HomeMy WebLinkAbout1977-0058.Kober.78-05-2558/77
‘C~bWb4 EMPLOYEES 416/598 0688 Suite 2166
GRIEVANCE SETTLEMENT 18O~Dundas Street West
BOARD TORONTO, Ontario
MSG lZ8
Between:
Before:
For the Grievor:
IN THE MATTER OF AN ARBITRATION'.
Under The
CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Mrs. Josephine. Kober
And
(Grievor)
Ministry of Solicitor General (Employer)
Prof. J. R. S. Prichard Vice-Chairman
Mrs. Mary Gibb Member
Mr. Harry Simon Member
Mr. M. Campbell
Representative
Ontario Public Service Employees Union
For the Employer:
Mr. Dennis W. Brown
Counsel
Ministry of Attorney General
Hearinq:
April 20, 1978
Suite 2100, 180 Dundas St. West
Toronto, Ontario M5G 128
In this grievance, the grievor, Mrs. Josephine Kober, alleges
that she was required to take a leave of absence against her wishes
and that this requirement was in violation of the provisions of the
collective agreement 'regarding maternity leave. She seeks compensation
for the period of time from when she was required to take her leave of
absence to when she would have voluntarily gone on maternity leave.
The relevant provisions of the collective agreement are found
in Article 11 of the benefits agreement.
ARTICLE 11 - MATERNITY LEAVE
11.0 A Deputy Minister shall grant leave of absence
without pay and without accumulation of credits
for the purpose of childbirth to a female employee who has
served mOre than one (1) year including service as a Crown
employee immediately prior to her appointment to the Civil
Service.
11.1 The leave of absence shell be in accordance with
the provisions of the Employment Standards Act.
11.2 A female employee returning from a leave of
absence under Section 11.0 to the Ministry in
which she was employed immediately prior to such leave shall
be assigned to her former classification and be paid at the
step in the salary range that she had attained when the leave
of absence was granted.
The relevant sections of the Employment Standards Act which are expressly
incorporated by Article 11.1 of the agreement are:
PARTXI
PREGNANCY LEAVE
35. No employer shall terminate the employment of or Pregnancy
lay off an employee who is entitled to a leave of absence leave
under section 36, but .the employer may require the employee
to commence a leave of absence pursuant to section 36 at
such time as the duties of her position cannot reasonably
be performed by a pregnant woman or the performance of her
work is materially affected by the pregnancy.
1974, C. 112, s. 35.
36.-(l) An employee who is pregnant and who has been employed When leave
by her employer for a period of at least twelve zonths and to be
eleven weeks immediately preceding the estimated day of her taken
delivery, whether such employment commenced before or after
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the coming into force of this Act, shall be entitled upon
her application therefor to a leave of absence of at least
seventeen weeks from her employment or such shorter leave
of absence as the employee~may request conimencing during
the period of eleven weeks immediately preceding the esti-
meted day of her delivery.
(2)Notwithstanding subsection 1 and subject to sub- Leave after
section 5, where the actual date of her delivery is later delivery
than the estimated day of her delivery, the leave of absence
shall not end before the expiration of six weeks following
the actual date of her delivery.
(3)The employee shall give her employer two weeks notice Notice
in writing of the day upon which she intends to commence her
leave of absence and furnish her employer with the certificate
of a legally qualified medical practitioner stating that .she is
pregnant and giving the estimated day upon which delivery will
occur in his opinion.
(4)Subject to subsection 5, en employee may, with the Leave
consent of her employer, shorten the duration of the leave may be
of absence requested under subsection 1. shortened
(5)An employee may shorten the duration of the six week Furnishing
period mentioned in subsection 2 upon giving her employer one of
week's notice of her intention so to do and furnishing her certificate
employer with the certificate of a legally qualified medical
practitioner stating that she is able to resume her work.
1974, C. 112, s. 36.
