HomeMy WebLinkAboutUnion 11-11-21
IN THE MATTER OF AN ARBITRATION
BET WEE N:
ST. LAWRENCE COLLEGE
(The "College")
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION, LOCAL 417
(The "Union")
AND IN THE MATTER OF A GRIEVANCE CONCERNING PARTIAL LOAD
TEACHERS
AND IN THE MATTER OF A PRELIMINARY AWARD CONCERNING JURISDICTION
BOARD OF ARBITRATION
David K. L. Starkman
Larry Robbins
Ann Burke
Chair
Union Nominee
College Nominee
APPEARANCES FOR THE EMPLOYER
Colin Youngman
Jim Gibson
Debbie McKay
Counsel
Manager, Human Resources
Director, Academic Operations
APPEARANCES FOR THE UNION
Mary MacKinnon
Erin O'Hara
Bijon Roy
Graeme Aubert
Mary Ann White
Counsel
Local Union President
Chief Steward
A Hearing in this matter was held on March 23, and October 4, 2011 at Kingston,
Ontario.
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PRELIMINARY AWARD
In August, 2009 the Union grieved that the College was in violation of the collective
agreement in that it was not paying partial load employees correctly.
The College requested particulars and, in March, 2011, counsel for the Union
responded in part as follows:
The grievance was filed by the Union when they were notified, on July 24,
2009, that a retreat had been held on June 9 at the Cornwall Campus,
and that partial load professors were mandated to attend.
I enclose a copy of an em ail July 24,2009 to Don Fairweather from Mary-
Ann White. I also enclose a copy of minutes from the retreat, which
identify the participants of the meeting and include a number of partial
load professors.
The Union bases the grievance on Article 26.02 A, which describes the
functions of partial load employees. Note that complementary functions
are not included in the requirements for partial load employees, as they
are for full-time employees. As a result, the Union grieves that the
College should not be imposing mandatory meetings, which are a
complementary function, on partial load employees. The Union will be
seeking a declaration that the College refrain from imposing these
functions on partial load employees.
In addition or in the alternative, for employees who have been obliged to
perform these functions, the Union will take the position that hours spent
performing these would be calculated as "voluntary overtime", as they are
overtime above and beyond what is required of the employee pursuant to
his or her contract. Thus, the partial load employee should be paid at a
rate that is equivalent to what a full-time person would receive for the
same number of hours (for example, an employee at step 4 in the salary
grid as a partial load employee, would be paid, 1 % of the full-time step 4
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salary rate for each hour of meeting attendance).
We understand that this is a continuing issue, as the Union has been
advised that within a number of other departments, various groups have
mandatory training sessions scheduled for the Spring and Summer. The
Union understands that, at the Brockville campus, the College intends to
schedule mandatory training for partial load employees with no
compensation.. .
This Preliminary Award concerns the Colleges's motion that this Board of Arbitration
does not have jurisdiction to consider this Union grievance because of article 32.09 of
the collective agreement which provides:
The Union or Union Local shall have the right to file a grievance based on
a difference directly with the College arising out of the Agreement
concerning the interpretation, application, administration or alleged
contravention of the Agreement. Such grievance shall not include any
matter upon which an employee would be personally entitled to grieve and
the regular grievance procedure for personal or group grievance shall not
be by-passed except where the Union establishes that the employee has
not grieved an unreasonable standard that is patently in violation of this
Agreement and that adversely affects the rights of employees...
The Employer submitted that the College's decision not to pay partial load teachers for
attending certain meetings was a matter that could have been grieved by individual
partial load teachers, and according to article 32.09, in such circumstances, the Union
can only grieve if it establishes that the decision not to pay was an unreasonable
standard which is patently in violation of the collective agreement, and adversely
affects the rights of other bargaining unit employees.
