HomeMy WebLinkAbout1983-0239.Union.83-11-29IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
Between: OPSEU (Union Grievance)
Grievor
- and.-
The Crown in Right of Ontario (Ministry of Citizenship and Culture)
Employer
Before: M. R.‘Gorsky Vice Chairman
E. J. Bounsall Member _
P. H. Coupey Member
For the Grievor: G. Richards
Grievance Officer Ontario Public Service Employees Union
For the Employer: N. J.~ Robinson
Staff Relations Officer
Staff Relations Division
Civil.Service Commission
Hearing: July 15, 1983
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! DECISION
I This is a Union grievance, dated March 21, 1983,
which is contained in the following letter from Sean O'Flynn,
the President Of the Union,to J. W. Ramsay, the Deputy Minister,
Ministry of Citizenship and Culture, which letter is as follows:
The Deputy Minister
bfinistry of Citizenship & culture
77 Bloor Street West, 6th floor
Toronto, Ontario
WA 2R9
Attention: Mr. James Ramsay
Dear Mr. Ramsay,
.:
The Union hereby grieves the violation of Article 2 of the
Collective Agreement in that the employer has refused to
deduct and remit dues on behalf of three part-tine nurses
employed by the Ontario Science Centre, namely,
Us. Linda Davis, Ms. Gail Hamel and Us. Marjorie Quinhill.
The Union requests that such dues be deducted and remitted
to the Union with respect to the period dating back to
September 24, 1982 when the Union first advised the employer that these nurses had been excluded from the bargaining unit
contrary to the provisions of Section l(l)(f) of the Crown
Employees Collective Bargaining Act.
In addition to the foregoing, we also request that you
direct that full compensation be paid to these nurses for
the loss of all wages and benefits to whith they would have
been entitled asa member of the bargaining unit, dating
Krom September 24, 1982.
Yours truly,
Sean O’Flynn
Peesident
SOF/GR: lm
C.C. Tony Petti, President, Local 949
Frances Chalmers
Linda Davis Gail IIamcl Marjorie Quinhill Louise Rose, Staff Representative
Nancy Robinson, Civil Service Commission
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The letter of September 24, 1982, referred to in
Mr. O'Flynn's letter, Was to Dr. J. TUZO Wilson, and is as follows:
Dr. J. Tuzo Wilson
Director General Ontario Science Centre
770 Don Mills Road
Don Mills, Ontario
M3C IT3
Dear Dr. Wilson:
Re: Status of Part-Time Nurses
Ontario Science Centrc
It has come to our attention that there are three part-time
nurses employed by the Ontario Science Centre who we
contend have been improperly excluded from the application
of the collective agreement between OPSEU and the Crown
in Right of Ont~ariob
We understand that Linda Davis, Gail Hamel and Narjerie
Quinhill have been regularly employed for the last 5 or
6 years to provide a nursing service to the.visitors and staff of the Science Centre in the absence of the regular
full time nurse, Frances Chalmers. .These nurses regularly
replace Ms. Chalmers on weekends, statutory holidays,
vacation and sick days. As such, we contend that they
do not come within the list of persons excluded from our
bargaining unit found in section l(l)(f) of the Crown Employees, Collective Bargaining Act.
We are therefore requesting that you cai&cnce forthwith
the payment of all wages cind benefits~described ix article 3 of the collective agreement to these employees
and further that you deduct and remit union dues on
their behalf.
The union understands that there is also a fourth part-time
nurse, Kay Murray, whom is enploycd by the Science Centre.
an a nore casual basis. While we do not have the right
to demand that she be treated in accordance with the
collective agreement, it would seem only fair that she also
be paid the same hourly rate as her colleagues.
Your early attention to this matter will be appreciated.
Yours truly,
Scan O'Flynn President
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Response to Mr. O'Flynn's letter of September 24 was
made in a letter of February 17, 1983, to George Richards, a
Grievance Officer with the Union, from Nancy Robinson, Staff
Relations Officer, with the Employer, which letter is as follows:
Hr. George Richards
Grievance Officer
Ontario Public Service Employees Union
1901 Yonge Street
Toronto. Ontario H4S 225
Deer Mr. Richards:
This is to advise you that we have investigated the question
of the status of the part-time nurses employed by the
Ontario Science Centre and agree that these nurses are
employees within the meaning of the Crown Employees Collective
Bargaining Act.
