HomeMy WebLinkAboutUnion 12-11-01In the matter of an Arbitration
Pursuant to the Colleges Collective Bargaining Act of Ontario
THE COLLEGE EMPLOYER COUNCIL FOR THE COLLEGES OF APPLIED ARTS
AND TECHNOLOGY
and
ONTARIO PUBLIC SERVICE EMPLOYEES' UNION
(FOR ACADEMIC EMPLOYEES)
Between:
DURHAM COLLEGE
(the Employer)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES' UNION, LOCAL 354
(the Union)
Re: OPSEU File #2011-0354-0001
AWARD
Board of Arbitration
Paula Knopf - Chair
David Guptill, Employer Nominee
Sherril Murray, Union Nominee
APPEARANCES:
For the Employer: Wallace Kenny, Counsel
Meghan Houghton
Sandra Bennett
For the Union: Seung Chi, Grievance Officer
Sheila Bell
Kirston Arbour Debra Wrautins
Michael McKeon David Smith
Ryan Brown
The hearing of this matter was held in Oshawa on October 4, 2012.
This case involves a Union Policy Grievance under the Academic Collective Agreement
alleging that Durham College [the Employer] is improperly classifying the position of
Disability Advisor in the Support Staff bargaining unit instead of treating it as being in
the Academic bargaining unit. The Support Staff Local Unit had been given notice of
this hearing, however, it did not attended or seek standing in this proceeding.
At the outset of the hearing, the Employer raised a preliminary objection to the Board of
Arbitration’s jurisdiction over the case. Accordingly, the parties presented submissions
regarding the jurisdictional issue and sought a ruling before any evidence was
presented. This Preliminary Award is based upon those submissions and concludes
that the essential elements of this Grievance preclude this Board of Arbitration from
assuming jurisdiction to determine the merits of this case. The reasons for this are set
out below.
The Grievance document sets out the “Statement of the Grievance:”
That the College has violated specifically, but not exclusively, Articles 11.04, 05,
14.03A1, 22.02 of the Collective Agreement and the C.C.B.A.1 in classifying the
Disability Advisors as members of the support staff bargaining unit. The class
definition in the C.C.B.A. reflects the work currently being done by the Disability
Advisors.
In order to understand the nature of the Union’s claims and the implications of the
Employer’s jurisdictional objections, some context is necessary. The Union’s advocat
gave a clear and helpful outline of the nature of the Union’s concerns and the reasons
for the Grievance. While the opening statement does not constitute evidence and no
conclusions have been drawn, the factual allegations that the Union is relying upon are
all assumed to be valid for purposes of this Preliminary Award.
The Union explained that Disability Advisors at Durham College work in the Disability
Centre. Their duties focus upon ensuring that the academic environment is fully
accessible to students with disabilities. The Disability Advisors work with Disability
Counsellors (who are in the Academic bargaining unit), a technologist, and other
1 Colleges Collective Bargaining Act, S.O. 2008, Chapter 15
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professionals dedicated to the same goals. The duties of the Disability Advisor were
said to include:
• Conducting intake interviews with students with disabilities to examine the
educational, social and practical problems they may encounter
• Referring students with disabilities to proper professional help
• Facilitating discussions between students with disabilities, faculty and
administration
• Participating in the pre-admission process by making recommendations to the
Registrar’s Office
• Assessing, evaluating, and dealing with students with disabilities on an ongoing
basis to assist in their emotional, social and educational development and
problems
• Assisting administration and faculty by identifying proper accommodations to be
put in place
• Providing educational information to students with disabilities to assist them in
their endeavors
• Providing one-to-one counselling to students with disabilities to assist them with
personal, social, emotional and educational issues/problems
• Participating in the orientation of new students with disabilities to the College
The Union alleges that the core functions of the Disability Advisor are qualitatively and
quantitatively equivalent to and/or include the duties listed in the Class Definition of
“Counsellor” under the Academic Collective Agreement as set out in Appendix A to this
Award, with the exceptions being that the Disability Advisors do not do Group
Counselling or any “teaching as assigned.”
While the Grievance Form stated that the remedy being sought was “dues lost as a
consequence of improper classification,” at the hearing the Union indicated that the
remedies it was now seeking were:
1. A declaration that the position of Disability Advisor should be included in the
Academic bargaining unit;
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2. An order that the three incumbents in the Disability Advisor position should be
placed in the newly classified/recognized position within the Academic bargaining
unit without interruption and without there being any posting or job competition;
3. “Any other remedy that this Board of Arbitration deems appropriate.”