37. An employee who does not apply for leave of absence LeaYe
under section 36, and who is otherwise entitled to pregnancy where
leave thereunder, shall be entitled to and shall be granted employee
leave of absence in accordance with section 36 upon providing ceases work
her employer before the expiry of two weeks after she ceased
to work with a certificate of a legally qualified medical
practitioner stating that she was not able to perform the
duties of her employment because of a medical condition arising
from her pregnancy, and giving the estimated day upon which,
in his opinion, delivery will occur or the actual date of her
delivery. 1974, C. 112, 5. 37.
38.-(l) An employee who intends to resume her employment Reinstatement
on the expiration of a leave of absence granted to her under and preserva-
this Part shall so advise her employer and on her return to tion of senior-
work her employer shall reinstate the employee to her position ity
or provide her with alternative work of a comparable nature at
not less than her wages at the time her leave of absence began
and without loss of seniority or benefits accrued to the commence-
ment of her leave of absence.
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(2) Where the employer has suspended or discontinued Idem
operations during the leave of absence and has not resumed
operations upon the expiry thereof, the employer shall,
upon resumption of operations, reinstate the employee to
her employment or to alternate work in accordance with an
established seniority system or practice of the employer in
existence at the time her leave of absence began with no
loss of seniority or benefits accrued to the commencement
of her leave of absence, and in the absence of such a
system or practice shall reinstate the employee in accord-
ance with subsection 1. 1974, c.112, s.38.
39. Where an employer fails to comply with the provisions Employment
of this Part, an employment standards officer may order standards
what action, if any, the employer shall take or what he officer may
shall refrain from doing in order to constitute compliance 'make order
with this Part and may order what compensation shall be paid
by the employer to the Director in trust for the employee.
1974, C. 112, s. 39.
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The grievor, Mrs. Kober, was employed as a security officer by the
Ontario Government Protective Service (OGPS). She first joined the OGPS in
September, 1974 and worked at that job continuously until December 9, 1976
except for a two month period during which she voluntarily transferred to
another position with the Ontario Provincial Police. The OGPS are the
security service responsible for patrolling and protecting certain government
buildings in Toronto including the Parliament Buildings, Queen's Park complex,
Osgoode Hall and OPP Headquarters. The OGPS consists of 137 employees,
approximately 8 of whom are women.
In October, 1976, the grievor became aware that she was pregnant and
on November 17 she met with Chief Inspector Pierce, the head of OGPS, to
explain the fact of her pregnancy and to get his advice about how long she
might continue to work while pregnant. While there is some dispute as to
the substance‘of that meeting,it is clear that the grievor indicated a desire
to continue working through a substantial portion of her pregnancy, perhaps
with some modification of her duties.
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On December 7, Inspector Pierce learned from his subordinate, Mr.
Williamson, that Mrs. Kober had told him that she could no longer wear
her security officer's uniform due to her pregnancy and that her doctor had
advised her not to wear tight fitting clothes. As a result she could only work in
plainclothes. Inspector Pierce reacted to this news by concluding that
since, in his mind, wearing a uniform was a prerequisite to doing the job of
a security officer, the grievor should be required to take a leave of
absence inmediately for the duration of her pregnancy. He prepared an order
to that effect (Exhibit 11) and had it served on the grievor on-December 9.
The grievor has not worked with OGPS since that date.
Although it is not relevant to the grievance, it is useful
to state for purposes of clarification that the grievor voluntarily declined
to rejoin OGPS after the birth of her child on June 8, 1977. Although two
or three opportunities to begin work .again were offered to her subsequent
to the date of birth, the grievor was unable to make satisfactory child
care arrangements and therefore resigned from OGPS in August, 1977. The
grievance does not relate to this post-birth period.
