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HomeMy WebLinkAboutUnion 24-07-15 1 In the Matter of an Arbitration Under the Labour Relations Act, 1995 BETWEEN: THE CORPORATION OF THE COUNTY OF FRONTENAC (the “Employer”) AND ONTARIO PUBLIC SERVICE EMPLOYEES UNION (the “Union”) (Union Policy Gr. 2019-0462-0010—Life Vests) BEFORE: Eli A. Gedalof, Sole Arbitrator APPEARANCES For the Employer Mark Mason, Hicks Morley Hamilton Stewart Storie LLP Gale Chevalier Marc Goudie Barb McCulloch Lisi Moreland For the Union Esther Song, Ryder Wright Blair & Holmes LLP (May 4, 2021) Robert Healey, Ryder Wright Blair & Holmes LLP (Feb. 29 and Apr. 22, 2024) Dave Doran Andrew Gagnon 2 AWARD INTRODUCTION 1. This matter is a health and safety policy grievance dated August 19, 2019, arising from the Employer’s choice of personal flotation devices (“life vests”) provided to paramedics working in and around the County of Frontenac (the “grievance”). There is no dispute that paramedics should be provided with life vests to be used when working next to one of the many bodies of water in the County. However, the Union alleges that the style of life vest provided by the Employer, while mitigating the risk of drowning, is bulky in nature, restricts movement, and therefore creates its own health and safety hazards for paramedics when carrying out their work. 2. Prior to 2015, paramedics relied on third parties, such as the Fire Service, to provide them with life vests when needed. In 2015, the parties’ Joint Health and Safety Committee (“JHSC”) recommended that instead each ambulance should be stocked with two life vests. It also recommended the “Mustang Life Vest MD” (the “Mustang”) as the “best product”. The Mustang is a life vest that is donned over the head and buckled at the waist, consisting of two “straps” at the front. Before contact with the water, the straps contain a deflated bladder. Upon contact with the water, a CO2 canister inflates the bladder creating buoyancy. 3. In response to the 2015 recommendation, the Employer began stocking ambulances with life vests. But instead of the Mustang, it provided a more standard “recreation-style” life vest. These are yellow life vests with the word “paramedic” across the back, lined with buoyant foam and fastened with 3 buckled straps. 4. No issues were raised concerning the appropriateness of the choice of life vests until 2018 when they were discussed at the JHSC. The committee did not reach a consensus on whether there was a problem with the life vests. On July 11, 2019, the Union’s representative made a unilateral recommendation that the life vests provided were not appropriate and requested that the Employer provide “Mustang type” life vests instead. The Employer rejected this recommendation. In response, the Union filed the grievance, alleging that the Employer has violated Articles 2.02 (Management 3 Rights), Article 9.01 (Health and Safety) and s.25 of the Occupational Health and Safety Act (“OHSA”). 5. The Union’s primary argument is that in order to meet its health and safety obligations, the Employer is required to provide paramedics with a Mustang type life vest. This argument is premised on the assertion that the current model is unsafe, and that a Mustang type life vest is the safe and appropriate option. In the alternative, it argues that it has raised legitimate health and safety concerns with the current model of life vest, and the Employer has failed to engage in an appropriate risk assessment and to ensure that the life vests it provides are safe. 6. The Employer maintains that the current model of life vest is safe, and that the Union has failed to put forward any cogent evidence to support any other conclusion. At best, the Union has articulated a preference for the Mustang. In meeting its health and safety obligations in providing PPE, the Employer is not required to provide the Union’s preferred option, or even the best possible option. It is rather required to “take every precaution reasonable in the circumstances for the protection of the worker.” The Employer maintains that it has met this standard. It further maintains that the Union cannot simply baldly assert a health and safety concern, without any evidentiary foundation, and thereby require the Employer to obtain expert opinions or to carry out studies or trials concerning the replacement of equipment that has not presented any substantiated health and safety risk over some eight years in use. 7. I note that while the Union argues that it is open to me to find that the Employer’s choice of left vest and refusal to investigate alternatives constituted an unreasonable exercise of management rights, it made no substantive arguments on this issue that were not also made in relation to ss.25(2)(h) of the OHSA. Indeed, in the absence of a finding of a breach of ss.25(2)(h), the Union has not put forward any basis for finding a breach of the Collective Agreement. Consequently, while I will identify the relevant collective agreement provisions, I will focus in this award on the arguments made under the OHSA. 8. Broadly framed, the issues are: i) whether the Employer has breached its duty under s.25(2)(h) by failing to address the hazards created by the 4 current life vest, ii) whether it is required to instead provide paramedics with Mustang type life vests and, alternatively, iii) whether it is required to further investigate the potential hazards