HomeMy WebLinkAbout2021-3327.Stanley.24-02-22 Decision
Crown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
GSB# 2021-3327
UNION# 2021-0649-0004
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Stanley) Union
- and -
The Crown in Right of Ontario
(Ministry of Natural Resources and Forestry) Employer
BEFORE Adam Beatty Arbitrator
FOR THE UNION Alex Zamfir
Ontario Public Service Employees Union
Grievance Officer
FOR THE EMPLOYER Jonathan Rabinovitch
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING October 31, 2023
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Decision
[1] The Grievor is employed by the Ministry of Natural Resources and Forestry (the
“Ministry” or the “Employer”) in the classification of Pilot 4 Twin Otter (DHC6
Pilot). In or around November 22, 2021, the grievor was placed on an unpaid
leave of absence, and was not assigned other duties, because he refused to
disclose his Covid 19 vaccination status. The decision to place the grievor on an
unpaid leave was the result of Transport Canada’s Mandatory Vaccination Policy
- Interim Order Respecting Requirements for Civil Aviation No. 43 (“IO 43”). He
grieves that decision. The grievance form was completed by the Grievor on
December 6, 2021 but was not received by the Employer until January 19, 2022.
[2] The Employer has raised three preliminary objections to this grievance. First, the
Employer argues that the grievance is untimely. Second, the Employer argues
that the Union is seeking to expand the scope of the grievance and that as such
it should not be permitted to proceed. Third, the Employer argues that the
grievance does not disclose a prima facie violation of the Collective Agreement
and therefore should be dismissed. This decision addresses these preliminary
motions.
[3] As will become clear below, what IO 43 required and did not require is very much
at issue in this grievance. That being said, for the purposes of this general
summary, it is sufficient to note that the Employer understood IO 43 to require
employees to disclose their vaccination status and to prohibit those who refused
to do so (as well as those who confirmed they were not vaccinated) from
accessing certain aerodromes, including those the grievor flew into and out of as
part of his duties as a pilot. Based on its understanding of IO 43, the Employer
implemented a rule requiring employees who would be physically present on any
aerodrome to be vaccinated. As a result of the Ministry’s rule, the grievor
effectively could not fly for the Ministry. The grievor was permitted to return to
work on June 27, 2022.
A. Timeliness
(i) Position of the Ministry
[4] The Employer relies on Article 22.2 of the Collective Agreement. Article 22.2
reads as follows:
If the complaint or difference is not resolved at the local level an employee
may file a grievance, in writing, through the Union, with their manager
within thirty (30) days after the circumstances giving rise to the complaint
have occurred or ought reasonably to have come to the attention of the
employee, who will in turn forward the grievance to the designated
management representative.
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[5] The Employer also relied on Article 22.14.1 of the Collective Agreement. Article
22.14.1 states as follows:
Where a grievance is not processed within the time allowed or has not
been processed by the employee or the Union within the time prescribed it
shall be deemed to be withdrawn.
[6] The Employer notes that the grievor was put on an unpaid leave on November
22, 2021. Accordingly, the grievance should have been filed no later than
January 6, 2022. However, as noted above it was not received until January 19,
2022, eight business days after the deadline established by Article 22.2 of the
Collective Agreement.
[7] The Employer acknowledged that the delay was relatively short but argued that
the grievance should be dismissed nonetheless. The Employer took the position
there were a number of factors that supported its position.
[8] First, the Employer accepted, for the purposes of this motion, that it was the
Union and not the grievor that was responsible for the late filing of the grievance.
The Employer argued that that should not matter. The fact that it was the Union
that was responsible for the delay is not a factor that should favour extending the
time-limits. The Union is a party to the Collective Agreement. One of their
responsibilities is to file grievances on behalf of their members. In this case they
missed the deadline and, according to the Employer, they must now bear the
consequences.
[9] Second, the Employer argued that the subject matter of the grievance favours
dismissing the grievance. As will be set out below in more detail, the underlying
subject matter of the grievance, according to the Employer, is back pay. The
grievor is seeking back pay for the period of time he was placed on an unpaid
leave (subject to his mitigation efforts). From the Employer’s perspective,
because the grievance is, at the end of the day, only about money, it raises less
significant issues than termination grievances, other grievances involving
discipline or grievances raising human rights issues. As such, the prejudice the
grievor will face if the grievance is dismissed for being untimely is not particularly
significant.
[10] Third, the Employer argued that the words of the Collective Agreement had to be
given meaning. The parties agreed to a specific time frame for the filing of
grievances. Allowing the Union to disregard the time limits for no reason
devalues the words agreed to by the parties. The Ministry also noted that the
delay occurred at the outset of the grievance procedure thereby increasing the
prejudice to the Ministry.