On January 12, 1977 Mr. Williamson wrote to the grievor asking:
"Would you be good enough, at your earliest convenience, to give me the date
that you will commence Maternity Leave. That is to say 11 weeks before the
expected date of birth of your child. Such information must be supported
by a Medical Certificate please." (Exhibit 16). On February 11, the grievor
submitted a medical certificate from her doctor saying in full: "This is to
certify that Mrs. Kober is 22 weeks pregnant. The pregnancy is normal and
Mrs. Kober is fit to resume her regular duties until the end of March."
(Exhibit 13). Following receipt of this certificate Inspector Pierce wrote
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to then grievor saying:
“It is our opinion that before a decision is made
in connection with your proposed return to duty with the OGPS, that all
of the ramifications should be discussed with your doctor, I hereby request
your permission to confer with your doctor in this connection." (Exhibit 12).
The grievor responded by letter (Exhibit 14) on February 21 denying Inspector
Pierce permission to confer with her doctor stating that it was her union
representative's view that there was sufficient information in the medical
certificate previously submitted.
At the hearing, the union produced a further medical certificate
from the grievor's doctor dated April 13, 1978 stating (Exhibit 10):
"With respect to your inquiry dated April 12, 1978, Mrs. Josephine Kober
did have a perfectly normal pregnancy, She did not suffer from any complica-
tions due to pregnancy. She was medically fit to perform her duties in
December, 1976 and in all probability she should have been able to continue
her job until February, 1977 (i.e. 26 weeks)."
At the hearing it was agreed by counsel that the employer should
proceed first. Inspector Pierce was the only witness called for the employer.
The union called the grievor and Mrs. E. Younie, another security officer
with OGPS. The oral evidence related to: (1) the duties of a female
security officer; (2) the reasons why Inspector Pierce decided to require
the grievor to begin her leave on December 9; and (3) the flexible treatment
previously accorded other employees of OGPS suffering from physical
disabilities. The substance of the relevant aspects of this evidence
is discussed below in the context of the application of Article 11 of the
collective agreement.
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The grievance turns on a proper understanding of Part XI of the
EmplOyment Standards Act, 1974, 5. O. 1974 C. 112 which is expressly incorp-
orated into the collective agreement by Article 11.1. The employer relies
on section 35 which states:
No employer shall terminate the employment of or lay off
an employee who is entitled to a leave of absence under
section 36, but the employer may require the employee
to commence a leave of absence pursuant to section 36
at such time as the duties of her position cannot reason;
ably be performed by a pregnant woman or the performance
of her work is materially affected by the pregnancy.
In particular, the employer argued both that the duties of a security officer
"cannot reasonably be performed by a pregnant woman" and that the performance
of the griever's work was "materially affected by the pregnancy".
Furthermore, the employer argued that some guidance as to when "the
duties of.her position cannot reasonably be performed by a pregnant woman" can be
derived from section 36 of the Act which states the period within which a pregnant
employee is entitled to commence a leave of absence on her own initiative. Section
36 provides that the employee "shall be entitled upon her application therefor to
a leave of absence of seventeen weeks from her employment or such shorter leave of
absence as the employee may request commencing during the period of eleven weeks
imnediately preceding the estimated day of delivery". The employer argues that
reasonableness in section 35 is thus being statutorily defined as a minimum eleven
week period preceding the date of birth and that the employer can rely on this
eleven week period in assessing whether or not the duties can reasonably be per-
formed by a pregnant woman. The employer did not, of course, argue that this
eleven week period was the earliest date at which the employer may require
the employee to take a leave of absence for in this particular case the leave
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was required approximately 24 weeks prior to the expected date of birth.
The union takes a different view of the provisions of the Employment
Standards Act. It argues that the sections were enacted to protect the
employee from unfair dismissal or layoff and should be read within the basic
prohibition of section'35 that "no employer shall terminate the employment of
or lay off an employee" who is pregnant and has been employed for the requisite
qualifying 64 weeks. Furthermore, the union argued that the employer must
bear the onus of demonstrating that the exception provided in section 35 applies
to the job or the employee in question. The union also disagrees with the
employer's view of the relevance of the eleven week period arguing that that
times-,period is designed solely to provide a framework of choice for the
employee, not the employer.