presented by the current life vests and possible replacements for those vests? THE COLLECTIVE AGREEMENT AND THE OHSA 9. In Article 2.01(e) of the Collective Agreement, the Union recognizes that it is the exclusive function of the Employer to, among other things, determine “the kinds and locations of equipment to be used”. Article 2.02 provides that the Employer shall not exercise these rights “arbitrarily, discriminatorily or in a bad faith manner consistent with the terms of this Agreement.” The Union alleges that the Employer has exercised its management right to select equipment unreasonably and in a manner that conflicts with its health and safety obligations. The Employer maintains that it has exercised its management right to select the kind of life vest supplied in a reasonable manner, consistent with its health and safety obligations. 10. The Employer’s health and safety obligations are recognized in Article 9.01, the relevant portion of which reads: The parties agree that the Employer, the Union and the employees will comply with the provisions of the Occupational Health and Safety Act, as amended, and the regulations there under and also agree that the Union shall have the right to have four (4) representatives, who are employees of the Employer, on the Safety Committee. … 11. Section 25 of the OHSA sets out the duties of employers. Both parties rely on ss.25(2)(h) which provides that an employer shall “take every precaution reasonable in the circumstances for the protection of the worker.” THE EVIDENCE 12. Each party called one witness. The Union called Dave Doran, Vice President of the local union and a member of the JHSC. The Employer call ed Marc Goudie, Deputy Chief of Performance Standards. While the parties each challenge the credibility of the other’s witness, I have no doubt whatsoever that both witnesses testified honestly. This was particularly apparent in cross 5 examination where both, to their credit, readily conceded the limits of their knowledge and recall concerning the issues and events relevant to this grievance. The more significant problem with the parties’ evidence is its cogency. The fact is that the witnesses had remarkably limited first-hand substantive knowledge of the facts that underlie this dispute. To be clear, neither was required to be an expert on the use of life vests in the paramedic sector. But Mr. Doran had no specific recollection of ever using the current model or of having any issues with its use in the course of working as a paramedic. Mr. Goudie was clear that he had never used a life vest during the time he worked as a paramedic in the field (although he did wear one while simulating an intubation, as discussed further below). Further, in many instances, the witnesses simply confirmed what was written in the documentary record, without any specific recollection of events, or any ability to elaborate on that record. 13. There is no evidence before me that any health and safety risk has actually materialized with the life vests. The evidence is that no paramedic has ever reported a health and safety event involving the use of the life vests. There is also no evidence that there has ever been a complaint that a paramedic has requested and been refused an individually sized life vest where there was a fit issue with the standard size placed on the ambulances. 14. The chronology of events giving rise to the instant grievance is found in the recommendations and Minutes of the JHSC, and the limited correspondence between the parties arising from those recommendations. 15. The issue of life vests first arose in 2015, when the JHSC made its April 29, 2015 recommendation that the Employer place two vests on each ambulance (the “2015 Recommendation”). The “Reasons for recommendation” read: The geographic region within the County of Frontenac (Lake Ontario, St Lawrence River, as well as hundreds of finger lakes and tributaries) can often create challenges\risks for the Paramedics of Frontenac Paramedic Services. Tiered response with Fire/Police often see paramedics working around this water environment (Harbours, Marinas, Docks, Islands, Watercraft etc.). Emergency responses to Island calls (via Watercraft) have Paramedics relying on personal flotation devices provided by the Fire department. 6 The JHSC identifies the importance of these personal flotation devices in our work environment and express safety concerns when/if these devices are being provided by another service (Fire) when responding to any/all water response/rescue calls. 16. The “Requirements for implementation” read: Having researched many personal flotation products, the JHSC identifies the Mustang Life Vest 3153 02 (EMS) as best product. The JHSC respectfully puts forward a recommendation for the purchase of this Mustang product (2 per vehicle as they are a universal fit). 17. Mr. Doran followed up on July 4, 2015 seeking a response to the recommendation. Mr. Doran could not remember precisely when the current vests were provided, but it appears that it was sometime thereafter in 2015. 18. There is no evidence before me of any issues or complaints concerning the adequacy of the life vests until a June 27, 2018 meeting of the JHSC when the issue of “Life Jackets” was placed on the agenda and the following Action Item was recorded in the Minutes: 27 Jun 18 – Recommend better equipment than what is currently in use. Research Ottawa and Toronto services about their life jackets. 