HomeMy WebLinkAbout2011-0378.Chapman et al.12-01-24 DecisionCrown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Fax (416) 326-1396
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
Téléc. : (416) 326-1396
GSB#2011-0378, 2011-0381, 2011-0382, 2011-0383, 2011-0385, 2011-0386, 2011-0387
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association of Management, Administrative and
Professional Crown Employees of Ontario
(Chapman et al) Association
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The Crown in Right of Ontario
(Ministry of Government Services) Employer
BEFORE Nimal Dissanayake Vice-Chair
FOR THE UNION Michael Mitchell
Sack Goldblatt Mitchell
Barristers and Solicitors
FOR THE EMPLOYER Paul Meier
Ministry of Government Services
Labour Practice Group
Counsel
REPRESENTATIVE
FOR INTERVENING
THIRD PARTY
Richard Novak
HEARING January 12, 2012.
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Decision
[1] The Board is seized with seven individual complaints, which were consolidated on
agreement. The grievances are:
GSB File No: Complainant
2011-0378 Mary Chapman
2011-3081 Catherine Hermon
2011-3082 Lain Joyce
2011-3083 Scott Margerison
2011-3085 Claudio Pevide
2011-3086 Judy Steenburggen
2011-3087 Yull Winter
[2] The complaints arise out of the following background which was orally presented by
Association counsel at the hearing on November 25, 2011. The complainants were
employed in the position of Facilities Management Coordinator (“FMC”) in the
Ministry’s Facilities Management Branch. These FMC positions were classified at the 19
AGA level. As part of a reorganization undertaken by the employer, all 19 AGA/FMC
positions were eliminated, resulting in the surplussing of the seven complainants. The
employer also created six new Regional Planning & Business Advisor (“RPBA”)
positions classified at the 20 AGA level. Three of the complainants were placed into
other positions following their surplussing, and the others used their seniority to bump
into other positions. Two of the complainants who bumped into other positions were
subsequently surplussed again from those positions. The employer posted the six new
RPBA positions under the collective agreement. While many of the complainants
applied, only one, Ms. Chapman, was granted an interview. Ms. Chapman was
unsuccessful in the competition and has grieved. That competition grievance filed by
Ms. Chapman is not before me in this proceeding.
[3] In an earlier decision dated December 6, 2011 in this matter, the Board set out in some
detail the various alternate positions advanced by the Association in support of the instant
complaints. For the present purposes, it suffices to note that the Association’s primary
position was to the effect that the employer’s actions were taken in bad faith and not in
pursuance of any legitimate business objectives. This decision relates to one of the
alternate positions advanced by the Association, which was described in the previous
decision at para. 4 as follows:
In the alternative, the Association takes the position that even if the
employer’s decision was not tainted by bad faith, the core duties of
the FMC positions the complainants held and the new RPBA
positions remained substantially the same after the purported
reorganization. The Association asserts that it was therefore
inappropriate for the employer to post the RPBA positions. It
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submits that the complainants ought to have been assigned to the
new positions without a competition and reclassified at AGA 20.
MOTION OBJECTING TO JURISDICTION
[4] When the Board reconvened on January 12, 2012, the employer made a motion to the
effect that the Board lacked jurisdiction to determine the foregoing alternative position.
[5] It is noted that on January 12, 2012, the seven intervening third parties were present
pursuant to notice provided by the Employer. Association Counsel advised that while no
objection would be made to their participation at the present, the Association reserves the
right to so object at future hearings in this matter. Therefore, the third parties
(individuals who were appointed to the RPBA positions) were granted the right, and did
participate, with Mr. Novak acting as spokesperson.
[6] The following provisions of the collective agreement are material to the positions
advanced by the parties:
3.1 Subject only to the provisions of this Agreement, the right and authority to
manage the business and direct the workforce, including the right to hire and lay-
off, appoint, assign and direct employees; evaluate and classify positions;
discipline, dismiss or suspend employees for just cause; determine organization,
staffing levels, work methods, the location of the workplace, the kinds and
locations of equipment, the merit system, training and development, appraisal; and
make reasonable rules and regulations; shall be vested exclusively in the
Employer.
