HomeMy WebLinkAbout1982-0429.Nicholls.82-12-29Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOP.R3
Between:
Before:
For the Grievor:
For the Employer:
Hearing: November 1, 1982
OPSEU (Bradley J. Nicholls)
Griever
- And -
The Crown in Right of Ontario
(Ministry of Health)
Employer
J. F. W. Weatherill
T. Traves
E. R. O'Kelly
Chairman
Member
Member
G. Richards
Grievance Officer
Ontario Public Service Employees Union
M. V. Quick
Counsel
Legal Branch
Ministry of Health
-2-
DECISION
In this grievance, dated September 8, 1982,
the grievor alleges that he was unjustly dismissed. The
employer's position is that the grievor was released
pursuant to section 22 of The Public Service Act, during
his period of probation. If the employer's position is
correct, then this Board would have no jurisdiction in
the matter. A probationary employee who is dismissed or
released is not entitled to file a grievance: article 27.6.1
of the collective agreement.
Three principal arguments were put forward on
behalf of the grievor. First, it was contended that the
grievor had in fact completed his probationary period.
Second, it was sa,id that, if still on probation, he had
not "failed to meet the requirements of his position" and
so could notproperly be released. Third, it was argued
that what occurred was a form of discipline for which
'there was not just cause, and that a lesser penalty should
be substituted for that which was imposed. We shall deal
with these arguments in turn-.
The first point is, as will appear, the crucial
one. Was the grievor a probationary employee at the time
of the termination of his employment or not? There is no
dispute as to the facts. The grievor was first hired by
. . ,
-3-
the employer for full time work on May 6, 1981. His
appointment was to the Unclassified Service. His work
.was that of Ambulance Driver. He was appointed to
the Classified Service, as an Ambulance Officer 2, on
November 30, 1981. There was no break in his service,
but it is clear that a new employment status was entered
when the grievor was appointed to the Classified Service
(see, in this regard, Johnston, 292/79). It was then
that the grievor became a civil servant, and entitled to
benefits under the collective agreement beyond those set
: out in article 3 thereof. (While article 27 - grievance
procedure - is made applicable to employees who are not
civil servants by article 3 itself, article 27 contains
the above-noted prohibition on grievances by probationary
employees).
The grievor's appointment to the Classified
Service was effective November 30, 1981. He was advised
of that appointment by letter dated November 20 of that
year. In that letter, the grievor was advised that his
appointment was "probationary for a period of one year".
This of course was consistent with section 22(5) of The
Public Service Act, which provides that a deputy minister
"may release from employment any public servant during
the first year of his employment". It was not suggested
that any objection was taken to the grievor's appointment
being probationary~for one year.
- 4-
The union relies heavily on article 25.1 of
the collective agreement, which provides as follows:
25.1 An employee's length of continuous service
will accumulate upon completion of a pro-
bationary period of not more than one (1)
year and shall commence from:
(a) the date of appointment to the Classi-
fied Service for those employees with
no prior service in the Ontario Public
Service; or
(b) the date on which an employee commences
a period of unbroken, full-time service
in the public service, immediately
prior to appointment to the Classified
Service.
"Unbroken service" is that which is not
interrupted by separation from the public
service; and efull-time" is continuous
employment as set out in the hours of work
schedules for the appropriate classifications.
The effect of that article in the instant case
would be that on completion of his probationary period,
the grievor's "continuous service" would be taken as
having begun on May 6, 1981. For that effect to occur,
however, the grievor would have had to have completed
his probationary period. While article 25.1 puts a
limit (one year) on the length of probationary periods,
it does not otherwise define them. Article 3.12 does
contemplate that, in setting a probationary period, con-
tinuous service prior to appointment to the Classified
Service may (up to a limit of six months), be taken into
account. Thus:
-5-
3.12 Where an employee is appointed to the Classi-
fied Service and has worked more than twenty-
four (24) hours per week on a continuous basis
immediately prior to appointment to the Classi-
fied Service, the time he actually worked within
the previous year may be considered to be part
of his probationary period to a maximum of six
(6) months.
While it may be that the time previously worked
by the grievor could have been considered part of his
probationary period, the fact is that it was not, and
no timely objection appears to have been raised in that
regard. It is not for this Board retroactively to alter
that state of affairs, of which the grievor was aware.
In the instant case, then, the griever's
probationary period had not ended at the time of his
release. The first argument therefore fails.
The second argument is that, if he was still
on probation (and we have found that he was), the grievor
had not "failed to meet the requirements of his position".
It is, with respect, for. the employer to make such
determination, under The Public Service Act. It is not
a question with respect to which this Board has juris-
diction. While we would have to exercise a preliminary
jurisdiction with respect to the characteriztion of the
action taken, it is clear that what occurred in the
instant case was a release on probation. The grievor's
licence to operate a motor vehicle had been suspended,
.:,
-6-
and the operation of a motor vehicle was an essential
part of the duties of his position. In these circum-
~.'.stances , it would be our view that it was open to the
employer to take the course it did. The, second argu-
ment, therefore, must also fail.
The third argument is', we think, contingent
on the success of one or the other of the first two.
