HomeMy WebLinkAbout2020-1161.Union.24-05-17 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# 2020-1161; 2020-1163; 2020-1165; 2020-1169
UNION# 2020-0229-0025; 2020-0229-0027;
2020-0229-0029; 2020-0229-0033
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Union) Union
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General) Employer
BEFORE Brian McLean Arbitrator
FOR THE UNION David Wright
Ryder Wright Holmes Bryden Nam LLP
Counsel
FOR THE EMPLOYER Paul Meier
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING February 5, 2024
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Decision
[1] I have before me a number of grievances relating to issues arising out of the
circumstances at the start of the COVID-19 pandemic in the late Winter and early
Spring of 2020. On February 5, 2024, the parties appeared before me to argue a
preliminary motion brought by the Employer with respect to four of the
grievances. These grievances were filed by the Union, (OPSEU and its Local
229), with respect to employees who work at the Ontario Correctional Institute in
Brampton.
[2] The circumstances of the four grievances are different. However, they have a
common issue in that in each case the Union, believing that a work requirement
was unsafe in light of COVID-19, sought an Order against the Employer from a
Ministry of Labour (MOL) Inspector under the Occupational Health and Safety
Act (OHSA). In each case the Inspector declined to make an Order against the
Employer under the OHSA. Then, rather than utilizing the appeal procedures
under the OHSA, the Union filed a grievance in each of the four cases which
alleged violations of the collective agreement and the OHSA.
[3] The Employer asserts in this motion that the Union’s actions in filing grievances
should be barred by issue estoppel, abuse of process, and/or an improper
collateral attack on the Inspectors’ decisions. Effectively, it argues, once the
Union/Grievors chose the OHSA inspector route they should be precluded from
pursuing the grievance arbitration route. The Employer asserts that If the Union
and the grievors were dissatisfied with an Inspector’s decision, the appropriate
course of action was for them to appeal to the Ontario Labour Relations Board
(OLRB) in accordance with the OHSA. Accordingly, the Employer asks me to
dismiss these four grievances.
The Facts
[4] At the Ontario Correctional Institute there was a significant COVID-19 breakout,
and it was eventually decided to temporarily close the facility and move the staff
and inmates to a wing of another correctional facility. The four grievances at
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issue, broadly speaking, relate to employee concerns around the time of the
breakout (both immediately before and after) and the Employer’s actions at the
start of the COVID-19 pandemic.
Grievance -GSB # 2020-1161
[5] The first grievance alleges that the Employer failed to take every precaution
necessary to protect the employees by providing them with personal protective
equipment (PPE) when inmates presented with “influenza-like” illness symptoms.
There is no dispute that this grievance arose out of an incident which took place
on April 14, 2020. On that day, a correctional officer (CO) was advised that four
inmates had reported flu-like symptoms and had been sent to the institution’s
health centre for assessment. They were returned to the institution’s D dorm and
were isolated as a precaution. The CO expressed a concern about entering D
dorm to do his work and asked for PPE (a mask) to protect himself against
possible COVID-19 exposure. The Employer declined to provide a mask on the
basis that the health centre had cleared the inmates as their symptoms were not
consistent with COVID-19.
[6] The CO met with the Employer and Union health and safety representatives in a
stage 1 health and safety meeting. At the conclusion of the meeting the CO was
not sure if he wished to engage in a work refusal under the OHSA. However, as
a result of the CO’s complaint, other COs refused to perform their duties in D
dorm unless they were provided masks. The Employer continued to decline to
provide masks.
[7] A MOL Inspector was called and conducted an investigation of the work refusal
by telephone. Many people were on the call, including the COs and their Union
representative. At the conclusion of the call the Inspector advised that the COs
did not have the right to refuse work over the absence of masks unless a case of
COVID-19 was confirmed. The Union representative advised the Inspector that a
different Inspector had ordered the Employer to provide masks at another facility,
South West Detention Centre. That information did not change the Inspector’s
view.
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[8] The Union did not appeal the Inspector’s decision. The grievance was filed on
July 2, 2020, and alleged a breach of the collective agreement and OHSA with
respect to the same incident.
Grievance- GSB # 2020-1163
[9] The second grieved incident relates to the April 14 – 20 time period. The Union’s
concern was that the Employer was not providing it with appropriate and required
information regarding a hazard in the workplace which it asserts it was entitled to
under s.25(2)(a) of the OHSA for the dates, among others, April 18 and 19. In
particular, it alleged that the Employer was not providing the Union with daily
updates as to the number of positive COVID-19 tests in the workplace. In this
regard, the Union alleged that Peel Public Health was providing the Employer
with this information, but the Employer was not keeping the Union apprised. It
now appears that five staff and 40 inmates tested positive for COVID-19 in this
period. An OHSA Inspector was called to investigate the Union’s complaint.
[10] The Inspector issued a report in which he stated that on April 20 he held a call
with Peel Public Health, the Employer and the Union representative, at which the
COVID-19 testing results were shared with the Union. The Inspector decided that
no further action was required by the Ministry of Labour at the time regarding the
complaint. The Union did not appeal the Inspector’s decision or his refusal to
make an Order.