[11] The Employer acknowledged that I have jurisdiction under Article 22.14.7 of the
Collective Agreement (by way of reference to section 48(16) of the Ontario
Labour Relations Act) to extend the timelines but argued that there was no
reason to do so in the circumstances. That statutory discretion may be exercised
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to extend time limits when there are reasonable grounds for the extension and
the extension does not result in substantial prejudice to the opposing party. The
Ministry argued that the Union had not provided any reason, other than the short
length of the delay, to justify granting the extension requested. Accordingly, the
grievance should be dismissed.
[12] The Employer relied on the following decisions in support of its position: Ontario
Public Service Employees Union (Ng) and Ontario (Ministry of Government
Services), GSB #2009-3379 (Mikus); Ontario Public Service Employees Union
(Smith et al.) and Ontario (Ministry of Community and Social Services), GSB
#2006-2107, 2006-2379 (Gray); Ontario Public Service Employees Union
(Mazara) and Ontario (Ministry of Community Safety and Correctional Services),
GSB #2009-1065 (Gray); B.C. Gas Utility Ltd. and Office & Professional
Employees International Union, Local 378, (1998) 72 L.A.C. (4th) 150 (Kelleher);
Helen Henderson Care Centre and Service Employees Union, Local 183, (1992)
30 L.A.C. (4th) 150 (Emrich).
(ii) Position of the Union
[13] The Union argues this is an appropriate case for the Board to exercise its
discretion and to grant an extension to the time-limits for filing a grievance. The
Union notes that the delay was only 8 days, that the reasons for the delay do not
lie with the grievor, and that the issues raised by the grievance are important.
Specifically, the Union characterized the grievance as raising issues related to
the exchange of the grievor’s labour for remuneration and submitted that this is a
fundamentally important issue.
[14] The Union noted that the grievance form was dated December 6, 2021.
According to the Union, after some back and forth between the Union and the
grievor, the Local inadvertently lost track of the timelines over the holidays. The
grievor, however, followed up with the Union after it came to his attention that the
Employer had not received his grievance. The Union also noted that after the
grievance was filed, the Chief Steward for the Local followed up with the
Employer to explain the delay in filing the grievance.
[15] The Union argued that the Employer would not be prejudiced if the extension
was granted. In fact, the Union noted that the Employer did not allege prejudice.
[16] Turning to the importance of the issue raised by the grievance, the Union argued
that at the time he filed the grievance, the grievor had been placed on unpaid
leave of absence and did not know how long it would last. On the spectrum of
grievances, the Union argued that being placed on an unpaid leave is a close
second to being terminated. The grievor was being denied the ability to work for
the Ministry and earn an income for an indefinite period of time.
[17] The Union also noted that this was the first time the grievor filed a grievance.
Accordingly, he was not familiar with the process. And regardless, the delay was
very short.
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[18] The Union relied on the following cases in support of its position: Becker Milk Co.
and Teamsters Local Union No. 647, (1978) 19 L.A.C. (2d) 217 (Burkett); Greater
Niagara General Hospital and Ontario Nurses’ Association, (1981) 1 L.A.C. (3d)
1 (Schiff); Royal Crest Lifecare Group and Service Employees International
Union, Local 204, (2000) 91 L.A.C. 389 (Craven); The United Brotherhood of
Retail, Food, Industrial & Service Trades International Union and Mevotech LP,
2020 CanLII 68807 (ON LA) (Nyman); and Ontario Public Service Employees
Union (Clark et al) and Ontario (The Ministry of Natural Resources and Forestry),
2018 CanLII 119575 (ON GSB) (Dissanayake).
(iii) Analysis
[19] Both parties relied on Arbitrator Burkett’s analysis in Becker Milk Co. In that
decision, Arbitrator Burkett identified the following three factors that arbitrators
should consider in determining whether it is appropriate to extend the time-limits
for filing a grievance:
1. the reason for the delay;
2. the length of the delay; and
3. the nature of the grievance
[20] In his discussion of the interplay between these factors, Arbitrator Burkett stated
as follows:
If the offending party satisfies an arbitrator, notwithstanding the delay, that
it acted with due diligence, then if there has been no prejudice the
arbitrator should exercise his discretion in favour of extending the time
limits. If, however, the offending party has been negligent or is otherwise
to blame for the delay, either in whole or in part, the arbitrator must
nevertheless consider the second and third factors referred to above in
deciding if reasonable grounds exist for an extension of the time limits. In
so far as re Pamour Porcupine Mines Ltd. and U.S.W. (1976) 12 L.A.C.