With respect, we find greater merit in the union's position. For
the purposes of deciding this grievance and for the benefit of the parties in
future applications of Article 11, we have set out below our views as to the
proper interpretation of the provisions.
The purposes of maternity leave provisions have been described in
general terms as follows:
The basic aims of childbirth leave for workers are to
provide a period of leave from work, long enough to
accommodate the employee's needs but short enough to
satisfy the employer's interest in continuity of his or
her work force, during which time the job of the absent
employee will be kept available: the entitlement to re.sume
the same or a comparable position with no loss of accumulated
fringe benefits and no reduction in wages; and protection
against dismissal for pregnancy. (Cook & Eberts, "Policies
dffecting Work" in Cook, Opportunity for Choice (1976) pp.
143 - 202 at 169)
A majority of the thirteen jurisdictions in Canada have adopted
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childbirth leave legislation similar to that in Part XJ of the Ontario
Employment Standards Act. Cook and Eberts trace the development of the
legislation:
British Columbia was the first jurisdiction to enact such
legislation; the Maternity Protection Act passed there
in 1921 grew directly out of the Maternity Protection
Convention of the International Iabour Organization.
The 1921 Act indicates the expectation of the British
Columbia legislature that passage of similar legislation
by other jurisdictions in Canada would soon be forthcoming,
but it was not until forty-three years later, in 1969, that
New Brunswick became the second Canadian jurisdiction to
make provision for leave legislation of general application.
Ontario, the federal government, Manitoba, Nova Scotia and
Saskatchewan acted in the years 1970 to 1973 to establish
legislation (p. 170: footnotes omitted).
Ontario first provided for maternity leave in section 9 of
the WC, S.O. 1970, c.33. The
leave provisions were moved to the Employment Standards Act by
S.O. 1972, c.119 and were amended and reenacted in the 1974 revisions
Of the Employment Standards Act.
Under section 35 the Ontario legislation if the employer wishes
to require a pregnant employee to take a leave of absence at any time
prior to the date of childbirth, he must demonstrate that either (1) the
duties of her position cannot reasonably be performed by a pregnant
employee or (2) the performance of her work is materially affected by the
pregnancy. It should be pointed out that the two tests are different in
nature. The first relates not to the individual employee but rather to
a class of employees defined by their pregnancy. In this sense it is a
generic text which the employer must meet by demonstrating an incompatability
of pregnancy and the job in question irrespective of the performance of the
particular employee. The second test is employee - specific; it demands
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that the employer demonstrate that the performance of the particular
employee was materially affected by her pregnancy.
It is our view that the employer must bear the onus of proof
for both of the tests. This allocation of the onus is~~,_implicit in the
only reported case construing an analogous maternity leave provision in
a collective agreement (Re United Coperatives (19751, 10 L.A.C. (Zd) 396
(weatherill) and is supportable by analogy to requiring an employee to
take sick leave [See Niagara Regional Bd. of Comm'rs of Police (1975).
9 L.A.C. (Id) 272 (Swan); Brown &Beatty, Canadian Labcur Arbitration
(1977) pp. 310 - 312 and cases cited therein). While it may have been
clearer if the legislation had specifically allocated the onus to the
employer asdoesthe Saskatchewan L&our Standards Act, 1969, as amended
by S.S. 1973, c.51, s. 50.4, the statutory silence on the issue in
Ontario is consistent with our finding.
In meeting this onus we reject the employer's argument that
the employer can rely on the eleven week period prior to childbirth
defined by section 36 as evidence of a reasonable time at which to require the
leave of absence. Given their plain meaning, sections 35 and 36 offer
no such interpretation. The eleven week period defines the earliest
point the employee may elect to leave; it leaves open to the employee
the right to stay at work until the date of birth subject to the
employer demonstrating either the generic or the specific test of section
35. Furthermore, to read the sections as suggested by the employer
would appear to be inconsistent with the legislative intent as demon-
strated by the statutory history of the provisions. One important
amendment introduced to the Ontario legislation in 1974 was an increase
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in the length of the pre-childbirth period in which the employee was
free to elect to take a leave of absence; the period was extended from
six weeks to eleven weeks. To accept the employer's argument would be
to find a corresponding legislative intent to reduce the employee's
protection from a forced leave of absence. We reject such a finding.