19. When asked about this entry and why the committee recommended better equipment, Mr. Doran testified that they felt the current life vest was too bulky and restrictive and would “possibly cause other hazards.” In cross examination, however, he acknowledged that he had no independent recollection of the meeting and did not have any recollection of what was discussed. 20. The issue remained on the agenda at the September 12, 2018 JHSC meeting, with the addition of the following note: 12Sept18- Concerns continue to be expressed from workers that the current model of life jacket being used limits mobility, creating other hazards. Concerns have also been expressed that the fit may not be suitable for all employees. ONGOING 7 21. Asked about this entry and what was meant by “other hazards”, Mr. Doran responded that he thought it meant they had other concerns with the bulkiness of the jacket. He explained that paramedics need to be able to freely move their arms during calls, and they get used to carrying things “a certain way”. He added that “if you have to carry equipment or a patient further out from the body it creates ergonomic hazards, and just being restricted causes hazards.” He also explained that concerns were expressed that the fit might not be suitable for all employees and that for larger employees the jacket might “ride up on them, half way up their torso because it appears to be too small”. However, when Mr. Doran was cross-examined about this meeting, he again acknowledged that he had no specific recollection of whether life vests were even discussed at the meeting, or of the contents of any discussion. He also acknowledged that he had no recollection of whether fit or suitability issues were raised by any paramedics who had been fitted for a life vest as the Employer has offered to do on an ongoing basis. I note that it appears from an August 14, 2015 email submitted by the Employer that employees were fitted for the life jackets when they were introduced, and 3 small life jackets were purchased for employees who required them. 22. While Life Jackets remained as a standing item on the agenda, it does not appear that there was any new information or action identified until the November 6, 2018 meeting, when Union committee member Jeff Liddell was tasked to “write up a recommendation for new life jackets” (this note was repeated for the December 5, 2018 meeting). Mr. Doran was not present at that meeting. At the February 11, 2019 JHSC meeting a note was added for the Employer co-chair to follow up with the Chief, and a Union representative to “talk to KPD to see what model they use.” 23. On April 1, 2019 Paul Charbonneau, who was then Chief Paramedic, wrote to both JHSC Co-Chairs as follows: Dave and Richard, I have had Chris McBain researching PDFs for a possible replacement of our current model. The question I need to understand is; what problem are we trying to solve here? We currently have PDFs available in each ambulance that meet the Coast guard standard. 8 Best Paul 24. Mr. Doran responded the same day: Good evening Paul, The current model of life jackets are not practical to work in. The life jacket is very restrictive and they don't properly flt some of the medics. The JHSC recommends a (mustang) type life jacket that would allow the paramedic to work with ease and would infiate if submerged in water. Best, Dave 25. On April 4, 2019 a note was added to the JHSC Minutes saying “[n]eed to review more models. What do other services use?” Apart from hearing that some services provided life vests while others did not (or provided them only to their marine unit) and that one service may have ceased providing life vests, I heard no evidence about what models other services used. I did hear, as discussed below, that Mr. Goudie borrowed a Mustang life vest from a neighbouring service in order to examine it, but I did not hear any other evidence about that service or its use of life vests. 26. At a May 10, 2019 JHSC meeting, the following note was added to the Minutes: 10May19 – Submit another recommendation based on further evidence. Some people do not fit, or cannot perform duties while wearing the current model. Andrew to write up a new recommendation for the Mustang PFD. As noted above, however, the Employer has offered to individually fit employees for their own life vest where needed, and there is no evidence that any employee has been denied a properly fitted life vest. Neither is there any evidence of a single instance where an employee could not perform their duties while wearing the current model, or where the life vest impacted their ability to perform those duties safely. 27. At a June 18, 2019 JHSC meeting, the task of writing up the recommendation was reassigned to Mr. Doran as follows: 9 18June19 – A safety concern/risk has been raised on multiple occasions that the current life jacket does not meet the needs of the paramedics, and does not work for all workers. Dave will do up another recommendation for different PFDs. 28. On July 11, 2019, Mr. Doran submitted his recommendation as the Worker Co-chair of the JHSC. Management did not sign off on or agree with the recommendation, which provided the following “Reasons for recommendation”: The JHSC has identified the need for a new style of life jacket. Although the JHSC appreciates that the employer has provided a life vest. The style of life vest provided was contrary to the original recommendation of mustang style life vests and is not practical for EMS. Paramedics need a life vest that allows them to be able to easily carry out the duties of our job. The current vests are very restrictive and there is also sizing issues with the current life vests. 