HomeMy WebLinkAboutHughes 24-05-29
In the Matter of an Arbitration
Under the Labour Relations Act, 1995
BETWEEN:
Ontario Public Service Employees Union Local 250
(THE “UNION” or “OPSEU”)
AND
Bruce County
(THE “EMPLOYER”)
(Re: Grievance of Allicia Hughes)
Before: Adam Beatty, Sole Arbitrator
Appearances
For the Union
Richard Dionne – Grievance Officer
Allan Rogers – Chief Steward
Allicia Rogers - Grievor
For the Employer
Victoria McCorkindale - Counsel
Jenn Robinson – Director of Human Resources
Steve Schaus – Director and Chief Paramedic Services
This hearing was held via videoconference on May 3, 2024.
AWARD
Introduction
1. At issue is whether the Employer is required to pay short term
disability (“STD”) benefits for an illness or injury where an employee has
made a claim to the Workplace Safety and Insurance Board (“WSIB”) for
that same illness or injury and is awaiting a decision on that claim.
2. The parties proceeded by way of an Agreed Statement of Facts
(“ASF”). No other evidence was called.
3. The Grievor, Ms. Allicia Hughes, was hired by the Employer on or
around March 3, 2014 as a part-time paramedic. The Grievor became a full-
time paramedic on or around November 3, 2021.
4. On or around November 3, 2022 the Grievor went on a medical leave.
When the Grievor went on leave she also made a claim to the WSIB. As part
of making a claim to the WSIB, the Grievor had to submit medical forms,
including a “Health Professional’s Report (Form 8)”. Through no fault of her
own, there was a delay in getting the Form 8 completed. The Grievor made
repeated efforts to have the Form 8 completed and sent in to her Employer
so it could be provided to the WSIB. The Grievor continued to provide the
Employer with updates on her situation. Unfortunately, the Form 8 was not
sent to the Employer until December 21, 2022.
5. On December 11, 2022, the Grievor asked if she could be paid under
the STD plan while she tried to have her WSIB claim processed. The
Employer responded the next day advising the Grievor that she could not be
paid under the STD plan while she had a WSIB claim pending. That is the
decision that is the subject of the current grievance.
6. On April 21, 2023, approximately six months after first going on leave,
the Grievor’s WSIB claim was approved. The Grievor was awarded full loss
of earnings dating back to November 7, 2022. The Grievor was without pay
throughout the entire period from when she went off on a leave until her
WSIB claim was approved.
Issue
7. As described above, the issue in this grievance is whether the decision
to deny the Grievor STD payments while she waited for her WSIB claim to
be determined violated Article 18.05 of the Collective Agreement. Given its
centrality to the issue in dispute, I will reproduce Article 18.05 in its entirety.
Article 18.05 states as follows:
18.05 Short Term Sick Leave Plan
The Corporation will provide, to eligible permanent full-time
employees who have completed three (3) months of their
probationary period, a short term sick leave plan.
a) Absence due to illness or injury, compensable by the Workplace
Safety & Insurance Board, shall not be charged against sick
leave entitlements.
b) Each claim of sick leave shall be supported by a certificate from
a qualified medical practitioner provided, however, that such
certificate shall not be required if the period of such absence is
not more than three (3) days. On the fourth (4th) day of illness
in any calendar year, such certificate will automatically be
required. Each illness thereafter, in such calendar year, may
require a doctor's certificate on a case by case basis.
c) Each eligible permanent full-time employee who has completed
his/her probationary period will be entitled to one (1) week of
sick leave at 100% of salary and fourteen (14) weeks of sick
leave at 60% of salary during the first year of service.
d) In each succeeding year of continuous service as a regular full-
time employee, an additional week of sick leave at 100% of
salary will be granted. The maximum allowable under the plan
will be ten (10) weeks of sick leave at 100% of salary and five
(5) weeks of sick leave at 60% of salary. A year shall commence
on the first pay of each calendar year.
e) Weekly earnings for employees paid by the hour will be
calculated on the basis of the employee's normally scheduled
workweek paid at their regular straight time rate.
f) For the purpose of this provision, "sickness", shall mean a
physical or mental disability, which renders the employee
incapable of fulfilling the normal requirements of his/her job.
g) Unused portions of sick leave will not accumulate from year to
year under any circumstances, and there shall be no cash
payout.
h) Employees will arrange all medical appointments (with the
exception of Specialists) to be taken on their scheduled days off.