[11] A grievance was filed and was referred to arbitration on July 2, 2020. It alleged
that the Employer contravened Article 9 of the collective agreement and the
OHSA “by failing to disclose information related to a hazard in the workplace to
workers” in contravention of s. 25(2)(a) of the OHSA. The Union asserted that the
Employer’s failure to inform workers on [Saturday] April 18 and [Sunday] April 19
that inmates at OCI had tested positive for COVID-19 as per Peel Region Public
Health”. In other words, the grievance mirrored the complaint made to the
Inspector.
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Grievance -GSB# 2020-1165
[12] The third grieved incident related to a work refusal by COs with respect to the
Employer’s failure to provide PPE (masks) to COs engaged in the transfer of
inmates on April 6, 2020. The Employer refused to provide masks because the
inmates had been cleared by the institution’s health care department to be
transferred.
[13] The Inspector met with the workplace parties and the refusing workers and found
that the work refusal did not meet the requirements of Section 43.3 of the OHSA.
The Inspector found it was “a normal condition” that masks are only provided
when there are confirmed COVID-19 cases and, in the circumstances, the
Employer made reasonable provisions for health and safety because there were
“no know[n] cases of Covid-19 in the workplace”. The Union did not appeal the
decision.
[14] The Union grieved the Employer’s failure to provide masks on this occasion. The
grievance was referred to arbitration on July 2, 2020. The particulars of the
grievance make it clear that the grievance was about the same incident as it
stated that: on April 6, 2020, CO Tom Heinbuch and CO Coker “refused to work
and requested face masks for staff that were doing transfers… as they would be
in a confined space for transport with no ability for physical distancing”.
Grievance -GSB# 2020-1169
[15] The fourth grieved incident concerns an alleged failure by the Employer to
comply with s.52(2) of the OHSA which requires the Employer to notify the Joint
Health and Safety Committee (JHSC) of details, among other information, when
an employee has contracted an occupational illness. The Union filed a complaint
on April 24, 2020, and it appears an Inspector contacted the parties a short while
later. The Employer had at that time, only provided the initials and addresses of
employees who contracted COVID-19.
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S.52(2) references the regulations to the OHSA which provide:
The Industrial Regulations section 5(2) outline the prescribed information
referenced in 52(2):
(c) the name, address and type of business of the employer;
(d) the nature and the circumstances of the occurrence and of the
bodily injury or illness sustained;
(e) a description of the machinery or equipment involved;
(f) the time and place of the occurrence;
(g) the name and address of the person suffering the injury or
illness;
(h) the names and addresses of all witnesses to the occurrence;
(i) the name and address of the physician or surgeon, if any, by
whom the person was or is being attended for the injury or illness;
and
(J) the steps taken to prevent a recurrence or further illness
(emphasis added)
[16] The Inspector investigated the Union’s complaint. The Inspector consulted with
the parties and advised that the investigation was ongoing at the time. The
Inspector’s report stated:
“Management stated that they are in consultation with their Legal Services
Branch who advised a proposed protocol for release of information,
including the names of employees, is being discussed corporately with
OPSEU. As per their counsel, Management are to wait until this protocol is
finalized before providing the names of any employees are provided [sic]
in the notices of occupational illnesses.”
[17] It appears no Order was made by the Inspector as a result of the discussions
occurring at the corporate level. The Inspector stated that the “investigation is
ongoing”. The Union did not appeal the refusal to issue an Order requiring the
provision of the information required by the Regulation.
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[18] The Union filed a policy grievance which alleged a breach of the OHSA by the
Employer in its failure to notify the Union of the names and other details of
workers that contracted COVID-19 as an occupational illness.
The Parties’ Positions
[19] The Employer’s position is that I should decline to hear and determine these four
grievances because, in each case, the Union first made a complaint to the
Ministry of Labour alleging a breach of the OHSA. In each case an Inspector
was appointed and either made a decision or did not make a decision after
consulting with the workplace parties. In either case, if the Union was
dissatisfied with the Inspector’s decision (or refusal to make a decision) it was
open to it to appeal to the OLRB. It did not do so and, in the Employer’s
submission, is now stuck with the enforcement route it chose.
[20] The Employer argues that the grievances and the referrals to arbitration
constitute collateral attacks on the Inspectors’ decisions, rather than using the
proper review processes found in the OHSA. They also amount to an abuse of
process due to an unnecessary multiplicity of proceedings brought with respect
to the same issues.
[21] The Union argues that it should not be precluded from having its grievances
arbitrated. There is no abuse of process because the parties have lost nothing
due to the referral of these grievances to arbitration. That is because while the
“appeal” to the OLRB of the Inspector’s order (or decision not to make an order)
is called an “appeal” under the OHSA, the reality is that it is not a true appeal
because the OLRB conducts a hearing “de novo”. In this regard, s. 61-3.3-3.6 of
the OHSA states:
(3.3) Subject to the rules made under subsection (3.8), the Board shall
hold a hearing to consider the appeal unless the Board makes an order
under subsection (3.4).
…
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(3.6) The Board shall determine its own practice and procedure but shall
give full opportunity to the parties to present their evidence and to make
their submissions. (emphasis added)
[22] Because the appeal before the OLRB is a hearing de novo, that means that all
the evidence and argument will be essentially the same before the arbitrator as it
would have been if the appeal to the OLRB had proceeded. In other words, the
Employer is in no different position in the grievance arbitrations than if the Union
had appealed the inspectors’ decisions to the OLRB.