The Employer’s response to these claims was to assert that because of the nature of
the remedies being sought, this is not a proper Union Grievance and is therefore not
arbitral under this Collective Agreement. The Employer pointed out several potential
implications of the remedies the Union is requesting:
• An examination of the merits of the case would require extensive evidence and
factual determinations regarding the nature of each Disability Advisor’s specific
functions and responsibilities vis-à-vis the Class Definition of Counsellor in the
Collective Agreement.
• The current Disability Advisors do not have the necessary qualifications or
experience to be placed in the Counsellor position.
• If the Union were to succeed on the merits of the case, the Employer would have
the choice of exercising its management right to either:
a) Leave the job duties as currently defined and then post vacancies
in the Academic bargaining unit that the incumbents could bid upon,
OR
b) Exercise its management right to refine the job duties and remove
the duties that this Board of Arbitration relied upon to conclude that
this is a position that belongs in the Academic bargaining unit. The
result would then be that the modified positions would remain in the
Support Staff bargaining unit,
OR,
c) Eliminate the Disability Advisor position altogether.
The Employer stressed that each of the Disability Advisors has/had the right to claim
that they have been improperly classified and have chosen not to do so, despite the
positions being in the Support Staff bargaining unit for several years. Given the
particular wording of this Collective Agreement, the Employer argued that in order for
this to be a proper Union Grievance, the Union has to establish that it fits within the
strict terms of Article 32.09:
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The Union or Union Local shall have the right to file a grievance based upon a
difference directly with the College arising out of the Agreement concerning the
interpretation, application, administration or alleged contravention of the
Agreement. Such grievance shall not include any matter upon which an
employee would be personally entitled to grieve and the regular grievance for
personal or group grievance shall not be by-passed except where the Union
establishes that the employee has not grieved an unreasonable standard that is
patently in violation of this Agreement and that adversely affects the rights of
employees.
The Employer argued that the Union has not established that there has been a “patent
violation” of the Collective Agreement because its case cannot be proven without the
presentation of detailed evidence regarding the positions of each of the incumbents, as
well as the duties of Disability Counsellors at the College. Further, the Employer
submitted that this case does not “engage” or affect the rights of other employees
because the remedies being sought are personal to only the three incumbent Disability
Advisors. The Employer argued that if the Union had simply restricted its remedy
request to a claim for Union dues, this might then have been deemed to be a proper
Union Grievance. However, the Employer submitted that given the nature of the
remedies being sought and the evidence needed to prove the Union’s claims, the
following caselaw precludes this Board of Arbitration from taking jurisdiction over the
case that the Union wishes to present: OPSEU and St. Lawrence College (Starkman,
17 November 2011);OPSEU and Fanshawe College (Knopf, 10 December 2007);
OPSEU and Cambrian College (H. Brown, 11 September 2002);OPSEU and Fanshawe
College (Brent, 22 February 1989); Weber v. Ontario Hydro, [1995] 2 S.C.R. 929;
OPSEU and Fanshawe College (H. Brown, 30 October 2009); OPSEU and Loyalist
College (O'Neil, 29 May 2001); OPSEU and Northern College (Shime, 18 June 1992);
OPSEU and George Brown College (Devlin, 8 June 1994); OPSEU and St. Lawrence
College (Leighton, 13 April 2012); Shorter Oxford English Dictionary, 6th ed.,
"standard."
On the basis of these cases and the terms of Article 32.09, the Employer asked that this
Grievance be dismissed at this stage.
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The Union responded to the Employer’s preliminary objection by strongly asserting that
this is a proper Union Grievance. It was stressed that the Union has a direct interest in
insuring that positions that belong within the Academic bargaining unit are properly
classified as such. It was asserted that this Employer’s failure to place the Disability
Advisors in this bargaining unit is a patent violation of the Recognition clause. Further,
the Union argued that it has properly asserted that the facts will reveal a patent violation
of the Collective Agreement that affects the rights of all employees because of the
impact upon the size of the bargaining unit and the Union’s entitlement to dues, thereby
establishing that this case falls within the exceptions spelled out in Article 32.02. The
Union also stressed that it is the nature of the allegation and the essence of the
Grievance that should determine arbitrability, not the remedy being sought. Therefore,
the Union argued that the cases cited by the Employer are distinguishable. The Union
submitted that the following cases support its claim that this is a proper Union
Grievance under this Collective Agreement: Fanshawe College and OPSEU, (Knopf,
December 17, 2002) and Humber College and OPSEU, (Schiff, May 25, 1999).