18.1 When a vacancy occurs in the Regular Service for a bargaining unit position or a
new regular position is created in the bargaining unit, it shall be advertised for at
least ten (10) working days prior to the established closing date. Where
practicable, notices of vacancies shall be posted, within the identified area of
search, either electronically or on bulletin boards.
Exceptions from the Requirements to the Posting and Filling of Positions
18.8.1 Vacancies may be filled without competition upon clearing surplus under the
following circumstances:
…
(g) a newly reclassified position shall not be considered a vacancy for the purposes of
Article 18.1 and the current incumbent shall retain the position. For clarity,
surplus clearance is not required or permitted in any such reclassification;
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[7] The employer’s primary position in support of its motion is to the effect that under
Article 3.1 the employer has the right to reorganize its workforce and to create new
positions and assign classifications to them, as it did here. It was argued, citing Re:
Bousquet, 541/90 (Gorsky), that the Board may review the employer’s exercise of
management rights only in two circumstances. First, where it is alleged that the exercise
of management rights was done in bad faith, and second, where the exercise of the
management right results in unduly limiting or negating a right conferred by the
collective agreement. Counsel noted that the Association has alleged that the employer
had exercised its management right to eliminate positions, to declare the incumbents of
those positions surplus, and to create new positions, in bad faith with the motive of
“cleaning house”. He conceded that the Board has authority to inquire into that
allegation.
[8] However, the Association’s alternate position under consideration here is on the
assumption that the employer had acted in good faith. In the absence of bad faith,
submits counsel, the Association must satisfy the Board that a right conferred on the
complainants by the collective agreement was unduly limited or negated by the
employer’s actions. It was the employer’s contention that no collective agreement right
of the complainants had been so affected in the circumstances of this case, and that the
Board therefore was without jurisdiction to review the employer’s exercise of
management rights.
[9] Counsel referred to several provisions of the collective agreement, which either imposed
obligations on the employer to provide notice/information to the Association when
eliminating positions or creating new positions. Other provisions dealt with the
consequences of such employer action. Counsel submitted that these provisions do not in
any way fetter the employer’s right under Article 3.1 to eliminate or create positions.
[10] Counsel submitted that Article 18.8.1.(g) does not assist the Association’s case, because
it only applies where an existing position is “newly reclassified”. In those circumstances
the employer is not entitled to post the newly reclassified position. Article 18.8.1.(g)
explicitly provides that in those circumstances, “the current incumbent shall retain the
position”. That provision, however, has no application here, submits counsel, because
what occurred here was not a reclassification of the existing FMC positions. Rather, the
FMC positions were eliminated. New RPBA positions were created, the duties evaluated
and an appropriate classification assigned. Therefore, no exception from the requirement
to post applied. As counsel put it, the complainants were not entitled to “competition
immunity” under Article 18.8.1.(g). On the contrary Article 18.1 clearly requires that
newly created positions be posted.
[11] Employer counsel submitted further that the Board should in any event decline
jurisdiction because the instant complaints were in fact “disguised classification
grievances”. Counsel reminded the Board that its right to determine the appropriateness
of classifications was taken away by explicit legislative amendment. Counsel pointed out
the Association’s position noted at para. 4 (supra) of the Board’s previous decision that
“the complainants ought to have been assigned to the new positions without a
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competition and reclassified at AGA 20” (emphasis added) and that one of the remedies
sought in each complaint is to the effect “Reclassify to the position of Regional Program
and Business Advisor, 20 AGA”.
[12] Association Counsel submitted that the complainants sought reclassification at the 20
AGA level only because that was the classification assigned by the employer to the
RPBA positions, which they claim are substantially the same as the FMC positions they
had held. Counsel conceded that it was not the complainants’ goal to be classified higher
or to increase their pay. They are merely seeking reinstatement to their positions now
occupied by others, regardless of the classification the employer may choose to attach to
those positions. Counsel stated that the complainants do not care whether the positions
are classified at AGA 19 or AGA 20, as long as they get their jobs back.