The Authorities
[23] In Toronto Transit Commission and Amalgamated Transit Union, Local 113, 197
L.A.C. (4th) 265, a case relied on by the Employer, Arbitrator Howe had before
him a grievance in which the Union sought to prevent its operator members from
being required/requested to investigate and extinguish fires in subway tunnels a
part of an employer policy called “Plan B”. An OHSA inspector had previously
been called in by the union to investigate the issue. In that case, the employer
brought a motion that is essentially identical to the one before me.
[24] The grievance before Arbitrator Howe was filed in 2008. In 2009 a MOL
inspector investigated a complaint with respect to the same issue brought by a
certified union member of the JHSA. The inspector made an order. Later in
2009 a different inspector also conducted an investigation and made orders
against the TTC. In 2010 another inspector, Mr. Fenwick, also investigated and
made further orders although not the ones sought by the union. Arbitrator Howe
found that the issue investigated by inspector Fenwick was the same as the one
in the grievance:
13. …It is evident from Mr. Fenwick's report that the issue of whether
the portion of Plan B impugned by the grievance is unsafe was
squarely raised by Mr. Jackson (in his capacity as a Certified Worker
Representative appointed by the Union as a JHSC Co-Chair) and
presumably also by Mr. Mackay (in his capacity as a Union Executive
Board Member) on behalf of the Union and the operators whom it
represents. The Inspector did not order the Employer to cease
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requesting operators to investigate tunnel incidents on a voluntary
basis.
[25] He later found in that same paragraph:
Thus, although the OHSA proceedings have not yielded the result sought
by the Union, Mr. Fenwick's report leaves open the possibility of further
MOL involvement if the parties are unable to satisfactorily resolve the
matter themselves. Consequently, if the Union is of the view that the
Employer is failing to "continue to review and amend the plan with worker
and operator involvement to ensure as safe a workplace as possible", to
duly script the wording for the control centre workers asking operators to
voluntarily investigate incidents so as to re-confirm and emphasize to
operators that the requested action is voluntary in nature, or to otherwise
satisfactorily resolve the Union's concerns regarding the safety of the
impugned portion of Plan B, it is open to the Union to further pursue the
complaint which gave rise to Mr. Fenwick's report, or to file a further
complaint with the MOL regarding that portion of Plan B.
[26] Finally, Arbitrator Howe held:
22 Although Union counsel disclaimed that his client is seeking to attack
the results of the aforementioned MOL proceedings under OHSA,
permitting the Union to proceed with the grievance for the purpose of
obtaining the relief set forth above would have the effect of allowing the
Union to challenge, through the impermissible route of relitigation in a
different forum, a portion of the orders made and conclusions reached by
the MOL Inspectors in those proceedings, and to do an end-run around
those proceedings. In order to prevent that impermissible collateral attack
and abuse of process, it is necessary and appropriate to decline to hear
the grievance.
[27] I note that while the union in that case first filed a grievance on the disputed issue
and then sought enforcement of the OHSA through an Inspector, the key point is
not the order in time of the commencement of enforcement efforts. The key point
seems to have been that the Union actually obtained decisions from the
Inspectors on the concerns it had raised prior to the start of the arbitration
proceedings before Arbitrator Howe.
[28] The Employer also relies on the Supreme Court of Canada decision in British
Columbia (Workers' Compensation Board) v. British Columbia (Human Rights
Tribunal) 2011 SCC 52, 2011. In that case three injured workers sought to be
compensated for chronic pain suffered following separate workplace injuries.
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The WCB granted each of them a fixed compensation award in accordance with
WCB policy. Each complainant appealed to the WCB’s Review Division, arguing
that a policy which set a fixed award for chronic pain was patently unreasonable,
unconstitutional under the Canadian Charter of Rights and Freedoms, and
discriminatory on the grounds of disability under s. 8 of the B.C. Human Rights
Code (the Code).
[29] At the Review Division of the WCB, the review officer found that only the Workers
Compensation Appeals Tribunal (the WCAT) had the authority to review WCB
policies for patent unreasonableness. He also concluded that he had no
jurisdiction to determine whether the policies were contrary to the Charter.
Finally, he accepted that he had jurisdiction over the Human Rights Code
complaint. However, he ultimately decided that the Board's chronic pain policy
was not discriminatory and therefore not contrary to the B.C. Code.
[30] The complainants appealed the review officer's decision to the WCAT. Before
the appeal was heard, the B.C. legislature amended the Administrative Tribunals
Act and the Workers Compensation Act, removing the WCAT's authority to apply
the Code. Based on the amendments, the complainants' appeal of the review
officer's human rights conclusions could not be heard by the WCAT, but judicial
review remained available.
[31] Instead of applying for judicial review, however, the complainants filed a
complaint with the B.C. Human Rights Tribunal (the HRT), repeating the same
Code arguments about the WCB's chronic pain policy that they had made before
the review officer. They did not proceed with their appeal to the WCAT from the
review officer’s decision that he did not have jurisdiction to find the WCB’s
chronic pain policy to be patently unreasonable.
[32] The WCB raised a preliminary objection before the HRT arguing that the human
rights complaint was an improper collateral attack on the WCB review officer’s
decision. In rejecting the objection, the HRT concluded that the substance of the
complaints was not appropriately dealt with in the review process. This decision
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was ultimately appealed to the Supreme Court of Canada (the SCC). The SCC
reviewed the concepts of issue estoppel, collateral attack and abuse of process.