We understand that the Ontario Science Centre is taking the
necessary steps to include these employees in the bargaining
unit effective January 24, 1983.
Yours truly,
Nancy Robinson
Staff Relations Officer
Mr. Richards replied to Ms. Robinson's letter Of
February 17, by a letter to Ms. Robinson, dated February 21,
1983, which letter is as follows:
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Ms. Nancy Robinson
Staff Relations Officer
Civil Service Commission
2nd floor, Frost Building South
Queen’s Park
Toronto, Ontario
b17A 125
Dear Ms. Robinson,
Re: Part-time Nurses, Ontario Science Centre
Thank you for your letter of February 17. While I am pleased
to learn that you agree that the part-time nurses are in fact
employees within the meaning of the Crown Employees Act, I am
not satisfied by your stated intention of implementing the
necessary steps effective January 24. In my opinion, the
Union is entitled to receive dues, and the employees are
entitled to receive the benefits of the Collective Agreement,’
retroactive to September 24, 1982, the date of Mr. O’Flynn’s
letter placing management on notice of our.concerns about this matter.
Unless you are willing to reconsider this matter, I shall recommend that the Union file a policy grievance claiming the
dues, and that the nurses in question file individual griev- ances claiming pay and other benefits retroactive to that,
date.
Yours truly,
George Richards
Gri A-Vance Officer
bee: Frances Chalmers, 75 Graydon Hall Dr. $905, Don Hills M3A 3M5 Tony Petti, President,
Scarborough MlB lA7 Local 549, 76 Corsey Square,
Louise Rose, Staff Representative
,i.
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A reply to the letter of February 21, was made by
MS. Robinson to Vr. Richards on March 8, 1983, which letter is
as follows:
Hr. George Richards
Grievance Officer
Ontario Public Service Employees Union
1901 Yonge Street Toronto, Ontario
H&S 225
Dear Mr. Richards:
Re: Part-time Nurses, Ontario Science Centre
In response to your letter of February 21, 1983. please be
advised that it is our view that January 24. 1983 was the
date that the parties reached agreement on the status of the
part-time nurses at the Ontario Science Centre.
It has not been the practice of the parties to make an egree-
ment retroactive, nor has the Tribunal ever directed retro-
activity, when individuals mve either into or out of the
bargainfng unit, and we are not prepared to make this case
an exception.
Yours truly,
N. Robinson
Staff Relations Officer
,The next correspondence in this matter was the letter
of March 21, 1983, first noted above.
Subsequently, the focus of the grievance was narrowed
in the manner set out in a letter frc.m Mr. Richards to Ms. Robinson,
dated July 7, 1983, the material portions of which are as follows:
'I understand that the employer has agreed to pay the three part-
time nurses their wages retroactively to September 24. 1982. as
originally requested. Therefore, the only issue remaining in dis-
pute is whether or not the Union is entltled to claim dues on
behalf of these nurses retroactively to the same date, unless
there is sane outstanding difference between the parties concern-
ing the calculation of monies pa5d to the nurses in question.
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Confirmation of Mr. Richard's understanding is
contained in a letter from G. A. Berry, Chief Personnel Services
of the Employer, to Nr. Richards, dated July 12, 1983, the
relevant portion of which is as follows:
I trust this will settle the matter of pay for the
part-time nurses as outlined in the Union's grievance
and will leave only the matter of retroactive dues
as the outstanding issue to tie argued before the
Grievance Settlement Board.
Accordingly, the issue before,this Board was restricted
to matter raised in Mr. Berry's letter of July 12, 1983, as
set out in the preceding paragraph.
Mr. w. J. Gorchinsky, Chief Staff Relations Officer,
Civil Service Commission, testified:
(1) That, in the first instance, the decision as whether a person
is an employee within the meaning of ss.l(l) (f) of the
Crown Employees Collective Barga.ining Act, and hence included
in the bargaining unit, pursuant to Article l.l.of the
collective agreement,is made by the Employer.
(2) That he performed this duty as delegate of the Executive
Director of the Staff Relations Division, who, in turn,
would be exercising this responsibility on behalf of the
Management Board of Cabinet.
