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HomeMy WebLinkAbout1981-0345.Barss.82-01-21 t ONTARIO CROWN EMPLOYEES GRIEVANCE SETTLEMENT BOARD 180 OuNOAS STREET WEST, TORONTO. ONUR10. M5G IZ8-SUITE 2700 TELEPI-IOVE; 4161598-0688 343/81 IN THE MATTER OF AN ARBITRATION Lander THE CRONT EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD Between: OPSEU. (Ms. Helen Barss) Grievor - And - The Crown in Right of Ontario (Ministry of Education) Emplover Before : Mr. 'E. -B. Jolliffe, Q .C . Vice Chairman Mr. J. McManus Member Ms . H.. J.' Laing Member For the Grievor: INir . G. Richards Grievance/Classi=ication Officer Ontario Public Service Employees Union For the Employer: Mr. M. P. :Moran, Counsel Hicks , Morley , Hamilton, Stewart & St:rie Bearings : September 29 and October 1 , 11081 "RE: HINTED - :March 1982 " rA 1 2 - D E C I S I O N The events giving rise to the grievance off Ms . Helen Barss are set out in an agreed Statement of ractsfiled by *_ e parties when this case came on for hearing . The statement , Exhibit 2 , is as follows : 1. Helen Barss is employed by the Province of Cntario in the Ministry of Education. 2. Prior to April 6, 1981, Ms. Barss was employed as a Data Processing Technician at a salary of $286.31 per week. 3. In this position she was required to operate a video display terminal for approximately 4 hours per day. 4. Cn March 30, 1981 Ms. Barss approached her supervisor, Mr. R. Battison, and told him that she was concerned about her own health and that of her unborn child (she was approximately 5 months pregnant at that time.) and that her doctor had recommended that she should not operate a video display terminal. She requested that she not continue operating the V.D.T. 5. Mr. Battison removed Ms. Barss from the V.D.T. and had her perform only the clerical duties of her job pending a decision on her request by his supervisor. The V.D.T. part of her job was performed by other Data Processing Technicians. Mr. Battison explained that he had no authority to grant such a transfer. 6. The following day after consulting with his supervisor Mr. Battison informed Ms. Barss that if she wanted a transfer away from the V.D.T. work she was to put it in writing and attach supporting information. 7. Cn April 3, 1981 Ms. Barss met with qtr. Battison and his supervisor, Mr. Ahrens, at which time she was informed that: - J - a) in response to her temporary transfer request,- t-he branch was prepared to transfer her to a position of records clerk which she had held until April 1, 1979, since she knew that job; b) during the time of the transfer her salary would be $267.34 per week, the maximum rate for that position; c) the transfer would be for the duration of her preg- nanhy at which time she would return to the position of Data Processing Technician. 9. Mr. Ahrens confirmed the arrangement with Ms. Barss at the April 6 meeting, by memo dated April 6, 1981. Copy attached as Schedule 2. 10. Ms. Barss was informed on numerous occasions by Ministry officials that there was no danger to her health or the health of her child, from radiation from the video display tezininal. The schedule attached to the Statement of Facts will be quoted separately. In her grievance dated May 6 , 1981 , Ms . Barss com- plained of "loss of income by virtue of being demoted to Clerk 2 General;=°' and referred to Article 18 .1 in the current collective agreement , which is as follows : The employer shall continue to make reasonable provisicns for the safety and health of its employees during the hours of their employment. It is agreed that both the 2nnlcyer and the union shall cooperate to the fullest extent pcssible in the prevention of accidents and in the reascnnable pro- motion of safety and health of all ecrplcyees. 4 The grievor also referred to Article 5 . 6 of the agreement, which provides as follows : Where, for reasons of health, an employee is assigned to a position in a classification having a lower maximum salary,- he shall not receive any salary progression or salary decrease for a period of six (6) months after his assignment, and if at the end .of that period, he is unable to accept employment in his former classification, he shall be assigned to a classification consistent with his condition. As a remedy, the grievor requested reinstatement in her salary scale as a Data Processing Technician 2 with no pecuniary loss in respect of time worked from the date of "demotion" until she took maternity leave . The sequence of events recited in the Statement of Fact was supplemented by the grievor ' s testimony . First employed in August, 1977, as a filing clerk , she became a Data Processing Technician in April ,, 1979 . In that post she ' spent about half her working day at a Video Display Terminal , here- inafter referred to as "VDT. " In January , 1980 , the grievor learned she was pregnant . However, it was not until March 30 that she saw an article in the Toronto Sun referring to Bell Canada workers who had won transfer to other jobs during pregnancy because of their tear that VDT work would be hazardous to their unborn _ 5 _ chilaren . Ms . Barss promptly consulted her physician , :.r . Gerald Isenberg , who had not previously known about the of her job. A letter dated April 2 from Dr . Isenberg , addressed to "to whom it may concern, " said : "I recommend that Helen Barss be transferred from working on the Video Display Terminals due to pregnancy, and possible risk to the developing foetus . " On April 3 Ms . Barss submitted the doctor ' s recommend- ation to management together with a Letter of her own as follows : To whom it may concern: Due to recent publicity concerning the unknown hazards of video Display Terminal Radiation on the development of the maturing fetus, it is on the recommendation of my doctor's advice that I am requesting temporary removal from exposure to the VDT. Research indicates that there is a wide range of radiation which can escape from the VDT and that there have been recorded cases where this type of incident has occurred. Also, there have been noted instances of "an unusually high rate of birth defects in children of women operating VDT's. " Research has also revealed that "the developing fetus is partic- ularly vulnerable to all forms of radiation". It is for the above reasons that I do not wish to operate the VDT for the remainder of my pregnancy, which will last t:ntil July 3, 1981. I am concerned with the physical development of another human being which has no choice in the matter of exposure to potentially harmful stimuli which is emitted by the