By way of reply, counsel for the Union argued that the decision in Fanshawe College
and OPSEU, (Knopf, December 17, 2002) was wrongly decided and is out of line with
the rest of the case law in this area, as it cited above. Further, it was stressed that it is
insufficient for the Union to simply assert that there has been a patent violation of the
Collective Agreement; instead it was said that the Union must establish a patent
violation in order to qualify as an exception under Article 32.09.
The Decision
This is a jurisdictional question. This Board of Arbitration’s ability to determine the
merits of this case is strictly governed by the terms of the Collective Agreement and the
specific context of the Grievance.
Article 32.09 provides the Union or its Local with the ability to file grievances based on
allegations of direct differences with the College arising out of the interpretation,
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application, administration or contravention of the Collective Agreement. However,
there are exceptions to this. The Union Grievance cannot be used to by-pass the
individual grievance process, except in certain specific circumstances. There is no
dispute that a claim that a person is improperly classified could be brought as an
individual grievance. Under Article 32.09, a Union grievance cannot be brought for a
matter upon which an employee would be personally entitled to grieve unless:
• The Union establishes that the employee has not grieved an “unreasonable
standard,” AND
• The “standard” is patently in violation of the Collective Agreement, AND
• The “standard” affects the right of employees.
It is well accepted in the arbitral jurisprudence in this sector that all three criteria must
be satisfied. If any one of the three tests has not been met, the grievance is not arbitral
as a Union Grievance, see George Brown College and OPSEU, (Devlin), supra at p. 5.
The question of whether the Union has met the test of establishing a “patent” violation of
the Collective Agreement has also been well canvassed by the arbitrators appointed
under the Academic Collective Agreement. Arbitrator Starkman ably summarized this in
the St. Lawrence College case, supra. He noted that the term “patent violation” sets a
high standard, requiring the Union to establish that the violation is “crystal clear” or
“leaps from the page.” It is not sufficient to allege that there is an arguable violation of
the contract; almost every grievance suggests an arguable violation.
The Grievance in this case alleges a violation of the recognition clause and/or an
improper classification of three employees. In real or practical terms, the determination
of this case demands an analysis of whether the core duties of a job function fit within
the scope of the Academic bargaining unit. The determination of that issue will require
the examination of the job duties of each of the current Disability Advisors and a
comparison of each with the details in the Class Definition of Counsellor. Therefore, it is
very hard to view this as a case where the Union has established a “patent violation” of
the Collective Agreement. The alleged violation is not crystal clear, nor is it apparent on
its face. Something that requires detailed evidence involves differing situations and
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demands the weighing of testimony falls far short of meeting the high burden of
establishing a “patent violation” of the Collective Agreement.
Further, this Grievance cannot be said to meet the test of affecting the rights of
employees. As recognized by Arbitrator Brown in Fanshawe College (October 30,
2009), supra, at p. 10, Article 32.09 is intended to allow for Union Grievances to be
processed in situations that could have been individual grievances only where it would
involve matters that “impact broadly on members of the bargaining unit.” It is true that
the question of inclusion of positions in the bargaining unit does have some impact on
the bargaining unit as a whole, in terms of future union dues. But the remedy being
sought in this case is one directed at the individual incumbent Disability Advisors. They
are seeking reclassification and direct appointments into this bargaining unit. These are
very individual remedies. The only impact on Union dues will be the potential of future
dues if the positions are put, and are retained in the Academic Unit. Therefore the
impact on the bargaining unit in terms of the potential of future dues is only an incidental
aspect of this case. Frankly, there are few grievances that do not impact a bargaining
unit in some way or another. However, it is clear that Article 32.09 has been
consistently applied to insure that it is not allowed to be used to by-pass the personal
grievance process where the matter involves personal claims. The essential nature of
the case at hand must be recognized as something that involves the assertion of
individual efforts to achieve reclassification. As such, it does not meet the criteria of
Article 32.09.
