HomeMy WebLinkAbout2023-01428.Barbosa.24-08-02 Decision
Crown Employees
Grievance Settlement
Board
Suite 600
180 Dundas St. West
Toronto, Ontario M5G 1Z8
Tel. (416) 326-1388
Commission de
règlement des griefs
des employés de la
Couronne
Bureau 600
180, rue Dundas Ouest
Toronto (Ontario) M5G 1Z8
Tél. : (416) 326-1388
GSB# 2022-7038; 2023-011428
UNION# 2022-0102-0008; 2023-0102-0026
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Barbosa) Union
- and -
The Crown in Right of Ontario
(Ministry of the Attorney General) Employer
BEFORE Brian McLean Arbitrator
FOR THE UNION Sarah Mikhaiel
Ontario Public Service Employees Union
Grievance Officer
FOR THE EMPLOYER Jordanna Lewis
Treasury Board Secretariat
Labour Practice Group
Counsel
HEARING June 14, 2024
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Decision
[1] I have two grievances before me. The Employer has raised a preliminary
argument that the second grievance should be dismissed for delay or, what it
stated in the hearing, a “timeliness motion”. The parties appeared before me on
June 14, 2024, to argue the Employer’s motion. This decision determines the
motion.
[2] The following brief allegations of fact are not disputed for the purposes of the
motion.
[3] The Grievor, Julie-Anne Barbosa, started working for the Ministry of the Attorney
General as a Court Reporter in 2005. On December 4, 2017, she became a
Court and Client Representative (CCR) and remains in that position. She was a
full-time employee working 36.25 hours per week.
[4] In October 2018 the Grievor was in an accident and suffered an injury. From
November 9, 2018 she was on sick leave on account of her injury. In October
2020, Ms. Barbosa contacted the Employer to return to work as her health was
improving. The workplace parties met and agreed to implement a temporary
return to work plan for March 26, 2021 which included, among other things, the
following accommodations:
- Work from home on a temporary basis
- Graduated [increase of] working hours
- Reduced work hours - 4 hours per day
[5] In April the Grievor sought to have her hours of work increased. On May 7,
2021, the Employer agreed to increase her hours to 4.25 hours per day. On July
29, 2021, following a meeting, the Grievor’s return to work plan was updated
again. It included, among others, the following accommodations:
- Continue to work from home
- Work hours to increase to 4.5 hours per day
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[6] The Grievor was assigned new work which required training. She suffered
medical issues while engaged in the training.
[7] In August 2021, the Employer updated the Grievor’s return to work plan. The
updated plan included the following accommodations:
- Continue to work from home
- Increase of work hours to 4.75 hours per day, commencing August 16,
2021
- increase to 5 hours per day, commencing August 30, 2021
- increase thereafter by 0.25 hours every 2 weeks
[8] In October 2021, the Grievor advised the Employer that on her own initiative she
had increased her hours from 5.25 to 5.5 hours per day starting on or about
October 12, 2021. Nevertheless, the Employer continued to have concerns
about the Grievor’s ability to do the work from a health perspective. The
Employer advised the Grievor that her hours of work would not be increased until
the Grievor provided further medical information in support of continued
increases. Around this time the Grievor received a letter closing out her LTIP
claim.
[9] On December 13, 2021, the Employer advised the Grievor that it would put
together a package of documents to provide to her doctor so that the Grievor
could obtain further medicals. It advised the Grievor, “we will continue your
reduced hours for now until we have a better understanding of your situation from
your healthcare providers.”
[10] Nevertheless, the Grievor wanted to work more hours and objected to the fact
that her hours were being held at 5.5 hours per day. In early February 2022 the
Employer sought to have the Grievor attend an Independent Medical
Examination. The Grievor had concerns with the Employer’s process to date and
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resisted the IME. As a result, the IME was delayed. In addition, the Grievor
expressed concerns that she was not receiving sick credits as she worked.