(2d) 122 (Dunn) stands for the proposition that the only factor to be
considered is the “reasonableness of the excuse” for the delay, I
respectfully disagree. The purpose of the section is to alleviate against
technical bars. If the offending party has been negligent in its processing
of the grievance but the delay has been of short duration an arbitrator
would be permitted to rely on the short period of delay as constituting
reasonable grounds for an extension. If the grievance involves the
termination of an employee, as distinct from some lesser form of
discipline, this is also an equitable consideration which must be taken into
account, in deciding if there are reasonable grounds to extend the time
limits. One arbitrator has gone so far as to state that in a discharge
grievance,
there would have to be a very clear case of unexpected,
unreasonable delay and prejudice to the employer before it would
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be proper to deprive the grievor of the right to a hearing on the
merits. (Emphasis added by Arbitrator Burkett)
[21] Whether there are reasonable grounds to extend the time limits for filing a
grievance requires a balancing of the factors outlined by Arbitrator Burkett.
Having regard to the facts here, I am satisfied that it is appropriate to grant the
extension and allow the grievance to proceed. Or, to put it somewhat differently,
it is appropriate to deny the Ministry’s motion to dismiss this grievance on
timeliness grounds.
[22] First, the length of the delay is relatively short. Any prejudice normally
associated with a delay at the beginning of the grievance process is reduced if
not eliminated as memories and information remain intact and available.
Second, the grievor was not responsible for the delay. The record shows that the
grievor was responsible for discovering the Local’s inadvertent error and was
doing his best to get the grievance before the Employer as soon as possible
thereafter.
[23] Third, the issue raised by the grievance is more serious than the Ministry argues.
As set out above, the Ministry argued that this grievance was about back pay.
That is too narrow a view. Conversely, I did not find the Union’s characterization
of the grievance to be particularly helpful either. Many grievances raise issues of
proper remuneration. Describing the issue as the exchange of the grievor’s
labour for remuneration is not compelling. Rather, this unpaid leave is more akin
to a lengthy suspension as, at the time the grievance was filed, the grievor did
not know how long it would last. While the grievor’s leave without pay did not
include the same disciplinary implications as a suspension, it was open-ended.
Accordingly, the grievor was effectively being denied the opportunity to work for
an indefinite period of time. That is a serious issue.
[24] Fourth, the Employer does not allege any prejudice as a result of the delay. In
the circumstances, and given the issues, any prejudice is unlikely.
[25] Lastly, the Employer argued that granting the extension to file the grievance is
effectively to read out sections 22.2 and 22.14.1 of the Collective Agreement. I
do not agree. When interpreting collective agreement provisions, meaning must
be found not only in the specific words used but also in the context of the
collective agreement as a whole and any applicable legislation. In this case, that
means that the sections relied on by the Employer must be read alongside Article
22.14.7 of the Collective Agreement and Section 48(16) of the Act. Therefore,
while they agreed to a thirty day time limit they did so in the context of provisions
(both in the Collective Agreement and the Act) that permit extensions to be
granted where an arbitrator is satisfied that there are reasonable grounds to do
so and the opposing party will not be substantially prejudiced. In the specific
circumstances of this case I am satisfied that there are reasonable grounds to
extend the time for the filing of this grievance. I am also satisfied that the
Employer will not be prejudiced as a result. Accordingly, the Ministry’s motion to
have this grievance dismissed on grounds of untimeliness is denied.
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B. Impermissible Expansion
(i) Position of the Ministry
[26] The Employer’s second preliminary motion is a request that this grievance be
dismissed because the position of the Union, as set out in particulars dated
October 4, 2023, constitutes an impermissible expansion of the grievance. The
Employer argued that the position being advanced by the Union in its particulars
is very different from what is laid out in the grievance. The Ministry requests that
all of the particulars be struck. The Employer argued that if this motion was
successful there would be nothing left in the particulars that could substantiate
the grievance. In the circumstances the grievance should therefore be
dismissed.
[27] The grievance states as follows:
I grieve specifically but not exclusively that the employer is in violation of
Articles 2, 3, 9, 21, 31 of the collective agreement, the Ontario Human
Rights Code (OHRC) and any other policies, Acts or legislation that may
apply when the employer failed to reassign me to other duties following
the Transport Canada policy restricting access to airports and aviation to
individuals vaccinated against covid-19, when the employer placed me on
indefinite unpaid leave which may result in constructive dismissal, and
when the employer prohibited me from discussing my unpaid leave with
other individuals.
[28] The Articles of the Collective Agreement referred to in the grievance are the
following:
• Article 2 – Management Rights
• Article 3 – No Discrimination/Employment Equity
• Article 9 – Health and Safety and Video Display Terminals
• Article 21 – Discipline and Dismissal; and
• Article 31 – Fixed-Term Employees
[29] The Ministry compared the issues raised in the grievance with those raised in the
Union’s particulars. In summary, the Ministry argues that the particulars raise a
new set of issues that are not present in the grievance, in that they focus
exclusively on the Federal Transportation Orders (the “Orders”), in particular IO
43 (and subsequent iterations) in support of the Union’s assertion that had IO 43
been applied correctly, the grievor should have been allowed to fly during the
period he was placed on an unpaid leave.