[13] The Board concludes that in light of the Association’s clarification of its position on the
classification to be assigned to the positions at issue, the “disguised classification
grievances” theory cannot prevail. See, Re: Dobroff et al, 2003-0905 (Dissanayake),
decision dated January 31, 2005.
[14] The remaining issue, therefore, is whether in the circumstances of this case, the Board
has jurisdiction to review the employer’s actions on the basis that it unduly limits or
negates a collective agreement right of complainants. As employer counsel correctly
pointed out, the only provision the Association pointed to in this regard is Article
18.8.1(g). The employer has taken the position that for these complainants, Article
18.8.1(g) does not provide the necessary link or hook to the collective agreement, so as to
bestow jurisdiction on the Board to embark on the inquiry. That argument is premised on
its position that Article 18.8.1(g) has application only in cases of existing positions being
newly reclassified, and not in cases where positions are newly created. It is submitted
that what occurred here was not the reclassification of the FMC positions. Instead, new
RPBA positions were created and an appropriate classification was assigned to it. In
those circumstances, Article 18.8.1(g) has no application.
[15] There is no question that Article 18.8.1(g) has no application to positions newly created.
However, there is a clear dispute between the parties whether or not the RPBA positions
are in fact new positions, or whether they are substantially the same as the former FMC
positions, albeit differently titled and classified. Is the fact that the employer asserts that
the RPBA positions were “newly created” determinative? The answer is “no”.
Particularly in the circumstances of this case where potentially the employment of seven
individuals is at stake, it is not reasonable or appropriate for the Board to accept that the
positions in question are newly created positions merely because the employer treats
them as such. A central position advanced by the Association is to the effect that the
RPBA positions are not new positions, but substantially the same FMC positions, retitled
and classified differently. Whether or not the exception to the posting requirement in
Article 18.8.1(g) applies depends on whether on an objective view of the facts the RPBA
positions are newly created positions as the employer asserts, or whether they are the
same as the FMC positions, as the Association submits. While the employer clearly has
the right to eliminate positions and replace them with new positions, whether it has
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actually done so must be based on a reasonable view of the objective facts. A position
cannot be accepted as “new” merely because the employer elects to call it as such, and
may even honestly believe it to be so. The Association has taken the position that the two
positions, based on the duties and responsibilities of the incumbents, are substantially the
same, and that what occurred was a mere change of title and classification. If the
employer is correct that the RPBA positions are newly created based on the objective
facts, Article 18.8.1(g) would have no application and the Board would be without
jurisdiction. However, if the Association is able to satisfy the Board that the RPBA
positions, although treated by the Employer as newly created, are in fact substantially the
same as the FMC positions held by the complainants, it would be able to rely on Article
18.8.1(g) to argue that what in fact occurred was a reclassification of the existing FMC
positions, and that therefore the complainants, as the incumbents, are entitled to retain
their positions.
[16] In summary, in order to uphold the motion, the Board would be required to accept the
employer’s position that the RPBA positions are newly created positions merely because
the employer believes them to be so. The Board would then have to deny the Association
the opportunity to demonstrate that based on a reasonable view of the objective facts, the
positions are in fact substantially the same, although differently titled and classified.
[17] Having considered the submissions of the parties, the Board concludes that it is faced
with a situation where the entitlement of the complainants to an exception from the
requirement to compete depends on an issue over which the parties have clearly joined
issue. In the Board’s view, it is not appropriate to accept the positions as new, merely
because the employer asserts and believes them to be so. The Association must be
afforded the opportunity as it seeks to do, to establish, that when the facts are viewed
objectively and reasonably what in fact occurred was a mere retitling of the FMC
positions the complainants held, and that the complainants are therefore entitled to the
benefit of Article 18.8.1 (g). The fact that this may entail a comparison of the duties and
responsibilities of the two positions, in the same manner as would occur in determination
of a classification grievance, does not deprive the Board of jurisdiction. The Board is
entitled to make the inquiry necessary to determine whether or not the complainants have
the right they assert under Article 18.8.1(g).