(3) When a decision was arrived at by the Employer to treat a
person, formerly excluded, as now having employee status,
so that the person was a member of the bargaining unit,
dues then, and only then, commenced to be deducted from
.the pay of the employee pursuant to Articles 3.13.1, 3.13.2
and 3.13.3 of the collective agreement:
(4) That persons "transferred in" to a bargaining unit were I;
not treated as having been transferred in retroactively:
that is at the date of receipt of the Union request or
any earlier date.
(5) The date of a person's being "transferred in," was, for
the purpose of deduction of dues, on the date of the decision,.
reached by the representative of the Employer that the I
person had employee status or the date of the decision as '
to employee status having been made by the Public Service
Labour Relations Tribunal,pursuant to a hearing conducted
I under the authority of s.40(1) of the Crown Employees
Collective Bargaining Act,
,. (6) That the practice, as described by Mr. Gorchinsky, was
never departed from.
..'
The position of the Union was that:
(1) The persons in respect of whom the grievance was filed are
included in Article 3.13.1 and that the Employer was
required to deduct union dues with respect to those
employees from the date of the notification by Mr. O'Flynn
to Dr. Wilson, on September 24, 1982, that the nurses
mentioned had been improperly excluded from the bargaining
unit.
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(2) The the Employer was put on notice of the ~Union's position
by Mr. O'Flynn's letter to Dr. Wilson of September 24, 1982.
There is nothing in the collective agreement which requires
the Union to file a grievance in order to be able to claim
retroactivity in cases such as this. On September 24, 1982,
clear notice of the Unionposition had been given to the
Employer, who then notified the Union, on February 17, 1983,
(letter to Mr. Richards from Ms. .Robinson) that the matter
had been investigated. To require that the Union file a
grievance in order to be in a position to claim retroactivity
to that date would interfere with the amicable settlement
of disputes. Where matters of retroactivity were concerned,
it would become necessary to quickly file a grievance in
order to be able to claim retroactive compliance by the
Employer. Such a requirement, it was submitted, would
unnecessarily complicate relations between the parties,
turning routine disagreements, which would often be settled
without the necessity of a ,grievance being filed, into ones
where settlement was less likely because a grievance had to
be filed,.
For the Employer, it was also urged that:
(1) There was no evidence that the part-time nurses become
members of the bargaining unit before January 24, 1983.
(2) There is no authority in the Act or the collective agreement
that provides for retroactivity in these circumstances. '
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(3) The Union was never led to believe that the Employer would
agree to retroactive compliance with Article 3.13.3.
(4) The Union was never discouraged from filing a grievance
or making an application to determine employee status.
During argument in reply, Mr. Richards stated that he
wished to submit evidence that the Employer had induced
the Union to believe that, in the circumstances of this
case, retroactive deduction of dues would be made. By
agreement he was to furnish the Employer with the examples
being relied upon. Thereupon the following exchange of
correspondence ensued:
Iris. Nancy Robinson
Staff Relations Officer
Civil Service Connnission
Room 249, Frost Fkrilding South
tieen’s Park
&onto, Gntario
M7A 125
July 22, 1983
Dear Ns. Robinson:
Re: Part-Time h'urses
Ontario Science Centre
This will confirm cplr telephone conversation in which I drew your
attention to three examples of cases in which the parties agreed
to dues deduction from employees retroactive to a date before the
date of their agreement on the status of those persons as employees
within the meaning of the Crown Employees Collective Bargaining Act.
Thisevidence would appear to contradict the statement of Mr.
Corchinskp to the Arbitration Board on July 15th to the effect that
dues deductions only commence from the point at r&rich the parties
agree on the transfer of persons into the Bargaining Unit.
Bill Lokay confirms that the principle as stated by Mr. Gorchinsky
is correct with respect to their dealing with large groups of
employees, but the principle dots not appear to have held through
in cases wfiere individuals or smaller groups were involved as these
cases demonstrate.
Under the circumstances, the Union contends that this extrinsic
evidence does not show a consistent pattern of past practice with
respect to the administration of Article 2 or Article 3.13.1 tich
hould justify the Board in dismissing the grievance in the instant
case.
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OnbioPubllcSaviab~i~ MS. ~~~~ ~~~~~~~ July 22, 1983 Page: 2
Civil Service Connnission
Even if the Union is wrong in the conclusions vrhich it draws from this
evidence, we would submit that the evidence per se is irrelevant
because the language of the Collective Agreement is not ambigious
according to the tests set out in re: Leitch Gold Mines Ltd. et al,
v. Texas Gulf Sulphur Company, 3D.L.R.(3D)161.