[11] In April 2022, the Grievor contacted the Union for assistance in communicating
the Employer regarding their denial in increasing her work hours. On April 28,
2022, Michael Kirlew, OPSEU/SEFPO Staff representative, requested a meeting
with the Employer, and with Ms. Barbosa and her support team in attendance, to
address her accommodation issues, including the Employer’s denial to increase
her work hours, and to clarify why she couldn’t access sick credits during her
reduced hours. Ms. Barbosa proposed a date for the meeting.
[12] The Employer replied that the proposed date was not feasible with her schedule.
It clarified that when the meeting took place, Ms. Barbosa was permitted only one
support person present at the meeting who would have a non-participating role.
She continued to clarify the purpose of the meeting, which would be to answer
questions about the IME and to provide clarification regarding the calculation of
STSP credits (sometimes referred to as sick credits in this award). She
requested that all the stakeholders provide alternate availability dates.
[13] In early May, 2022 Mr. Kirlew phoned the Grievor and told her that he realized
the reason she couldn’t access sick credits was that she wasn’t working 7.25
hours a day. On the same day, he contacted Ms. Bates and said there was no
longer a need to discuss STSP credit calculation in a meeting.
[14] On May 13, 2022, Mr. Tim Lochhead, a close friend of the Grievor, replied to Ms.
Bates’ email to say that he understood the purpose of a meeting was broader
than the Employer answering questions about the request for the IME or to
discuss STSP credits, but that the Grievor and he understood the purpose of the
meeting was to discuss:
- Why the Employer stopped Ms. Barbosa’s hours at 5.5 hours per day
- Why the Employer stopped communicating with Ms. Barbosa’s primary
medical provider, her occupational therapist, Ms. Gough
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- The Employer’s expectation of Ms. Barbosa’s work performance during
her graduated return within her limitations and restrictions
[15] Among other issues, he emphasized that Ms. Barbosa’s return to work plan
should have continued as agreed with increased work hours. He also expressed
concerns with the delay in requesting an IME, while Ms. Barbosa’s hours were
stopped, causing her financial loss.
[16] On May 16, 2022, Ms. Bates replied to Mr. Lochhead’s email and reiterated that
the purpose of the meeting would be only to discuss IME questions, and STSP
credit calculation. She also advised that accommodation alternatives would be
discussed once the Grievor completed the IME On May 27, 2022. The Grievor
advised the Employer that she did not have questions about the IME or STSP
credit calculations.
[17] On June 6, 2022, the Grievor filed the first of the two grievances that are before
me, alleging the Employer violated the collective agreement, specifically, but not
limited to Article 2 and Article 3 (discrimination), including allegations of a
violation of the Ontario Human Rights Code and the Return-to-Work Policy. For
the next several months the parties engaged in periodic discussions about the
Grievor’s situation.
[18] On February 13, 2023, the Grievor completed the IME. On March 13, 2023, the
Union provided particulars for the first grievance. On March 15, 2023, the first
day of hearing in this matter took place. There were settlement discussions, but
no resolution was reached.
[19] On June 5, 2023, the Grievor filed a grievance (the “second grievance”) against
the Employer which alleged:
I …grieve that the Employer has violated my rights under the collective
agreement by deny (sic) sick, leave with pay namely the denial of sick
leave credits specifically, but not limited to Articles #2, #3, #44.1, 44.2,
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44.12 and #71 including rights under the Ontario Human Rights Code, The
Return to Work policy and any other article, policy, Act, Code, or legislation
that may apply.
[20] The parties appeared before me on June 14, 2024, at which time the Employer
made this motion. It argues that the second grievance should have been filed
when the Grievor became aware or ought to have been aware of the
circumstances of the grievance, those circumstances being when the Employer
failed to provide her sick leave credits. It argues that was in or about March 2021
when the Grievor returned to work at reduced hours. Shortly after that she would
or should have been aware that she was not accumulating sick credits. Even if
that is not accepted, according to the Employer, she would have been aware by
October 21, 2021, at the latest, that she was not accumulating sick credits
because she had been told by the Employer, at that time, that her hours of work
would not be increased and, therefore, as a result, she would not be
accumulating sick credits. There was reasonably significant discussion about the
issue in the Spring of 2022 where ultimately the Union advised the Grievor that
she was not entitled to sick credits because she was not working full time hours.