Viewing the evidence in this framework, the employer's case
can be seen as relying primarily on the generic test; that is, the employer
argued that the duties of an OGPS security officer cannot reasonably
be performed by a pregnant woman. The employer argued that the point
during the pregnancy at which the incompatability arises is the point
at which the employee is unable to wear her uniform. In this case,
the grievor was unable to wear her uniform on December 7 and thus the
employer argued that the required leave of absence on December 9 was
justified.
Apart from the inability to wear her uniform, there was no
evidence suggesting that the grievor's work was in any way affected by
her pregnancy. Furthermore, the grievor's medical certificate indicated
her fitness to work through to the end of February. The employer argued
that it was effectively barred from producing employee-specific evidence
of the grievor's medical condition because of her refusal to allow
Inspector Pierce to consult with her physician. The employer's concern
was that unless the physician fully understood the grievor's duties,
her opinion as to the grievor's ability to continue work could not
usefully be relied on. However, the grievor testified that she gave
her physician a full description of her duties and that the medical
certificate was prepared in light of these duties.
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While we are not convinced that the employee should have prevented
the employer from conferring with her physician, her failure to do so is not
fatal to her grievance. As the union pointed out, the employer could have
relied on Article.13.8 to require the grievor to undergo a medical examination
by a physician selected by the employer. While we are of the view that a
more co-operative approach on the part of the employee may have been in the
best interests of both parties as it would have met the employer's needs
while respecting the employee's choice of physician, the outcome of this case
is not affected by the grievor's refusal.
The employer presented four reasons relevant to the generic test
to justify the forced leave of absence. The first relates to the uniform;
to quote from Exhibit 5, the employer stated: "Because your pregnancy
prevents you from wearing your uniform and because the wearing of a uniform
is a requirement of your position, you are therefore unable to fulfil
the requirements of your position". The second reason relates to a
concern for the employee; to quote from Exhibit 8, the employer stated:
"The high potential of exposure to hazardous situations associated with
the duties of a security officer represent a latent risk to your health and
to the life of your unborn child". The third reason relates to the duties
of a security officer; in particular, the employer argued that a security
officer must be prepared to use force in the execution of her duties
and that a pregnant officer would be unable or unwilling to do so.
The fourth reason relates to the range of jobs within the OGPS; the
employer argued that there were no positions in the OGPS with less
demanding duties to which the grievor might have been assigned for the
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duration of her pregnancy.
After hearing and considering the evidence, we find that none
of the reasons are adequately supported by the evidence, and that as a
result the employer has failed to meet its onus.
Regarding the first reason - the uniform - the evidence
indicated that in numerous cases the employer's conduct had been
inconsistent with the reasons offered. The grievor and Mrs. Younie
offered unchallenged evidence that in several situations security
officers had worked in plainclothes. Indeed, the grievor herself and
Mrs. Younie both worked for 3 - 4 months in 1974 without uniforms
following their joining the OGPS. Although the reasons for the plain-
clothes incidents varied, it was clear that while the uniform is
conducive to the work of the OGPS, exceptions can and have been made
to meet special temporary needs. In our view, pregnancy presents one
such need.
