induce her to alter her behaviour and which may have a prejudicial effect on her position in
future grievance proceedings will likely be regarded as being disciplinary in nature.
&RQYHUVHO\ZKHUHWKHZULWWHQZDUQLQJIRUPVQRSDUWRIWKHHPSOR\HH¶VUHFRUGIRUWKHSXUSRVH
of determining the severity of future discipline, or where it does not involve a change in status
or a monetary loss, or where the warning merely indicates what disciplinary or other action
might be taken in the future, arbitrators have ruled that such notations are not disciplinary in
QDWXUH«
Following this reasoning, the Board determined that³>L@QRUGHUWRFRQVWLWXWe discipline, a written
ZDUQLQJPXVW«EHOLNHO\WRKDYHa prejudicial effect on the position of the grievor in future
JULHYDQFHSURFHHGLQJV´%DVHGRQWKHIDFWVWKHUH the Board found that the attendance letter was
non-disciplinary. It was not intended as discipline and did not form paUWRIWKHJULHYRU¶V
- 22 -
disciplinary record, nor would it be used in some future incident. There was no allegation of
fault on the part of the grievor and, while there was some ambiguity to the letter, there was no
allegation that the absences were not bona fide.
[45] The attendance meetings and letters received by the grievors are similar to the situations
cited above. The meetings were to address concerns that the Employer KDGDERXWWKHJULHYRUV¶
DWWHQGDQFH±WKDWWKHUHDSSHDUHGWREHSDWWHUQVWRsome of the absences. At neither the meetings
nor in the letters was there an allegation that the absences were not bona fide, although as in Re
OPSEU (Selkirk), supraDWS³LWZDVZRUGHGLQVXFKDZD\DVSRVVLEO\WRUDLVHDQLQIHUHQFH
WKHUHRI´%XWHYHQVRWKH(PSOR\HUXQGHUWKH*6%FDVHODZLVSHUPLWWHGWR³FRUUHFW
employees through guidance, counseling, or even warning without engaging in disciplinary
DFWLRQ´Re OPSEU (Black), supra.
[46] The attendance meetings, as stated by Superintendent Kasha, were to express the
(PSOR\HU¶VFRQFHUQVDQGFODULI\Hxpectations about attendance. It was also an opportunity for
the grievors to address the EmplR\HU¶VFRQFHUQV,WSXWWKHJUievors on notice that the Employer
would be reviewing attendance to determine if patterns existed, which the Employer has the right
to do.Canada Post Corporation and C.U.P.W., supra. Although the meetings were upsetting to
both grievors, particularly Ms. Mijatovic, they were not intended to punish; the intent was to
inform and clarify expectations. Likewise, baseGRQWKH*6%¶VFDVHODZWKHIDFWWKDWWKHOHWWHU
to Mr. Landriault advised him that a future culpable absence could lead to a loss of sick pay does
not render the letter disciplinary.Re OPSEU (Black), supra.
- 23 -
[47] Neither the fact of the mHHWLQJVQRUWKHUHVXOWLQJOHWWHUVZHUHSODFHGLQWKHJULHYRUV¶
personnel files. Further, the grievors were assured, verbally, that the process was non-
disciplinary. It would have been better, as stated in Re OPSEU (Selkirk), supra, if the letters
specifically stated that the review process was non-discLSOLQDU\8QGHUWKHFLUFXPVWDQFHV±
particularly the filing of the grieYDQFH±LWLVXQGHUVWDndable that Superintendent Kasha did not
amend the letter, as requested by the grievor. But, as in Selkirk, that omission does not render
the letter disciplinary.