The second grievance was not filed until June 5, 2023.
[21] The Employer notes that ignorance is not an excuse for the Grievor; she is
presumed to know the collective agreement and how it applies. She must have
known, by a review of her paystubs, that she was not accumulating sick credits
from her return to work in 2021. In any event, she continued to raise the issue
through at least 2022, well before the date she filed her second grievance.
[22] The Employer relies on Articles 22.1 and 22.2 of the collective agreement.
Those Articles read:
22.1 It is the intent of this Agreement to adjust as quickly as possible any
complaints or differences between the parties arising from the
interpretation, application, administration or alleged contravention of this
Agreement, including any question as to whether a matter is arbitrable.
…
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22.2 If the complaint or difference is not resolved at the local level an
employee may file a grievance, in writing, through the Union, with their
manager within thirty (30) days after the circumstances giving rise to
the complaint have occurred or have come or ought reasonably to
have come to the attention of the employee, who will in turn forward the
grievance to the designated management representative.
(emphasis added)
[23] The Employer points out that the last allegation set out in the Union’s particulars
(set out above) is February 13, 2023, and the grievance was only filed on June 5,
2023, well after the 30 day period provided for in Article 22.2 had passed.
[24] The Employer relies on OPSEU (Finn) v Ministry of Agriculture, Food and Rural
Affairs 2019 CanLII 35308 (Dissanayake). In Finn, the grievor was off work sick
and then was fit to return to work with accommodation. The grievor was not
immediately returned to work by the employer and it was alleged that the grievor
was forced to use sick credits before the employer was able to accommodate the
workplace to meet the grievor’s restrictions. The union grieved, among other
things, that the grievor was not sick while the employer arranged for the return to
work and therefore requiring the use of sick credits was inappropriate.
[25] The employer in that case brought a motion that the grievance was filed beyond
the time limits set out in the collective agreement. It argued that the union was
required to grieve within 30 days of the date the employer first decided to put the
grievor on sick days. The union, like the Union before me, argued that the
employer was in continuous violation of the collective agreement each day it
required the grievor to use sick days while he awaited accommodation.
[26] The arbitrator allowed the motion, finding that the grievance was grieving the
initial decision made by the employer and not the ongoing requirement to use his
sick days. The arbitrator held:
However, that is not what the union has done. It has grieved the employer
decisions themselves. The decision … that a specific period of absence will
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not be treated as a period of leave with pay and must be treated as sick
leave. It may be that the two grievances raise some factual assertions
relevant to the larger issue, which the employer agrees is properly before
the Board. If so, the union may rely on those facts in support of that larger
issue. What it is not entitled to do is to file grievances outside the time limits
grieving employer conduct as discreet violations and seeking remedies with
respect to those alleged violations.
…
In the sick leave grievance he seeks an order that “I be put on paid leave
for this period”. Thus discreet allegations are made and most importantly,
redress is sought with respect to those allegations. These aspects of the
grievances are not insulated from the timeliness requirements in the
collective agreement, simply because the larger issue is also referred to in
these grievances.
[27] The Employer also relies on OPSEU (Bremner) v Ministry of the Attorney
General 2020 CanLII 14807 (Misra). In Bremner there were three grievances
before the Board. One alleged:
that the Employer violated Article 44 of the collective agreement as the
grievor alleges that she had worked for the requisite 20 days to qualify for
access to the Short-Term Sickness Plan (“STSP”) and other entitlements in
February and March 2014, but that she had not been given access to the
STSP and other entitlements since 2014.
[28] Arbitrator Misra allowed the employer’s motion because the grievance was filed
three years late. She stated in part:
[34] I also cannot accept as a reasonable excuse for the delay that the
grievor commenced an approved medical leave in or around 2014. Based
on the facts before me, the grievor believed she had qualified for STSP and
other credits as of March 2014. She was on and off work throughout the
rest of that year until sometime in November 2014 when she finally went off
on a medical leave for an extended period of time. As such, the grievor was
in a position to file a grievance any time in early 2014 after she purportedly
qualified for sick leave benefits, but was not receiving them.