The onus is on the employee to provide proof of appointment
acceptable to the Shift Supervisor ie. Doctor's note or
Appointment card.
Position of the Union
8. The Union argued that the Grievor was entitled to STD benefits under
Article 18.05 while waiting for a determination of her WSIB claim. The Union
relied on the decision of Arbitrator Surdykowski in Ontario Power Generation
and Society of Energy Professionals, 2015 CanLII 56079 (ON LA) (“OPG”) for
its summary of the principles of interpretation applicable to collective
agreements. In OPG, Arbitrator Surdykowski held as follows:
7. The fundamental rules of collective agreement interpretation can
therefore be summarized as follows:
(i) the words used must be given their objective plain and ordinary
contextual labour relations meaning;
(ii) all words must be given meaning, and different words are
presumed to have different meanings unless this would lead to a
result that is illegal, absurd or inconsistent with the overall
scheme and structure of the collective agreement.
(iii) words or phrases cannot be inferred unless they is [sic] essential
to the purposive operation of the collective agreement, or to
make the collective agreement consistent with mandatory
legislation which constitutes the statutory labour relations
framework in the jurisdiction.
10. The Union acknowledged that Article 18.05 did not explicitly state that
employees were entitled to STD benefits while waiting for a WSIB claim to
be determined. However, according to the Union, the Grievor met the
requirements for STD benefits under Article 18.05 and there was no
language in that Article (or any other Article) that justified the decision to
deny her STD benefits while she waited for the WSIB claim to be
determined.
11. The Union argued that Article 18.05(a) established that where
absences were eligible for compensation by the WSIB, those absences would
not be charged against sick leave entitlements. The purpose of Article
18.05(a), according to the Union, is to ensure that sick leave entitlements
would not be affected by absences approved for coverage by the WSIB. The
purpose of Article 18.05(a) is not to deny employees STD benefits while
awaiting a determination on their WSIB claims. At the time the Grievor was
told that she was not entitled to STD benefits it remained unclear whether
her absences would be eligible for compensation by the WSIB. As such,
there were no grounds to “disqualify” the Grievor from receiving STD
benefits.
12. The Union submitted that there was no dispute that the Grievor
qualified as having a “sickness” as defined by Article 18.05(f). She had a
diagnosis that rendered her incapable of fulfilling the normal requirements of
her job. The Grievor had also satisfied the requirements of 18.05(b). The
Union argued that she provided the required medical documentation to the
Employer as requested. As such, pursuant to Articles 18.05 (c) and (d), and
given her seniority, the Grievor was entitled to two weeks of STD benefits at
100% of her salary and 13 weeks at 60%.
13. The Union also argued that its interpretation was consistent with the
past practice of the parties. The Union relied on the example of “Employee
B”. According to the ASF, Employee B filed a claim for non-occupational sick
leave and received STD benefits. Employee B then filed a claim for an
occupational illness with the WISB. Upon filing the claim with the WSIB, the
Employer changed their internal coding and no further STD benefits were
paid. The WSIB eventually approved the claim and credited the Employer
for the sick leave paid. The Union argued that the example of Employee B
showed that the WSIB could have reimbursed the Employer for sick leave
that had been paid out if the Grievor’s claim was approved.
14. The Union also argued that the Employer’s interpretation leads to
unintended adverse effect discrimination depending on where and how an
employee became sick. According to the Union, an employee with a
documented injury outside the workplace would have their benefits flow
under Article 18.05 but an employee whose suffered an injury at work
cannot access Article 18.05 and has to wait for the WSIB process to play
out. The Union argued that this could not have been the intention of the
parties.
15. The Union relied on the decision of Arbitrator Knopf in Hamilton Civic
Hospitals and Ontario Nurses’ Association Unreported; September 22, 1986
(Knopf). In that decision, commenting on the possibility of nurses not
receiving benefits while awaiting approval of a Worker’s Compensation claim
(a situation analogous to the situation of the Grievor) Arbitrator Knopf noted
that “a loss of a source of income for any period of time would only add to
the trials and hardships of a disabled nurse and his or her family”. Arbitrator
Knopf also noted that if possible she would adopt an interpretation of the
applicable documents that would “accord with the intent and desirability of
preventing an interruption of earnings in the event of a disability”.