As we have found, the grievor was released while still
a probationary employee. In our view, what occurred
was an exercise of the power to release, and not a
disciplinary measure. In any event, the collective
agreement does not alloti the filing of grievances in
respect of the dismissal of probationary employees
(article 27.6.1), and this Board has no jurisdiction to
alter, change, amend or enlarge any provision of the
collective agreement (article 27.12). Accordingly,
the third argument must also fail.
For all of the foregoing reasons, it is our
conclusion that the grievance is not arbitrable, and
that this Board has no jurisdiction in this matter.
The grievance is accordingly dismissed.
DATED AT TORONTO, this 29th day of December, 1982.
7: 3560 .
2: 1100
Ii1 “&issent,, (see attacheh) m m.--ryr,Tr M^".h,."
.
:.
G. S. B. #429/82
‘
- 7 -
DISSENT
Nicholls/Ministry of Health
I must dissent from the majority view in this case. While I With respect,
concur with the finding that Mr. Nicholls was still a probationary employee, I
accept the Union argument that he was dismissed and not released, as the majority find.
Mr. Nicholls was judged on two occasions prior to his dismissal to be a competent
employee by the IYinistry. The first appraisal came, implicitly, when he was
transferred from the unclassified service to the classified service on 30 November
1981 after working for nearly seven months as an ambulance driver. Subsequently,
he received a positive appraisal of his performance on 29 January 1982. There is
no evidence to suggest that he would have been released from his position but for
the temporary suspension of his driver's license and the employer made no claim
otherwise. The sole reason he was released was that he would not have a valid
and subsisting drivers' license for three months and therefore he could no longer
meet the requirements of his position, albeit only temporarily.
The issue of whether 1Mr. Nicholls was released or dismissed turns on our
understanding of whether he was able tq.meet the requirements of his position.
The clearest presentation of this problem is to be found in Keane (596/81:
Under La, the question whether a probationer was "released" or
"dismissed", and hence whether the probationer can grieve his termi-
nation, depends upon whether he or she was terminated for failure to
meet the requirements of his or her position. The definition of what
compromises "the requirements of the probationer's position" must,
therefore, be treated as cruciai. Upon this definition rests the interest
of the Employer in being able to weed out unsatisfactory probationers .
without confronting the possibility of a full-blown and expensive process
of grievance and arbitration. On the other side of the coin is the
probationer's interest in being heard on a matter as important as the
loss of his economic livelihood.
When we balance these interests--as the drafters of the legislation must have
when they drafted the relevant provision of the Public Service Act--we
conclude that the drafters must have intended the expression "requirements
of his /or hex? position" primarily to mean job requirements such as those
which are set forth 'in the descriptions the government generates for
positions in the.public service (which usually are referred to at great
length in the context of classification grievances) g. lo-11
My difference Qith the majority in this grievance turns on the relative weight
assigned to the temporary nature of Mr. Nicholls license suspension. My reasoning
in this matter proceeds by analogy. If the griever had been sick for a week or _.
two with a non-recurring illness he would not have been released. If he had been
, .
Nicholls/Ministry of Health
December lSth, 1982
- 8 -
ill for a longer period, doubtless the Ministry would have made inquiries after
his long term prognosis, and if it was clear that his medical problems were
non-recurring and that his absence was to be of a limited duration, previous
findings by this Board (Richardson 517/81 and Temple 12/76) suggest that they
would iiot have grounds for release due to a temporary inability to perform. In
this'case Mr. Nicholls was not sick; he lost his license due to an alcohol related
offense while he waS off duty. His inability to meet the requirements of his
position was temporary. In the longer term his capacity to fulfill all of his
job functions was in no way diminished and based on his previous performance
appraisals there is evidence to suggest that he would be a competent employee.
This after all is the point of the probaticzary period, to judge such matters,
and this too is the employer's long-term interest in the matter. It should be
pointed out that in other cases where permanent employees have had their licenses
temporarily suspended they have not been dismissed. This practice demonstrates the
employers true long-term interest in such caSes. Under these circumstances then
I must conclude that the qrievor was not properly released but rather was dismissed.
Although it is not central to their finding since the majority in this c&Se
agree that the griever was properly,Yreleased, they also conclude that probationary
employees cannot grieve dismissal in any event under Article 27.6.1. In my
reasoning this point takes on greater significance and once again I must dissent
from the majority. My position is founded on Section 18.2~ of the Crown Employees
Collective Bargaining Act which gives all employees the right to grieve dismissal
without just cause, a right which has been found to be in addition to any procedure
found in the Collective Agreement, and which, of course, takes precedence over any
limitations imposed by such an agreement. (Keeling, 45/78, upheld in Divisional
Court 14 April 1980; and Barnard, 327/82). On these grounds then, I would find
that Mr. Nicholls was dismissed and that he had the right to grieve against his
dismissal as without just cause.
On the main issue in my reasoning, dismissal without just cause, I would find
that the qrievor was disciplined excessively given his positive performance
appraisal and his clear work record. That is not to say, however, that the temporary
suspension of his license for driving while off duty with a blood alcohol level
above -08 is not a very serious matter. This Board did not hear extended arguments
about alternative forms of discipline given the employer's contention that Mr.
Nicholls was properly released, but it was mentioned that other options were available
/9
.
, i.
- 9 -
such as suspension, lay off if no other work was available,
or leave of absence without pay. I would have favoured some
such option, but given the majority award it is pointless now
to disctiss the merits of these various possibilities.
T. Traves, Member