Please understand that I am perfectly willing 'to refs-n to work on the VDT after this pregnancy is over. However, I do fee'_ that more testing and research on the effects of the :adiatien I _ 6 _ emitted from VDT's is necessary for the physical and mental' well-being of terminal operators due to the recent reports on the hazards of VDT radiation. Ms . Barss had spoken to her immediate supervisor , Mr . Battison. He said she could do clerical work as long as her terminal was covered by other employees , who had already agreed to do so . Her request was passed on to Mfr . Battison' s superior, Mr . H. F. Ahrens, the Correspondence Superintendent. Mr . Ahrens on April 6 wrote Ms . Barss as follows ; With reference to your request for a temporary change of assignment., I would like to advise you of our willingness to cooperate within the parameters of our operational requirements. Based on the best information available, the government as an employer has no knowledge that there is any health hazard connected with C.R.T. display terminals., However, we do appreciate your personal concerns and are prepared to concur with your personal wishes with regards to reassignment. In order to grant your request for an assignment away from the terminal, administration requirements must be considered. This will necessitate moving you to a position with lower compensation than your present position] in accordance with your request, your new assignment will be to the position of Records Clerk, classified as Clerk 2 General, effective from April 8, 1981 to July 3, 1981 at a salary of $233.94, the maximum for the class. While we do not acknowledge any r -health hazard connected with your recent assignment we are prepared to make this operational adjustment based on your personal request. -- Please confirm your intentions in writing at your earliest convenience. The discrepancy between the figure of $233 , 94 above and the figure of $267. 34 in the statement of fact is apparently due to a change in the rate as of May 1 , 1981 . I 4 } _ 7 Telephone calls were exchanged about tie same "_:me and ( also on April 6 ) Mr . George Richards of the O . P . S . . . wrote Mr . Ahrens as follows : I am writing on behalf of Mrs. Helen Barss to advise that she will accept your offer to transfer her to the position of Re:oras Clerk, effective from April 8th to July 31st, 1981. As stated in my telephone call to Mr. A.H. Glendenning, Director of Personnel in your Ministry, Mrs. Barss' acceptance is made without prejudice to her basic contention that she is entitled to a temporary transfer away from her regular position which involves the operation of a video display terminal as a matter of right, pursuant to cl. 18.1 of the collective agreement. M-at clause provides that: "The employer shall continue to make reasonable provisions for the health and safety of its employees during the hours of their employment. . ." Simply put, the union contends that it would be unreasonable for the Ministry to refuse Mrs. Barss' request, given the fact that it is made on the basis of a written recommendation of her physician, Dr. Isenberg, dated April 2, 1981, a copy of which is attached. The union further submits that cl. 18.1 can be triggered by an employee's reasonable apprehension of damage to his or her health and safety, and that it is unnecessary for us to prove conclusively the existence of a hazard, especially where, as in this case, we are dealing with relatively new technology about which there may as yet be insufficient medical, research on which to .base definite conclusions. I would therefore ask that you reconsider the terms on which you have offered to make the change in assignmant and failing which, I would ask that you consider this letter as a grievance submitted cn behalf of Mrs. Barss, alleging a violation of her rights under cl. 18.1 and cl. 5.6 of the collective agreement. 'fie remedy requested is maintenance of Mrs. Barss' regular rate of pay, as required by cl. 5.6, rather than reduction to the rate of a Clerk 2 and as indicated in your memo of April 6th. The result was as stated in the third paragraph of Mr . Ahrens ' letter to Ms . Bar-ss . From April 8 to July 3 , 13310 she worked as a records clerk , classified Clerk 2 General , a-:: a salary of $233 . 94 per week, or $52 . 37 less than the salary she had received as a Data Processing Technician . The grieVor began maternity leave July 3 and her first child was born July 30 . When she appeared as a witness before this Board on September 29 she expected- to resume work in November and emphasized that she was quite willing to serve as a Data Processing Technician, there being no longer any risk to her child . In cross-examination, Ms . Barss said she was not aware of scientific studies on the subject , but she did know of other pregnant women in the service who had worked on VDT; she mentioned one in 1979 , another in 1980 and a third in the spring of 1981 . The grievor was shown an extract from an O. P. S .E. U. publication, which she thought had been shown to her physician. However , there seemed some doubt whether she had in mind the O. P. S . E. U. article or the report in the Toronto Sun . She said she usually watched television for an hour or so at night and about the same when she was home on maternity leave . She 9 _ couldn ' t recall seeing an article on VDT in "Topical , " a government publication. She had discussed the problem with other employees who may have told her of what they read in newspapers . Ms . Barss said her only concern was with the welfare of her unborn child ; she did not worry about herself . For the purpose of establishing that VDT are not hazardous to the health of operators , the employer ' s counsel called two expert witnesses . Dr . Maxwell Fitch, M.D. , is Director of the Special Studies and Services Branch at the Ministry of Labour and earlier had been Director of the Occupational Health Protection Branch . A graduate of McGill and the University of Toronto , he holds a diploma in Industrial Health and is a FRCP in Public Health . Among his studies was radiation of all kinds , and his branch is the only one in the Ontario Government involved with the problem . His staff in the area includes Dr . Harry Aitken, Chief of the Radiation Protection Service (who has several physicists assisting him ) and Dr . A-. M. Mue, a Ph . D. in physics and a specialist in respect of non-ionizing radiation; Dr . Ross Hirninh , a Ph . D. in physics specializing in X-ray . He said these three are concerned with the effects of radiation . i - 10 - The only applicable legislation is the Radiation Emitting Devices Act, a federal statute , which however is concerned only with- X-radiation . Dr . Fitch explained t:iat there are two kinds of radiation, ionizing (such as X-ray ) and non-ionizing . The safety guidelines are in a list pub- lished under the Ontario Occupational Health and Safety Act and are based on material previously issued by the American Conference of Governmental Industrial Hygienists , of which Dr . Fitch and other colleagues are members , Dr . Muc happens to be a member of its sub-committee . Dr . Fitch believes that the guidelines will become part of the Regulations under the Occupational Health and Safety Act. The prescribed limits are 0 . 