HomeMy WebLinkAbout2010-2436.Moody.12-05-23 DecisionCrown Employees
Grievance
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Commission de
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GSB#2010-2436
UNION# 2010-0122-00149
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Moody) Union
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The Crown in Right of Ontario
(Ministry of Community and Youth Services) Employer
BEFORE Randi H. Abramsky Vice-Chair
FOR THE UNION Anne Cumming
Koskie Minsky LLP
Barristers and Solicitors
FOR THE EMPLOYER Heather McIvor
Ministry of Government Services
Legal Services Branch
Counsel
HEARING
SUBMISSIONS
CONFERENCE CALL
April 24, 2012
April 26 and 27, 2012
May 8, 20122
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DECISION
[1] The Employer has raised a preliminary objection to the jurisdiction of the Board
to hear this grievance. It asserts that the Board lacks jurisdiction because the
grievance was not referred to arbitration in a timely manner. The Union opposes
the Employer’s motion.
Facts
[2] The relevant facts pertaining to the Employer’s motion are not in dispute, and no
evidence was called.
[3] The grievance was filed on August 4, 2010, and alleges the following:
Management is in violation of Article 2.1 and Article 25.1 of the collective
agreement. The employer did not independently or accurately consider
my situation using the supporting documents and recommendations of
the Medical Profession. Only half of the requested time was granted. I
believe that Management acted in bad faith with this decision.
[4] The words “not limited to these articles” also appears in the written grievance.
Article 2.1 is the Management Rights provision, and Article 25.1, Leave-Special,
provides that a “[l]eave of absence with pay may be granted for special or
compassionate purposes to an employee for a period of: (a) not more than six (6)
months with the approval of his or her Deputy Minister.”
[5] The grievor’s request for paid special or compassionate leave was for six weeks
in order to care for her father who was to have hip replacement surgery. The
Ministry approved it for three weeks (15 eight-hour shifts), with the remaining
time to be covered by vacation or other credits.
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[6] A Stage Two meeting was held on October 29, 2010, and the Employer denied
the grievance in writing on November 3, 2010. The grievance was referred to
arbitration on January 18, 2011 by Grievance Officer Tim Mulhall, with a copy
sent to the Manager, Employee Relations Advisory Services, the Employer
contact person.
[7] A hearing date and Vice-Chair were selected for this grievance at the October
2011 joint file review, and on October 21, 2011, notice of the hearing was issued
by the Registrar of the Grievance Settlement Board (GSB) to Grievance Officer
Mulhall and Employer Counsel Suneel Bahal. The hearing date was set for April
24, 2012.
[8] On March 20, 2012, Mr. Bahal wrote to Mr. Mulhall advising that counsel for the
Ministry would now be Heather McIvor, and also requesting “all material relating
to this matter…along with full particulars.” This was requested “at your earliest
convenience in order to allow adequate time to prepare for the hearing date
scheduled on April 24, 2012…”
[9] On April 9, 2012, Anne Cumming, counsel for the Union, wrote to Ms. McIvor
advising that her firm had been retained on this matter, and requested production
of all particulars and documents upon which the Employer intended to rely,
including a number of specific items.
[10] On April 10, 2012, Ms. McIvor responded to Ms. Cumming. She referred to the
March 20, 2012 letter’s request for particulars and stated: “Upon receipt of our
request, we will then provide relevant disclosure documents and advise of any
preliminary arguments.”
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[11] On April 13, 2012, Ms. Cumming provided the particulars and documents
requested, and again requested the information outlined in the April 9, 2012
letter.
[12] On April 18, 2012, Ms. McIvor provided the requested particulars and responded
to the document request. The letter also advises “that the Employer intends to
raise a preliminary objection, specifically, that the grievance is out of time.”
[13] After the hearing in this matter on the preliminary motion, the Union requested
leave to reopen the record to present evidence that the instant grievance was
discussed by the parties at a mediation/arbitration session involving a number of
grievances before Vice-Chair Stephens on August 18, 2011. The Employer
opposed that motion, and a conference call was held on May 8, 2012, to hear the
parties’ submissions. Based on my consideration of the arguments of the parties,
and the case law submitted, I conclude that the motion to reopen the hearing
should not be granted. The information about the mediation in August 2011 was
information that was in the possession of and available to the Union at the time of
the hearing and should have been raised at the original hearing. Re OPSEU
(Seager) and Ministry of Community, Family & Children’s Services, GSB No.