29. Mr. Doran indicated the following “Requirements for implementation”: In accordance with the Occupational Health and Safety Act Sec 25 (2)h, the employer must do everything reasonable to protect the worker. The JHSC requests that the employer Provide two Mustang type life vests for every ambulance. We look forward to receiving your written response to this recommendation within 21 days. We anticipate that your written response will include a timetable for implementation or reasons why you do not agree with the recommendation (pursuant to OHSA s.8(13) or 9(20)(21) as applicable. 30. On August 6, 2019, the JHSC noted that it had not received a response to the recommendation and the Employer Co-Chair was tasked to follow up. 31. On August 9, 2019, the Chief rejected the recommendation on the grounds that the Employer had provided life vests that meet Canadian Standards and that employees who cannot fit into the standard sizing are offered individual issue. She did not support purchasing Mustang type vests for each ambulance. 32. On August 19, 2019, the Union filed the instant grievance. The Statement of grievance reads: 10 The Union grieves the violation of the collective Agreement , including, but not limited to Article 2.02, Article 9.01 and the Occupational Health and Safety Act. Sec 25, - Failure to cooperate with the JHSC in regards to addressing safety hazards. - Failure to do everything reasonable to protect the worker as is required. 33. The relief sought in the grievance includes providing two Mustang style life jackets for every ambulance, that the Employer cease the arbitrary practice of not following the JHSC recommendations, and that it cooperate with the JHSC on all matters of workplace safety. 34. When Mr. Doran began his evidence, he had been with the County for approximately 13 years. However, he candidly acknowledged in his evidence in chief that as a result of his various Union and health and safety duties, he has spent very little time working on an ambulance during the relevant period. Mr. Doran had no personal experience with any difficulties performing paramedic duties wearing a life jacket, as he did not recall ever having done so. 35. Mr. Doran explained that prior to the Employer providing life vests, paramedics would simply not wear one when working near the water’s edge. When on police or fire vessels, they would wear vests supplied by those services, and when on private vessels they would use whatever vests were available. It was the concern over this reliance on third parties that caused the Union to bring forward the issue in 2015. According to Mr. Doran, the committee recommended the Mustang in particular because it was a universal fit, you can work easily in it, it is not restrictive, bulky or cumbersome, and “it allows you to do the job we need to do”. 36. Mr. Doran testified that he tried on the current life vest and found it “very restrictive” and “very bulky”, particularly when worn over the uniform winter parka. He found bending and reaching in front of his body restricted by the padding in the jacket, and “a little bit” restrictive of twisting. When bending it “kind of crunches” into the abdomen area restricting ease of motion. Over the spring or fall uniform jacket, he described it as “definitely restrictive but not as restrictive as the winter jacket”. Mr. Doran also raised a concern that the vests did not have reflective patches on them. However, in cross 11 examination, he acknowledged that the reflective patches on the paramedic uniform were still visible while wearing the life vest. 37. Both parties submitted photographs of paramedics wearing the life vests. The photographs were useful in illustrating what the equipment in issue looks like, but their utility did not extend much beyond that. The Union’s photographs depict paramedics in various positions with either ill-fitting or improperly worn life vests, including life vests “riding up” on the model. Absent any substantive evidence of how these models and life vests came to be in these positions, however, they demonstrate only that the life vests are not a universal fit, which is not in dispute, and that they can be badly worn. They do not reveal such obvious bulk or restriction of movement to suggest, absent further evidence, an inherent safety hazard if properly sized and donned. 38. The Employer’s photographs depict a life vest properly worn by Mr. Goudie while he performs an intubation on a mannequin. Mr. Goudie is, as he described himself, “a bigger guy”, and the life vest was snug. He testified that it added a level of “discomfort”, but this was not in his view significant. He did not find that it restricted his range of motion or interfered with his ability to conduct the procedure. He agreed that in general it might be a little more restrictive than not wearing a life vest, but noted this was also the case with other forms of PPE such as when wearing a gown. He identified no health and safety issues arising from wearing the vest while performing the procedure and did not believe it would raise any issues in carrying out the work of a paramedic more broadly. 