16. Next, the Union relied on the decision of Arbitrator Dissanayake in
Brandt County Healthcare System and Ontario Nurses’ Association, [2007]
O.L.A.A. No. 551. In that decision, Arbitrator Dissanayake interpreted
specific language in the applicable collective agreement as providing income
continuation while awaiting a determination from the WSIB. The Arbitrator
held that the purpose of the relevant article of that collective agreement was
“to bridge the period during which a nurse would otherwise be left without
any income due to possible delay by the WSIB in issuing a final decision on
an application”. The Union argued that Article 18.05 plays the same role in
the Collective Agreement.
17. Finally, the Union relied on the decision of Arbitrator Weatherill in
Bendix Automotive of Canada Ltd. v. U.A.W., Local 195, (1973) 3 L.A.C. (2d)
21. In that decision, Arbitrator Weatherill noted that where entitlements to
Workers’ Compensation may be uncertain, payments of sickness and
accident benefits have been made on the understanding that if the Workers’
Compensation benefits are ultimately paid, the sickness and accident
benefits would have to be repaid.
18. By way of remedy, the Union seeks a declaration that the Employer
has violated Article 18.05 of the Collective Agreement. The Union is also
seeking reimbursement of certain insufficient funds charges the Grievor
received. According to the Union, the Grievor received these charges from
her bank because the Employer’s failure to provide her with STD benefits left
her without income for a significant period of time. Finally, the Union seeks
$5000 for the Grievor for aggravated damages related to the pain and
suffering for the mental distress when the Employer removed her from
payroll pending a determination by the WSIB.
Position of the Employer
19. The Employer agreed with the general approach to collective
agreement interpretation summarized by Arbitrator Surdykowski in OPG.
The Employer also relied on another decision of Arbitrator Surdykowski,
Maple Leaf Consumer Foods (Hamilton Facility) and United Food and
Commercial Workers Canada, Local 175, 2011 CanLII 6860 (ON LA). In that
decision, Arbitrator Surdykowski emphasized that words must be give their
plain and ordinary meaning, all words must be given meaning and different
words should be given different meanings. The Employer highlighted where
Arbitrator Surdykowski wrote that the “rights and obligations of the parties
and bargaining unit employees depend on the specific collective agreement
language in issue.”
20. The Employer argued that there is no basis for the position of the
Union. According to the Employer, Article 18.05 does not include a provision
that permits an employee to collect STD benefits while waiting on WSIB to
determine a claim. Nor does the Employer’s consistent past practice.
21. The Employer submits that there are two streams for sick leave
benefits. Either an employee has a non-occupational illness or an
occupational illness. If it is the former, the claim is processed through
Article 18.05. If it is the latter, the claim is made to the WSIB. The
Employer submits that the Union, and the Grievor, were aware of this
distinction.
22. According to the Employer, the onus is on the Union to establish a
breach of Article 18.05. The Employer argued that the Union has failed to
satisfy its onus. The Employer relied on three arguments in support of its
position.
23. First, the Employer argued that it is well-established principle of
collective agreement interpretation that monetary benefits must be shown in
clear, specific, and unequivocal terms. According to the Employer, there is
no such language in the Collective Agreement.
24. The Employer relied on the following decisions in support of its
position: Canadian General-Tower Limited and United Steelworkers of
America, Local 862, 2011 CanLII 73194 (ON LA) (Surdykowski); , Unifor,
Local 973 and Coca Cola Canada Bottling Ltd., (2022) 337 L.A.C. (4th) 392
(Beatty); and Golden Giant Mine v. U.S.W.A., Local 9364, [2004] O.L.A.A.