[18] It follows from the foregoing that the employer’s motion fails and is hereby denied.
REQUEST FOR PRE-HEARING PRODUCTION ORDER
[19] Also dealt with at the hearing on January 12, 2010 was a request by the Association for
an order for production which was opposed by the Employer and the interveners. The
request was for the production of:
(a) All work related e-mails including attachments, sent and received by each person who
performed in the RPBA position, including those who may have acted in the position.
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(b) All work related calendars of persons referred to in (a) above, meaning documents
that show their work schedules, meetings and appointments.
[20] The Association sought the production of the above described material for the period
commencing the date of the first appointment to the RPBA position up to October 31,
2011. Noting that the next scheduled hearing date was April 5, 2012, counsel for the
Association requested that the Employer be ordered to complete the production no later
than February 15, 2012. Counsel argued that at least that period of time was necessary
for the Association to review the material produced in preparation for the April 5, 2012
hearing.
[21] Counsel for the Employer submitted that while the Board has discretion under s.
48(12)(b) of the Labour Relations Act to order pre-hearing production, the Board must
balance the competing interests of the parties in exercising that discretion. Reference was
made to para. 7 of the recent decision of the Board in Re: Bokhari, 2010-2873, 2010-
2933 (Dissanayake), where the Board stated that it must balance the potential prejudice to
the responding party if production is ordered on the one hand, and the probative value
and need for the requesting party to have access to the material in order to be able to
adequately present its case, on the other.
[22] Counsel submitted that the requested material is at best of marginal probative value. On
the other hand, the requested order, if granted, would potentially be highly prejudicial to
the Employer as well as the incumbents. There could be confidential information such as
business information, information relating to bids and court floor plans and even labour
relations information. The employer would have to sort through material covering six
employees over a period in excess of six months to identify personal and confidential
information. That would require significant effort involving much time and costs.
[23] Counsel submitted that the stated purpose for requesting the production is to establish
what work the incumbents of the RPBA positions actually performed. It was argued that
it was open for the Association to establish those facts by calling the incumbents to
testify.
[24] Counsel relied on the following observation in Re: Koonings, 2003-31-1 (Gray) at para.
26:
An allegation of “bad faith” or the like by a union would be
made in relation to management’s having taken or failed to take
some particular action for legally improper motives. Before
production of documents could be sensibly addressed in such a
case, either by the employer or by an arbitrator, particulars of the
acts or omissions complained of would be needed, from which it
would become apparent which individual’s (or individuals’)
motivation was in issue and during what time frame. It is not at
all obvious that allegations of bad faith and the like of necessity
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make an obligation to produce arguably relevant documents
limitless. In addition, it is hardly an objection to the doing of
justice that its requirements may be burdensome.
The Board was advised that while the Association had undertaken to provide particulars
of its bad faith allegation, it had not done so to date. It was argued that in the
circumstances the requested order should be denied.
[25] The employer further argued that the Board should also consider the fact that all of the
material requested post-date the employer’s decisions, which the Association claims to be
tainted by bad faith. That material, therefore, could not possibly be relevant to the
Employer’s motivation at the time the decisions were made.
[26] Counsel in the alternative submitted that if the Board was inclined to grant the order for
production, its scope should be more reasonable than that requested. Counsel suggested
that the order should be limited to the period from September 1 to October 31, 2011.
That, according to counsel, would be a more reasonable balancing of the interests of the
parties.
[27] Counsel also submitted that considering the volume of work that may be required, it was
not feasible to complete production by February 15, 2012, even if the Board’s order is
issued as early as January 20, 2012. Counsel suggested a time line of March 15, noting
that the Association still would have approximately 3 weeks to review the material prior
to the next scheduled hearing date.