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[35] In the alternative, assuming without finding that the grievor did not
know she had been disentitled to sick leave benefits in 2014, she certainly
knew by January 2015, when she sent the employer an email so stating,
and essentially outlining the same issue that she finally raised in the June
26, 2017 grievance. Clearly the grievor was capable of, and did,
communicate with her employer while off on an approved medical leave, so
I cannot find that she was incapable of filing a grievance, especially by
January 2015. Finally, on this point, I note that there is no medical
evidence before me to suggest that the grievor’s medical condition at the
time impacted her ability to file a grievance.
[29] The Employer also relies on OPSEU (Poblete) v Ministry of Government and
Consumer Services 2019 CanLII 21745 (Herlich). The grievor grieved job
competitions that occurred several years prior. The employer brought a motion
alleging on a few grounds that the grievances should be dismissed, including that
they were untimely. Arbitrator Herlich stated:
[34] In this regard, I am in agreement with the employer, even assuming
that the collective agreement does not provide an exclusively objective
approach to the timeliness of filing a grievance. The collective agreement
ties the timeliness of a grievance to the “circumstances giving rise to the
complaint” not to a grievor’s knowledge about labour relations in general,
the existence of a trade union and its function or, more importantly, the
specific provisions of and rights under the collective agreement. Any such
lack of knowledge cannot be visited upon the employer by requiring the
processing of grievances to arbitration years beyond the circumstances
which gave rise to them.
Union Argument
[30] The Union’s argument is that the violation of the collective agreement was
continuous. A violation occurred every period that the Grievor worked 20 days
and was not credited with a sick credit. Given that the Grievor has not been
given sick credits since her return to work in 2021 and that she has worked
essentially continuously from that date until she filed the second grievance, the
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grievance is timely. It was filed within 30 days of the most recent period where a
sick credit was not provided.
[31] The Union argues that the Employer was obligated to provide sick credits when
the Grievor performed work. The Union relies on Article 44.2 of the collective
agreement which provides:
44.1 An employee who is unable to attend to their duties due to sickness or injury
is entitled to leave of absence with pay as follows:
(a) with regular salary for the first six (6) working days of absence,
(b) with seventy-five percent (75%) of regular salary for an additional one
hundred and
twenty-four (124) working days of absence, in each calendar year.
44.2 An employee is not entitled to leave of absence with pay under Article 44.1
until the employee has completed twenty (20) consecutive working days of
employment.
44.3 Where an employee is on a sick leave of absence which commences in one
(1) calendar year and continues into the following calendar year, the employee is
not entitled to leave of absence with pay under Article 44.1 for more than one
hundred and thirty (130) working days in the two (2) years until the employee has
returned to work for twenty (20) consecutive working days.
44.4 An employee who has used leave of absence with pay for one hundred and
thirty (130) working days in a calendar year under Article 44.1 must complete
twenty (20) consecutive working days before the employee is entitled to further
leave under Article 44.1 in the next calendar year.
[32] The Union’s position is that under Article 44.2 the Grievor is entitled to a leave of
absence with pay after working 20 consecutive days. Accordingly, every 20
working days the Grievor earns a sick credit. Since no sick credits were paid, the
violation is ongoing.
[33] The Union relies on Ontario Public Service Employees Union (Belgrave) v The
Crown in Right of Ontario (Ministry of the Attorney General, 2023 CanLII 61427
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(ON GSB)) (Waddingham). Belgrave involved facts very similar to those before
me. In that case Arbitrator Waddingham first distinguished Bremner (which was
also relied on by the Employer in this case) and then held:
[34] In OPSEU (Hunt et al.), supra, Arbitrator Abramsky considered the
employer’s preliminary objection to the arbitrability of the grievance on
grounds of timeliness. The grievance was filed following a change in the
employer’s practice several years earlier impacting the payment of an
overtime premium. Arbitrator Abramsky undertook a thorough review of the
arbitral jurisprudence, and considered a definition of a “continuing
grievance” drawn from the 1981 edition of Evidence and Procedure in
Canadian Labour Arbitration (p. 35), as set out in Re British Columbia and
B.C.N.U., 1982 CanLII 5128 (BC LA), 5 L.A.C. (3d) 404 (Getz), at page
415:
“The appropriate rule for deciding the isolated or continuing nature
of the grievance is the rule developed in contract law. The
recurrence of damage will not make a grievance a continuing
grievance. It is necessary that the part in breach violate a recurring
duty. When a duty arises at intervals, and is breached each time, a
“continuing” violation occurs, and the agreement’s limitation period
does not run until the final breach. When no regular duty exists and
the harm merely continues or increases, without any further breach,
the grievance is isolated, and the period runs from the breach,
irrespective of damage.”