No. 600 (Marcotte). In Canadian General-Tower the Arbitrator noted that
“the clear language for economic benefit” principle has been consistently
applied in Ontario. In Coca Cola Canada Bottling Ltd, I held that “clear and
unambiguous language is needed where a union seeks to establish a
financial entitlement in a collective agreement.” In Canadian General-Tower
Arbitrator Surdykowski quoted from the decision in Cardinal Transportation
and C.U.P.E. (1997), 62 L.A.C. (4th) 230 (Devine – B.C.), where Arbitrator
Devine defined the clear language for economic benefit principle in the
following manner:
“Where a monetary benefit is asserted, it normally falls to the Union to
show in clear, specific and unequivocal terms that the monetary
benefit is part of the employee’s compensation package. Such an
intent is not normally imposed by inference or implication …”
Arbitrator Devine also held that where there is an ambiguity in the collective
agreement there “must be clear and cogent evidence that the Employer
intended to infer a monetary benefit.”
25. In Canadian General-Tower Arbitrator Surdykowski also held that the
clear language for economic benefit principle is a necessary corollary to the
principle that “bargaining unit employees are entitled to only those (non-
statutory) benefits that their union is able to extract from the employer in
bargaining”. In that decision, Arbitrator Surdykowski noted that parties are
only entitled to what they have bargained for in the collective agreement.
Albeit in a very different context, Arbitrator Chertkow reached the same
conclusion in Wire Rope Industries and U.S.W.A., Local 3910, (1982) 4
L.A.C. (3d) 323. In Wire Rope, the Arbitrator held that “arbitrators ought
not to impose a monetary obligation on an employer that he clearly did not
bargain to pay” and that arbitrators should “not impose upon an employer
any restrictions … unless it clearly and unequivocally bargained so to do.”
26. Applied to the facts of this case, the Employer argued that by seeking
to be granted STD benefits while awaiting a determination on a WSIB claim,
the Union was seeking an economic benefit that was not clearly spelled out
in the Collective Agreement. The Employer noted that the language of
Article 18.05 does not grant employees the right to claim STD benefits while
waiting for the WSIB to decide their claim. Rather, the Collective Agreement
is silent on that issue. Since there is no such language, bargaining unit
employees are not entitled to the benefit and no such benefit should be
inferred or imposed on the Employer.
27. The Employer also argued that if the Union’s interpretation was
adopted, it could lead to a significant amount of uncertainty with respect to
how employees were paid while waiting for their WSIB claim to be
determined. In particular, it could lead to real financial uncertainty in the
event the WSIB approved a claim after the Employer had already started
provided STD benefits.
28. The Employer noted that if employees were entitled to STD benefits
while awaiting a determination of their WSIB claim, the parties would need a
mechanism for repayment in the event the WSIB claim was approved.
There is no such mechanism in this Collective Agreement. The lack of
language to this effect can be compared to the situation described by
Arbitrator Dissayanake in Brandt County. In that collective agreement, the
parties included language that stipulated that employees would only be
entitled to receive short term disability while waiting for a WSIB claim to be
determined if the employee provided, amongst other things, a “written
undertaking satisfactory to the Hospital that any payments will be refunded
to the Hospital” following a determination of the WSIB claim. The Employer
argued that a minimum, the parties would have acknowledged in the
Collective Agreement the possibility that STD benefits might have to be
repaid in the event of a successful WSIB claim. According to the Employer,
the lack of any such language supports the conclusion that the parties did
not intend employees to be eligible for STD benefits while waiting for a WSIB
claim to be determined.
29. Next, the Employer argued that if the Collective Agreement language
is ambiguous, the past practice, going back to 2017 (three years before the
Collective Agreement took effect) makes it clear that the Employer has not
permitted employees to claim STD benefits while awaiting determination of a
WSIB claim. The Employer noted that it has clearly taken the position that
employees are not entitled to STD benefits while a WSIB claim is
outstanding and that the Union has acquiesced to this position.
30. The Employer argued there is no evidence of any employee continuing
to receive STD benefits after they have made a WSIB claim and are waiting
for a decision on that claim. The Employer did note that there are three
cases going back to 2017 where employees received STD benefits for
occupational illnesses. However, in each of those cases (as set out in the
ASF), the employee received STD benefits because the illness was initially
considered non-occupational (and therefore eligible for STD benefits). Once
the employee applied to the WSIB, the STD payments stopped pending a
determination of the WSIB claim. Finally, there was one employee who was
advanced one day wages under a Letter of Understanding with respect to
“Critical Calls”. The parties agreed in the ASF that the employee in that case
only received the advancement because of the LOU. The LOU has no
application to the facts of this grievance.