[48] The situation here is markedly different from the situation in Re Hilton Villa Care Centre
DQG%ULWLVK&ROXPELD1XUVHV¶8QLRQ'HQHV*ULHYDQFH
VXSUD, cited by the Union. In that case,
a letter sent to the employee concerning QXUVLQJSUDFWLFHLVVXHVWKRXJKODEHOHGD³QRQ
GLVFLSOLQDU\OHWWHURIH[SHFWDWLRQ´ZDVGHWHUPLQHGWREH³FOHDUO\DFFXVDWRU\´DQGLQYROYHG
³FXOSDEOHPLVFRQGXFW´,WZDVDVIRXQGE\WKHDUELWUDWRUDWSDU³VRPHWKLQJPRUHWKDQWKH
clarification of performance expectations; its purpose was also to correct misconduct at the
ZRUNSODFH´,WZRXOG³XQGRXEWHGO\KDYHDQDGYHUVHHIIHFWRQWKH*ULHYRU¶VHPSOR\PHQW
SURVSHFWV´3DU
7Kat is not the case here.
[49] Nor, in the case of Mr. Landriault, does the requirement that he produce a medical
certificate for any absence for the next thirty days render the letter disciplinary. Whether or not
the Employer had the right to do so under Article 44.10 will be addressed below, but the
requirement itself does not consWLWXWH³GLVFLSOLQH´7KHUHquirement to produce a medical
certificate is not a penalty to induce better behaviour; it is a mechanism to ensure that an absence
isbona fide. The requirement to produce a medical certificate for future absences does not, in
- 24 -
and of itself, have a prejudicial effect on the grievor in future grievance proceedings. His failure
to provide a note, when required, may have a prejudicial effect, but that does not mean that the
imposition of the requirement does.
[50] Finally, the fact that the grievors were permitted to bring a union representative to the
attendance meeting does not make the meeting disciplinary. As Superintendent Kasha testified,
the meeting could lead to potential discipline, and it was therefore both prudent and appropriate
for the individual to have the assistance of a union representative. But again, the meeting itself,
for the reasons set forth above, was not disciplinary.
3.:DVWKHUH³GRXEOHMHRSDUG\´KHUHDQGGLGWKH(PSOR\HULPSURSHUO\FRPELQH
culpable and non-culpable absences?
[51] The GSB has determinedWKDWWKHWHUP³GRXEOHMHRSDUG\´³KDVEHHQOLPLWHGWR
circumstances in which management, having made a final determination of what discipline to
LPSRVHWKHUHDIWHUVHHNVWRUHYHUVHLWVHOIDQGLPSRVHPRUHVHYHUHGLVFLSOLQH´Re OBLEU (Drury)
and Liquor Control Board of Ontario, GSB No. 1707/84 (Roberts), at p. 6. The Union, however,
does not rely on this doctrine in a technical sense, but on the concept, asserting that the grievors
having their attendance again reviewed and questioned, after they successfully exited the
attendance management program based largely on the same absences, is a form of double-
jeopardy.
- 25 -
[52] The ASP dealt solely withQRQFXOSDEOHRU³LQQRFHQW´DEsenteeism. As stated in Re
OPSEU (Union Grievance) and Ministry of the Solicitor General and Correctional
Services/Management Board Secretariat), supra at p. 4:
According to the Attendance Support Program ManuaOWKHJRDORIWKHSURJUDPLVWR³PDQDJH
absenteeism in the Ontario Public Service by committing to employment accommodation and
assistance for all employees who require it and prRYLGLQJDFRQVLVWHQW236ZLGHDSSURDFK´,W
³IRFXVHVRQLQQRFHQWRUQRQFXOSDEOH
DEVHQWHHLVP´ZKLFKLVGHILQHGDV³ZKHQDQHPSOR\HH
WKURXJKQRIDXOWRIKLVRUKHURZQLVDEVHQWIURPWKHZRUNSODFHEHFDXVHRILQMXU\RULOOQHVV´
7KHPDQXDOVWDWHVWKDW³>W@KLs type of absence must be treated appropriately, as a non-
disciplinary issue, recognizing that affected employees may require assistance to return them
WRUHJXODUGXWLHV´&XOSDEOHDEVHQWHHLVPRUDbuse of sick leave provisions, is defined as
³GHOLEHUDWHPLVUHSUHVHQWDWLRQRUPLVXVHRIVLFNOHDYH´DQG³LVGHDOWZLWKWKURXJKWKH
GLVFLSOLQDU\SURFHVV´
>@7KXVWKHUHDUHWZRW\SHVRIDEVHQFHV±culpable and non-culpable. The existence of a
program to address non-culpable absences does not mean that the Employer may not review an
HPSOR\HH¶VDEVHQFHVWRGHWHUPLQHLIVRPHRIWKem may not be legitimate. The assumption, with
innocent absenteeism, is that the absences are legitimate. The focus in culpable absenteeism is
completely different, and with patterns, it is only in hindsight that one can detect if a pattern
exists. Inclusion in the ASP, or exiting it, does not mean that the Employer may not review the
HPSOR\HHV¶DEVHQFHVWRGHWHUPLQHLIWKHUHLVDquestionable pattern to them. As stated by
employer counsel in closing argument, exiting WKH$63SURJUDPGRHVQRWPDNHDQHPSOR\HH¶V
attendance immune from review.