[30] According to the Ministry, none of the issues raised by the Union in the
particulars are found in the grievance or were raised with the Employer prior to
being set out in the particulars. Nor were they raised by the Union during the
Formal Resolution Meeting on February 22, 2022. The Employer emphasized
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that at no time during that meeting did the Union raise any issue with respect to
how the Ministry was applying IO 43 to the grievor.
[31] In addition, the Ministry notes that the grievor has been aware of the Employer’s
position, that the grievor was unable to carry out his duties because he was not
in compliance with IO 43, since at least November 12, 2021. The Ministry relied
on an email from the Ministry to the grievor dated November 22, 2021 in support
of its position. In that email, Mr. Rizzuto on behalf of the Ministry, referred both
to a memo provided to the grievor on November 12, 2021, and a conversation
with the grievor on November 15, 2021. According to the November 22, 2021
email, the grievor was advised, in both the memo and the conversation, that
pursuant to IO 43 he had to be fully vaccinated in order to access aerodrome
property and that anyone who had not received at least one vaccine by
November 15, 2021 would be placed on an unpaid leave of absence.
Notwithstanding being aware of the Employer’s position since that time, the
grievor did not raise any issues with respect to the application of IO 43 until
October 4, 2023, approximately two years later.
[32] The Employer relied on the decision in Ontario Public Service Employees Union
(Lefkowitz) and Ontario (Ministry of Community Safety and Correctional
Services), GSB #2010-2380 (Briggs). In that decision, the Board refused to allow
the Union to expand the scope of the grievance before it. In that case, the
grievor asserted that she had been verbally assaulted by a manager and a
member of public. The grievor also alleged that the employer had failed to
protect her and violated her rights under Bill 168. In the union’s particulars prior
to the hearing, the grievor sought to include reference to gender as a contributing
factor and to a poisoned work environment. The union also sought to include
allegations with respect to the Human Rights Code and Article 3 of the Collective
Agreement. Arbitrator Briggs held that in light of the failure of the union to make
reference to either the Human Rights Code or Article 3 of the Collective
Agreement in the actual grievance, and given that other statutes and provisions
of the Collective Agreement were specifically referenced, it would amount to an
impermissible expansion of the grievance to allow the union to proceed with
those new allegations. The Ministry argued that I should reach the same
conclusion in this matter.
[33] The Ministry also relied on the decision in Ontario Public Service Employees
Union (Boudarga) and Ontario (Ministry of Government and Consumer Services),
GSB # 2018-1811 (McLean). The decision reviewed the Board’s practice when
determining whether a grievance has been improperly expanded and quoted
from the decision in Ontario Public Service Employees Union (Louis) and Ontario
(Training, Colleges and Universities), 2019 CanLII 78767 (ON GSB) (Gee) where
the Board held:
[9] An arbitrator’s jurisdiction is limited to determining the issues that are
raised by the grievance. Issues raised in a grievance are referred to as “in-
scope.” The Union cannot add additional issues to the grievance that has
been filed. Where there is an attempt to add issues to a grievance, it is
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said that the Union is attempting to “expand the scope of the grievance”;
the Union is attempting to add “out of scope” issues to the grievance.
[10] When an issue as to whether the Union is attempting to expand the
scope of the grievance arises, it must be determined whether or not the
issue in dispute falls within the scope of the grievance as referred to
arbitration. The leading case in this area is Re Blouin Drywall Contractors
Ltd. And Carpenters Local 2486, (1975) 1975 CanLII 707 (ON CA). The
following summary of the principles to be applied when determining the
scope of a grievance is contained in Re Greater Sudbury Hydro Plus Inc.
(2003) 121 L.A.C. (4th) 193 (Dissanayake):
14. I find two countervailing principles in the foregoing statement by
the Court of Appeal. The first is that, where on a liberal reading of
the grievance an issue, although not articulated well, is inherent
within it, an arbitrator ought to take jurisdiction over that issue,
despite any flaws in form or articulation. However, there is also a
countervailing principle to the effect that an arbitrator ought not, in
the guise of “liberal reading”, permit a party to raise at arbitration an
issue which was not in any manner, even inherently, joined in the
grievance filed. To do that would be to defeat the very purpose of
the grievance and arbitration procedure.
[11] This Board in Re Labanowicz 2012-3224 etc. (Lynk) decision dated
September 12, 2014, referred to the Greater Sudbury Hydro Plus decision
(supra) and wrote at para. 22:
22. When faced with this issue, an arbitrator’s considerations would
include some or all of the following: (i) a review of the language of
the grievance, (ii) a review of the language of the collective
agreement; (iii) a consideration of any other admissible evidence
that would cast light on the parties’ understanding of the issues
raised by the grievance, such as the scope of the discussions and
exchanges during the grievance process; (iv) a review of the
remedy sought; (v) an assessment of the time frame involved; and
(vi) the degree of prejudice, if any, suffered by the employer. One
useful indicator is to ask whether the other party reasonably should
have understood upon reading the grievance and engaging in the
grievance process that the new claim in question was organically
part of the original grievance: Re Greater Sudbury Hydro Plus,
supra.