39. Mr. Goudie also borrowed a Mustang life vest from a neighbouring service to examine. He testified the manual for the Mustang indicates that it is not appropriate for weak or non-swimmers, and that there may be delays in inflating in cold water. He also testified that they are not actually a “universal” fit as the Union asserted, and that people at extreme ends of the weight and size spectrum would still need their own appropriately sized life vest. 40. Mr. Goudie also testified that in the usual course, paramedics would not be wearing the life vests for long while treating patients. The general practice is to move away from the water as quickly as possible. These paramedics are not “water rescue” employees. 12 ARGUMENT AND ANALYSIS The Union’s Argument 41. The Union argues that the Employer failed to take reasonable precautions, as required by Article 9 of the Collective Agreement and ss.25(2)(h) of the OHSHA, when it failed to address the hazards caused by the current life vests. Those hazards arise from a restricted range of motion, sizing, discomfort in performing duties and the lack of reflective material. The risks were identified in the 2019 and 2020 JHSC recommendations. Those recommendations were undoubtedly provided to the Employer and the Union emphasises that there is no requirement for a unanimous recommendation from the committee in order to trigger the Employer’s obligations under ss.25(2)(h). 42. In the Union’s submission, Mr. Doran provided detailed evidence to establish the existence of identified hazards, and the reasonable and necessary precaution to address those hazards was to provide a Mustang type vest. In contrast, it submits that Mr. Goudie’s evidence was insufficient to establish that the Employer took any reasonable precautions to prevent those hazards. Further, it submits that Mr. Goudie’s evidence failed to establish that the Employer had cooperated with the JHSC in any meaningful fashion. Apart from perhaps the one instance where Mr. Goudie performed an intubation on a mannequin while wearing the vest, the Employer did not conduct any meaningful tests to assess the current vests. It conducted no testing on a Mustang vest. It did not consult with any expert or seek input from any of the paramedics in the field who had used the vest while working. 43. In the Union’s submission, in response to the Union identifying hazards, the Employer has effectively demanded that the Union first provide “hard evidence” that the risks have actually caused harm before acting. In the Union’s submission, the Employer’s untenable position is essentially that a crisis must materialize while responding to an emergency before it will take any steps to address the hazards identified. The Union’s primary position is that the appropriate response in addressing the identified hazards is to provide a Mustang type life vest. In the alternative, it maintains that ss.25(2)(h) requires that the Employer at the very least engage in a meaningful 13 assessment of the hazards identified and determine whether a Mustang type vest would address those hazards. 44. In support of its argument, the Union relies primarily on the decision in Cambridge Memorial Hospital and OPSEU Local 239, Re, 318 CarswellOnt 3847 (Ont. Arb.)(Marcotte)(“Cambridge Memorial”), which it asserts is on all fours with the present case. It also relies upon Canada Border Services Agency v. PSAC, 2014 CarswellNat 2387 (COHST)(“Canada Border Services”) and Prairie North Health Region and CUPE, Local 5111 (Employee Name Tags), Re, 2015 CarswellSask 768 (Sask. Arb.)(Ponak)(“Prairie North”), cited therein. As in Cambridge Memorial, the Union argues that in the absence of a formal risk assessment, neither the Employer nor the arbitrator can properly assess the risks posed by the current vests. In the Union’s submission, the Employer’s uninformed opinion that there are no such hazards is not sufficient to meet its obligation under ss.25(2)(h). The Employer’s Argument 45. The Employer argues that from the outset the Union has premised its case on an inaccurate articulation of the Employer’s obligations under ss.25(2)(h), and bald unsupported assertions. It argues that I ought to prefer the direct and forthright evidence of Mr. Goudie to the vague and poorly remembered evidence of Mr. Doran. The onus in this case is on the Union, and the Employer maintains that the Union has failed to meet that onus. The Employer accepts that one need not wait for a health and safety problem to materialize before acting, but there must, it argues, be some basis put forward for investigating or addressing a concern. In this case, the only actual evidence of using the current vest while carrying out paramedic duties was the test performed by Mr. Goudie, who said the vest was “snug” but created no problems. 46. The 2015 JHSC recommendation identifies the risk of working near water, which the Employer submits it has addressed with the current vests. The recommendation identifies the Mustang as the “best product” and indicates that the committee “researched many personal flotation products”. But it identifies no actual safety-related basis for choosing the Mustang, and there is no evidence of any research conducted. The current vest addresses the risk that was identified in 2015 and had been in use for several years 14 without issue before the Union raised any concerns. It has now been in use for several more years, and the Union has still not identified a single specific concern beyond its vague and speculative assertions. 