[54] Both grievors, however, felt that it was unfair for the Employer to question their absences
after they had successfully exited the ASP program. While that view is understandable, it is
based on the view that the two types of absences are mutually exclusive. To a certain extent, that
is correct, but not entirely. In an attendanFHSURJUDPWKH(PSOR\HUPD\QRW³PL[WKHWZR´Re
- 26 -
Scarborough Fire Fighters Association, Local 626 and City of Scarborough (Attendance
Program Grievance)[1995] O. L.A.A. No. 9 (Mitchnick), at par. 15. Rather, the two have to be
kept separate, but they may and do coexist.
[55] Then Arbitrator Whitaker in Re Communications, Energy & Paperworkers Union, Local
33-X and Hydro Agri Canada (Attendance Management Policy Grievance) (2001), 95 L.A.C.
th
(4) 99 (Whitaker), at par. 22, noted that the two types of policies may separately coexist:
Policies which deal with culpable sick time abuse and policies which deal with non-culpable
attendance management should remain distinct and separate. Employees must clearly
understand the distinctions between these two types of policies and should not be led to
believe that discipline will follow as a result of absences which are beyond their control. At
the same time, it is quite appropriate for employees to be advised that discipline will apply
where there is culpable behaviour. Where it appears that the two DUH³EOHQGHG´DQGWKH
distinctions are blurred, clarity should be restored.
[56] In this case, the Employer did not blend the two. Instead, it did a separate staff-wide
review of attendance to determine if any patterns were present. The grievors, however, appeared
to have had some confusion about this, believing that exiting the ASP meant that their absences
could not be further questioned. At the meetings, Superintendent Kasha spent time discussing
the differences between culpable and non-culpable absenteeism. This, then, may well be an area
that needs further clarification. Nevertheless, although the two types of absences cannot be
FRPELQHGLQWRDVLQJOHSURJUDPWKH(PSOR\HU¶VVHparate review of the JULHYRUV¶DWWHQGDQFHIRU
potential patterns was not improper and did not constitute a form of double-jeopardy.
4.Did the Employer violate Article 44.10 of the collective agreement?
>
- 27 -
$UWLFOH±LVWKHSLYRWDOLVVXHLQWKLVFDVHand the most difficult one. Article 44.10 provides
as follows:
$IWHUILYH
GD\V¶DEVHQFHFDXVHGE\VLFNQHVVQROHDYHZLWKSD\VKDOOEHDOORZHGXQOHVVD
certificate of a legally qualified medical practitioner is forwarGHGWRWKHHPSOR\HH¶VPDQDJHU
certifying that the employee is unable to attend to his or her official duties. Notwithstanding
this provision, where it is suspected that there PD\EHDQDEXVHRIVLFNOHDYHWKHHPSOR\HH¶V
manager may require an employee to submit a medical certificate for a period of absence of
less than five (5) days.