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The Union submitted that the grievance raised the issue of whether it was appropriate
for the College to require partial load employees to attend mandatory meetings, and if
so, how such employees were to be compensated. In its view, the grievance was broad
in nature, and as such, affected the integrity of the collective agreement. The Union
indicated that the grievance it was not seeking monetary compensation for any
individual employee.
Reference was made to a considerable number of decisions between the parties which
interpreted and applied article 32.09. In Seneca College and Ontario Public Service
Employees Union, unreported, November 21,1990 (P.C. Picher) the Union grieved that
the College had assigned teaching at the School of Communication Arts contrary to the
requirements of the collective agreement. The agreement at that time had identical
language to article 32.09. At page 7 the Board cited with approval from p. 8 of the
decision in Sir Sandford Fleming College and OPSEU, unreported, April 25, 1988 (G.
Brent) as follows:
In our view, in order for a violation of the collective agreement to be called
"patent" it must be evident or plain on its face that there has been a
violation of the agreement. That is, it is not sufficient that the Union can
show that arguably it has a case which could be a violation of the
collective agreement dependant on which of two reasonably possible
interpretations are accepted, but rather that there has been a clear,
evident and plain violation of the collective agreement.
In Northern College and OPSEU, [1992] O.L.A.A. No. 840 (0.8. Shime) the Union
grieved that the College was improperly classifying employees. The College objected
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to the Union policy grievance on the grounds that an individual grievance could have
been filed, and the objection was dismissed as the Board found that the issues
concerning the scope of the bargaining unit were not matters which could have been
grieved by individual employees.
In Loyalist College of Applied Arts and Technology and OPSEU, Local 420, unreported,
May 29,2001 (K.G. O'Neil) the Union grieved the assignment of instructors to teach
theory in the automotive technician program claiming that the work was reserved to
Professors. The College objected on the grounds that an individual grievance could
have been filed, and in upholding the objection at p. 21 the Board commented on the
words "patent violation" as follows:
The words "patent violation" have been held to create a high standard
(Seneca College and OPSEU, P. Picher, January 31,1991), to mean the
violation has to be crystal clear (Sir Sanford Fleming and OPSEU, Brent,
April 25, 1988), or "leap from the page" (Centennial College and OPSEU,
M.C. Picher, January 20, 1992). In Fanshawe College and OPSEU
(Kruger, September 16, 1997), the Board decided that a case that was
arguable on both sides was "not a patent violation").
In Fanshawe College and OPSEU, unreported, December 10, 2007 (P. Knopf),the
Union grieved the manner the College granted Professional Development Leave to a
professor in 2005/06. The college objected pursuant to Article 32.09, and the Board
allowed the objection because there was no evidence that the rights of other employees
were affected.
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There is no doubt that there are many situations which can give rise to either a policy
grievance or an individual grievance, and in such circumstances where an individual
could grieve but has chosen not to, arbitrators have generally allowed Union policy
grievances to proceed if the issue raised is of broad application to the bargaining unit.
In Re Ontario Institute for Studies in Education and Professional Staff Assn. of Ontario
Institute for Studies in Education, [1996] O.L.A.A. No. 572 (K.G. O'Neil), the Union filed
a policy grievance with respect to limitations on an Early Retirement Incentive plan, and
the grievance was allowed to proceed to the extent that it dealt with the institutional
issues such as bad faith rather than the individual rejection of an application", In
Toronto Transit Commission and Amalgamated Transit Union, Local 113 (Overtime
Grievance) [2000] O.L.A.A. (M.K. Saltman) the Union filed a policy grievance with
respect to an overtime policy. The Employer objected that it was not a proper policy
grievance. The Board dismissed the objection for a number of reasons and noted that
the policy had a broad general application and raised issues between the Commission
and the Union. In Cancoil Thermal Corp. and United Food and Commercial Workers
Canada, Local 175 (Vacation Scheduling Grievance), (2008) 174 L.A.C. (4th) 334
(D.K.L. Starkman), the Union filed a policy grievance alleging that the employer was in
violation of the vacation scheduling provisions of the collective agreement. The
employer objected that it was not a proper policy grievance and in dismissing the
objection the Board noted that the Union was seeking declaratory relief with respect to
a policy that applied to all members of the bargaining unit and that it was an appropriate
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use of the provisions in the collective agreement as it applied to union grievances.