The Supreme Court held:
38 When an adjudicative body decides an issue within its jurisdiction, it
and the parties who participated in the process are entitled to assume
that, subject to appellate or judicial review, its decision will not only be
final, it will be treated as such by other adjudicative bodies. The
procedural or substantive correctness of the previous proceeding is not
meant to be bait for another tribunal with a concurrent mandate.
…
47 "Relitigation in a different forum" is exactly what the complainants in
this case were trying to do. Rather than challenging the Review Officer's
decision through the available review route of judicial review, they started
fresh proceedings before a different tribunal in search of a more
favourable result. This strategy represented, as Stromberg-Stein J. noted,
a "collateral appeal" to the Tribunal (para. 52), the very trajectory that s.
27(1)(f) and the common law doctrines were designed to prevent:
... this case simply boils down to the complainants wanting to
reargue the very same issue that has already been conclusively
decided within the same factual and legal matrix. The complainants
are attempting to pursue the matter again, within an administrative
tribunal setting where there is no appellate authority by one tribunal
over the other. [para. 54]
48 The Tribunal's analysis made it complicit in this attempt to collaterally
appeal the merits of the Board's decision and decision-making process. Its
analysis represents a litany of factors having to do with whether it was
comfortable with the process and merits of the Review Officer's decision.
49 To begin, it questioned whether the Review Division's process met the
necessary procedural requirements. This is a classic judicial review
question and not one within the mandate of a concurrent decision-maker.
While the Tribunal may inquire into whether the parties had notice of the
case to be met and were given an opportunity to respond, that does not
mean that it can require that the prior process be a procedural mimic of
the Tribunal's own, more elaborate one. But in any event, I agree with
Stromberg-Stein J. that there were no complaints about the complainants'
ability to know the case to be met or the Board's jurisdiction to hear it:
Each of the complainants participated fully in the proceedings; each
knew the case to be met and had the chance to meet it. Each of the
complainants had the benefit of competent and experienced
counsel who raised the human rights issues within the workers'
compensation context. The issues were analyzed and addressed
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fully by the Review Division. It was implicit in their submissions to
the Review Division that they accepted the Review Division had full
authority to decide the human rights issue. [para. 52] (See also
Rasanen v. Rosemount Instruments Ltd. (1994), 112 D.L.R. (4th)
683 (Ont. C.A.), at p. 705.)
As long as the complainants had a chance to air their grievances
before an authorized decision-maker, the extent to which they
received traditional "judicial" procedural trappings should not be the
Tribunal's concern.
[33] The Employer also relies on another decision of the Supreme Court of Canada,
Danyluk v. Ainsworth Technologies Inc. 2001 SCC 44. In Danyluk an employee
made a complaint against his employer under the Employment Standards Act
(the ESA) for alleged unpaid commissions. An employment standards officer
(ESO) was assigned to investigate the employee's complaint. The ESO spoke
with the employee by telephone and on or about January 30, 1994, met with her
for about an hour. The employee gave the ESO various documents, including
her correspondence with the employer. They had no further meetings.
[34] More than six months after filing her claim under the ESA but having not yet
received a decision from the ESO, the employee commenced a lawsuit for
wrongful dismissal. In her suit, she also claimed the unpaid wages and
commissions that were the subject matter of her ESA claim. Later the ESO
advised the respondent employer (but not the employee) that she had rejected
the claim for unpaid commissions. At the same time, she ordered the employer
to pay the employee two weeks' pay in lieu of notice of termination under the
ESA. The employer then brought a motion asserting that the employee’s
wrongful dismissal and other claims were barred by issue estoppel. The matter
was ultimately appealed to the Supreme Court of Canada.
[35] The Supreme Court first found that the adjudication of the claim following the
ESO’s investigation was judicial in nature. It then applied the three-part test from
Angle v. Minister of National Revenue, 1974 CanLII 168 (SCC), [1975] 2 S.C.R.
248 to establish whether the doctrine of issue estoppel applied:
1) Was the same question decided?
2) Was the decision final?
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3) Were the parties the same?
[36] The Supreme Court determined that each of these questions should be
answered in the affirmative. The Supreme Court then went on to discuss
whether it should exercise its discretion to refuse to apply issue estoppel even
though the three factors had been satisfied. It reviewed cases where it had been
repeatedly noted that a court might not apply the doctrine of issue estoppel
where to do so would result in an injustice.
[37] The Supreme Court noted that there was no right to an appeal in that a
dissatisfied party had to apply to the Director of Employment Standards to be
granted an appeal. In this regard, s. 67(3) of the ESA provided, “the Director
may appoint an adjudicator who shall hold a hearing”. The Supreme Court found
that the use of the word “may” in the statute indicated that the Director had
discretion about whether to permit an appeal to proceed. I note that this is not
the case under the OHSA; a party who is dissatisfied with an inspector’s decision
may appeal as of right.
[38] The Supreme Court held that the doctrine should not be applied. The allegations
before the Court were set out in the decision in describing the employee’s
argument:
26 The appellant’s argument is that even though the ESA officer was required
to make a decision in a judicial manner, she failed to do so. Although she had
jurisdiction under the ESA to deal with the claim, the ESA officer lost jurisdiction
when she failed to disclose to the appellant the case the appellant had to meet
and to give the appellant the opportunity to be heard in answer to the case put
against her. The ESA officer therefore never made a “judicial decision” as
required.