The second sentence of this provision, by its terms, does not include a temporal limitation. The
question is whether the provision, as a whole, allows the employer to determine, in advance, that
³WKHUHPD\EHDQDEXVHRIVLFNOHDYH´DQGWhus require an employee to submit a medical
certificate for a period of time as the Employer asserts, or whether the Employer must assess if it
suspects abuse at the time of the absence as the Union asserts. There is case law to support each
view, although the predominant view VXSSRUWVWKH8QLRQ¶VLQWHUSUHWDWLRQ
[58] In Re International Union of Operating Engineers, Local 987 and Health Sciences
th
Centre(2003), 114 L.A.C. (4) 400 (Spivak), involved a Union policy grievance contesting the
Attendance Management Program, which gave the employer the discretion to require a medical
certificate for each absence after an employee had EHHQDEVHQWVL[WLPHV7KHSDUWLHV¶DOVR
introduced evidence that one employee, due to his high rate of absenteeism, had been required by
the employer to produce a medical certificate for any future absence due to illness until he
achieved regular attendance. The arbitrator held at par. 68 that ³GLVFUHWLRQ>WRUHTXLUHDPHGLFDO
certificate] is not compatible with a blanket policy in advance unrelated to the individual
FLUFXPVWDQFHVRIHDFKDEVHQFHWKDWLVLPSRVHGRQVRPHHPSOR\HHV´1RUZDVWKHSROLF\VDYHG
- 28 -
by the fact that the employer could determine which employees who met the threshold had to
produce medical certificates. The arbitrator concluded at par. 69:
While management may exercise a discretion as to which employees that meet the threshold
will be required to produce medical certificates, those employees will have the automatic
requirement to produce medical certificates in the future based on past conduct and not on the
specifics of the future absences. Those employees will have to automatically produce medical
certificates without any consideration of the actual circumstances of the absence giving rise to
DQLQGLYLGXDOHPSOR\HH¶VFODLPIRUVLFNOHDYHLQWKHIXWXUH
In terms of the individual who was required to produce a medical note for future absences, the
%RDUGGHWHUPLQHGWKDWKH³ZRXOGKDYHWKHDXWRPDtic obligation to provide a medical certificate
for every absence in the future relating to illness, irrespective of the nature and duration of the
illness, and even when there is no question about the legitimacy of his claim to have been
LQFDSDFLWDWHGE\LOOQHVV´7KDWZDVQRWSHUPLVVLEOHEXWWKHHPSOR\HUFRXOGUHTXHVWDQRWH³RQD
case by case basis where there are reasonable groXQGVWRGRXEWWKHWUXWKRIWKHHPSOR\HH¶VFODLP
WKDWKHZDVDZD\EHFDXVHRILOOQHVV«´
[59] The idea that discretion must be exercised on a case-by-case basis is supported by a
number of the arbitration cases cited by the Union. E.g., Re City of Toronto and C.U.P.E., Local
79 (1984), 16 L.A.C. (3d) 384 (M. Picher);Re NAV Canada and Canadian Air Traffic Control
th
Association (2000), 86 L.A.C. (4) 370 (Brault); Manitoba and Manitoba Government
(PSOR\HHV¶8QLRQ [2007] M.G.A.D. No. 40 (Jones); 5H6W-RVHSK¶V*HQHUDO+RVSLWDO(OOLRW
th
/DNHDQG2QWDULR1XUVHV¶$VVRFLDWLRQ2VERUQH0D\*ULHYDQFH
(2008), 170 L.A.C. (4) 115
(Sheehan).