5 milli-roentgens per hour at a distance of 5 cm . from the device , i .e . about two inches . These limits are specified in regulations under the federal Act but they apply only to X-rays , which he said include VDT and television receivers . According to Dr . Fitch : "We have devices to measure emissions . We can measure to about one-hundreth of t`.:e federal limit , as does the Radiation Protection Bureau at Health and Welfare Canada , with whom we are in close contact . " He said his Branch has measured hundreds of video display terminals , and "we have never found any measureable X-radiation . " Dr . Fitch then referred to an article in *_he Canadian Medical Journal by the head of the Radiation Protection Bureau , Environmental Health Directorate , Health Protection Branch , Department of National Health and welfare , which appeared in the issue dated September 15 , 19$1 --- several months after Mrs . Barss became disturbed by the alarmist reports she had read - in newspapers . The contribution of Dr . Ernest Letourneau will be reproduced later in this decision . Dr. Fitch said his Branch receives the results of considerable research done under the auspices of. the U.S . National Institute of Occupational Safety and Health , now part of the Department of Health and Human Resources . He added "the reports I' ve seen are essentially the same as ours . " Dr . Fitch then discussed the matter of non-ionizing radiation. This includes the whole range of electromagnetic radiation such as the ultra-violet and sunshine . The same equipment could not be used to measure its strength . It would be measureable if greater than the non-ionizing radiation which reaches everyone on earth from natural sources . He said that "the readings we have are one-one thousandth of the guidelines . In most cases , nothing is detectible . " In the opinion of Dr . Fitch , there is no hazard in 12 - being exposed to VDT. On being questioned about the shoe store X-ray devices which were in use three decades ago , Dr . Fitch agreed that such devices "were not perceived to be dangerous for some years - quite a while . " He said he was not aware of any U . S . studies or of studies made by the Quebec' Department of the Environment suggesting there ware dangers in exposure to VDT. He confirmed that use .of such devices has greatly increased . He also made the observation that "science does not have all the answers . " Referring to an earlier controversy about the use of VDT at the Toronto Star , Dr. Fitch said that all Star terminals had been tested and there was no evidence of any X-ray emissions or of other radiation . He agreed, however, that the effects of ionizing radiation, if any, could be cumulative. The second expert witness was Dr . James Henry Aitken , Ph . D. , Chief of the Radiation Protection Service at the Ministry of Labour . A nuclear physicist, he has tested "quite a number of VDT" but not tested any four-phase units , such as those operated by Ms . Barss . However , thev had been tested I_--v the U . S . Health Protection Bureau . The main testina is done tc 13 measure X-ray emissions under "normal operating conditions . " The- device will measure low-level emission. One of the tech- niques used in testing is to "sabotage the gadgetry " inside the -box, thereby simulating a failure of the circuitry to a level representing the maximum capability of power supply . It is then measured again, because the effect of the sabotage is to increase emission, perhaps doubling it . Dr . Aitken said he had read the American reports on older models which had been banned for failure to meet the U. S . standard, which is the same as Canada' s . In this technology, he said "the early 70 ' s is old . " The failures came to his attention in the last couple of years and the results were circulated widely . The failures occurred in the sabotage test , when X-ray emissions slightly exceeded the prescribed standard. Dr . Aitken said we are all exposed to ionizing radiation from the ground, from buildings and from cosmic radiation. In� Toronto for example people receive 100 radiation units per year . In northern Ontario it might be between 150 and 200 . At Banff it could be 150 or higher-- due to increased expos- ure to cosmic radiation. Flying in a -jet over the Atlantic one would receive about 5 units but in a Concorde it could be four times that level . He estimated an operator would receive from a VDT about 5 units over a year . He had attempted to measure non-ionizing radiation from VDT. it can be emitted 14 from a VAT if the device is not well-grounded . According to him the measurable radiation of broadcasts exceeds the VE"T levels and can be created by many electronic gadgets or ever, by combing human hair . VDT frequencies are much lower than from a radio or pocket calculator . Dr . Aitken identified Exhibit 7 , an article by Dr . Muc of his branch in "Topical " (an Ontario Government publi- cation ) in which appears the following statement : "It has been calculated that the body burden of radiation carried by one' s bed partner exposes you to more radiation than working with a VDT all day. " Another statement by Dr . Muc was that "you pick up more ionizing radiation from the CN Tower or ,a microwave oven than a VDT. " Referring to the Radiation Emitting Devices Act, Dr. Muc said that "certain concerns addressed by the legislation have already evaporated with the progress of a technology . " Dr . Aitken- testified he had not received anv inauiry from Mr . Ahrens or Mr . Battison as to the safety of VDT. He also explained that the harmful effects of exposure to radiation were known at an early date , but it was not until 1'??7 that the International Congress of Radiology recommended safetv levels . Its standard had not been reduced since 1960 . He said the detection limit is about one-tenth of the standard . in his