1999-1841 (Mikus); Re Unimin Canada Ltd. and United Steelworkers of America,
Local 5393 (Davis) [2008] O.L.A.A. No. 188 (Luborsky).
Reasons for Decision
[14] Section 7.(3) of The Crown Employees’ Collective Bargaining Act, 1993, S.O.
1993, Ch. 38, states as follows:
Every collective agreement related to Crown employees shall be
deemed to provide for the final and binding settlement by
arbitration by the Grievance Settlement Board, without stoppage
of work, of all differences between the parties arising from the
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interpretation, application, administration or alleged violation of the
agreement, including any question as to whether a matter is
arbitrable.
[15] Article 22 of the collective agreement, Grievance Procedure, sets out a
procedure for the processing of complaints and differences between the parties.
Stage One states that an employee with a complaint “shall meet, if practical, and
discuss it with the employee’s immediate supervisor within thirty (30) days…” If
the matter is not satisfactorily settled, Stage Two, a written grievance, may occur.
Article 23.3.1 states that “the employee may file a grievance, in writing, through
the Union, with their immediate supervisor who will in turn forward the grievance
to the senior human resources representative for the ministry or his or designee.”
The senior human resources representative, or his or her designee, then has
fifteen (15) days of the receipt of the grievance to hold a meeting about it, and
then “shall give the grievor his or decision in writing within seven (7) days of the
meeting with a copy to the Union steward.”
[16] Article 22.4 provides:
If the grievor is not satisfied with the decision of the senior human
resources representative or his or her designee or if she does not
receive the decision within the specified time, the grievor may
apply, through the Union, to the Grievance Settlement Board
(GSB) for a hearing of the grievance within fifteen (15) days of the
date he or she received the decision or within the fifteen (15) days
of the specified time limit for receiving the decision.
[17] The collective agreement, Article 22.14.2 provides that “[i]n Article 22, ‘days’ shall
include all days exclusive of Saturdays, Sundays and holidays.” Consequently,
because the Employer submitted its Stage Two decision in this matter on
November 3, 2010, the grievance should have been referred to the GSB by
November 24, 2010. It was referred on January 18, 2011.
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[18] The collective agreement also permits the parties to extend the time limits in
Article 22 in writing, but there is no evidence that this was done in this case.
[19] Also relevant are Articles 22.14.1 and 22.14.16 which state:
22.14.1 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 have been
withdrawn.
22.14.6 The GSB shall have no jurisdiction to alter, change,
amend or enlarge any provision of the Collective Agreement.
[20] The GSB thus has the statutory authority to resolve, through arbitration, “all
differences between the parties …” The parties, in their collective agreement,
established the grievance procedure for bringing such “difference” to the GSB.
The collective agreement provides for specific timelines for bringing and
processing grievances, as outlined above.
[21] Under Section 48(16) of the Labour Relations Act, which applies to the GSB, an
arbitrator has the power “to extend the time for the taking of any step in the
grievance procedure under a collective agreement, despite the expiration of the
time, where the arbitrator …is satisfied that there are reasonable grounds for the
extension and that the opposite party will not be substantially prejudiced by the
extension…” The GSB case law, however, is “clear, unequivocal and consistent”
that “[n]otwithstanding section 48(16) of the Labour Relations Act, an arbitrator
does not have the jurisdiction to extend the time limits in a collective agreement
for a referral of a grievance to arbitration.” Re OPSEU (Seager) and Ministry of
Community, Family and Children’s Services, GSB 1999-1841 (Mikus, 2003), at p.
12; Re OPSEU (Johnston) and Ministry of Attorney General, GSB 2009-1147
(Dissanayake, 2009); Re OPSEU (Cherry) and Ministry of Finance, GSB 0626/01
(Gray, 2003); Re OPSEU (Goring) and Ministry of Community Safety and
Correctional Services, GSB 2008-1661 (Briggs, 2010).