- 29 -
[60] Some of these cases rely on a decision by Arbitrator Swan in Re Meadow Park Nursing
Home and Service Employees International Union, Local 329 (1983), 9 L.A.C. (3d) 137 (Swan),
LQZKLFKWKHFRQFHSWRI³GLVFUHWLRQ´LQUHODWLRQWRVLFNSD\ZDVdiscussed. In that decision, the
board of arbitration cited to Mullan, Administrative Law (Carswell, 1973) for, among other
WKLQJVWKHLGHDWKDW³GLVFUHWLRQVKRXOGEHH[HUcised in relation to each individual matter coming
before the decision-maker and should not be automatically determined or even fettered by reason
RIDULJLGSROLF\ODLGGRZQLQDGYDQFH´*XLGelines or principles for future action were
DFFHSWDEOH³VRORQJDVKHVWLOOFonsiders the merits of each individual matter for decision in the
light of those guidelines and principles and is prepared to admit of exceptions to the general
policy in appropriate caseV´7KHERDUGGHWHUPLQHGDWS>:]e think that the exercise of the
HPSOR\HU¶VGLVFUHWLRQPXVWEHLQJRRGIDLWKPXVW be a genuine exercise of discretion and not
merely the application of a rigid policy, and must include a consideration of the merits of each
LQGLYLGXDOFDVH«´
[61] The Employer contends, however, that it KDVIXOO\H[HUFLVHGLQGLYLGXDOGLVFUHWLRQ±
through its filtering review and individual meetings, and that it exercised discretion in
determining that certain employees, such as Mr. Landriault, did not sufficiently address the
HPSOR\HU¶VFRQFHUQVDQGWKDWLWWKHUHIRUHKDGDreasonable basis to suspect that there may be an
abuse of sick leave so as to require the employee to submit a medical certificate for absences for
the next thirty days. It submits that the emSOR\HHV¶SDVWDWWHQGDQFHUecord is a sufficient,
objective basis to suspect that there may be abuse of sick leave.
- 30 -
[62] This was an approach accepted in 5H6W-RVHSK¶V+HDOWK&Hntre and Canadian Union of
Public Employees, Local 1144 (1988), 34 L.A.C. (3d) 193 (Joyce). In that case, the Employer,
GXHWRDQHPSOR\HH¶VH[FHVVLYHDEVHQWHHLVPrequired him to produce a medical note for every
absence. The arbitrator concluded that it could do so, at pp. 202-203:
*LYHQWKHJULHYRU¶VKLVWRU\RIXQDFFHSWDEOHattendance, the employer had reasonable grounds
for concern over the legitimacy of the frequent absences from work. This being so, the
employer had reasonable grounds to question, in depth, the reason for each absence. This
being so, the employer acted properly in its decision that the grievor must produce a medical
certificate in the case of each absence due to alleged illness until such time as his absenteeism
reached an acceptable level.
,QWKHDUELWUDWRU¶VYLHZLWZDV³IDLUDQGRIDEXQdant common sense for the grievor to be aware of
WKLVUHTXLUHPHQWLQDGYDQFHRIHDFKVXFKDEVHQFH´
[63] Similarly, in Re Skeena Cellulose Inc. and Christian Labour Association of Canada,
Local 44 [2001] B.C.C.A.A.A No. 164 (Blasina), the Company had observed the grievor in
circumstances which led it to suspect that the grievor had been untruthful about his absences, and
thereafter instructed hiPWREULQJDGRFWRU¶VQRWHLIKHZDs absent on medical grounds in the
future. The arbitrator noted, at par. 18, that³DUELWUDWRUVKDYHUHDFWHGXQIDYRXUDEO\ZKHUH
medical certificates are required as a matter of general policy, and not in response to individual
RUSDUWLFXODUFLUFXPVWDQFHV´ZKLFKZDVYLHZHG³DV an abdication of manageULDOGLVFUHWLRQ´7R
the arbitrator, however, the Company did not adopt a blanket policy applicable to all employees
±MXVWZLWKUHVSHFWWRWKHLQGLYLGXDO+HDOVRdetermined that the Company could not make this
an ongoing requirement into the future indefiQLWHO\EXWFRQFOXGHGWKDW³WKHUHPD\EH
circumstances where it would be appropriate to require a medical certificate to verify every
asserted medical absence occurring within a deILQHGSHULRGRIWLPH´+HFRQWLQXHG³)RU
example, where an employee has demonstrated a pattern of excessive absenteeism, characterized
- 31 -
by numerous short absences, and perhaps for varying reasons or perhaps exhibiting some
connection to weekends, it would not be unreasonable for an employer to suspect some measure
RIFXOSDEOHFRQGXFW´7RWKHVDPHHIIHFWLV5H6REH\¶V,QFDQG8QLWHG)RRG &RPPHUFLDO
Workers International Union, Local 175 (Wight Grievance), supra.