66 In my view it was an error of principle not to address the factors for and
against the exercise of the discretion which the court clearly possessed. This is
not a situation where this Court is being asked by an appellant to substitute its
opinion for that of the motions judge or the Court of Appeal. The appellant is
entitled at some stage to appropriate consideration of the discretionary factors
and to date this has not happened.
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67 The list of factors is open. They include many of the same factors listed in
Maybrun in connection with the rule against collateral attack. A similarly helpful
list was proposed by Laskin J.A. in Minott, supra. The objective is to ensure that
the operation of issue estoppel promotes the orderly administration of justice but
not at the cost of real injustice in the particular case. Seven factors, discussed
below, are relevant in this case.
[39] The factors found by the Court to be relevant in that case were as follows:
(a) The Wording of the Statute from which the Power to Issue the
Administrative Order Derives. In this case the ESA provided in s.6(1) that: No
civil remedy of an employee against his or her employer is suspended or affected
by this Act. In other words the ESA contemplated the possibility of parallel
proceedings.
(b) The Purpose of the Legislation.
The Court found:
73 Nevertheless, the purpose of the ESA is to provide a relatively quick
and cheap means of resolving employment disputes. Putting excessive
weight on the ESA decision in terms of issue estoppel would likely compel
the parties in such cases to mount a full-scale trial-type offence and
defence, thus tending to defeat the expeditious operation of the ESA
scheme as a whole. This would undermine fulfilment of the purpose of the
legislation.
(c) The Availability of an Appeal. As noted, the Court found the statute did not
provide for an automatic right of appeal, although she had the possibility of an
administrative review.
(d) The Safeguards Available to the Parties in the Administrative
Procedure. The Court found that the expeditious procedures suitable for an
ESO’s determination “may simply be inadequate to deal with complex issues of
fact or law”. Moreover, in this case, the ESO’s actions breached the natural
justice rights of the employee.
(e) The Expertise of the Administrative Decision Maker. The Court found
this factor weighed against deference since the ESO was not legally trained.
Moreover, the ESO applied a “rough and ready “approach which was “not the
expertise required…”
(f) The Circumstances Giving Rise to the Prior Administrative
Proceedings. The Court appeared to find this factor to be neutral. The ESA
claim was filed at a time of personal vulnerability for the employee. However,
she also claimed $300,000 in unpaid commissions as part of her ESA claim.
(g) The Potential Injustice The Court found that a “final and most important
factor” was, taking into account all of the circumstances, whether an injustice
would result if issue estoppel were applied. In this regard the Court was
concerned that the employee’s claim for $300,000 in unpaid commissions had
never been adjudicated and therefore the doctrine should not be applied against
her.
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[40] Another case relied on by the Employer is Hebron v. University of Saskatchewan
2015 SKCA 91 in which the Saskatchewan Court of Appeal considered whether
a human rights complaint brought by a student enrolled in a veterinary medicine
program could proceed. The case arose out of the fact that the student advised
the University that he had a learning disability and needed accommodation for
his studies. Sufficient accommodations were allegedly not provided, and the
student was required to discontinue his studies because he failed to achieve and
maintain the requisite academic standard. The student unsuccessfully appealed
through the University's internal appeal board and then commenced a human
rights complaint, alleging a failure to accommodate by the University. The
University argued that the student had chosen the internal appeal route and
should be precluded from advancing a human rights complaint to the
Saskatchewan Human Rights Commission (SHRC). The SHRC disagreed with
the University.
[41] The Court of Appeal held that the Human Rights Commission should not have
accepted the complaint and commenced investigating it. The Court stated:
69 As the record in this appeal has amply demonstrated — and to
paraphrase Abella J. (at para. 47) — relitigation in a different forum is
exactly what Mr. Hebron was trying to do when he filed his SHRC
complaint. Rather than challenging the UCAB panel decision through the
available route of judicial review, he started fresh proceedings before the
SHRC in search of a more favourable result. The effect of the Chief
Commissioner's decision was to permit Mr. Hebron to reargue the very
same issue that has already been conclusively decided within the same
factual and legal matrix. In as much as this would be a 'collateral appeal'
to the UCAB panel decision, it is exactly what s. 27.1(1)(d) of our Human
Rights Code and the common law doctrines of issue estoppel, res judicata
and collateral attack were designed to prevent. On an overall basis, the
Chief Commissioner's decision would have had the effect of obstructing
the goal of avoiding unnecessary litigation and it was, therefore, properly
found to be unreasonable.
[42] The Employer argues that together these cases stand for the proposition that a
party may not choose one legal/statutory avenue and then, dissatisfied with the
result, start down another legal/statutory path to try to obtain the desired result.
This it says, is exactly what is going on here. OPSEU and its members asked a
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health and safety inspector to determine whether the Employer was in violation of
the OHSA on four occasions, and the inspector exercised powers under the
OHSA to do that. It notes these powers include:
57 (1) Where an inspector finds that a provision of this Act or the regulations is
being contravened, the inspector may order, orally or in writing, the owner,
constructor, licensee, employer, or person whom he or she believes to be in
charge of a workplace or the person whom the inspector believes to be the
contravener to comply with the provision and may require the order to be
carried out forthwith or within such period of time as the inspector specifies.