[34] Applying this approach to the instant grievance, the Ministry argued that the
issues raised in the particulars cannot be included in the grievance, as originally
filed, even if the grievance is given a liberal reading. According to the Ministry,
the issues raised in the Union’s particulars are not “in any manner, even
inherently, joined in the grievance filed”. Nor were they raised in the First
Resolution Meeting in February 2022.
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[35] The Ministry also noted that in Boudarga, the Board declined to allow the Union
to expand the grievance. It held that a “liberal reading” does not allow a party to
change the grounds of the grievance “when deliberate choices were made” about
what the grievance is about when it was first drafted and filed. Again, the
Ministry argued that I should reach the same conclusion.
[36] The next decision relied on by the Ministry was the decision in Ontario Public
Service Employees Union (Botosh) and Ontario (Ministry of the Attorney
General), GSB # 2014-1088, 2014-1089, 2014-1238 (Abramsky). In that
decision, the Board set out many of the same principles as those set out in
Boudarga. Applying those principles to the grievances before it, the Board
concluded that the Union had included particulars that impermissibly expanded
the grievance and ordered that those particulars be struck.
[37] The last case relied on by the Ministry for the purposes of this motion is the
decision in Ontario Public Service Employees Union (Hagopian) and Ontario
(Ministry of Finance), GSB# 2017-2476 (Gee). This decision also reviewed the
principles applied in determining whether a party is seeking to impermissibly
expand the grievance. In addition to reviewing the principles already set out
above, the Board noted that parties to a labour dispute should strive to work
towards a quick and simple resolution. In order for parties to resolve an issue,
they must both be aware of its scope. Failure to ensure that both parties are
aware of the scope of a grievance deprives the party that “is in the dark” from the
opportunity to resolve the matter prior to arbitration. The Board also noted that
allowing a party to expand the scope of grievance beyond what was referred to
arbitration effectively results in an arbitrator taking jurisdiction over a grievance in
respect of which they were not appointed.
(ii) Position of the Union
[38] The Union argued that the case law is clear on this issue. Grievances should be
construed liberally. They are drafted under time constraints by lay people.
Grievances should not be lost on technicality of form. Applied to the instant
grievance, the Union took the position that focussing only on the human rights
aspects of the grievance to the exclusion of the Union’s argument that the
Employer misapplied IO 43 would be an overly technical reading of the grievance
and contrary to the relevant case law.
[39] The Union relied on the decision of Arbitrator Burkett in Enbridge Gas
Distribution Inc. and C.E.P., Local 975, (2006) 150 L.A.C. (4th) 225 (Burkett),
where the Arbitrator distinguished between the claim, the legal arguments in
support of the claim, and the remedy that could flow if the claim was successful.
According to the Union, as long as the claims are properly raised in the grievance
then a party is entitled to bring forward full legal argument and full remedies in
support of that claim.
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[40] The Union argued that in this grievance the grievor is claiming that he should
have been permitted to continue working and that he should not have been
placed on an unpaid leave. That claim has not changed since the grievance was
filed. As such, according to the Union, there has been no expansion of the
grievance.
[41] The next case relied on by the Union was Canac Kitchens Ltd. and C.J.A., Local
1072, (1996) 58 L.A.C. (4th) 222 (Abramsky). In Canac Kitchens, the union filed
three grievances. All of the grievances related to allegations by the union that
the employer was failing to recognize the union as the employee’s designated
bargaining agent. At the hearing, the union sought to argue that its business
representatives were being denied the right to tour the plant in violation of the
collective agreement. The union acknowledged that none of the grievances
specifically made reference to a plant tour, however the union argued that
reference was not required because the “issue is encompassed in and flows
naturally from what is expressed in the grievances”. The union also noted that all
of the grievances raised questions about union access and that all of the
grievances referred to an article in the collective agreement that granted union
representatives, not employed by the employer, the right to meet with the Local
union Chief Steward in the plant, with prior permission from the employer.
[42] In reviewing the position of the union, Arbitrator Abramsky noted that the fact that
the grievances did not specifically mention the issue of a plant tour was not
determinative. The Arbitrator noted that the case law established that grievances
should be given broad and liberal readings so as to ensure that the real issue
between the parties is determined. The Arbitrator also held that grievances
should not be won or lost on the technicality of form.
[43] Ultimately, Arbitrator Abramsky concluded that the issue of union representatives
being denied the right to tour the plant did not “flow naturally” from the grievances
and therefore constituted an impermissible expansion of grounds. In reaching
this conclusion, the Arbitrator noted that the issue of plant tours was
substantively distinct from the broader issues raised in the grievances.