opinion the level of risk is in the order of one in a million . He added that there is a controversy among scientists which has been. distorted by newspaper reports . Answering a question, he said that a chest X1-ray may amount to 35 units and a dental X-ray even less . In his argument on behalf of the grievor , Mr . Richards said the facts here are not really in dispute, although there is a difference between the opinions expressed by Dr. Isenberg and Dr . Fitch. He was relying on Article 5 .6 in ' the collective agreement , which raised the vital question: was the grievor assigned to a different position "for reasons of health? " He further argued that under Article 18 .1 , the employer had an obligation to honour a request for transfer by an employee when that request is supported by a physician' s certificate . He submitted that there are precedents to support the proposition that _when an employee has a reasonable belief in danger , con- firmed by medical opinion, that is sufficient to establish an obligation on the part of the employer. He cited such cases as Martindale Sash ( O' Shea ) 1 L. A. C. ( 2&) 324 : Lake Ontario Steel ( Weiler ) , 19 L. A.C. 103 , and American ':Rotors ( Krever ) 17 L.A.C. 210 (noted but not reported . ) Mr . Richards further contended that the arievor :-sad advanced a reasonable scheme which was acceptable to her fellow workers , i .e . they were willing to cover her position temper- arily . He contended also that the employer made no ef.'crt whatever to dispel the grievor ' s fears . A meeting could nave been arranged to discuss the problem ; all management did was to assure her that in the employer ' s opinion there was no risk . Referring to the expert evidence , Mfr . Richards pointed out that both witnesses were government employees . He said that expert opinions "at this late stage " are untimely and not sufficient to meet the obligation recognized by Article 16 .1 . In any event, the witnesses could give only opinion evidence , and it was clear that a definitive conclusion in respect of the hazards of exposure to VDT radiation has yet to be established. Mr . Richards also referred to a provincial statute , the Employee Health and Safety Act of 1976 , and in particular to section 9 thereof . Under that legislation, there was a du-:v imposed on the employer not to penalize an employee when the employee has acted in compliance with other provisions of the Act . He referred also to the Occupational Health and Safety Act of 1978 in which Section 24 resembled Section 9 in the earlier Act . Both made clear that it was unlawful for the employer to penalize an employee in any way for declining to perform duties which the employee has reasonable cause to believe may be unsafe . I 17 - Mr. Richards submitted that the onus is on the employer to prove a product is in fact safe ; on the other hand, the employee need not provide conclusive proof of the hazard ; only a reasonable belief is required . This was "a limited exception" to the general rule that an employee receiving a questionable order should "obey now and grieve later . " - He cited Cominco and United Steelworkers. -as, well as Pherand and Inca Metals (which he said were unreported ) with their discussion of the standard for "reasonable belief . " in most cases , he asserted, an employee acts on the basis of his own opinion ; in this case , the grievor had wisely acted on medical advice ., Counsel for the employer , Mr . Moran, based his argument on three assertions . First , the grievor had obtained a transfer at her own request "for personal reasons . " Secondly, there was no safety or health hazard to her or to anyone . Thirdly , she was not assigned "for health reasons " to a position in a lower classification , as contemplated by Article 5 .6 in the collective agreement . Mr . Moran suggested that grievances of this nature cause employers to become inflexible . In this case , yr . Battison had responded sympathetically to the grievor , -a-'ked , to his supervisor and suggested she should obtain a .medical opinion and submit her request in writing . She was then told clearly by Mr . Ahrens the conditions of the transfer . However , there was no requirement under 5 . 6 that her request should be granted . If refused, she could have declined to perform her duties and would either be subject to discipline or proceedings under the Occupational Health and Safety Act . if she had refused to continue at the VDT and then grieved , an inspection would have been done by Dr . Fitch ' s Branch . Mr . Moran said it was now too late to refer to tae Occupational Health and Safety Act . The relevance of that Act had not been an issue until the hearing of the case . However , counsel denied that there had been any breach of the Act . All that had to be considered here was the application, if any , of Articles 5 . 6 and 18 .1 . In Mr . Moran' s submission , the employer could assign the grievor "as we see fit , " unless she could show the assign- ment to be contrary to some provision of the collective agree- ment , and the onus would then be upon her to prove her case . The power of assignment was statutory , appearing in what is now Section 18 ( 1 ) of the Crown Employees Collective Bargaining Act , formerly section 17 (1 ) . No problem about expesure to VDT had been demonstrated at the time of the transfer ; the articles in the Toronto Sun and the O . F . S .E. U . newspaper were not 19 . persuasive or authoritative ; on the other hand , the article in "Topical , " the Government ' s publication , rude clear tsar management had irifo:irma'tion based'-on scientific tests , that there was no danger in exposure to VDT. In these circumstances , it was not reasonable to rely on the statement of a general practitioner . Mr . Moran denied that there was any obligation on the part of the Employer to act on the basis of a medical certificate . He cited Firestone (weatherill ) 3 L .A .C. ( 2d ) 12 , to the effect that where the onus is on the employee it is for that employee to find expert witnesses . Here the onus was on Ms . Barss to show that her transfer was "for health reasons ; " that onus had not been discharged by her testimony . Mr . Moran said that whether there is anv hazard caused by exposure to VDT radiation is a question of fact which must be determined by the Board. If in fact there is no hazard, neither Article 5 .6 nor 18 .1 have any application. He urged that the Union be directed to publish the article from the Canadian Medical- Journal , which was the most authoritative statement anvwhere in evidence . In reply , Mr . Richards said that the last suggestion made by Mr . Moran should be directed by the Government to the President of the O. P . S . E. U. rather than to this Bcard . :" ev 20 _ were both in agreement , however , that Article 5 . 