[35] Among the cases reviewed by Arbitrator Abramsky is Re Port Colborne
General Hospital and O.N.A., in which Arbitrator Burkett defines a continuing
grievance as follows:
It is clear from a reading of the cases that the question that must be
asked is whether or not the conduct that is complained of gives rise to a
series of separately identifiable breaches, each one capable of supporting
its own cause of action. Allegations concerning the unjust imposition of
discipline, the improper awarding of a promotion or the failure to provide
any premium or payment required under the collective agreement on a
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single occasion, while they may have ongoing consequences, constitute
allegations of discrete non-continuing violations of the collective
agreement. In contrast, an allegation of an ongoing failure to pay the
wage rate or any benefit under the collective agreement or an ongoing
concerted work stoppage constitute allegations of continuing breaches of
the collective agreement. In these cases the party against whom the
grievance is filed takes a series of fresh steps each one giving rise to a
separate breach. In this latter type of case the time-limits for the filing of
a grievance, apart altogether from any question as to when damages
commence to run, must be found to be triggered by the breach closest in
time to the filing of the grievance.
(Emphasis added.)
[36] Vice Chair Abramsky found that the alleged ongoing failure to comply with
the overtime requirements set out in the collective agreement constituted a
continuing grievance. Arbitrator Abramsky concluded, at page 27:
…that the grievance involves an alleged ongoing failure to comply with
the overtime requirements set forth in the collective agreement. The
grievance alleges that by changing the practice, ‘we have been forced to
perform authorized duties on overtime hours without overtime pay,
contrary to…the collective agreement.’ It is not the change in practice,
per se, that is being grieved. It is the alleged consequence of that change
in practice – the alleged breach of the overtime provisions – and that
alleged breach is ongoing.
[37] I concur with the reasoning of Arbitrators Burkett and Abramsky. The
Employer argues that its determination that the Grievor did not qualify for STSP
benefits was made on October 4, 2021 and communicated to the Grievor.
However, in determining whether a grievance is a “continuing” one, the focus is
not on the nature of the employer’s decision (that is, whether the decision is
recurring) or on when the Grievor first became aware of the employer’s decision.
Rather, the focus is on whether or not the employer has an ongoing obligation
under the Collective Agreement (that it is allegedly in breach of).
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[38] The provision of STSP inter alia sick days is an ongoing and specified
benefit under the Collective Agreement. The Employer has a recurring duty
under the Collective Agreement to provide STSP benefits in accordance with
Article 44. The Grievor, when she was on an accommodated work plan
attempted to access her STSP benefits. The Employer responded with a denial
of STSP benefits, claiming she was ineligible to receive them. The Grievor’s
STSP benefits were not restored until after she returned to her regular work
schedule in October 2022. This denial amounts to an alleged violation of Article
44 of the Collective Agreement and the Employer’s ongoing obligation under the
Collective Agreement. The Employer’s denial of STSP benefits to the Grievor in
October 2021 and again on May 30, 2022 can be assessed on its own for
compliance with the Collective Agreement on this basis.
[39] When as here, the duty is ongoing but arises at intervals, and it is allegedly
breached each time, a “continuing violation” occurs and the Collective
Agreement’s limitation period for filing a grievance does not run until the final
breach occurs. At the time the grievance was filed on July 15, 2022, the Grievor
continued to be denied STSP credits. The Grievor’s STSP credits were not
restored until sometime after October 2022, when she returned to regularly
scheduled hours. I find this to be a continuing grievance to be determined on its
merits. The issue of remedy is separate from the timeliness issue and may be
dealt with at a later date.