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[22] The real question presented by this case is whether the Employer may waive its
objection to an untimely referral to arbitration. The Employer asserts that the
Union’s failure to timely refer a grievance to arbitration is jurisdictional, not
procedural, and cannot therefore be waived. It submits that without a properly
referred grievance, this Board has no jurisdiction over the grievance. It cites to
Re OPSEU (Dales) and Ministry of Correctional Services, GSB 1280/00 (Mikus,
2002); Re Ontario Power Generation and Society of Energy Professional (Health
Statement Grievance) (2004), 137 L.A.C. (4th) 44 (Goodfellow); Re Algonquin
College and OPSEU, Local 4156 (FSL Grievance) (2001), 100 L.A.C. (4th) 234
(Knopf), and Re Atomic Energy of Canada Ltd. and Society of Professional
Engineers and Associates (1994), 41 L.A.C. (4th) 310 (Knopf).
[23] In the alternative, the Employer submits that under the facts, it did not waive its
objection to the Union’s failure to refer the grievance in a timely manner. It
submits that its conduct cannot be inferred to have relinquished its objection. It
advised the Union that the Employer would, upon receipt of the Union’s
particulars, identify any preliminary arguments it might raise. Counsel then did so
within days of receiving the Union’s particulars. It submits that no “fresh step”
had been taken and the Union was advised of the objection as soon as counsel
received the Union’s particulars and documents. In support it cites to Re OPSEU
(Ireland et al.) and Ministry of Community Safety and Correctional Services, GSB
2007-2368 (Briggs, 2011).
[24] The Union asserts that its failure to refer the grievance within the fifteen day time
limit was a procedural defect which the Employer waived by agreeing to the
hearing date at joint file review, discussing the case through correspondence and
not raising an objection until April 18, 2012 – six days before the hearing. It
submits that the Employer, at all relevant times, knew of the late referral, and
learned nothing new through the Union’s particulars. The Union submits that
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through the Employer’s silence, it led the Union to believe that jurisdiction would
not be in issue, and that the Board must given meaning to that representation. It
contends that the Employer should not be allowed to “sit on its hands” and waste
the parties’ and Board’s time and resources by asserting a jurisdictional issue at
this time. In support of its position, the Union cites to Re OPSEU (Union
Grievance) and Ministry of Community Safety & Correctional Services, GSB
2003-3075 (Herlich, 2005); Re Amalgamated Transit Union, Local 1587 (Union
Grievance) and Ontario (Metrolinx-GO Transit), GSB 2010-2210 (Dissanayake,
2012).
[25] It is notable that in Re OPSEU (Ireland), supra, the same issues arose, but Vice-
Chair Briggs determined that she could rule, based on the facts, that the
Employer did not waive its right to object to the timeliness of the referral to
arbitration, and thus was able to “avoid that matter of determining whether the
doctrine of waiver as argued by the Union applies in this situation.” It appears to
me that, under the facts of this case, the issue must be addressed.
[26] Waiver, according to Palmer in Collective Agreement Arbitration in Canada, at p.
164, is a common law doctrine which arises in “situations where failure to make
timely objection to non-compliance with the procedural requirements of the
grievance procedure prevents the objection from being raised later.” In contrast,
fundamental issues of jurisdiction – substantive arbitrability – cannot be waived,
and may be raised at any time. This distinction was noted in Re OPSEU (Dales),
supra at p. 8, where the Board determined:
There is no question that a party can waive its right to object to
procedural irregularities in the processing of a grievance. If a party allows
the other side to continue without alerting it to a forthcoming objection, it
risks being estopped from doing so later. However, a party cannot waive
an objection to the jurisdiction of the Board.
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[27] The issue in this case, therefore, is whether the time limit for referral to arbitration
is a “procedural” matter, or a “substantive” one. Having carefully considered the
jurisprudence and arguments of the parties, I conclude that the time limits for
referral to arbitration are procedural, not substantive, and may be waived.
[28] Traditionally, time limits in the grievance procedure have been viewed as
procedural matters, which may be waived. As set out in Brown and Beatty,
Canadian Labour Arbitration, at p. 2-107, cited in Re Amalgamated Transit Union
– Local 1587 and Ontario (Metrolinx – GO Transit), supra at par. 27, in relevant
part:
The concept of “waiver” connotes a party not insisting on some right, or
giving up some advantage. However, to be operative, waiver will
generally require both knowledge or and an intention to forego the
exercise of such a right. …
[B]y not objecting to failure to comply with mandatory time-limits until the
grievance comes on for hearing, the party who should have raised the
matter earlier will be held to have waived noncompliance, and any
objection to arbitrability will not be sustained.