3 in t^e agree- ment., intended for a -different purpose , had no 'bearing on t:.iS case and they were asking the Board to ignore it . He said ,e doctor-patient relationship is based on trust , and it was only prudent of the grievor to take the advice of her physician , which in itself provided reasonable grounds for her belies .hat she should not be exposed to VDT during pregnancy . Mr . Richa;3s also pointed out that the article by Dr . Letou_neau had not appeared in the Canadian Medical Journal until September, 1981 , some months after Dr . Isenberg gave his recommendation. As to whether there was a ,health problem, he said it should be remembered that fear can itself constitute a health problem , the more -so when that fear is founded on •medical ,advice . Before stating our reasons for decision it may be well to make clear what this Board is not deciding in this case . We are not deciding whether exposure to VDT involves dangerous radiation . Fortunately , we lack both the authority and the ability to arbitrate issues which can' be determined only by prolonged scientific inquiry . We accept, Mr . Moran° s submission that what must be decided here is the correc-� interpretaticn of Article 5 . 5 and 18 .1 in the applicable collective agreement . However , in view of the serious effort which has been :jade tc show that , according to current sci'enzific opinion , t1here *-s no 21 - danger in exposure to VDT radiation , we reproduce herewith the article by Dr . Letourneau in the Canadian, Medical Journal of September, 1981 , Exhibit 6 . Whatever the ultimate con- clusions on the matter may be, it is an authoritative state- ment of the present view, arrived at ' by investigators in both the U.S .A. and Canada . It is at least more impressi7e than the Toronto Sun headline which disturbed Ms . Barss : "Pregnant Belles Can Refuse VDT Use . " Are video display terminals sale? ERNE: J G. t.iiouR:,rtau, %tn Monochrume (black-and-white) televisiun sets have The adverse publicity and unbupponed eat: been used for more than 30 years and have caused led to notch unneccsssry concern, oar:ict[i:sriti anon very little content to the population. Iltmever, in the womc[I, that �'DFS couid be detriiiwni;:l to the hu:[:th late 1960N there was quite a furore abuut the x-ray of the uperatur, and to the case of a ,arre_rtant wum::u. emissions from certain colour televisions. At that time her fetus. everyone agreed that monochrome televisions could The radiation protection bureau of the health pro- not emit x-rays because of their inherent physitat teetion branch. Department of National Hcalth snd Characteristics. Welfare ha. been monitorine television sets and VDI's However, in the past 3 ye.trs rnonuchrome tclevi- for th,' past 10 year, as hurt of its rcgulatorv' Coo- Siuns, in tilt ��uisc of video display terininals (VDTs), pliante prltgrani under the R;ttli;iIIt+n Etttittilt�, Dcvlces have become a cansc of concert. VDTs are relatively .act. Dluring that time. detaikJ r.[diatiun Of snexpcnsivc, legs-power niomicttrc[ntc television sets over No different VDTs have been nt.tde f unpuh3ish.:j that are honked up to keyboards and electronic data- data, 1981 ). The results of these ;urvevti. ancf IhObt handlil[i! systunts. Their proliferation, especially in of other scientific grtrups -around the :vc)rid, call he area., involving the media. has given rise to a rush ,uminariicd as follOwN.- uf claim, of radiation el`Ncts. as if thetie systems were • S+,ft .r-ray+ art produced Him,!,: the o;,:-,utc trtdowcd with sonic special nialtgnant properties not however, thuv are totally absorrcd bt the ;nul pr4scttt in their cousins ill most homes. therefore du nut tnttrcc from the tube, - -_____ . ____-._- - _- __._ . — -- __ _-. - ! The meaaurcJ level of ultray.,,,ict ru+lr.a:.t,r .b a Rrt?rtnr rc4W'ta w: Dr. Ernest G. Utuurnesu, Director, thousand tinlcs lover than that Ntrnt[ttet€ in �lmtmut u� R:I+llatlaJn prvteuhun hurcau. Knl. tilt, Fnriruninental heaitt► J"Clrur.+IC. Fteal[h pr.Ncojon hranch, Devarinienl of occulmtio nal Or. for tt„+t ni i,.,cr tl,:.il[It ..n.l «'clf;trc, Hwt1k Od RoAti. Curllc&r.ltion ouI+{+few, �IC1C1:[• S)I l.iy�a, t)w KLA 1C-1 Zhcr< I,_ of Lotlr�e, rr IN4 ...�..ar.Ott, ++t�:,::'•,'�: - 22 - tlliC r,111uid imi cc ;wkihing oo the \crcen. 1-11c h,iLht- �I•.al it;1, •4� :'Ir ,rl:r_:7 ;11 :.�• .' •:a,n ncv\ dCpCml% on the adjus,tnu•nl of the "green, but it hC:tltli plidilvill\ t..w.-t-d h% •1 ..k it,;! U : is ,till tier% low — some 200 lime`; tower than the I.,mL: 11-1. i,f rtlmpki7sit\. 'uci7 .,� ;;:I;;; ::;c ; ::n level 111 11.011 ouldoors on a cloudy clay. rn the haCk. 'iu111lrlcr\• 11ra(l. !r,','F ;r,n\ •,nr) .,r;ct The aniounl of infrared r0dirltiun enliticd is hayc hce11 ;lithlVdit-d. Hit: rtic;vncr r, ;;I rt1: r7•rni -,f nc',liLihle. icsllnlollials and doe, mil •.tr:rki:lc p In \Hale models there is a lrtw level of ulnc�iru• VDr\ causes arty snort- prt,NvIlls :ham .:n% ri:llcr oc- uhrawuund cinission. clipatiuu that lllv.cllycs •(,ntc•:(hai t�:lit,ns .%tirk rct;i;r o The design of the ciccillaturs in VD rs 1u)d the ing a fixed pv,citiou ;Ind vi\uril cmik:ciiimlic1n. S�.7Tlr- natnre of their operation precludes the emission of lulus from the tise of VDTS are iimv1 pvvihc :Ind are rnir•rowavr radiation. found i21 Moen% 1.4`111k siitianons. 111forts to ;61c•,ime O 'mc frequency.cif cntined viccirru,rrignrtir raffia- Ihe%c nttllsa(liatImi l,roil(•rns are useful and -Ihould null is low less than itl %mz. 'Chis radiation ortCtu- 31SO cnaIHC Ihcrn to he cllrret:i.•d in site other Iitualions :uec in the cicctrical circuits and is conimonly found in +hich :hc% ha« ari,cn. hear c•>:rriin household cicctrical appliances: ncc fic€ds hlle bcsl advice a pliv\iciall can ,1%. a Irstic:a ;:N,ul are vcr,v I(1w at the operator's position. VDTs is that they rtro no hors d an,crous thmi the Many of the reports published in the Bast year Con- iii(m lchnime islc'.i\ir+n acts found in honicc ;Ind ;hat tcrning the ailc_,ed health hazards of VDTs Ilcrpetuatc thcv carne no radiation haiard. the myth that ;onlc low-level x-ray radiation is emitted from VI)I's." In fact, the most sophisticaLcd ineasuring Itefercnces techniques used at the radiation protection bureau. which involve low-background chambers. cotifirm that I. "" Firrr,lrrtrrrn eel F,rrlrar„rn Frrrt,.rcln jerrm rider) ;)hriai Ter,mrneis. MIS ruhl FDA RI-Alt?, US neat of health .end Nieman Scrricm the basic laws of physics are still operating and that Truhiie ilcairh sc-1ce. F--d and r)mIt Adminrsiratlnn, Rurrw of Radiolopc;d t{c,tl;h. Rn,:.,ilc• Md. Feb 1991 There 1S 7.Cf0 x-raV Cn11FSE(111 from these terminals. (Zero P"M111\W ]T: Re-rr of the l.rrrrar,,Pr ,•n llralrh Ha,-ards n, in this case IC dCfltled as less than one thousandth of -- :•teen, f)"rla1 Trrnrrrrnls, C.,nue7;an Ccnite 4•t Q.cur.,unnai lieallh the natural radiation back-urnnnd to which even'one is Ind Safety, liantdwn, Ont, Oct 19PO - I. 1fe"Pir rllr,r, rri t•,drrr hr,riat Tr•.nr.,ul, TAr ,\'un-kuri,,rrrr.n rrve•- cxpclsed,1 Irmt, hcallh :,dl,lr:u, nn,t. ncN of PuNiC 11:..;th. T„rnnio. 