L
GR:eg
cc: Prof. M.R. Gorsky
Vice Chaii-man
Crown Enployees Settlement Board
Mr. E.J. Bounseli
Member Grievance Settlement Board
Mr. P.H. Coupey
kmber Grievance Settlement Board
.
Civil
Service
Commission
July 29, 1983
Kr. George Richards
Grievance Officer
Onrario Public Service Exployees Unim
1901 Vonge street
Toronto, Ontario
H4S 225
Ilear PZ. Richards:
Re : Part-time Nurses
Ontario Science Centre
I acknowledge receipt of your letter dated July 22, 1963 with
respect to dues deductions for p?rt-:ize nurses at the Ontario
Science Cectre.
I note that Mr. Lokay has agreed to t:7e principle as stated by
Kr. Gorchinsky, that dues deductions ax c-rrent and not retro-
active a where large groups of employees sre involved. Since
that is the principle applied to larce groups, clearly that same
principle shollld be applied to all trcsfers, including single
mdividuals or small groups.
The three exceptions to the principle are indeed exceptions, eri
clearly no new "principle" shocld be established far individuals
01 small groups. Further, e?ch of t:la t:?ree exceptions are dis-
tinguishable fron the Frir.cl?ie. Fcr exa?le. C.R. FAodes et.
al. were in the bargainin? -7,;: and sz:i:: dues, x.'cre removed
from the bargaining unit ir. error a-.6 wre placed in the bargaining
unit with full retroactivitv because a.5 error had been made in
removing them in the first instance.
1n all three exceptions to the rule, ir: fact, there was no dis-
agreement between the parties as to the a?-;irop:riate date.
Even if the t!!ree exceptions were no: tirtinqrishable. the
irrinciple acreed to should continue tc qeveil. The exceptions,
distinguishable or not, shoc?d nor become the rcle.
./2
t
In accordaxe'with the directior. of the Board. would you indicate
whether there is any disagreement that in eve-y case where a
question has been referred to the Tribunal, dues have been
deducted or have ceased to be deducted as.of the date of the
Tsibunal decision, including the cases of Mr. Zuibrickyi and Mrs.
Thonigs, raised at the hearing on July .15, 19837'
Yours truly,
xancv Rcbinson
Staff Relations Officer
CC: Prof. N.R. Gorsky e
i'ice Chairman
Ontario Crown Err?loyees Grievance
Settlenent Board
3%. E.J. Bounsell
Mazbar Grievance Settlenent 6oard
?!r. F.H. Coupey
?!embe+ Grievance Settlement Board
.AGgust 26, 1983 :
Ms. Xancy Robinson
Staff Relations, qfficer
Cii.il Service Commission
2nd floor
Frost Building South
Toronto, Ontario ’
Mi.4 115
Dear >ls. Robinson: ,
;X+.: :-. :L!t!;;,;, i
.--z*-
i
Re: Part-Time Rurses
Ontario Science Centre
Replying to your letter of July 29th, I have no reason
to believe that your statement concerning the practice
of the Employer with regard to the deduction of Union
dues following a decision on the Employees’ status by
the Tribunal is incorrect.
At the same: time, I would point out that the Law on this
subject, such as it is, appears to have been set out by ,
the Tribunal in the decision re OPSEU and the Crown in Right of Cntario regarding Mr.Ian h’elton, File No. T3/76 decided April 6th, 19?7 by Mr. Owen Shime at Page 4:
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“he are concerned with the dates and responsibilities
as they exist at the date of the making of the
application. This is a policy generally followed
by Boards and Tribunals called upon to make similar
determinations as the one we are required to make
in the present case (regarding employee status).
The policy is designed to discourage implementing
changes in the duties and responsibilities of a
person who was the subject matter of the application.
There could be situations where ex post facto
changes are made in an attempt to subvert the
application. We hasten to add that there was no
hint of that type of conduct in this case, but
since this is the first case of its kind to come
before this Tribunal as ‘it is presently constituted,
we feel that it is appropriate to forecast our
general position in order to assist the parties in
future cazes .‘I
c
I/
In my opinion, it follows from this decision as a matter
of Law that all deductions or cessations of deductions
of IJnion dues should stem from the date of an application
to the Tribunal pursuant to Section 40 of the Crown
Employees Collective Bargaining Act, rather than from
the date of the Tribunal’s decision.