Neither of the three non-College decisions referred to in the above paragraph had
identical or even similar language to the collective agreement language in question in
this arbitration proceeding. Furthermore, the language in this collective agreement has
been in effect since at least 1988 and had been interpreted and applied by a number of
Boards of Arbitration, and in general has been applied consistently.
In this matter it is clear that an individual partial load teacher who is required by the
Employer to attend a meeting and is not paid for attending such meeting can grieve
both the requirement to attend and the non-payment of money for such attendance. It
is also clear that the issue of mandatory attendance and non-payment of money affects
the rights of other partial load teachers in the bargaining unit. As confirmed by the
arbitral jurisprudence however, in order for the Union to proceed, it must, amongst other
things, demonstrate that the mandatory attendance and/or the non-payment is in patent
violation of the collective agreement. With respect to this issue the Union noted that
article 26 of the collective agreement is about partial load employees and article 26.02A
provides:
A partial-load employee shall not receive salary or vacations but shall be
paid for the performance of each teaching contact hour at an hourly rate
calculated in accordance with 26.04.
The Union submitted that, insofar as partial load teachers are not paid or credited with
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complementary functions, which includes meetings, as full-time professors are,
therefore partial load teachers cannot be required to attend meetings, or if they can be
required to attend meetings, they must be remunerated for such attendances. A
reading of article 26, which specifically addresses partial load teachers, and article 11,
which addresses the calculation of complementary functions for full time professors
does not, in our view, indicate that the College is in patent violation of the provisions of
the collective agreement. At best it indicates that the College is arguably in violation of
the collective agreement, and as the arbitral jurisprudence has made clear, an arguable
violation is insufficient to give this Board of Arbitration jurisdiction over an issue which
could have been grieved by an individual partial load teacher.
Accordingly this Board of Arbitration does not have jurisdiction to consider this matter
and the grievance is dismissed.
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Dated at Maberly, Ontario this 21 st day of November, 2011
"See attached Dissent"
Larry Robbins
"I concur"
Ann Burke
IN THE MATTER OF AN ARBITRATION BETWEEN:
ST. LAWRENCE COLLEGE
and
ONTARIO PUBLIC SERVICE EMPLOYEES UNION LOCAL 417
UNION POLICY GRIEVANCE RE PARTIAL LOAD INSTRUCTORS
(#2009-0417-0015)
DISSENT
I have reviewed the A ward of the chairperson in this matter and regret that I must respectfully
dissent. I would begin with the well known principles set out in the decision of the Ontario
Court of Appeal in Blouin Drywall Contractors Itd. and United Brotherhood ofCmpenters and
Joinel;~' of A merica Local 2486, A ug.!75 that unions should be given some latitude in the form of
a grievance, and that grievances should not be won or lost based on a technicality of form, but on
their merits where possible.
In this particular case, when one examines the grievance and the Union's reply to the Employer's
request for particulars dated March 17, 2011, it is clear that the Union had general institutional
concerns. Could the College impose mandatory meetings which are a complementmy function
on partial load employees, and if so, how should such employees be paid? The case came to light
because of the retreat held at the Cornwall Campus on June 9/09, but the Union was not
concerned about seeking a remedy on behalf of the two partial load employees who attended.
Moreover the minutes of that meeting suggested that partial load employees would not be paid
for their attendance at these meetings in the future. The Union also made it clear in the above
letter that it saw this as a continuing issue, and that other mandatory meetings were to be
scheduled in the spring and summer.