47. The 2019 unilateral recommendation from the Union JHSC representative, submits the Employer, misstates the standard under ss.25(2)(h) and does not raise any health and safety issue with the current vest. The issues identified are that it is “not practical for EMS”, they need a life vest “that allows them to easily carry out the duties of [their] job”, and “the current vests are very restrictive and there is also sizing issues with the current life vests.” The Employer has addressed the sizing issue by offering employees a fit test and agreeing to issue individually sized vests where required. The other concerns raised may explain why the Union prefers the Mustang, but do not raise health and safety risks, which must be the basis for a complaint under s.25 of the OHSA. 48. The Employer does not accept that the unsigned 2020 “recommendation” is a proper recommendation of the committee. Nonetheless, the 2020 recommendation primarily relates to concerns about restricted range of motion and the comfort and ease of carrying out paramedical duties; not health and safety issues. It does not raise issues of fit. The only actual health and safety concern raised is the absence of reflective material, and Employer submits that on the evidence, the reflective material on the paramedic’s uniform is visible while wearing the life vest. To the extent that the recommendation asserts that the current vests were designed primarily for recreation, there is no basis put forward to establish why, from a health and safety perspective, this feature would render it any more or less appropriate than the Mustang. The Mustang, it notes, is also used for recreation. 49. In sum, the Employer submits that the Union has baldly asserted a preference for one product over another and seeks to require the Employer to either satisfy that preference or engage experts and perform testing of that product, in the absence of any actual identified health and safety problem. Further, in response to the Union’s 2019 recommendation, Mr. Goudie did investigate the Mustang, and identified potential concerns from the product manual (risk of non-inflation and risk to poor swimmers). The Mustang may also require additional maintenance on an ongoing basis. In the 15 circumstances, the Employer maintains that there is no basis to replace a product that is working without issue with one that may introduce new identifiable risks. In forwarding this argument, the Employer emphasizes that its paramedics do not engage in search and rescue on and around the water. Indeed, their practice is to move the patient away from the water at the earliest opportunity. 50. In support of its argument, the Employer relies on the principles in Glencore Canada Corp. v. Sudbury Mine, Mill & Smelter Workers’ Union, Local 598, [2015] OLRB Rep. 887 (“Glencore”), Grain Workers’ Union, Local 333 v. British Columbia Terminal Elevator Operators’ Assn., 2001 CarswellNat 6819 (Can. Arb.)(Jackson)(“Grain Workers’ Union”), O.P.S.E.U. v. Ontario (Community & Social Services), 2008 CarswellOnt 10283 (Ont. GSB)(Watters)(“Community & Social Services”) and Humber College and Ontario Public Service Employees’ Union, unreported, April 27, 2023 (Raymond)(“Humber College”). It further distinguishes and questions the precedential value of Cambridge Memorial, which does not appear to have been followed in any other case (see Toronto Transit Commission and ATU, Local 113, 2021 CarswellOnt 449 (Ont. Arb.)(Slotnick)). Union Reply 51. In reply, the Union emphasises that a JHSC recommendation is not a formal legal pleading and should not be read as a comprehensive statement of the Union’s case. The Employer’s obligations under ss.25(2)(h) stand absent any recommendation from the JHSC. In addressing the authorities relied upon by the Employer, the Union emphasizes that a “reasonableness” analysis is always fact driven, and those cases are easily distinguished on their facts. It maintains that the Cambridge Memorial decision provides the best analogy to the current case. 52. In response to the Employer’s submissions on onus, the Union argues that while it may bear the ultimate onus to establish its grievance under the Collective Agreement, it has more than done so. Once it identified a genuine risk of harm, as it maintains it has done, it became the Employer’s obligation to meaningfully address that risk. The Union does not bear some additional obligation or evidentiary onus in order to trigger the Employer’s duty to act. The OHSA is remedial public welfare legislation, it emphasizes, which should be interpreted broadly (see Quinten Steel, 2017 ONCA 1006 CanLII). 