(6) Where an inspector makes an order under subsection (1) and finds
that the contravention of this Act or the regulations is a danger or
hazard to the health or safety of a worker, the inspector may,
(a) order that any place, equipment, machine, device, article or
thing or any process or material shall not be used until the order
is complied with;
(b) order that the work at the workplace as indicated in the order
shall stop until the order to stop work is withdrawn or cancelled
by an inspector after an inspection;
(c) order that the workplace where the contravention exists be
cleared of workers and isolated by barricades, fencing or any
other means suitable to prevent access thereto by a worker until
the danger or hazard to the health or safety of a worker is
removed.
(11) An inspector is not required to hold or afford to an owner,
constructor, licensee, employer or any other person an opportunity
for a hearing before making an order.
[43] Moreover, while the Inspector is not required to hold a hearing before making an
Order (see s.11) on the facts, each of the Inspectors met with the parties (it
appears over the telephone, given the pandemic) and gave them a full
opportunity to state their position and make arguments.
[44] The Union asks me to keep in mind what the OHSA does and does not do. It
argues, most importantly, that the OHSA does not set up a system where the
decision of an Inspector is a final decision. That, it argues, is because the
“appeal” of the Inspector’s hearing is a de novo hearing rather than an appeal
based on alleged errors of fact or law or other similar appeal grounds. In this
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regard, s.61(1) (3.6) of the OHSA gives the parties “full opportunity… to present
their evidence and to make their submissions” before the OLRB.
[45] This means, the Union argues, that an MOL Inspector’s decision is not final “in
the normal way”. This contrasts with the statute which creates the GSB which
provides that it “shall…” hear and determine grievances”. Importantly, it asserts,
the GSB and grievance procedure are the processes under which these
grievances must be heard.
[46] In addition, the OHSA does not provide the OLRB with exclusive jurisdiction over
OHSA matters. It is not disputed that I, as an arbitrator of the GSB, have
jurisdiction to interpret and apply the OHSA in the grievances before me. In
addition, the Inspector does not have to afford the parties any natural justice
rights. He/she may make an order against a party without hearing from them:
s.57
(11) An inspector is not required to hold or afford to an owner, constructor,
licensee, employer or any other person an opportunity for a hearing before
making an order.
[47] That, the Union argues, confirms that Inspectors’ decisions do not carry the same
gravitas as other administrative decisions so that they must be appealed if a
party disagrees, rather than filing a grievance on the same subject.
[48] The Union also asserts there is a context to the grievances which could not be
raised on an appeal of the Inspectors’ decisions. That context includes the fact
that following the SARS outbreak some years ago, the parties agreed to do
certain things to protect workers in case of another similar (or worse) outbreak.
The Union alleges these agreements were breached and it does not want to wait
for another pandemic to have these important questions determined.
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[49] The Union relies on the Supreme Court of Canada decision in Penner v. Niagara
(Regional Police Services Board) [2013] 2 SCR 125. In that case Penner was
arrested for disruptive behaviour in an Ontario courtroom. He filed a complaint
against two police officers under the Police Services Act (the “PSA”), alleging
unlawful arrest and unnecessary use of force. He also started a civil action
claiming damages arising out of the incident. The hearing officer appointed by
the Chief of Police under the PSA found the police officers not guilty of
misconduct and dismissed the complaint. That decision was reversed on appeal
by the Ontario Civilian Commission on Police Services on the basis that the
arrest was unlawful. On further appeal, the Ontario Divisional Court concluded
that the officers had legal authority to make the arrest and restored the hearing
officer’s decision. The police officers then successfully moved in the Ontario
Superior Court of Justice to have many of the claims in the civil action struck on
the basis of issue estoppel. While finding several factors weighed against the
application of issue estoppel, the Ontario Court of Appeal concluded that
applying the doctrine would not work an injustice in this case and dismissed
Penner’s appeal.
[50] On appeal, the Supreme Court first discussed the and the importance of the
doctrine of issue estoppel in ensuring fairness to parties:
[28] Relitigation of an issue wastes resources, makes it risky for parties
to rely on the results of their prior litigation, unfairly exposes parties to
additional costs, raises the spectre of inconsistent adjudicative
determinations and, where the initial decision maker is in the
administrative law field, may undermine the legislature’s intent in setting
up the administrative scheme. For these reasons, the law has adopted a
number of doctrines to limit relitigation.
[29] The one relevant on this appeal is the doctrine of issue estoppel. It
balances judicial finality and economy and other considerations of fairness
to the parties. It holds that a party may not relitigate an issue that was
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finally decided in prior judicial proceedings between the same parties or
those who stand in their place.
[51] However, the Court then continued in para. 29 to note that the application of the
doctrine was discretionary:
…However, even if these elements are present, the court retains
discretion to not apply issue estoppel when its application would work an
injustice.
[30] The principle underpinning this discretion is that “[a] judicial doctrine
developed to serve the ends of justice should not be applied mechanically
to work an injustice”: Danyluk, at para. 1; see also Toronto (City) v.
C.U.P.E., Local 79, 2003 SCC 63, [2003] 3 S.C.R. 77, at paras. 52-53.
[52] The Court agreed that the three conditions necessary for the application of issue
estoppel were present. It then discussed the approach to the exercise of
discretion. It held that the essential question in any given case is whether it
would be unfair to apply the doctrine in the circumstances of the case.