While I agree that the two individuals (Tinkess and Roberts) could have theoretically filed a
grievance over payment for the June 9th retreat, it would have been a velY different grievance
from the one filed by the Union in this case, and would have been limited to payment for them
for that particular meeting.
At this point there was not yet any individual who could grieve over the future meetings. We
certainly were not advised that any partial load employees had already been assigned to attend
thcm at that point.
It should also be stressed that the interests of the Union may be very different from that of
individual partial load employees, in that their major concern is to ensure that the status of full
time teachers is protected, and that the scope of duties of partial load instructors is not expanded.
I turn now to the language of Article 32.09. While it does restrict the Union's ability to file
policy grievances, the purpose of the restriction is set out, namely that the regular grievance
procedure for individual and group grievances shall not be bypassed. The purpose is not to
prevent the Union from enforcing the collective agreement at all. The language states: "Such
grievance shall not include any matter upon which an employee would be personally entitled to
grieve".
The chairperson states that none of the three non-College decisions relied on by the Union had
identical or cven similar language to that in question here, But in my view all three essentially
had the same restriction,
In the T. T.C case (supra) the language states: "A grievance which arises directly between the
parties to this Agreement, which could not form a grievance to be processed under
the foregoing grievance procedure by an affected employee, may be submitted in
writing... .
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In Cancoil Thermal C01p. (supra) the language reads as follows: "A grievance capable of
forming the subject matter of one 01' more individual employee's grievance may not be submitted
as a Union or Company grievance."
Finally in the OlSE case (supra) the language reads as follows: "Such grievance shall not include
any matter upon which an employee would be personally entitled to grieve and the regular
grievance procedure shall not be by-passed,"
In my view, the restriction in the other three cases is essentially the same, and those cases
provide a sound legal basis for rejecting the Employer's preliminary objection in this case.
What makes the wording different in this case is the added language which sets out certain
exceptions whereby, even if it is a matter that could be personally grieved by an individual, a
policy grievance can still be filed. The wording reads as follows: "except where the Union
establishes that the employee has not grieved an umeasonable standard that is patently in
violation of this Agreement and that adversely affects the rights of employees."
The chairperson focuses on this exception and finds that the Union hasn't met the test,
specifically because of the requirement that it be a patent violation of the Agreement. I don't
dispute the finding that the Union did not meet the requirements of the exception. But one
doesn't get to the exception unless there is a finding that the grievance was a matter which could
have been filed by an individual employee. In my view, that was not the case here for the reasons
set out above. This added language in the College agreement is not intended to make the
provision even more restrictive, It's supposed to provide an exception, albeit a very limited one,
which would allow the filing of a policy grievance even where the matter was appropriate for an
individual grievance.
The rcsult of this award is that it makcs it very difficult for the Union to enforce the terms of the
collective agreement. Partial load employees given their lack of job security and uncertain status
would be very unlikely to launch such a grievance on their own, I agree that a grievance asking
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for a remedy for the two individuals who attended the June 9/09 retreat would be clearly the
subject matter for an individual grievance. But a grievance over the general institutional issues
raised by the Union is quite different, and should not be caught by the restriction in Article
32,09.
To put it another way, in contrast to the case of Loyalist College (supra), there is still something
of substance to decide here once we remove the two individuals from the equation.
While I agree that Article 32,09 does restrict the ability of the Union to file policy grievances,
and that one cannot ignore the language of the collective agreement, it is my view that the
chairperson's interpretation expands the scope ofthe restriction beyond what was intended,
namely that the regular grievance procedure for individuals not be bypassed. The Union would
appear to be left without a way to grieve at all to deal with these institutional concerns,
Perversely the Employer would be free to launch a grievance on the same issue under Article
32,10 of the Agreement. This cannot have been the intent of the parties,
For all of these reasons I would have dismissed the Employer's preliminary objection.
DATED AT TORONTO, this lih day of November, 2011.
"Larry Robbins"
Larry Robbins, Union Nominee
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