[28] Arbitrators have recognized that labour relations policy considerations favour liberal pre-
hearing disclosure. Thus in Re: West Park Hospital, (1993) 37 L.A.C. (4th) (Knopf) 160
at p. 167 in reaching that conclusion the arbitrator wrote:
In coming to the conclusion, several factors have been taken into
account. Let us start with the principle that labour arbitration is
effective in providing a speedy and efficient resolution for the
parties of important issues in a forum they can control and which
they have designed. Boards of arbitration exist to assist the parties.
The decision evolves from the concepts which are intended to
foster fairness, harmony and sensible labour relations. Anything
which can assist in the preparation of cases, the refining of issues
or which will facilitate settlement should be encouraged. As a
general proposition, pre-hearing disclosure will assist with all these
matters and should occur wherever possible. Indeed, parties do as
a matter of course provide pre-hearing disclosure to each other for
these very reasons.
[29] This Board in Re: Koonings, (supra) at para. 14-15 wrote as follows:
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[14] Subsection 48(12) of the LRA does not oblige parties to
make pre-hearing disclosure of documents in the absence of an
order, as parties to civil litigation are obliged to do as a matter of
course under the rules of civil procedure. In that respect employer
counsel is correct that there is no equivalent of that obligation in
labour arbitration proceedings. I do not agree, however, that an
arbitrator’s imposing such an obligation, at an appropriate stage
and in an appropriate manner, is somehow inimical to the purposes
of labour arbitration or to the interests of good labour relations
generally.
[15] Good labour relations require that the process for
resolving rights disputes at arbitration be both expeditious and fair.
Full pre-hearing disclosure of all arguably relevant documents
advances that interest. In that regard I adopt the observations of
arbitrator Germaine in British Columbia v. British Columbia
Government Service Employees’ Union, [2003] B.C.C.A.A.A. No.
150 at paragraph 48:
48 Prehearing production of relevant documents is consistent with
the right of parties to a fair hearing and the process values of
expedition and cost saving: Pacific Press Limited and the
Newspaper Guild, Vancouver-New Westminister Guild, Local 115,
(1983) 2 CLRBR (NS) 277 (BCLRB Decision No. 109/83).
Fairness is advanced by assisting the parties to know and prepare
for the case they must meet, and by avoiding surprise at the
hearing. Expedition and economy are served by minimizing the
adjournments necessitated by unanticipated evidence at the hearing.
These considerations, combined with the absence of any structured
procedure in labour arbitration, recently persuaded a prominent
arbitrator to take “a liberal view…with respect to the production of
documents”: Toronto District School Board and CUPE, Local
4400 (2002), 109 LAC (4th) 20 (Shime), at page 31. The same
considerations have been recognized specifically in relation to pre-
hearing production of medical documents containing personal and
private information: West Park Hospital and ONA (1993), 37 LAC
(4th) 160 (Knopf, at page 167; Stelco and U.S.W.A., Local 1005
(1994), 42, L.A.C. (4th) 270 (Dissanayake), at page 274.
That fairness favours full production is underscored by the decision
of the Court of Appeal in Ontario (Liquor Control Board) v. Lifford
Wine Agencies, supra, which held that the AGCO’s failure to
compel production of documents at the request of a party to the
proceedings (in that case by refusing to issue or enforce a summons
duces tecum to a third party) amounted to a denial of justice.
[30] However, these policy considerations have not led arbitrators to order any and all
production requested by a party. Certain criteria have been developed in the
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jurisprudence that are considered in the exercise of the discretion to order production.
These are summarized in the often cited passage in Re: West Park Hospital, (supra) at p.
167 as follows:
However, where the disclosure is contested, the following factors
should be taken into consideration. First, the information requested
must be arguably relevant. Second, the requested information must
be particularized so there is no dispute as to what is desired. Third,
the board of arbitration should be satisfied that the information is
not being requested as a “fishing expedition”. Fourth, there must
be a clear nexus between the information being requested and the
positions in dispute at the hearing. Further, the board should be
satisfied that the disclosure will not cause undue prejudice.