[53] The Court noted that in Danyluk there was a list of factors which might be
considered to determine whether a prior proceeding was unfair. However, it
emphasized that was not an exhaustive list. It then stated:
[39] Broadly speaking, the factors identified in the jurisprudence illustrate
that unfairness may arise in two main ways which overlap and are not
mutually exclusive. First, the unfairness of applying issue estoppel may
arise from the unfairness of the prior proceedings. Second, even where
the prior proceedings were conducted fairly and properly having regard to
their purposes, it may nonetheless be unfair to use the results of that
process to preclude the subsequent claim. Ultimately the decision about
whether to apply these doctrines is up to the arbitrator based on whether
to do so would lead to injustice.
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[54] The Court noted that the PSA did not foreclose a civil proceeding after a
complaint had been filed. In fact, there were provisions in the PSA which the
Court found specifically contemplated parallel proceedings. It noted that
Penner’s civil action was filed almost a year before the hearing officer released
his decision. In Danyluk, the civil proceedings had commenced before the
administrative proceedings concluded. Accordingly, the respondents were well
aware that they were faced with parallel and overlapping proceedings. In
addition, other cases had found that issue estoppel did not apply in similar
circumstances. Finally, Mr. Penner might well not understand that a proceeding
in which he had no financial stake could preclude a claim for damages in a civil
action.
[55] The Court was also concerned that the application of issue estoppel in a case
like that might cause someone like Penner to decline to participate in the PSA
proceeding for fear of compromising any civil action he might have. This would
undermine the police disciplinary process. This is especially the case since it is
the Chief of Police who appointed the investigator, the prosecutor and the
hearing officer with respect to Penner’s complaint against the officers. While
these processes might be appropriate for the disciplinary matters, they might well
be seen as unfair by Penner if the findings went against him.
[56] The Court held, therefore, that applying issue estoppel to Penner in these
circumstances was “fundamentally unfair”. The Court referred the matter back so
that Penner’s civil claims could be adjudicated.
DECISION
[57] As noted above, the test for whether the doctrine of issue estoppel applies is set
out in Angle v. Minister of National Revenue, supra, as follows:
1) Was the same question decided?
2) Was the decision final?
3) Were the parties the same?
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[58] I deal first with the argument that the decisions of Inspectors are not final. In the
BC WCB case the Court had this so say about what makes a decision “final”: (at
para 51): "Final" means that all available means of review or appeal have been
exhausted. Where a party chooses not to avail itself of those steps, the decision
is final. Even under the strict application of issue estoppel, which in my view is
not in any event what s. 27(1)(f) was intended to incorporate, the Review
Officer's decision was a final one in these circumstances. Having chosen not to
judicially review the decision as they were entitled to do, the complainants cannot
then claim that because the decision lacks "finality" they are entitled to start all
over again before a different decision-maker dealing with the same subject
matter (Danyluk, at para. 57)”.
[59] In the cases before me, the Union had the right to file an application to the OLRB
to appeal the Inspectors’ decisions. They did not do so. That makes the
Inspectors’ decisions final in these circumstances.
[60] In my view, it is also clear that the parties are the same. The parties before the
Inspectors were the Union and the Employer. While it might be said that the
individual employees were the parties before the Inspectors, the Union acts and
acted on their behalf. The parties before me are also the Union and the
Employer.
[61] Similarly, there is no dispute (with one possible exception) that the questions
before me are the same as before the Inspectors. The grievances before me
involve the same people and circumstances. I do note that the Union did identify
an additional issue in one of the grievances which it said was not dealt with by
one of the Inspectors. I am unclear which grievance the Union was referring to
and have sought information from the Union at the end of this award.
Exercise of Discretion
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[62] Having decided that the conditions are present for the application of the doctrine
of issue estoppel I must next determine whether to exercise my discretion to
apply the doctrine and dismiss the grievances. There is no dispute that I have
the authority to do so.
[63] The Union argues, nevertheless, that I should not do so. In particular, it notes
that the Employer has suffered no prejudice whatsoever if it is required to litigate
the grievances at the GSB. That is because the hearing held by the OLRB is a
hearing de novo. The hearing at the OLRB and before me would, as a result,
take roughly the same amount of time and resources to litigate. The issues
before me on the merits are essentially the same as would have been before the
OLRB had the Union appealed the Inspectors’ decisions. The Employer suffers
no prejudice if the arbitrations proceed.
[64] There is no suggestion before me that the Inspector proceedings were unfair
since there is no real question whether the parties had notice of the case to be
met and were given an opportunity to respond. Indeed, they each participated in
the Inspectors’ process after which he made his determination. In each case the
Inspector met with the parties over the telephone and gave them a full
opportunity to explain their position. There is no suggestion that the Inspectors
do not have expertise in health and safety matters. The kinds of issues raised by
these complaints are at the heart of the Inspectors’ experience and training.
[65] Importantly, each of the parties before the Inspectors had a right of appeal within
30 days of the decisions. Rule 41.2 of the Board’s rules grants the Board or its
Registrar wide authority to schedule hearings in way which meets the objectives
of OHSA and the needs of the parties and the workplace. I have little doubt that
the Board could have scheduled the appeals in an expeditious manner in
accordance with the objectives of the OHSA.
[66] That leaves whether it would be unfair to use the results of the Inspector
processes to preclude the arbitration of these four grievances. The Court in
Penner identified an area of potential unfairness, that being “where there is a
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significant difference between the purposes, processes or stakes involved in the
two proceedings” (at para 42). That is not the case here. The purposes and the
stakes of the two proceedings are essentially identical; to ensure worker health
and safety. While the processes are somewhat different, those differences are
designed to enhance health and safety in the workplace. In the route chosen by
the Union/Grievors they got a speedy adjudication of their pressing and serious
workplace concerns. If they had appealed the Inspectors’ decisions to the Board,
they would have likely ended up with a hearing process very similar to that as
before the GSB.