51as :991 Similarly. it has becil claimed that In-w-level tionlon- s. I nA •cc, nn radf:rt;,,n vii VDT ,ccccns. r !CAI: :!Z: t12:1- izing radiation has lone-term effects.' Once again, the 1121 t, r"I'lernr! N,uldr Nu:Jldl ,rl v,a-r, nf,riar -r.rnrr•rgr. ,Oak:and Tr,- effcetS of ntlnionizing Mdi.16011 ;ire haled on known Imne1, to 41M.PtA. US nern of Stealth and Ttuman SCr%tces, 'uNic 11t7ath Sern,e. i,mcrs for Dkease Control. Nwirnal Ina,ture bttphySlCal CnlCCptS of abzOCp[lUn Of radiation at Irlr ocoorar[r,nai s:dr1? .r,d Health. Cincrnn7111. Ohio. 1991 various ,kavelengths. Claims for effects of nlicrox%aves h, P.u...... ! fl.•alrh li.r-.rrd, ..7 I'i,lrn rii,r,lu, .T.-imais filar Shrr!a ;ere illil,_ical as no tmcr(awaves are emitted, and those ,I ('alil....nu,, T.+t 'rr•ruf>•KS}, CS Dcr" of Henlih and !Wn:rn Scr•'rCC,. Puhh, F1c:rl,h Gcr•'tce. Centers t„r r)i.ca%e C-•mere. N'., wn.1l for effects of electromagnetic radiation would be hard In.utute for 0.,uralj,.na1 S•,icr1 .Ind 11c.tlih. Cinctmrlmi. f+hto. IoR1 to Substantiate scientifically in the presetice of all- 1. P..rr rrra! IJ.ulrh Nu:red, w T';,l.v. 11„riat 7 er-mal, FAan i•ten,n,r .\',•r.r,errr -teener. �hr.,nlrlr and F.tamrn,rl. TA pen•asiv� electrical noise. next ni Itenilh anti 111MM13 SCr�Xe%. rsrhlic health Scr,icc. C,nter' - In summary, VDTs smelt no ionizing radiation fx- for DiscaNc ConU1N. N.NU,nal ImMute rat rltcurntionai S.tf C1, and raysl. There is no evidence that at the detected levels ncalth. Crra.nn.lu. Ohio, 7981 the nonignizing radiation emitted from VDTs can pro- Thesc references arc n•pre%cntali%r of the abundant Juice biologic effects or pose any hazard to health. literature an lideu rli,plav lerlitinas. Farther references Thus, in the absence of a cause it is hard to establish are mailahfe frngt the author. a link between VDTs and cataracts or birth defects. By Coincidence or otherwise , the editors of the journal_ reproduced ---- immediately following Dr . Letourneau' s article --- two quotations from authors of an earlier day . Of these , the latter (by William Heberden ? is as follows : 2 J _ No aphorism of Hippocrates holds truer to this day, than that in which he laments the length of time necessary to establish medical truths, and the danger, unless the utmost caution be used, of our being misled even by experience. The Board was impressed by Dr . ritch ' s candid state- ment in his testimony that "science does not have all the answers . " Although the result of this- case does not turn on the validity or invalidity of the prevailing scientific opinion about VDT, the matter calls for further comment because such issues arise with increasing frequency in the area of Occupational Health and Saf ety . In our view, the .public in general and workers in particular can have complete confidence in the scientific approach . That approach has made possible in the last century more progress and more improvement in the lot of mankind than occurred in several previous millenia. [nevertheless, any alert member of the non-scientific community is entitled to remain sceptical in respect of some conclusions proclaimed as eternal verities by eminent scientists . There are reasons for scepticism , and scientists should try to understand what those reasons are and not place all the blame on exaggerations and distortions by journalists . I 24 - The principal reason for scepticism is ' the well-kncwn "- fact that scientists can and do change their minds . Toc of-.en what has been thought acceptable is suddenly found to be unac- ceptable . The public is well aware of changing opinions about the harmfulness --- or harmlessness --- of urea formaldehyde , DDT, 2-4-D, contraceptive pills , saccharin and a host of other products once hailed as a boon to mankind --- not to mention thalidomide . These changes do not affect the validity of the scientific approach ; they merely demonstrate that any scientist , being human, can make mistakes and that if he works in a highly specialized field ( as most scientists do ) he may overlook some- thing of importance which may (or may not ) be noticed by other scientists much later . A second reason for public scepticism is the snail- like pace at which research scientists overtake the by-products of_ applied science . The public has noticed that it took many years before much interest was shown in the effects on the ecology and the food chain of acid rain, mercury , PCB' s , asbestos and other contaminants in the air , soil or water . Mercury pollution was almost completely ignored by Canadian environmental authorities until a Swedish scientist happened to visit this country . A third reason is a phenomenon with which :nano lawyers i I 25 - and judges are familiar . When an issue of scientific import gets into the courts , each side almost invariably seems able ( if it has the money ) to find a distinguished expert witness to give opinion evidence diametrically opposed to the views of an equally distinguished expert retained by the other side . These gladiatorial contests ,seldom reflect credit or credibility on the scientific community, and the public has noticed it . On a more sophisticated level , there is a certain weakness in scientific methodology , as distinct from the scientific approach. it is the tendency to 2uantiLZ phenomena rather than search for qualitative results . It is of course much easier to measure something than to discover all its effects but there are risks . in . relying exclusively on measure- ment , which is often made only for the purpose of comparison with an arbitrary standard. Thus science has enabled the policeman to quantify the level of alcohol in the blood , but of course the quantification does not disclose how much damage has been done by alcohol to ,organs within the body ; it is not the policeman ' s job to find out . Similarly , by taking samples of hair and blood , a trained technician can measure accurately the level of mercury in a human body , but he cannot judge the effect, if any , mercury poisoning has had on the brain or other organs . . r - 26 - Unfortunately , the emphasis in Dr . Lezourneau ' s article , Exhibit 6 , is on measurement , i .e . the quantification of radiation: He is probably correct in stating that measure- able VDT radiation is so low as to be negligible , or even zero --- being "less than one-thousandth of the natural radiation background =to which everyone is exposed . " Nevertheless , the history of "regulation" by the "radiation protection bureau of the health protection branch, Department of National Health and Welfare " is rather strange , to say the least . The disturbing fact is ( as Dr . Letourneau failed to mention ) that until March 2, 1979 , there was no regulation at all applying to VDT in Canada. Further , the fact that a regulation was found necessary at that very late date suggests that there could be something more than "zero " radiation emitted from VDT, perhaps by reason of a malfunction or a defective product . Or perhaps because it became known that certain models had to be withdrawn from the market in the U.S . A. after failing their tests . The Radiation Emitting Devices Act 1969-70 , C. 37 , R. S . C. 1970 lst Supplement , C. 34 , enacted by Parliament in 1970 (presumably on the advice of the federal Government ' s scientific staff ) was not proclaimed in force until March 1 , 1:72 . It defined "radiation emitting device " as "anv device that is t - 27 capable of producing and emitting radiation . " Referring co importation, sale or lease, Sections 5 , 6 and 8 use the term "any radiation emitting device of a class for which standards have been prescribed. " By Section 11 the Governor in Council. was authorized to make regulations prescribing the "classes " of radiation emitting devices for the purposes of =he Act and also prescribing "standards regulating the design, construction, and functioning of any prescribed class of radiation emitting device and their components for the purpose of protecting ,per- sons against personal injury, impairment of health or death from radiation. " The Act of course did not mention any specific device , that was left to the Regulations , of which no less than eight have been adopted and gazetted by July, 1981 . The original regulations appear in Consolidated Regulations of 1978 , volume 14 ,c. 1370 . Section 3 provides that the "classes " contemplated by the Act are those set out in Schedule I (now Schedule A ) . The standards applicable thereto are specified in Schedule II (now Schedule B ) . There were 10 classes defined in Schedule I, in- cluding TV receivers , dental X-ray equipment , microwave ovens , baggage inspection devices , photofluoroaraphic X-ray equipment and certain "lasers " --- but no mention of VDT. 28 - Throughout a series of amendments over several years the regulations ignored VDT until March 2 , 1979 (more -han a decade after VDT arrived in Canada ) when the definition of Class 1 . (TV receivers ) was amended to include VDT. It appears that scientific research and regulation proceeded at the usual snail ' s pace referred to earlier in this decision, while the technology and its uses continued to advance by leaps and bounds . The definition of Class 1 , in Schedule I (now Sechudule A) as amended March 2 , 1979 , now reads as follows : Television receivers including video monitors and video display systems, being electronic appliances designed to display a picture or alphanumeric information, or both, after receiving signals through electromagnetic waves, cable or other means of transmission and including the cabinet or case of such appliances. The present standard for TV receivers (which include VDT since March 2 , 1979 ) is specified by paragraph 3 in Part I of Schedule II (now Schedule B) as follows : 3. Every television receiver shall function in such a way that (a) when the receiver ' (i) is fully assembled, (ii) is used with any supply voltage up to the maximum test voltage, (iii) is used with any settings of the user controls and service controls and (iv) displays a synchronous raster covering at least 60 per cent of the viewable screen area, the emission of ionizing radiation therefrom is such that the exposure rate of X-rays, uben averaged over a period of 5 minutes - 29 - to an object having a 10 square centimentre cross sect-ion and centred at 5 centimetres from any accessible ex-�:ernal surface of the television receiver does not exceed 0.5 milliroentgen per hour. . . . . The above is subject to an exception : if the TAI or VDT is without a "case , " the limit is "not over 2 . 5 milliroenrgen" per hour . The standard set out above appears to be the standard referred to by Dr . Fitch., who expects it to be embodied in provincial regulations under The Occupational Health and Safety Act , R.S:O. 1980 , C. 321 , which replaced an earlier statute , The Employees Health and Safety Act , S. O. 1976 , 2nd Sess . C. 79 , as might be expected, . the Canadian (and Ontario ) standard is derived from the standard previously adopted in the U. S . A. The present Ontario Act provides in Part V, Section 23 ( 3 ) that : A worker may refuse to work or do particular work where he has reason to believe that, (a) any equipment, machine, device or thing he is to use or operate is likely to endanger himself or another worker. it is also provided in Parr VI, Section 24 ( 11, as follows : .. 3 0 _ No employer or person acting on behalf of an employee shall, (a) dismiss or threaten to dismiss a worker; (b) discipline or suspend or threaten to discipline or suspend a worker; (c) impose any penalty .upon a worker; or (d) intimidate or coerce a worker, because the worker has acted in compliance with this Act or the regulations or an crde_r made thereunder or has sought the enforcement of the Act or the regulations. As Mr . Richards - pointed out , these provisions of she present Act are similar to those in the 1976 Act and are expressly stated to be binding on the Crown. " The intent of the legislation was anticipated in the exhaustive review of arbitral jurisprudence made by Professor Palmer in Steel Co . of Canada Ltd. and U. S . W. Local 1005 (1975 ) 8 L. A. C. (2d ) 375 . After citing numerous cases (which need not be repeated here ) he made at page 379 the following statement , with which we concur : It follows therefore, that in fact there may be no serious danger ; but ,. if it is possible nor a reasonable person