While pre-hearing production of documents may lead to a certain
amount of “discovery”, that should not deter arbitrators from
ordering production of documents that are arguably relevant to the
matters in dispute. Re Mallenhauer LTD. (1987) O.L.R.B. Rep.
Sept. 1156, at 1159 and Re F.W. Fearman Co., (1990) 15 L.A.C.
(4th) 294 (Marcotte).
[31] In relation to the fourth criterion set out in Re West Park Hospital (supra), I agree with
the observation by Vice-Chair Gray in Re: Koonings (supra) at para. 19 that the “clear
nexus” test does not add anything to the “arguably relevant” test. In the instant matter,
the Association has advanced three arguments in support of the complaints (see the Board
decision dated December 6, 2011), only one of which is based on an allegation of bad
faith on the part of the Employer. It is very clear that central to all of the arguments of
the Association is its assertion that the FMC position which the complainants had held
and from which they were surplussed, and the RPBA positions which the Employer
claims to be newly created, were in fact substantially the same. The Employer did not
dispute that the material sought would tend to disclose the actual duties performed by the
RPBA incumbents. Its position was that the production requested was too cumbersome
and expansive and that the Association could obtain the same information by calling the
RPBA incumbents to testify.
[32] The Board is convinced that the production sought is arguably relevant to a central issue
in this proceeding, namely, whether or not the RPBA positions are new positions. The
issue for the Board to determine is whether there are countervailing considerations which
should cause it to deny the production of this arguably relevant information.
[33] The fact that the Association has not particularized its bad faith allegations in the Board’s
view is irrelevant. In Re Koonings (supra), at para. 28, the Board wrote:
Although I do not accept that particularization by the requesting
party is a prerequisite to production independent of the implications
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of the “arguably relevant” test, I do agree that when framing an
obligation to produce documents other than those relied upon by
the producing party it is desirable that the scope of the obligation
be made as clear as possible.
There is no suggestion that the scope of the production requested in
the present case is not sufficiently clear. The particulars which are
missing presently have to do with the “who”, “what” and “when”
of acts or omissions the Association asserts, that would amount to
bad faith. It has nothing to do with the relevance of the disclosure
to the factual assertion by the Association that the two positions are
substantially the same. The absence of particulars relating to the
bad faith allegation does not preclude or even hinder the
determination of whether the production requested is arguably
relevant to the Association’s “same position” theory.
[34] In the Board’s opinion, the ability of the Association to call the RPBA incumbents to
testify about their duties and responsibilities is not a reasonable alternative so as to cause
the Board to deny production which is otherwise arguably relevant. This is more so in
the present case, where the RPBA incumbents have clearly placed themselves in a
position adverse to the interest advanced by the Association, and where success of the
Association’s complaints may potentially impact adversely on them.
[35] The potential prejudice that may result to the responding party is a valid consideration in
the exercise of the Board’s discretion under s. 48 (12)(b) of the Labour Relations Act.
One potential prejudice asserted by the Employer is the concern that the material sought
by the Association may contain confidential information. While the Board has
recognized the importance of protecting confidential information that may be contained
in the material sought, it has not denied production on that basis alone. In Re Koonings
(supra) at para. 16, the Board wrote:
In that regard I remain of the view that any party who seeks an
order for pre-hearing production impliedly undertakes not to
make use of the information thus obtained except for the purposes
of the proceeding in which the order was made: Re Thermal
Ceramics, Division of Morganite Canada Corp. and United
Steelworkers (1993), 32 L.A.C. (4th) 375 (Gray) at p.383. If in
any case there is any doubt that such an undertaking is implied,
then that limitation should be made express in the order for
production.
[36] In the present case there is no necessity to imply an undertaking. Counsel for the
Association explicitly not only made that undertaking, but also agreed that if the
Employer so wishes, it could redact any confidential information contained in the
material produced. Given that undertaking, the mere possibility that the material sought
may contain confidential information is not a basis to deny production.