In the instant case, the Union refrained from making an
application to the Tribunal, because we were given every
indication that the Employer was seriously considering our !
position as set out in the letter of September 24, 1982.
Under the circumstances, the Union submits that the
Employer should be estopped from asserting the position ’
that it has taken before the Grievance Settlement Board
because its conduct caused the Union to act to its
,
detriment by failing to assert its claim concerning the
status of the part-time Kurscs in the Ontario Science
Centre before the Tribunal in .a more timely fashion.
liith regard to your arguments concerning the three reported
exceptions to the principle or rule regarding dues deductions,
I have no further comment beyond that set out in my letter :
of July 22nd to the effect that the language of the
Collective Agreement concerning the deduction of Union dues :
is not ambiguous, and hence extrinsic evidence concerning
the past practice of the parties is inadmissable as an ;
aid to deciding the correct interpretation and application
of the clause in dispute.
.
Yours truly, _. --~~ .__.,_
,,/.- : 7 -J-.,,
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“‘\
,-ls;L.., . -.----. / ,I,’ ‘-.’
George A. Richards
Grievance Officer
Crown Employees Grievance Settlement Board
Mr. E.J. Bounsell
Member, Grievance Settlement Board
Mr. P.tl. Coupey
Member, Grievance Settlement Board
\\'.A. Lokay
Grievance Classification Officer GR:dl
I am satisfied that the cases relied on by the Union
in its letter of July 22, 1982, do not disclose a practice which
was intended to indicate to the Union that dues retroactivity
would become the norm in dealings between the parties. Tie
cases referred to by Mr. Richards were dealt with on the basis
of special factorsiheing those present which explain each action.
Mr. Richards referred to the Welton case in his letter
of August 26, 1983. Mr. Shime, in that case, did not say dues
deductions would be retroactive to some date. Rather, he said ,
that duties for determining employee status would be those
existing on the date the application was made. It does not follow,
nor was it demonstrated, that deductions would be ordered to be
made from the date of the application.
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The Employer's conduct in indicating that the matter
was being investigated did not amount to a representation upon
which an estoppel could be founded. There was no evidence of
an Employer invitation or request to cause the Union to delay
filing a grievance or to make an application to the Tribunal.
I agree with Mr. Richards that the relevant agreement
provisions are not ambiguous. Under Article 3.13.1, dues deductions
can only be made from an employee covered by that Article.
Mr. Richards referred to the case of Zuibrycki and the
Ministry of Industry and Tourism (Swan), unreported. There, it
was held that a decision that a person was an employee, whether
of the Tribunal or of the parties, "is merely declaratory of a
pre-existing status, created by the statute or by the collective :
agreement. " (Zubrycki case at p.14). I would find that a
decision reached by the Employer that a person is not "a person il ,,
not ordinarily required to work more than one-third of the
normal period for persons performing similar work . .." and hence
is an employee under the Crown Employees Collective Bargaining
Act, is also "declaratory of a pre-existing status." Does the
Employer's decision to recognize the persons in question as employees,
effective January 24, 1983, impose an obligation on it to deduct
dues from those employees retroactively because the decision has \
a retrospective effect? That is: because it "is . . . declaratory of d
a pre-existing status .,..I( If that were the case, the duty to 'I
deduct dues would be retroactive to the date when the person actually
becomes an employee and not to the date when the Union first notified,
:~,?.
.:
..(,
::
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,.:
;
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the Employer that the person had been excluded from the bargaining
unit contrary to the provisions of the Act.
The issue, here, requires a determination of whether
Article 3.13.1 of the collective agreement has a retrospective
operation and not only whether a person's employee status has a
retrospective operation. That is, once it is ascertained that a
person is an employee under the Act, and governed by Article 3.13.1,
must deductions be made for the period from.when employment status
WdS, in fact, first achieved, even though the existance of that
status only came to light at a later time through agreement of
the parties, a decision of the Tribunal or a decision of the
Employer following investigation? If Article 3.13.1.has a retro-'
spective operation, then the Employer would now have to deduct
all dues that were payable by the employees affected by this
grievance from future wage payments for the period from when
they first actually become employees.