[67] On the other hand, by grieving and then ultimately referring the matter to
arbitration, especially given the agreed upon arrangements that were made with
respect to grievances during the pandemic, which resulted in significant delays,
the Union likely ended up with a much less quick process.
[68] In these circumstances there is little unfairness to the Union and its members to,
having chosen the Inspector route to deal with their health and safety concerns,
require them to follow that process through rather than to choose a different
process: the grievance and arbitration procedure.
[69] Moreover, the process chosen by the Union amounts to a collateral attack on the
Inspectors’ decisions which has an impact on the Inspector. In an appeal to the
Board, the Inspector is routinely made a party to the appeal either because they
are a “Director” as defined in the OHSA or because the Board makes them a
party pursuant to s. 61(2). As a party, the Inspector can (and usually is)
represented by counsel at the Board’s hearing. I note that there is no evidence
before me to suggest that the Inspector was given notice of the hearing in this
matter before me or that such notice could be given and the Inspector made a
party. These circumstances involve a collateral attack on the Inspectors’
decisions. These circumstances are much the same as the circumstances
before Arbitrator Howe in the T.T.C. case discussed above where he decided
that allowing the Union to proceed to arbitration would be improper.
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[70] It is true, as the Union argues, that the resources which would be needed to be
expended at the GSB, if I exercised my discretion to let it proceed, would be
similar to the resources which would have had to be expended at the OLRB had
the Union appealed. However, that is just one of the considerations in exercising
my discretion. I am satisfied that none of the factors identified in Danyluk and
Penner apply here while recognizing that the lists of factors set out in those
cases are not exhaustive. Those factors are:
(a) The Wording of the Statute from which the Power to Issue the
Administrative Order Derives. In Danyluk the ESA provided in s.6(1)
that: No civil remedy of an employee against his or her employer is
suspended or affected by this Act. In other words, the ESA contemplated
the possibility of parallel proceedings. That is not present here but there is
agreement that the parties’ collective agreement also contains measures
for the protection of workers. The two schemes operate in parallel.
(b) The Purpose of the Legislation. The purpose of the legislation is
to, among other things, to provide and mandate workplace systems to
ensure the health and safety of workers. It is identical (and much more
broad) than the purpose of the health and safety provisions in the
collective agreement. The OHSA is designed to have workplace safety
concerns addressed expeditiously. That objective has been thwarted.
(c) The Availability of an Appeal. There is an appeal under the OHSA
available as a matter of right.
(d) The Safeguards Available to the Parties in the Administrative
Procedure. In Danyluk the Court found that the expeditious procedures
suitable for an ESO’s determination “may simply be inadequate to deal
with complex issues of fact or law”. It also found that the ESO’s actions
breached the natural justice rights of the employee. Here, there is no
suggestion that the natural justice rights of the Union or employees were
breached. There is also no suggestion that the expeditious procedures
used by the Inspectors were inadequate in the circumstances.
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(e) The Expertise of the Administrative Decision Maker. There is no
suggestion that the Inspectors do not have expertise in workplace health
and safety. The issues before them did not involve complex legal issues.
Instead, they mostly involved an assessment of whether the workers’
health and safety was at risk in the circumstances. Under the OHSA
inspectors have broad powers to carry out their duties.
(f) The Circumstances Giving Rise to the Prior Administrative
Proceedings. This factor is discussed below.
(g) The Potential Injustice. While it is true that the Union’s claim that
arbitration is necessary to deal with respect to alleged breaches of
agreements made in a previous pandemic, it is clear that is not the focus
of the grievances. Instead, the grievances are about the circumstances
which occurred in the instances in question. There is also no suggestion
that other grievances directed at alleged breaches of prior agreements
could not have been filed as seperate policy grievances.
[71] I do have some concerns about the circumstances under which the Inspectors
made their decisions. It was the start of a pandemic when it was not entirely
clear how deadly the virus was. The COs work in a congregant setting where it
might be expected that it would be relatively easy for the virus to take hold
among the population. It was critical that decisions be made quickly. As a result,
the Inspectors conducted their investigation by telephone.
[72] Certainly, the circumstances under which the Inspectors made their decisions
were not ideal. However, to some degree that is the nature of being an
Inspector. Work refusals, for example, almost always involve considerable
workplace tensions. They often happen in the dead of night and often over the
telephone. In my view, the circumstances that existed at the time should
diminish the deference given to these decisions by these Inspectors. Those
circumstances do not justify a collateral attack on them.
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[73] Fundamentally, I disagree with the Union that it and the grievors that, to quote
the Court in Penner, “even where the prior proceedings were conducted fairly
and properly having regard to their purposes, it may nonetheless be unfair to use
the results of that process to preclude the subsequent claim”. I do not find any
unfairness here. While the Union claims that it should be entitled to continue with
the grievances so that it can raise issues regarding breaches of agreements
made following the SARS pandemic, as noted, that objective could have been
obtained through other means.
[74] For all the foregoing reasons I decline to hear and determine these four
grievances.
Dated at Toronto, Ontario this 17th day of May 2024.
“Brian McLean”
Brian McLean, Arbitrator