Notwithstanding this conclusion, the Union in the current case argued that I
should adopt the same approach as that endorsed by Arbitrator Abramsky in her
decision.
[44] The next decision relied on by the Union was the decision in DDM Plastics Co. v.
I.A.M. & A.W., Local 2792, 2008 CarswellOnt 4312 (Williamson). In that case,
the Union grieved that the Employer was having employees do “customer visits”
without regard to their seniority. As a preliminary matter, the Arbitrator had to
determine whether the grievance was limited to three employees named in the
resolution section of the grievance or, as argued by the union, whether the
grievance was a broad policy grievance.
[45] Arbitrator Williamson concluded that the grievance encompassed the union’s
broader policy claim. In reaching this conclusion, the Arbitrator noted that the
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grievance was drafted broadly and was not limited in scope to the three
individuals.
[46] Finally, the Union relied on the decision in North Bay General Hospital and
O.P.S.E.U., (2006) 154 L.A.C. (4th) 425 (Randall). In that case, the grievor, a
nurse working at a hospital during an influenza outbreak, was terminated for
failing to take a prescription drug that provided protection against the flu during
the two week interval while the flu shot was taking effect. During the course of
the hearing the union alleged that the employer’s health services department
violated the Occupational Health and Safety Act by notifying management that
the grievor had not taken the prescription drug as required and by participating in
the employer’s investigation into the grievor. In response, the hospital argued
that the union’s allegations constituted an expansion of the grievance.
[47] Arbitrator Randall allowed the union to raise the alleged breach of the grievor’s
medical privilege finding that it was encompassed or flowed naturally from the
assertion contained in her grievance that she was dismissed unjustly. Arbitrator
Randall also noted that the foundation for the union’s allegations came out of the
cross-examination of an employer’s witness underscoring that the factual basis
for the claim was the same as the factual basis for the grievance.
[48] The Union argued that were this matter proceeded to a hearing and management
witnesses testified that they were simply applying IO 43 when they placed the
grievor on unpaid leave, it would be open to the Union to challenge that basis for
the Employer’s decision. Accordingly, the Union argued it should be permitted to
raise that issue from the outset.
(iii) Analysis
[49] For the reasons set out below, I am satisfied that the particulars provided by the
Union do not amount to an impermissible expansion of the grievance.
[50] There is no dispute regarding the applicable principles. The question to be
asked is whether or not the “new allegations” flow naturally from, are
encompassed by, or are inherent to, the existing grievance or are they effectively
a new grievance. In answering this question, arbitrators have concluded that
grievances should be given a liberal reading and that grievances should not be
lost on technicality of form. That being said, while arbitrators should afford
grievances a liberal reading, arbitrators have also noted that even liberal
readings have limits.
[51] The tension between giving a grievance a liberal reading, and finding that an
allegation or issue falls outside the scope of the original grievance has been
addressed by a number of arbitrators. In Greater Sudbury Hydro Plus, supra,
Arbitrator Dissanayake held that to include an issue through a “liberal reading” an
arbitrator must be able to conclude that the “employer reasonably should have
understood” that the issue being raised formed part of the grievance. Arbitrator
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Dissanayake also held that parties should not be permitted to raise issues which
are not in any manner joined in the grievance and arbitration procedure.
[52] In North Bay General Hospital, supra, Arbitrator Randall commented:
Obviously, while the grievance should be construed liberally, the Union is
not allowed to argue a whole new matter, and certainly not one requiring
an entirely different factual foundation. ‘We can’t be left with’, in the words
of Arbitrator Goodfellow (see Cold Spring Farms Ltd. v. Cold Springs
Farms Employees’ Assn., Local 100 (2000) 88 LAC (4th) 213 (Ont. Arb.),
at 222)
an attempt by the Union to expand the original grievance to include
both legal and factual issues that were not raised previously and
that would, if allowed, support an independent breach of the
collective agreement and provide an entirely separate basis for
relief.
[53] Similarly, in Canac Kitchens Ltd., supra, Arbitrator Abramsky held that an issue
must be “encompassed in and flow naturally from what is expressed in the
grievance” and that the “corollary to that, of course, is that if an issue is a distinct,
substantively new issue that may not be reasonably viewed as encompassed in
and as flowing naturally from the grievance, and was never addressed during the
grievance process, it would not be arbitrable.”
[54] Whether or not an allegation forms an inherent part of the original grievance or is
a distinct issue requires an objective assessment. In answering the question,
arbitrators can look at a number of factors (although not all factors will
necessarily be relevant in each case). In Boudarga, after reviewing the case law,
Arbitrator McLean set out the following factors that may be relevant to this
question:
i. the wording of the grievance;
ii. the wording of the collective agreement;
iii. consideration of other evidence that would cast light on the parties
understanding of the issues raised by the grievance;
iv. the remedy sought;
v. the applicable time frame; and
vi. the degree of prejudice to ER.