[34] The Union argues that the same reasoning should apply to the case before me.
It also notes that the issue of remedy (and whether that may be limited by the
date the Grievor filed her grievance) is a separate issue and need not be decided
at this point.
[35] The Employer replies that the second grievance only deals with the Employer’s
failure to provide STSP credits. It is a stand-alone complaint. The “decision” or
failure to deny sick credits was made in 2021 and that decision was not
challenged until 2023.
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DECISION
[36] The starting point of my decision is Article 22.2 of the collective agreement which
provides:
22.2 If the complaint or difference is not resolved at the local level an
employee may file a grievance, in writing, through the Union, with their
manager within thirty (30) days after the circumstances giving rise to the
complaint have occurred or have come or ought reasonably to have come
to the attention of the employee, who will in turn forward the grievance to
the designated management representative.
[37] The essence of the Employer’s argument is that the Grievor became aware (or
ought reasonably to have been aware) of the circumstances giving rise to her
complaint many months prior to filing her grievance in that she was aware (or
ought reasonably to have been aware) that she was not accumulating sick
benefits after her return to work in 2021.
[38] The Union does not dispute that assertion. However, its position is that the
breach of the collective agreement is a continuing one: a new breach occurs
each time the grievor worked 20 days without being credited with a sick credit.
Therefore, the grievance is timely, and the timeliness issue raised by the
Employer is only relevant for determining what damages might be owing to the
Grievor.
[39] In Re Port Colboume General Hospital and O.N.A., supra, at pp. 327-28,
Arbitrator Burkett discussed what makes a "continuing" grievance:
It is clear from a reading of the cases that the question that must be asked
is whether or not the conduct that is complained of gives rise to a series of
separately identifiable breaches, each one capable of supporting its own
cause of action. Allegations concerning the unjust imposition of discipline,
the improper awarding of a promotion or the failure to provide any premium
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or payment required under the collective agreement on a single occasion,
while they may have ongoing consequences, constitute allegations of
discrete non-continuing violations of the collective agreement. In contrast,
an allegation of an ongoing failure to pay the wage rate or any benefit
under the collective agreement or an ongoing concerted work stoppage
constitute allegations of continuing breaches of the collective agreement. In
these cases the party against whom the grievance is filed takes a series of
fresh steps each one giving rise to a separate breach. In this latter type of
case the time-limits for the filing of a grievance, apart altogether from any
question as to when damages commence to run, must be found to be
triggered by the breach closest in time to the filing of the grievance.
[40] That reasoning has been applied to cases before the GSB. For example, in Re
The Crown in right of Ontario (Ministry of the Attorney General) and Ontario
Public Service Employees Union (Hunt et al.) Vice Chair Abramsky found that
there were two ways to look at these sorts of cases:
There are two ways to view this grievance. First, it can be viewed as a
challenge to the revision of a practice that, on the Union's evidence, took
place in 1991, and on the Employer's evidence, took place in either 1998 or
1999. Under this view, the grievance would clearly be untimely. It would be
either ten years or two to three years too late.
The second way to view the grievance is as a challenge to the ongoing
impact of the change in practice in relation to the overtime provisions in the
collective agreement. Under this view, the grievance would be a
"continuing grievance" and the time for filing it would run from the latest
breach.
[41] Applying that sort of analysis here, one way to look at facts before me is that this
grievance is about the Employer’s decision to not provide sick credits to an
employee accommodated by not being required to work full time hours. Here,
that decision was made, at the latest, sometime in the last quarter of 2021. The
other way to look at the grievance is that it is a challenge to the ongoing refusal
to provide a sick credit to the Grievor each time she works twenty days. As in
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Hunt, under this view, the grievance would be a "continuing grievance" and the
deadline for filing it would run from the latest breach.