16 Analysis Is the Employer Required to Provide a Mustang-style Vest? 53. The Union’s request for an order that the Employer supply Mustang style type life vests in place of the current vests is easily disposed of. There is, quite simply, no cogent evidence before me to support a positive conclusion that the current model is unsafe, or that that the Employer is required to provide a Mustang style instead, in order to meet its obligations under s.25 of the OHSA. I will address the evidence concerning the current life vests below. With the respect to the Mustang, however, the Employer articulated concerns about delayed inflation in cold water and that the equipment may not be suitable for use by poor or non-swimmers. These concerns are based on Mr. Goudie’s review of the manual for the product and are therefore not without some foundation. But on the evidence before me I have no basis for assessing how significant (or insignificant) these concerns might be, and how one might weigh these concerns against the relative advantages and disadvantages of any other available option. A Mustang or Mustang style life vest may well be an excellent option. But it would constitute an entirely inappropriate incursion into management rights to order the Employer to use that particular piece of equipment in these circumstances. Does the Current Model Raise Health and Safety Issues? 54. The more substantial issue in this case is whether the Union has raised sufficient health and safety concerns with the current model life vest such that the Employer is required to either replace it or to at least conduct further studies or inquires with respect to those safety issues. Before assessing the evidence on this issue, it is useful to set out some general principles concerning the application of s.25 of the OHSA. 55. First and foremost, it must be emphasized that one need not wait for a health and safety risk to manifest before the Employer’s obligation to “take every precaution reasonable in the circumstances for the protection of the worker” is triggered. It is also beyond dispute that where new policies, practices or equipment introduce a new health and safety risk to the workplace, the OHSA requires that those risks be examined, understood and, subject to the standard established by s.25, addressed. As the Union correctly 17 emphasizes, the Occupational Health and Safety Act is remedial legislation and it should be broadly interpreted and applied in support of its purpose. The primary and obvious purpose of health and safety legislation is to prevent injury from happening in the first place. 56. The Union relies primarily on the principles articulated in Cambridge Memorial. That case arose from the introduction of name tags for hospital staff, and the concern that displaying staff member’s full first and last names might enable stalking and other targeted behaviours by patients and their families. There was at least some evidence that patients had threatened employees in reference to their personal lives outside the workplace. The arbitrator concluded that in introducing its name tag policy, the employer had introduced a risk into the workplace, and had failed to assess that risk as required by the collective agreement, or to take steps to mitigate against that risk as required by the OHSA. 57. In reaching these conclusions, the arbitrator in Cambridge Memorial recognized that the assessment of risk under the OHSA must be both objective and grounded in the circumstances of the particular workplace (para. 45). He cites Toronto Police Association for the proposition that a finding of risk must be based on “predictability through empirical data, not speculative information or conjecture” (at para. 43). The risks associated with the introduction of name tags, particularly in workplaces where employees may be subject to retaliation, have been the subject of prior awards, reviewed in detail by the arbitrator (see Canada Border Services and Prairie North). It appears that the arbitrator in Cambridge Memorial, upon reviewing these awards, concluded that there was an objective basis for finding a similar risk in the workplace before him. As the Employer notes, other cases addressing employee identification do not reach the same conclusion as those cited by the Union. Clearly, each case must be assessed on its own facts and having regard to the circumstances of the particular workplace. I take no issue with the general principles articulated in Cambridge Memorial, but it bears little in common with the instant case. 58. In broad terms, the cases cited by the Union stand for the proposition that even where a risk may be remote, if it is significant and objectively founded, the employer must meet its obligations under s.25 of the OHSA. The cases do not, however, stand for the proposition that it is sufficient to merely 18 articulate a speculative risk without objective foundation, and thereby require an employer to alter its existing practices. Rather, the awards emphasize the need to look to the specific circumstances in each case, and to conduct an objective assessment of risk based on the facts. 59. The cases cited by the Employer largely address the issue of proportionality. The Employer emphasizes that its obligation is not to eliminate all risk, but to take every reasonable precaution in the circumstances. It emphasises that its obligations under the OHSA are proportionate, not absolute, and that the Act strikes a balance between the risk of harm and the employer’s ability to carry on business (see, e.g., Glencore at paras. 168-171). It emphasises that paramedics do not engage in water rescue, and that they do not generally carry out their duties wearing life vests. Rather, on those occasions where they are required to wear a life vest—which appear to be relatively infrequent based on the limited evidence of use before me —their aim is to move the patient away from the water as quickly as possible. 