[29] Similarly, Palmer, in Collective Agreement Arbitration in Canada, at p. 165,
(citations omitted) states: “Failure to comply with mandatory time limits in the
collective agreement, filing of a grievance as a policy rather than an individual
grievance, defects in the form itself and failure to proceed through all the
specified steps of the grievance procedure have been held to be procedural
irregularities which can be waived.”
[30] The Employer accepts that a failure to follow mandatory time limits in the
grievance procedure may be procedural, but asserts that at the arbitration stage,
it becomes substantive. The distinction, it submits, is based on Section 48(16) of
the Labour Relations Act, which empowers arbitrators to extend mandatory time
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limits in the grievance procedure, but not a referral to arbitration. With respect, I
cannot agree.
[31] While it is true that Section 48(16) of the Labour Relations Act applies only to the
grievance procedure, and not a referral to arbitration – at least under the parties’
collective agreement – the absence of such a statutory provision does not
change the nature of a time limit. It remains procedural, and is subject to waiver.
The absence of statutory authority to extend the time limits does not change an
untimely referral into a matter of fundamental, substantive jurisdiction that cannot
be waived.
[32] Prior to the amendments of the Ontario Labour Relations Act which empowered
arbitrators to relieve against mandatory time limits, the doctrine of waiver applied.
Arbitrators would analyze whether or not the time limits were mandatory or
directory. If they were directory, arbitrators could generally hear the grievance. If
they were mandatory, the arbitrator would have no jurisdiction unless the
objection had been waived. As set forth in Palmer, supra at p. 156-157 (citations
omitted):
Before the amendment, however, a failure to meet the mandatory
time limits set out in the collective agreement meant that the
arbitrator had no jurisdiction to deal with the merits of the case. The
general principle has been stated as follows:
… [T]here is a wealth of authority to establish that where a
mandatory grievance procedure is set forth in a collective
agreement, the grieving party must follow it meticulously,
unless the other party has waived one or more of the
requirements set forth in that procedure, and that in the
absence of such waiver, the grievance is not arbitrable and
the arbitrator is therefore debarred of jurisdiction to entertain
it….
As mentioned in this quote, the other party can waive mandatory
grievance procedure requirements. Without waiver, the provisions will be
strictly applied.
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[33] The enactment of the predecessor to Section 48(16) eliminated the need to
analyze whether a time limit provision was mandatory or directive, but it did not
eliminate the doctrine of waiver. Nor was waiver eliminated by the amendment
that removed arbitration from the ambit of the provision. The legislation also did
not transform time limits for referral from a procedural issue into a substantive
one.
[34] There is no question that a timely referral to arbitration under the parties’
collective agreement is mandatory, not directory. This is clear from Article
22.14.1 which states that “[w]here 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 have been withdrawn.” This creates a
mandatory requirement, and specifies the consequences for failure to comply.
As concluded by the Board in Re OPSEU (Cherry), supra at par. 13: “A
grievance that has been withdrawn is not arbitrable.”
[35] The decision in Re OPSEU (Cherry), supra, however, does not determine the
issues in this case. The Vice-Chair there was correct when he stated at par. 16
that the collective agreement “gives the GSB no power to extend the collective
agreement’s time limit for referring his grievance to arbitration” nor was that
power conferred by any provision in the Crown Employees Collective Bargaining
Act or the Labour Relations Act. But in that case, the issue of waiver did not
arise, nor was it argued. Under the facts, upon referral of the grievance to
arbitration, the “Ministry promptly advised the union that it was objecting to the
referral on the basis that the grievance had not been referred to arbitration within
the mandatory time limits set out in Article 22.4 of the Collective Agreement. “
(Par. 10). Consequently, the fact that the Board cannot extend the time for
referral under Section 48(16) of the Labour Relations Act does not mean that the
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Employer cannot waive its objection to an untimely referral, and Re OPSEU
(Cherry), supra, does not stand for that proposition.