[42] Upon careful consideration, I conclude that the grievance involves an alleged
ongoing failure to comply with the requirements in the collective agreement. The
grievance alleges that “the Employer has violated my rights under the collective
agreement by deny (sic) sick, leave with pay namely the denial of sick leave
credits…”. It is not the Employer’s decision that is being grieved. It is the alleged
consequence of that change in practice — the alleged breach of the sick leave
provisions — and that alleged breach is ongoing.
[43] I acknowledge that the allegations of fact before me have elements of each of the
categories of cases that the parties rely on in support of their respective positions
and arguments. There is little doubt that the Employer made a decision that the
collective agreement did not require it to provide sick benefit credits to the
Grievor and communicated that decision to her. The Grievor did not grieve that
decision within 20 working days of receiving this information from the Employer.
That is the kind of situation where employees are generally precluded from filing
a grievance more than thirty days after the Employer’s decision. On the other
hand, the benefit claimed by the Grievor is the type of benefit, similar to wages,
that she arguably earns periodically as she works. The failure to pay that benefit
is, assuming the Grievor’s entitlement, a recurring breach of the collective
agreement which can be grieved each time it occurs.
[44] The difficulty with a finding that the grievance is untimely is that it could mean
that the Grievor is essentially disentitled to a benefit (again, assuming, without
finding that she is so entitled) until she returns to work on a full-time basis. This
is surely part of the reason for the continuing grievance caselaw. It is not fair, for
example, that an employee permanently receive a lower wage than they are
entitled to because they did not grieve the Employer’s decision at first instance.
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[45] The facts of this case are essentially on all fours with Belgrave. In that case the
grievor asked the employer why she was not in receipt of STSP credits. The
employer responded that she had not worked 20 consecutive days which was a
requirement for the entitlement to STSP under the collective agreement. The
grievor continued to ask questions on and off until in May 2022 the grievor raised
the issue again and the employer again denied her request. The grievor filed a
grievance in July 2022 and it was found to be timely since it was filed within thirty
days of the most recent failure to provide the benefit. The delay did not matter
because each of the employer denials constituted a fresh breach which could be
grieved.
[46] These are different circumstances than the cases relied on by the Employer. In
Finn, Arbitrator Dissanayake found that the union “grieved the employer
decisions themselves” including that a “specific period of absence will not be
treated as a period of leave with pay and must be treated as sick leave”. Here,
the Grievor did not grieve any specific employer decision. She grieved the fact
that she was not receiving credits in the normal course.
[47] In Bremner v Ministry of the Attorney General 2020 CanLII 14807 (Misra) there
were three grievances before the Board. One alleged:
that the Employer violated Article 44 of the collective agreement as the
grievor alleges that she had worked for the requisite 20 days to qualify for
access to the Short-Term Sickness Plan (“STSP”) and other entitlements in
February and March 2014, but that she had not been given access to the
STSP and other entitlements since 2014.
[48] Arbitrator Misra found in favour of the employer that the grievance was untimely.
However, in that case the Union did not argue that there was a continuing breach
of the collective agreement in the Employer’s failure to provide the grievor STSP
benefits. It is therefore distinguishable.
[49] In OPSEU (Poblete) v Ministry of Government and Consumer Services, supra,
the Union grieved job competition decisions that occurred years previously. The
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grievance was dismissed as untimely. However, in that case there was no
ongoing breach of the collective agreement alleged. What was being grieved
was the employer’s decision in the job competitions; it was not a continuing
breach of the collective agreement.
[50] For these reasons, in my view, this is a continuing grievance and ought not to be
dismissed for delay. Instead, any concerns with respect to delay can be
addressed in the damages phase of this case, if there is one. The Grievance is
not about an Employer decision. Instead, the Employer applied its usual policy in
these circumstances and did not permit the Grievor to earn and accumulate sick
credits.
[51] Finally, in my view there is no basis, at this point, for a finding that the Union has
improperly expanded the grievance. If appropriate, that issue can be re-raised
during the evidence phase of the hearing or during opening statements if the
Employer believes that there is an improper expansion.
[52] For all the foregoing reasons the Employer’s preliminary motion is dismissed. I
remain seized.
Dated at Toronto, Ontario this 2nd day of August 2024.
“Brian McLean”
Brian McLean, Arbitrator