31. The Employer also relied on Minutes of Settlement (the “MOS”) agreed
to by the parties on July 8, 2020 in support of its position with respect to
past practice. The MOS stated, amongst other things, that the Employer
would not dissuade employees from applying for WSIB benefits and that if
an employee in receipt of short term disability benefits chose to apply for
WSIB, the Employer would “discuss with the Employee and the Union the
implications of the application and the effect, if any, on the continuation of
short term disability benefits.” The Employer argued the MOS spells out
what the Employer is required to do when employees in receipt of STD
benefits make a WSIB claim. The Employer emphasized that it is required to
have a discussion with the employee and the Union. It is not required,
according to the Employer, to continue the STD benefits.
32. Finally, the Employer argued that the decision not to allow an
employee who has applied for WSIB benefits to receive STD benefits is a
reasonable exercise of management rights. The Employer argued that it had
reasonable operational reasons not to allow STD benefits during the WSIB
waiting period. First, it would provide a greater benefit for part-time
employees because only full-time employees are entitled to STD benefits.
Second, it would also create an administrative burden for the employer
because STD benefits would have to be reimbursed when a WSIB claim was
approved. This would be the case for short-term and long-term WSIB
claims.
33. In terms of remedy, the Employer noted that despite taking until April
2023 to issue its decision, the WSIB did award the Grievor full loss of
earnings benefits backdated to November 7th, 2022. Accordingly, the
Employer argued that the Grievor had been made whole and was not
entitled to any further monetary remedy, regardless of how I determined the
interpretive issue. The Employer argued that the Grievor’s claim for
payment to compensate her for insufficient funds charges should be
dismissed out of hand. According to the Employer, the insufficient funds
charges have no link to the grievance before me and there is no evidence
that the Grievor would not have received these charges if she had received
her STD benefits.
Analysis
Applicable Principles of Interpretation
34. The principles of interpretation are not in dispute. As discussed, in
the awards by Arbitrator Surdykowski referred to by the parties, words
should be given their plain and ordinary meaning. They are to be read in
the context of the specific article and the Collective Agreement as a whole.
All words must be given meaning and words or phrases cannot be inferred
unless they are essential to the operation of the collective agreement, or to
make the collective agreement consistent with applicable legislation.
35. It is also now well-established that provisions of a collective
agreement must be interpreted in light of the surrounding circumstances
known to the parties at the time. The surrounding circumstances include the
labour relations context known to the parties. I agree with the position of
the Employer that rights and obligations in a collective agreement must be
based on the language in the collective agreement and that benefits with a
significant monetary value must be based on clear and unambiguous
language and should not be inferred.
36. With these principles in mind, the question to be answered is the
following: has the Union established that there is clear and unambiguous
language, whose plain and obvious meaning when read in context of the
collective agreement as a whole, and in light of the surrounding
circumstances, including the labour relations context, that the Grievor was
entitled to STD benefits while awaiting a determination of her WSIB claim.
The answer to that question must be no. In short, the Union has not
negotiated that benefit.
37. When read in context, Article 18.05 is silent on the question of
whether STD benefits are payable when an employee has made a claim to
the WSIB in respect of the same illness or injury. I agree with the Union,
that the Grievor satisfied the definition of “sickness” under Article 18.05(f).
However, I am unable to conclude that the Union has established that Article
18.05 entitles the Grievor to STD benefits while awaiting a determination on
a WSIB claim.
38. As set out above, employees are only entitled to those rights and
benefits they have bargained for and monetary benefits are expected to be
expressed in clear unambiguous language. Arbitrators cannot add or imply
rights and obligations into a collective agreement. Put differently, the
parties are bound by what they have agreed to. No more and no less.