[36] Consequently, there is no basis to conclude that time limits in relation to the
grievance procedure are procedural while time limits in relation to a referral to
arbitration are substantive. As a purely conceptual matter, there is no basis to
distinguish time limits at the two stages of the grievance arbitration process.
The fact that there is no statutory power under Section 48(16) of the Labour
Relations Act does not transform compliance with the time limit for referral to
arbitration into a substantive arbitrability matter. Whether time limits have been
met still goes to procedure, not substance, and procedural requirements may be
waived. Substantive arbitrability, in contrast, involves a fundamental issue of
jurisdiction.
[37] In Re Ontario Power General and Society of Energy Professionals (Health
Statements Grievance), supra, an issue of substantive jurisdiction was raised in
closing arguments, after the completion of a four-day hearing on the merits.
Specifically, the Employer argued that the grievance – which challenged the
Employer’s requirement to have applicants for employment complete a detailed
health questionnaire – was inarbitrable because the Union did not, and could not,
represent applicants. The arbitrator concluded at par. 5 that as applicants, “they
are not covered by the Society collective agreement and the Society would
appear to have no right to speak on their behalf.” Accordingly, there was “no
possible foundation for the grievance and nothing over which I could possibly
have jurisdiction.” While the arbitrator was highly critical of the employer for
bringing such a motion “extremely belatedly”, he nonetheless determined that it
could not be waived. He concluded at par. 9:
Finally, it is clear that, as a fundamental objection to jurisdiction,
this issue is one that can be raised at any time. The strong
majority of the case law concludes, rightly in my view, that such
objections can neither be waived nor made the subject or an
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estoppel by a failure to raise them in a timely way…. Jurisdiction
is a matter of law, not equity, and while an employer can expressly
agree not to pursue a specific jurisdictional point or, indeed, can
expressly agree to confer on an arbitrator certain kinds of
jurisdiction that he or she might not otherwise possess, it cannot
be held to have doe so simply by an act of omission or by a failure
to raise an objection at an early stage in the proceedings.
[38] To the same effect is the decision of Vice-Chair Mikus in Re OPSEU (Dales),
supra, and Arbitrator Knopf in Re Atomic Energy of Canada Ltd. and Society of
Professional Engineers and Associates, supra.
[39] In this case, there is no dispute that the subject matter of the grievance is
substantively arbitrable. The only issue is the timeliness of the referral to
arbitration. As a procedural matter, as opposed to a substantive one, objection
to the timeliness of the referral may be waived.
[40] Consequently, I must determine whether the Employer waived its objection to the
Union’s late referral to arbitration in this case. Applying the Board’s
jurisprudence to the facts of this case, I conclude that it did waive any objection it
might have raised.
[41] The notion that the Employer did, in fact, take a “fresh step” when it agreed to
schedule the grievance for hearing, without raising any objection, is consistent
with the authorities. In Re OPSEU (Union Grievance), supra, Vice-Chair Herlich
was faced with an objection that the grievance was not filed in a timely manner
(as opposed to an untimely referral to arbitration) and should be dismissed. The
Union responded that the grievance was a continuing grievance and, therefore,
was in fact timely. It also asserted that the Employer waived any right to object
to the timeliness of the grievance because it had scheduled the matter through
the Joint Review Process. The Board accepted both reasons for denying the
Employer’s preliminary objection.
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[42] On the issue of waiver, the Board quoted, at par. 27, from Brown & Beatty,
Canadian Labour Arbitration, regarding the doctrine of “waiver of procedural
irregularities”:
In its application, waiver is a doctrine that parallels the one utilized
by the civil courts known as “taking a fresh step”, and hold that by
failing to make a time objection and by “treating a grievance on its
merits in the presence of a clear procedural defect, the party
waives the defect.” That is, by not objecting to failure to comply
with mandatory time-limits until the grievance comes on for
hearing, the party who should have raised the matter earlier will
be held to have waived non-compliance, and any objection as to
arbitrability will not be sustained. …Where, however, the objection
to timeliness is made at the earliest opportunity, even if it is not
made in writing, it will preclude a finding that the irregularity was
waived.