[55] Applying those factors to the instant grievance, the following conclusions can be
drawn. First, both the grievance and the particulars challenge the decision to
place the grievor on an unpaid leave. Accordingly, they both address the same
specific event.
[56] While IO 43 is not specifically mentioned in the grievance, the grievance does
make reference to the management rights provision of the Collective Agreement,
and “any other policies, Acts or legislation that may apply when the employer
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failed to reassign” the grievor “following the Transport Canada policy restricting
access to airports and aviation against covid-19.”
[57] Second, the notes taken during the Formal Resolution Meeting make reference
to IO 43. At a minimum, the notes from that meeting support two conclusions.
First, that the Ministry told the Union and the grievor that it was required to follow
Transport Canada’s directions and that it believed those directions (in the form of
IO 43) required the grievor to be placed on an unpaid leave. Second, the notes
also establish that the grievor was challenging the decision to place him on an
unpaid leave. There was a connection being made between IO 43 and the
decision to place the grievor on an unpaid leave of absence. The Employer
advised the Union and the grievor that the Ministry was required to follow
Transport Canada’s directions and that because the grievor chose not to follow
those directions, he was no longer permitted to fly.
[58] Third, the time frame captured by the grievance and the particulars is the same.
Both deal with the period of time that the grievor was placed on an unpaid leave.
[59] Fourth, the remedy sought in the grievance and the particulars has not changed.
Throughout, the grievor seeks to be compensated for the time he was placed on
an unpaid leave.
[60] Having regard to these facts, I am satisfied that the particulars do not constitute
an impermissible expansion of the grievance. As set out in the case law above,
grievances are to be given a liberal reading. Where an issue can be said to flow
from, or be inherent to, the grievance as filed, an arbitrator will find that no
expansion of the grievance has taken place. That is the case before me.
[61] The decision to place the grievor on an unpaid leave is the central issue in both
the grievance and the particulars. IO 43 is at the center of the decision to place
the grievor on leave. The Employer said as much in its November 22, 2021
email to the grievor putting him on an unpaid leave. In that email, the Ministry
wrote:
Further to our discussion on November 15th, effective immediately you are
being placed on an unpaid leave of absence until further notice as you are
not in compliance with requirements under Transport Canada’s Interim
Order Respecting Requirements for Civil Aviation Due to COVID-19, No.
43 (“Interim Order”) or the Aviation Services Mandatory Vaccination
Policy.
[62] The Union’s claim that IO 43 has been misapplied flows from the claim in the
grievance that the Employer’s decision violates the Collective Agreement “any
other Act, policies or legislation.” There is reference to those external
considerations in the grievance form. As well, the management rights clause in
the Collective Agreement requires that the Employer’s decision to place the
grievor on unpaid leave be reasonable. Were the Employer to have misapplied
IO 43 or ‘any other Act, policy, or legislation’, its decision would be open to a
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finding that it was unreasonable. That a factor taken into account in decision-
making may be subject to challenge should not come as a surprise to any
employer.
[63] IO 43 was confirmed during the Formal Resolution Meeting as a significant part
of the part of the rationale for the Employer’s decision. Accordingly, the position
of the Union challenging the application of IO 43 to the grievor flows naturally
from the challenge to the decision to place the grievor on an unpaid leave.
[64] Finally, the time frame at issue and the remedy sought in both the grievance and
particulars further support for my conclusion that the applicability of IO 43 flows
naturally from the grievance. Both deal with the same time frames and both seek
the same remedy. For all of the foregoing reasons, I have concluded that the
particulars provided by the Union flow naturally from the grievance and therefore
do not constitute an impermissible expansion of the grievance.
[65] The position of the Ministry falls squarely within the caution issued by Arbitrator
Burkett in Enbridge Gas Distribution, supra. A party is not required to specify
within the grievance the legal arguments it intends to marshal in support of its
claim. From the outset, the Union and the grievor have challenged the decision
to place him on an unpaid leave. That claim is clearly set out in the grievance.
The particulars are now setting out in greater detail the legal argument in support
of that claim. It was not required to set those arguments out in the grievance.
C. No Prima Facie case
(i) Position of the Ministry
[66] The Ministry argues that the Union has not pleaded a prima facie violation of the
Collective Agreement. The Ministry submits that the Union should be held to the
five articles they alleged to have breached in the grievance: Articles 2, 3, 9, 21
and 31. They argue there is nothing in the particulars that could, even if
accepted as true and provable, constitute a violation of any of these Articles of
the Collective Agreement, except for Article 2 the management rights clause.
[67] With respect to Article 2, the Ministry submits that it cannot, in and of itself,
sustain a grievance. The Ministry submits that there must be a hook beyond
Article 2 and that in this case there is no such hook. According to the Ministry, at
its core the position of the Union is that the Employer’s interpretation of IO 43 is
not reasonable. In other words, the Union is arguing that the Ministry exercised
its management rights unreasonably.