[64] The parties do not dispute that discretion must be exercised in relation to the second
sentence of Article 44.10. They differ in regard to when that diVFUHWLRQPD\EHH[HUFLVHG±LQ
advance for a period of time based on past conduct, or in relation to an actual absence. The
(PSOR\HUDUJXHVWKDWWRDFFHSWWKH8QLRQ¶VLQWHUSUHWDWLRQLPSRVHVDWHPSRUDOOLPLWDWLRQQRW
found in the language of the collective agreement. With respect, I cannot agree. It is, instead, a
matter of interpretation of the provision. After careful consideration, I conclude that the
discretion related to Article 44.10 must be exercised at the time of the absenFH±DOWKRXJKLWPD\
EHLQIRUPHGE\WKHHPSOR\HH¶VSDVWDEVHQWHHLVPrecord and the existence of any patterns of
absence.
[65] What this means is that the Employer may not decide, as it did with Mr. Landriault, that
he must provide a medical note for any absence during the next thirty days. There may be times,
as noted in Re International Union of Operating Engineers, Local 987, supra at par. 69, when
WKHUHLV³QRTXHVWLRQDERXWWKHOHJLWLPDF\RIKLVFODLPWRKDYHEHHQLQFDSDFLWDWHGE\LOOQHVV´
7KH(PSOR\HUPD\KRZHYHUEDVHGRQWKHHPSOR\HH¶s past attendance record, request a medical
note for an absence that involves the same patteUQ±RUDQ\RWKHUVXVSLFLRXVDEVHQFH7KH
HPSOR\HH¶VSDVWUHFRUGRIDWWHQGDQFHLVFOHDUO\Drelevant factor for the employer to consider in
the exercise of its discretion under Article 44.10.
- 32 -
[66] In light of this determination, I find it unQHFHVVDU\WRFRQVLGHUWKH8QLRQ¶VRWKHU
FRQWHQWLRQFRQFHUQLQJ$UWLFOH±QDPHO\WKDWan instruction to provide a medical note for
each absence violates the first sentence of that provision, and therefore violates the collective
agreement.
[67] Finally, I note that no arguments were presented concerning Article 3 of the collective
agreement or the Ontario Human Rights Code.
Conclusion:
For all of the reasons set forth above, I conclude as follows:
1.The methodology used by the Employer to determine attendance patterns was not
unreasonable.
2.7KHDWWHQGDQFHPHHWLQJVDQGOHWWHUVGLGQRWFRQVWLWXWH³GLVFLSOLQH´
3.7KHUHZDVQR³GRXEOHMHRSDUG\´LQYROYHGLQWKH(PSOR\HU¶VUHYLHZLQJWKHVDPHDEVHQFHV
for potential patterns that had EHHQLQYROYHGLQWKHJULHYRUV¶inclusion in and subsequent
exit from the ASP.
4.The Employer violated Article 44.10 when it required Mr. Landriault, in advance, to
submit a medical certificate for each absence for the next thirty days.
5.The November 14, 2008 letter to Mr. Landriault should be amended to delete any
reference to such a requirement.
nd
Dated at Toronto this 2 day of September 2011.
Randi H. Abramsky, Vice-Chair