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[37] In Re Bokhari, (supra), the Board was faced with a similar objection to production of
arguably relevant material on the basis, inter alia, of confidentiality and privilege. At
para. 9 the Board wrote:
I find that the material listed in the Association’s request for
disclosure, (item 9 having been withdrawn) is arguably
relevant to the issues raised in the grievances. If the employer
objects to the disclosure of a particular document on specific
grounds, it may be raised. Then the Board would be required
to engage in the balancing exercise – for example the relative
value of the material to the Association in preparing its case
compared to the effort and cost to the employer – or to decide
upon any legal impediment to the production of the material in
question such as privilege or confidentiality. Employer
counsel asserted that compliance with the Association’s
request may result in disclosure of privileged documents. If
and when an objection is made to the disclosure of a particular
document or documents, the Board would be required to
decide whether those documents ought to be disclosed, and if
so, whether such disclosure should be made subject to
conditions. In the absence of objection to any specific
documents, and having regard to my finding that the material
requested is arguably relevant to the issues raised by the
grievances, the employer is hereby ordered to comply with the
Association’s request for disclosure.
That, in the Board’s view, is the appropriate approach where there is concern that the
material subject to production may include sensitive or confidential information. It is not
appropriate to altogether deny production of otherwise arguably relevant material, merely
because of the possibility that the material sought may include confidential or privileged
information.
[38] Mr. Novak, on behalf of the intervening third parties, additionally submitted that the
requested production order should be denied because it amounts to a “fishing expedition”
on the part of the Association. In Re Koonings, (supra) at para. 20, the Board described
a “fishing expedition” in the context of a production request as follows:
A “fishing expedition” is said to be an endeavour “not to obtain
evidence to support [a] case, but to discover whether [one] has a
case at all”: Canada Post, supra, at 57 L.A.C. (3d) 159. If one
can have production only of documents arguably relevant to
allegations of fact already put in issue in the case at hand, it follows
that there cannot be production in aid of discovering a case not
already asserted.
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[39] In the present case the Association’s production request cannot be reasonably seen as
fitting that description. It has clearly made an assertion as a central part of its case that
the former FMC positions and the new RPBA positions are in fact substantially the same.
The production is sought to support that assertion already made.
[40] For the foregoing reason, the Board concludes that the material sought is arguably
relevant to an issue between the parties, and as such, production ought to be ordered.
[41] That leaves for consideration the Employer’s alternate submissions with respect to the
scope of the production and the timing of production. In determining the appropriate
scope of production, the Board must balance the effort and costs that may be incurred by
the Employer, and the importance of the material to the Association in supporting its
case, keeping in mind that the complaints are about the potential loss of employment of
the complainants. The production should cover a reasonable period which serves the
purpose for which it is sought, ie. to demonstrate the nature of the duties and
responsibilities of the RPBA position. Similarly with regard to the timing of production
the Employer should be afforded a reasonable period to gather the required information.
On the other hand, the timing of the production should be such that the Association has a
reasonable opportunity to review and assess the material in preparation of its case. With
those considerations in mind, the Board orders as follows:
(a) The production shall cover the period August 1, 2011 to October 31, 2011. It is
possible that the incumbents assuming new positions may not have performed the full
range of duties immediately upon starting in March or April. It is the Board’s view that a
period of three months starting in August 2011, would provide a fair and reasonable
reflection of the duties and responsibilities performed by the incumbents, and that the
effort and costs required would not be unduly onerous on the employer in the particular
circumstances.
(b) While there is no evidence as to the exact degree of effort and time the Employer
may be required to invest in order to gather the material to be produced, having regard to
the nature of the material involved and the need for the employer to review and identify
potentially sensitive and confidential information, the Board orders that the production
herein ordered should be completed by the Employer on or before March 15, 2012. If
this does not afford the Association sufficient time to prepare for the scheduled hearing
on April 5, 2012, it may have to consider requesting an adjournment.
[42] The Employer is directed to produce the material sought by the Association in
accordance with the terms set out herein. The Board remains seized with the instant
complaints.
Dated at Toronto this 24th day of January 2012.
Nimal Dissanayake, Vice-Chair