39. This conclusion is consistent with the jurisprudence cited by the Union.
As discussed by Arbitrator Dissanayake in Brandt County, in Hamilton Civic
Hospitals, Arbitrator Knopf held that in the “absence of a specific provision in
the collective agreement there was no entitlement to any advance payment
pending the determination of a workers compensation claim.” Arbitrator
Knopf also noted that an illness or injury is either a “compensable accident”
or it is not and that WSIB claims and STD benefits are two distinct paths for
benefits stemming from an absence or illness. Article 18.05 (a) speaks to
this difference and establishes that illnesses or injuries compensable by the
WSIB shall not be charged against sick leave entitlements. In other words,
where an absence qualifies for WSIB benefits, that absence will not be
deducted from the employee’s STD benefits. This makes sense given that
the employee that qualifies for WSIB benefits is not in need of STD benefits.
Both parties agreed that employees are not entitled to “double dip” and
claim both STD and WSIB benefits. A choice between the two options must
be made.
40. Further support for this conclusion can be found by interpreting Article
18.05 in the context of the Collective Agreement as a whole. Here, it is
important to note that the parties did not include any language addressing
the possibility that the Employer might need to be reimbursed in the event
an employee claiming STD benefits was subsequently approved for WSIB
benefits. Put differently, if the Union’s interpretation is correct, and the
Grievor is entitled to STD benefits while awaiting a determination on her
WSIB claim, it would be reasonable to expect the parties to have turned
their mind to the possibility that such STD benefits may need to be
reimbursed to the Employer. As such, the lack of any such language, even
acknowledging the possibility that STD benefits may need to be reimbursed
to the Employer stands out.
41. The lack of any such language is particularly notable when compared
to the decision of Arbitrator Dissanayake in Brandt County. As discussed by
Arbitrator Dissanayake, the parties in that matter added language to address
the gap identified by Arbitrator Knopf in Hamilton Civic Hospitals. In
Hamilton Civic Hospitals, Arbitrator Knopf noted that there was no language
that established that employees were entitled to STD benefits while awaiting
a Workers Compensation claim. According to Arbitrator Dissanayake in
Brandt County, the parties added language in their collective agreement to
fill that gap. While the lack of comparable language in this Collective
Agreement is not, in and of itself, determinative, it is a factor that must be
considered.
42. I also note that this conclusion is consistent with the surrounding
circumstances known to the parties at the time they agreed to the language
in this Collective Agreement. In this regard, the Employer emphasized that,
going back to 2017, no employees had been granted STD benefits while
awaiting a determination of their WSIB claim. More importantly, where
employees first claimed STD benefits and then subsequently decided to
pursue a WSIB claim, the Employer stopped providing STD benefits upon
being notified of the change.
43. It is also consistent with the MOS agreed to by the parties. There the
parties agreed the Employer would discuss the implications of an employee
in receipt of STD benefits electing to apply for WSIB benefits and the effect,
if any, on the continuation of short term disability benefits. It is noteworthy
that here too, the parties did not agree that employees could access their
STD benefits while waiting on their WSIB claim. This omission, like the
failure to include any language in the Collective Agreement speaking to the
possibility that STD benefits may need to be repaid, is a factor that favours
the position of the Employer. Had the parties wanted to grant employees
the right to access STD benefits while waiting on a WSIB claim they could
have done so and could have included such language in the MOS.
44. Finally, I note that the cases relied on by Union do not stand for the
proposition that employees are entitled to STD benefits while waiting for a
WSIB claim to be determined. Both Arbitrator Knopf in Hamilton Civic
Hospitals and Arbitrator Weatherill in Bendix Automotive of Canada Ltd
speak to the desirability, from a policy perspective, of employees having
access to income continuation where an employee is waiting on a
determination of a claim by WSIB. However, Arbitrator Knopf and Arbitrator
Dissanayake also note that while such income continuation may be desirable
from a policy perspective, it must be based on the language of the collective
agreement. Arbitrator Knopf noted that “we cannot accede to the
Association’s request because we find the position compelling, just or
meritorious. We can only allow the grievance if we find it is well founded on
the language of the collective agreement or by the terms of HOODIP.” In
Hamilton Civic Hospitals there was no language establish the right sought.
In Brandt County there was. In the present case there also is no such
language.
45. Accordingly, and for all of the foregoing reasons, the grievance is
dismissed.
Dated at Toronto, Ontario, this 29th day of May 2024.
“Adam Beatty”
___________________
Adam Beatty, Arbitrator