Regarding the second reason - concern for the health of the
mother and unborn child - the evidence failed to indicate that the work
of a female security officer involved "a high potential of exposure to
hazardous situations." Although the position specifications (Exhibit 9)
indicate that the job may involve certain hazards including the carrying of
firearms while providing security for money escorts, it became clear from
the evidence that female security officers are excluded from situations
involving hazards whenever possible. As a result, the grievor was never
involved in a situation involving physical contact in her over two years
with the OGPS. Similarly, Mrs. Younie's experience was limited
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to one situation of some physical contact (being shoved by a senior
civil servant) in her time with OGPS. The majority of a female
security officer's work appears to be the provision of information
to the public and it is an overstatement to describe it as having a high
potential for hazard.
This is not to say that there is not some potential hazard
involved in the job. Clearly there is. It is simply a finding that
given the structure of the security service and the duties assigned to
female officers, the potential is relatively modest and not incon-
sistent with pregnancy. It is certainly not sufficiently hazardous
to deny to the pregnant woman the right to choose the best course of
action for herself and her unborn child. We are of the view that the
hazards are sufficiently minor that the question of leave based on this
reason is best left to the self-determination of the employee.
The third reason - the need to be willing and able to use
force-is also not supported by the evidence. Experience with the OGPS
indicates that it is extremely unlikely that a female officer will be
called on to use force in the exercise of her duties and that in almost
all situations where she might be, some alternative solution is possible 9
if not preferable. The evidence of the grievor and Mrs. Younie was that
neither of them had ever been called upon to use force or exercise their
powers of detention and search under the Public works protection Act.
(The Case Of Regina & Pacific Western Airlines Ltd., 75 CLLC 14,287 (Prov.
ct., B.C.) construing the analogous provision in the Canada ~abour Code
is indirectly relevant to the employer's argument on this point. In our
view, however, our decision is not inconsistent with the PWA case. -
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The fourth reason - the absence of alternative jobs - was also
not supported adequately by the evidence. Indeed, it was on this point
that evidence most damaging to the employer's case was produced. It
appears that over the past three years there have been a number of situa-
tions in which persons with physical disabilities have been assigned to
the desk and radio job at Queen's Park to accommodate their temporary
inability to wear a uniform and/or to move about freely. The cases of
Groves, Prentice, Younie and Johnston are representative in this regard.
Inspector Pierce was emphatic in stating that each of these
cases occurred without his knowledge and that in future he did not intend
to permit it. Without disputing that evidence, however, the situations are
clear evidence of the potentialfor flexibility in work assignments to
accommodate special needs and in our view it would be unfair and unjust to
deny similar treatment to a pregnant employee if and when she may need it.
In sum, therefore, we find that the employer has failed to meet
the requirements of section 35 and thus of Article 11 of the collective
agreement, in that it has not been demonstrated that the duties of a
security officer cannot reasonably be performed by a pregnant woman or
that the performance of the grievor's work was materially affected by the
pregnancy.
We wish to stress that by this decision we do not mean to in
any way detract from the importance of the work performed by the OGPSor the
professional manner in which it is carried out. Rather, we are simply of the
view that the work of the OGPS and of security officers within it will
not be impeded by a pregnant officer. We believe that there
can be sufficient flexibility in the OGPS to accommodate the needs of a
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pregnant officer. We are aware that this is the first case of an
employee of OGPS becoming pregnant since women first joined the
service in 1974 and we are hopeful that the experience with this
first case will be of assistance to OGPS in handling future cases.
With respect to the remedy for the grievor, she is entitled to
her wages for the period she would have worked between December 9 and
the date she would have ceased work voluntarily. Unfortunately there is
some ambiguity as to this latter date. While the employee's first medical
certificate (Exhibit 13) indicated she could work to the end of March,
her second certificate (Exhibit 10) indicated that she would have been
able to continue her job until the end of February. Since the grievor
offered no explanation for this difference between the two certificates,
we find that her compensation should be limited to the end of February.
We retain jurisdiction on the amount of compensation payable for the
period from December 9, 1976 to February 28, 1977, if the parties are unable
to reach agreement.
Dated at Toronto this 25th day of May 1978.
J. Robert S. Prichard Chairman
I concur
Mary Gibb Member
I concur
Harry Simon Member