[43] In that case, the evidence established that the grievance was filed on October
15, 2003. No Stage Two meeting was held and there was no Employer response
to the grievance. On November 28, 2003, the Union advised the Employer and
the Registrar of the GSB that it was referring the grievance to arbitration. On
June 9, 2004, the matter proceeded to the Joint Review Process under the
collective agreement and a hearing date of December 14, 2004 was scheduled. It
was adjourned and then rescheduled for March 22, 2005, and the Employer first
raised the issue of timeliness on March 14, 2005.
[44] Vice-Chair Herlich determined at par. 42 that “[t]here is no doubt in my mind that,
in the present case, the Employer’s participation in the Joint Review Process as
contemplated by Article 22.17 of the collective agreement and described therein
as ‘an integral part of the dispute resolution mechanism’ constituted a fresh step
in the proceedings.” He continued: “At a minimum, the Employer’s failure to raise
any timeliness issue for the period of approximately 1-1/2 years between the
filing of the grievance and the eve of the hearing before me requires some
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compelling justification to avoid the conclusion that the Employer has waived its
right to raise any timeliness objection.”
[45] Based on the facts there, he found no such justification. The Employer learned
nothing new in the Union’s particulars that would have alerted the Employer, for
the first time, that a timeliness issue existed. He concluded at par. 49:
In other words, on March 14, 2005 the Employer was in no better
position to raise a timeliness objection than it had been on
October 15, 2003. And (apart, of course, from the imminent
commencement of the arbitration proceedings) neither did it
suddenly face any more pressing urgency to do so. In the interim,
it had foregone any opportunity to raise the issue either during the
grievance procedure or during the Joint Review Process or by way
of any other less formal communication between the parties.
[46] Applying the holding reached in Re OPSEU (Union Grievance) to the facts of this
case, as I am required to do under Re Blake et al. and Amalgamated Transit
Union, GSB No. 1276/87 (Shime, 1988), I conclude that the Employer waived
any objection to the timeliness of the referral of the grievance to arbitration. The
Employer knew, at the time of the referral, that the referral was late. It knew that
at the joint file review process, when the hearing was scheduled. It learned
nothing new from the Union’s particulars in terms of the late referral that it did not
know earlier.
[47] To the same effect is the recent decision in Re Amalgamated Transit Union-
Local 1587, supra. In that case, Vice-Chair Dissanayake dealt with the issue of
waiver in the context of a late referral to arbitration. In his ruling he proceeded
“on the assumption, without determining, that the time limit for referral to
arbitration in the collective is mandatory” and could be waived. No argument was
raised that it was a jurisdictional issue. Vice Chair Dissanayake determined at
par. 28, that waiver need not be explicit, but may be inferred by conduct. He
described the test as an “objective” one – “was it reasonable for the Union, in all
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of the circumstances, to conclude that the employer would not be objecting on
the basis of time limits?” If so, “then intention to waive time limits would be
inferred.” Based on the facts there, he determined that the Employer had waived
any objection.
[48] This approach requires the Employer to raise objections to arbitrability based on
an untimely referral to arbitration at the Joint File Review (JFR) process, or prior,
before a “fresh step” is taken. Although it has been my understanding that the
focus of the JRF process involves the administrative action of scheduling and,
given the volume of cases, both sides may not turn their minds to a case until
shortly before the hearing, as occurred here, after Re OPSEU (Union Grievance),
the Employer was on notice that the GSB viewed scheduling a hearing at JFR as
a “fresh step” as it relates to the doctrine of waiver. While the Employer may
have viewed that decision as applying strictly to objections based on the
timeliness of filing a grievance, as opposed to referrals to arbitration, it is my view
it must apply in both situations.
[49] Therefore, based on the facts and jurisprudence, it is my conclusion that the
Employer waived its objection to the timeliness of the referral by taking a “fresh
step.”
Conclusion
1. The timely referral of a grievance to arbitration is a procedural matter, and
therefore may be waived.
2. The Employer, based on GSB case law, waived its objection to the Union’s
delay in referring the grievance to arbitration.
3. Accordingly, the Employer’s preliminary motion to dismiss the grievance must
be dismissed. The matter is referred to the Registrar for scheduling a hearing
on the merits.
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Dated at Toronto this 23rd day of May 2012.
Randi H. Abramsky, Vice-Chair