Given these conclusions and the requirement that the Union meet all three criteria in
Article 32.09, there is no need to explore whether the Union has also established that
there has been an “unreasonable standard.”
Accordingly, despite the clear and able submissions of the Union, it must be concluded
that the essence of this Grievance does not meet the criteria for a Union Grievance
under Article 32.09. Therefore, this Board of Arbitration lacks the jurisdiction under this
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Collective Agreement to hear and determine the merits of this case. As a result, the
Grievance is hereby dismissed.
Dated at Toronto this 1st day of November, 2012.
__________________________
Paula Knopf - Chair
I concur _______"David Guptill"________
David Guptill, Employer Nominee
I dissent in part - see below ________“Sherril Murray”______
Sherril Murray, Union Nominee
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Union Nominee’s Partial Dissent
When a member of the support staff on an individual basis attempts a grievance
reclassifying their position into the academic unit they generally face a further
preliminary objection from employer’s counsel as to the arbitrability of their claim.
However, in this case, “The Employer stressed that each of the Disability Advisors
has/had the right to claim that they have been improperly classified and have chosen
not to do so, despite the positions being in the Support Staff bargaining unit for several
years.” (pg.3)
In that the employer agrees that an individual has the right to grieve the reclassification,
it is not difficult to understand why the majority of this Board has declined to assess
whether the rights of the individuals have been abrogated.
However the decision of the majority continues to disregard that there are no individual
grievances and the Union has both an obligation and a right to pursue and police their
collective agreement. As the Chair says “Frankly, there are few grievances that do not
impact a bargaining unit in some way or another.” (pg 7) The majority continues to find
that the grievance affects few individuals. With respect, I disagree. The class definition
of counsellor as found on page 145 in the Collective Agreement is the standard which
describes the work done by academic unit members. An allegation that that standard is
met on the core duties of the position and yet the work is assigned outside the
bargaining unit to which it is assigned by class definition and to some extent The
College Collective Bargaining Act is the “patent violation”. It also violates the recognition
clause, impacts on the potential of erosion of bargaining unit positions and a multitude
of other entitlements. It offends the Trade Union’s sense of fairness as a possible
misclassification results in members of two different bargaining units doing essentially
the same work for dissimilar pay and benefits.
Therefore to put these claims in context:
The Union has established that the individual employee has not grieved, (and although
the employer and the Board finds they could have, no such grievance has been filed)
the exclusion of the “Disability Counsellors” from the Academic Bargaining Unit and
essentially sending that work out of the Bargaining Unit is an unreasonable standard of
conduct by the employer’s actions to include that work in the Support Staff Unit and in
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violation of the recognition clause is a patent violation. As seen in the Fanshawe
College and OPSEU, (Knopf, December 17, 2002) it is the Union’s submission the
correct analysis and ruling was given, having regard to the recognition of the Union’s
interest. Likewise in Humber College and OPSEU, (Schiff, May 25, 1999) at pgs 112
and 113 “The grievance focused not on the individual but the work they are doing, the
scope of the agreement, coverage and damage to Union income.”
All of which is respectfully submitted, Sherril Murray, Union Nominee
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“Appendix A”
CLASS DEFINITION - COUNSELLOR
COUNSELLOR
A Counsellor is responsible for assisting students and potential students to function effectively
as learners and as individuals by helping them understand, prevent or overcome personal,
social or educational problems that may hinder learning or their ability to cope with everyday
living. The Counsellor's duties include:
1. a) Developing and maintaining appropriate counselling programs.
2. b) Interviewing individuals, by appointment, to explore personal or social difficulties or
vocational/educational decision making, including:
o - referring students as appropriate to proper professional help;
o - facilitating discussion/dialogue between students, faculty and administration;
o - participating in pre-admission interviewing and testing as required.
3. c) Group counselling as a non-instructional activity.
4. d) Testing and evaluation of individuals to assist them in their personal,
educational/vocational development.
5. e) Assisting administration, faculty and staff, in a consultative role in identifying student
problems, dealing with student problems, and relationship problems among students.
6. f) Providing educational/vocational information to students or directing them to
available sources.
7. g) Participating in the orientation of new students to the College.
8. h) Teaching as assigned.
In addition, the Counsellor may, from time to time, be called upon to contribute to other areas
ancillary to the Counsellor's role, such as student recruitment and selection, student
employment, liaison with community service programs and agencies, professional development
and control of supplies and equipment.