In this case, there is evidence that the subject
persons'were 'employees within the meaning of the,Act, at least from
September 24, 1982. There was no other evidence on the point. I
do not believe that,the Employer was urging that the nurses were
not employees under the Act as at September 24, 1982. What was
being put forward as the position of the Employer, was that the
nurses could not be treated as such for the purpose of dues deduction
until the day they were declared to be employees by the Tribunal,
by agreement of the parties or unilaterally by the Employer. Because
I agree with the reasoning and conclusion of Mr. Swan in the
.
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Zuibrycki case, I cannot accept the Employer's argument. Recog-
nition of the nurses' status for pay purposes, from September 24,
1982, as set out in Mr. Berry's letter to Mr. Richards of July 12,
:
1983, discloses that the nurses should have been treated as
employees as at the former date. What the Employer objected to
,was treating Article 3.13.1 as having an operation retroactive
to that date: when the facts disclose they were employees. The
Employer maintained, throughout,that the article operated only
to bind it to make deductions from the date when the employee
status of the nurses was recognized by it (January 24, 1983).
My reading of Article 3.13.1 satisfies me that its
language does not envisage retrospective operation of the duty
to deduct dues on the part of the Employer. I interpret Article
3.13.1 as being intended to bind the Employer to deduct dues
from the pay of employees for a current dues period and not
with respect to dues owing for a previous period. Articles
3.13.1, 3.13.2 and 3.13.3, deal with dues deductions from
seasonal or part time employees. Article 2 deals with the "Check-
off of Union Dues" from the "regular staff," and is as follows: :
C
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That article is couched in language indicating deductions for
current dues from "the regular weekly pay." The language of
Article 2.1 does not lend itself to the deduction of dues
accruing retroactively.
Article 3.13.1, being worded.less precisely, might be
capable of being read so as to include dues owing from a previous
pay period. It is unlikely that the parties would have intended‘
dues deductions to have a retrospective operation for part-time
staff and a prospective operation for regular staff. In order to
furnish business efficacy to the agreement, the two articles
should be dealt with on the basis of their having a prospective
operation unless the language of Article 3.13-l is clear in
supporting the conclusion suggested by the Union. It is not,
while Article 2 is~ clear in suggesting a prospective operation.
There is no reason for failing to,endeavor to harmonize both
articles, which purport to achieve the same purpose.
Appendix 1 of the agreement, which is referred to in
Article 2, is as follows: '
STAFF RELATIONS DIVISION
2nd Floor, Frort’Sulldlng Soulh
965-2002
February 13. 1978
Mr. J. Poitras
Negotiator
Ontario Public Service Employees Vnion
1901 Yonge SIreel. 71h Floor
TORONTO. Oniario (M4S rye)
Dear Mr. Poiffas:
This letter will confirm the understanding reached during
the 1978 Working Conditions Negotiations with reference lo
Article 2 of the Agreement.
1. By June 30. 1978, the Employer shall provide the Union
with a monthly reconciliation tape on Union dues. The
tape shall contain the fallowing information: Employee
Name. SIN.. Sex, Ministry, Category and Group.
Clessificalion Code. Classificadan Tide. Geographic
Location Code. Schedule (Hours), D.C.S.. Duss Indicator,
Dues Deducted, “Dropped” Indicator, “Added” In.
dictum. Reasons (“Dropped” and “Added”).
I,4 “eskimels
SENIOR STMF RELATIONS OFFICER
This Appendix is worded in a manner which makes its
operation consistant with current deduction of union dues payable :
C
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on a bi-weeklybasisand not with payment of dues owing from previous
dues periods.
If the parties had intended retrospective operation OF th;?
., dues deduction provisions of Article 3, they might have done so ~
through the use of appropriate language. Cf. Re The Queen in Right
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of New Brunswick and New Brunswick Nurses' Union et al. (1983)
146 D.L.R. (3d) 523 (N.B.c.A.) at 526. Accordingly,and for the
reasons ,given, the grievance is denied.
DATED AT London, Ontario
this 29thday of November I983.
M. R. Gorsky
Vice Chairman
"I dissent"
E. J. Bounsall
Member
eJ+r
P. H. Coupey
Member
I