to come to this conclusion , that suffices to satisfy this point . Thus if a person is given advice, even if eventually shown to be incorrect , by his doctor not to undertake certain activity , such advice can be used as a basis for drawing the conclusion that a person was acting reasonably in following it . See Re U. A . W . Local 63_6 and F.M. C. of Canada Ltd _Link Belt Soeeder Division (1971 ), 23rL. A. C. 234 ( O' Shea ) . Professor Palmer then offered the followi:ic qualifications : In the same vein, where senior officials cf .the employer, knowledgeable in the area, have given assurances cf safety to a person, it tends to show a lack of reasonability_ on the part of that person if he continues to refuse to do :he work so pronounced safe. See Gen'1 Truck Drivers' Union, Local 879 and_QuigleZ Construction Ltd. (1962) 13 L.A.C. 45 (Reville) The final requirement in this area is that the grievor must, at the time of the refusal, communicate his reasons for refusal to his employer. . . . . On the last two points above we are not persuaded that any person "knowledgeable in the area" gave assurance of safety to Ms . Barss . Mr . Ahrens did not testify, but the employer ' s expert witnesses said they had received no inquiry from Mr . Ahrens or his off ice . In this case of course the grievor asked that she be allowed to perform other duties , and the employer complied, so that the question of "refusal " does not arise . Secondly , she certainly made her reasons clear, orally and in a detailed letter supported by Dr . Isenberg ' s recommendation. The facts here are very different from those in the case decided by Professor Palmer, but we think the tests he used are entirely appropriate . First , was the type of apprehended danger , whether real or imaginary , of sufficient seriousness to justify the grievor ' s request for a change of duties ? 32 As to this test , our view is that t.�e grievor ` s fear of harm to her unborn child was indeed a serious matter , whether or not her fear had a basis recognized by scientists . Secondly , assuming for the moment that there was no real danger, did the grievor have "reasonable grounds " for believing that exposure to VDT radiation would. put her child at risk? Our answer to this question must be in the affirmative . Every pregnant woman (unless she is a fool ) consults her phys- ician and is entitled to rely on his advice, whether he be proved right or wrong by subsequent inquiry . We cannot accept the argument that there is an onus on the employee in circumstances such as these to prove actual danger . The argument is not con- sistent with the provisions of Article' 18 .1 in the collective agreement . In any event , it would be absurd to require an individual employee to mobilize all the scientific expertise available to management . Third , as already indicated , the grievor cave management a detailed explanation of her reasons . Her behaviour as well as her letter cannot be faulted . We are not overlookirc the fact she had the agreement of co-workers to cover her VDT station for the period of four hours each day when she usually D 33 worked there . ' This arrangement would have co __n_,e^ c-nly _mac months (until she took maternity leave ) but management decided she should be placed in a lower classification . The final and crucial question to be determined is whether, in these circumstances , Ms . Barss was "for reasons of health . . . . . assigned to a position in a classification having a lower maximum salary , " within the meaning of Article 5 . 6 in the collective agreement . It is perfectly clear that the grievor was in fact assigned temporarily to a position having a lower classification where she was paid at a lower rate , and not according to the protective clause in Article 5 . 6 . Did this occur "for reasons of health? " The Employers position is that there were no reasons of health but that a change was granted at the grievor' s request . The fact is that the grievor did not request a demotion ; she requested a different arrangement . Fier sole reason for making the request was the belief (we think on reasonable grounds ) -::::at the change should be made for the protection of her unborn chit.: . It would be a quibble of the meanest rind , and an unrealistic one , to pretend that the health of the foetus is _r � R 34 unrelated to that of the mother , and we do not believe that could possibly be the position of the Employer . At least during pregnancy the health of one is the health of the other. Argument on behalf of the Employer proceeded almost entirely on the basis that the grievor"' s fears were unfounded . That approach could have strange results in a different case . It would mean, for example, that if an employeee were assigned under 5 .6 as the result of a mistaken medical diagnosis , the - employer could subsequently decide that once a correct diagnosis showed there were in fact no valid "reasons of health" for the assignment, the employee must lose (retroactively ) the protection provided by 5 .6 . That would be a highly- inequitable result , not one contemplated by the parties in 18 . 1 or elsewhere . Since the hearing of this case, Mr . Richards has provided us with citations for the Galt Metal Industries case, decided by the Supreme Court of Canada and reported in 46 D. L. R. ( 3d) 150 aub . nom . McLeod v. Egan . That case , however , turned on a very different issue arising under the Employees' Health and Safety Act of 1976 . Mr . Moran has also cited St . Jean de 3rebeuf Hospital and C. U. P. E. Local 1101 16 L. A. C. ( 2d ) 199 ,- as authority for "the principle that an employer is entitled to refuse a doctor ' s ,t s 35 - note and require additional medical evidence . " Undcubtedl•,r there are cases where a medical certificate can be :roceriv rejected as ambiguous , irrelevant , frivolous or incredihwe , but we are satisfied that this is not such a case . As previously' stated , this Board is not deciding whether work on VDT is safe or unsafe . For reasons explained above, we hold that the grievor was assigned to a lower class- ification "for reasons of health " and is entitled to be com- pensated in accordance with the provisions of Article 5 . 6 in the collective agreement . If there be any dispute about the compensation payable , we retain jurisdiction and may be spoken to . DATED at Toronto this 21st day of January, 1982 .0, - e E. . Jo1J B `7ice Chairman 1 r� mcmaixas Member "t H. J. Laing M^. Meurer EBJ , jce NOTE: SECOND PRINTING - March 1982 (includes minor typographical corrections pages~ 11 , 16 and 4 )