60. I take no issue with the proportionality analysis, subject always to maintaining a purposive application of health and safety legislation as discussed above. I emphasize, though, as is also noted in Glencore, that while the Act does not impose an absolute obligation to eliminate risk of harm, it is nonetheless “heavily slanted in favour of eliminating risk” (at para. 168). But as the Employer also argues, in order to engage the proportionality analysis there must be objective evidence of a risk to health an d safety in the first place. To be clear, I do not suggest a need for “scientific proof”; in matters of health and safety, particularly where there is risk of serious harm, the precautionary principle applies. But as the cases make clear, evidence of subjective feelings, absent an objective factual foundation, is not sufficient. 61. In this case, I find that the Union has failed to put forward an objective factual basis for its subjective concerns regarding the current life vests. While the original JHSC life vest recommendation in 2015 identified the Mustang as “best product”, it does not identify any health and safety basis for this conclusion. When the issue was raised again in 2018, the Union representatives on the JHSC asserted a need for “better equipment”, and that the current vest limited mobility “creating other hazards”. It also raised issues of fit. The evidence supports the Employer’s position that it has addressed the concerns related to fit and continues to offer individual issue where 19 appropriate. The evidence does not establish that the Union identified any particular “other hazards” prior to the hearing of this grievance. Then Chief Charbonneau asked the right question when he wrote “[t]he question I need to understand is; what problem are we trying to solve here?”. In response, aside from the fit issue which has been addressed, he was advised that the current vests were “not practical” and that a Mustang type vest “would allow the paramedic to work with ease and would inflate if submerged in water”. He was not advised of any actual health and safety risk posed by the current life vests. 62. The closest the Union’s evidence approaches to identifying an actual health and safety risk was Mr. Doran’s testimony that Paramedics become used to carrying things a certain way and that if you carry equipment or a patient further out from the body it creates “ergonomic hazards”. But Mr. Doran was not able to provide any objective factual basis for the claim that the current vests create such a risk in the performance of a paramedic’s actual duties. The fact that there has not been a single issue or complaint arising from the actual use of the life jackets over a period of several years supports this conclusion. I emphasize again that this is not to say that the Union requires proof of injury to make its case. But the concern raised by Mr. Doran in his evidence relates to restriction of motion and ergonomics, risks (as opposed to actual injury) that one would expect to arise on a routine basis with use of the life jackets. Yet I heard no evidence of a single actual circumstance in which the use of the life vests created this risk. 63. The only evidence before me that provides any insight into the real- world impact of wearing a life vest as a paramedic was the evidence of Mr. Goudie’s simulated intubation. While hardly a scientific or exhaustive assessment of the use of life vests by paramedics, it demonstrates that the Employer did not simply dismiss the Union’s concerns out of hand. In response to a vague and unparticularized health and safety concern, Mr. Goudie donned the vest to perform an invasive procedure that required him to bend over in an awkward position, and he found that the vest did not cause any health and safety concerns. The photographs, in conjunction with his testimony, support his evidence. Had the Union identified any particular risk posed by the life vests, based on realistic circumstances of use by paramedics, the Employer might well have been required to investigate further. But in the absence of any 20 such objectively grounded concern, Mr. Goudie cannot be criticized for failing to conduct further tests or trials. 64. Considering all the evidence before me, I find that the Union has not put forward an objective basis for finding that the Employer’s use of the current life vests creates a health and safety risk that it has failed to properly assess or address. The Union did identify a specific risk related to fit, but I find that the Employer has addressed this risk by offering fitting on an ongoing basis and offering individual issue where appropriate. CONCLUSION 65. For all these reasons I do not find that the Employer has breached Article 9.01 of the Collective Agreement or s.25 of the OHSA in selecting and issuing the model of life vest currently in use. There is no dispute that the current life vests serve the health and safety purpose for which they were introduced, i.e. to mitigate the risk of drowning. The Union has failed to put forward an objective basis for concluding that the equipment selected to address this risk itself introduces new health and safety risks that must be addressed. The Employer has exercised its management right under Article 2.01(e) to select the kind of equipment to be used, and the Union has not established a basis for finding a breach of management rights under Article 2.02. 66. The grievance is therefore dismissed. Dated at Toronto, Ontario, this 15th day of July 2024. “Eli Gedalof” ______________ Eli A. Gedalof Sole Arbitrator