[68] The Employer argues that some of the cases speak in terms of a failure to plead
a prima facie case while others speak to the Board not having jurisdiction where
no breach could be established. According to the Employer, there is no
meaningful distinction between the two approaches and that in any event, the
Board does not have jurisdiction in this case (because no prima facie case has
been pleaded). The Ministry relied on the following decisions in support of its
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position: Ontario Public Service Employees Union (Kolmann) and Ontario (The
Ministry of Community Safety and Correctional Services), GSB # 2016-0562;
2016-0566 (Abramsky); Ontario Public Service Employees Union (Brown et al)
and Ontario (Ministry of Labour, Training and Skills Development), (GSB #2018-
2461 et al) (Gee); and International Brotherhood of Electrical Workers (System
Council No. 11) and Canadian National Railway Company, 2023 CanLII 44118
(CA LA) (Clarke).
(ii) Position of the Union
[69] The Union argues that the decision to place the grievor on an unpaid leave
breaches any number of Articles in the Collective Agreement. According to the
Union, where any right under the Collective Agreement is unduly limited, negated
or abrogated, as is the case here with the decision to place the grievor on an
unpaid leave, the Board has jurisdiction.
[70] The Union argues that the grievor’s rights under the Collective Agreement were
affected in any number of ways. For example, the grievor was unable to use his
sick leave, or accrue vacation, or access entitlements to holidays. The grievor
also lost the ability to earn shift premiums, work overtime, be paid meal
allowances, or receive holiday payments. Accordingly, the decision to place the
grievor on an unpaid leave, and more importantly the grievance challenging that
decision, establish a variety of prima facie violations of the Collective Agreement.
[71] The Union relies on the following decisions in support of its position: Ontario
Public Service Employees Union (Couture et al) and Ontario (Ministry of
Government Services), 2011 CanLII 100933 (ON GSB) (Dissanayake); Ontario
Public Service Employees Union (Gauntlett) and Ontario (Ministry of Finance),
2008 CanLII 70504 (ON GSB) (Gray); Ontario Public Service Employees Union
(Union) and Ontario (The Ministry of Community Safety and Correctional
Services/ Ministry of Children and Youth Services), 2010 CanLII 42118 (ON
GSB) (Harris); Ontario Public Service Employees Union (Dufour et al) and
Ontario (The Ministry of Community and Social Services), 2013 CanLII 18486
(ON GSB) (Briggs)and; Ontario Public Service Employees Union (Cote et al) and
Ontario (Ministry of Natural Resources and Forestry), 2020 CanLII 63603 (ON
GSB) (Wacyk).
(iii) Analysis
[72] I am satisfied that I have the jurisdiction to hear this grievance. Put differently, I
am satisfied that the Union has pleaded a prima facie case.
[73] This issue can be dealt with quite briefly. The Employer placed the grievor on an
unpaid leave of absence. Neither the grievor nor the Union agreed to this
decision. As an employee, the grievor is entitled to work and to enjoy the
benefits of the Collective Agreement subject to any restrictions specifically
imposed by that Collective Agreement or restrictions imposed by Employer
policies. Employer policies must be reasonable and reasonably applied. The
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grievor was prohibited from working due to the Employer’s application of a policy
adopted. The question of whether or not that decision was justified gives rise to
a justiciable issue and is one to be determined on its merits.
[74] The Union is correct when it argues that the decision to place the Grievor on an
unpaid leave adversely affects any number of rights under the Collective
Agreement. As set out in Arbitrator Harris’ decision in Ontario Public Service
Employees Union (Union), supra, where there is an allegation that the employer’s
exercise of management rights has adversely impacted an employee’s rights
under the Collective Agreement, an arbitrator will have jurisdiction to hear that
allegation.
[75] The position of the Employer must be rejected, at least in part, because it takes
an overly restrictive view of the grievance. In the same way that the Employer
took a narrow view of the grievance when it argued that the Union was seeking to
expand the grievance, the Employer takes a similarly narrow view of the
grievance in arguing that the Union has not pleaded a prima facie violation of the
Act. It is the Employer’s decision to place the grievor on unpaid leave that forms
the basis of the grievance. The fact that the grievor was put on an unpaid leave
pursuant to an alleged improper or unreasonable decision of the Employer is
sufficient to establish a prima facie case.
[76] Accordingly, I am satisfied that the Union has pleaded a prima facie case of the
Collective Agreement and I have jurisdiction to hear that grievance.
[77] The parties are to contact the Board to schedule hearing dates.
[78] I am seized.
Dated at Toronto, Ontario this 22nd day of February 2024.
“Adam Beatty”
_________________________
Adam Beatty, Arbitrator