HomeMy WebLinkAbout1996-2779.UNION98_11_24
OwrARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'OwrARIO
1111 GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 800, TORONTO ON M5G 1Z8 TELEPHONf/7-ELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 800, TORONTO (ON) M5G 1Z8 FACS/MILEfTELECOPIE (416) 326-1396
GSB #2779/96, 0141/97
OPSEU #97U008, 97U056
. IN THE MATIEROF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Union Gnevance)
Grievor
- and -
The Crown In RIght of Ontano
(Mirustry of Commuruty & SOCIal SefV1ces )
Employer
BEFORE S Stewart Vice-ChaIr
FOR THE G Leeb
UNION Gnevance Officer
Ontano PublIc SefV1ce Employees Uruon
FOR THE B Loewen
EMPLOYER Counsel, Legal SefV1ces Branch
Management Board Secretanat
HEARING July 14, 15, 16, 1998
DECISION
The issue before me is whether the Employer has fulfilled
its reasonable efforts obligations in accordance with Appendix 9
of the Collective Agreement Appendix 9 provides as follows
The Government is aware that its restructuring initiatives
over th~ next two fiscal years (1996/97, 1997/98) could
have a significant effect on employees, some of whom
have served for a lengthy period Accordingly,
commencing with the ratification of the collective
agreement and ending on December 31, 1998, the Employer
undertakes the following
1 ( a) The Employer will make reasonable efforts to ensure
that, where there is a disposition or other transfer of
bargaining unit functions or jobs to the private or
broader public sectors, employees in the bargaining
unit are offered positions with the new employer on
terms and conditions that are as close as possible to
the then existing terms and conditions of employment of
the employees in the bargaining unit, and, where less
than the full complement of employees is offered
positions, to ensure that offers are made on the basis
of seniority When an employee has been transferred to
a new employer he or she will be deemed to have
resigned and no other provisions of the Collective
Agreement will apply except for Article 53 or 78
(Termination Pay)
(b) Where the salary of the job offered by the new
employer is less than eight-five percent (85%) of the
employee's current salary, or if the employee's service
or seniority are not carried over to the new employer,
the employee may decline the offer In such a case,
the employee may exercise the rights prescribed by
Article 20 (Employment Stability) and/or paragraphs 2
to 5 of this Appendix The employee must elect whether
or not to accept employment with the new employer
within three (3 ) days of receiving an offer In
default of an election, the employee shall be deemed to
have accepted the offer
The issue of the reasonable efforts obligation arises here
in the context of the closure of a number of large facilities
which provide services and treatment to persons with
developmental handicaps It has been determined that the care of
2
the residents of these facilities will be transferred to
community agencies, with the consequential closure of the
facilities and the displacement of the OPS employees
In a depision of Vice-Chair Kaplan, dated June 2, 1997, this
Board determined that the Ministry efforts to that point did not
fulfil its obligations under Appendix 9 At P 18 of the
decision, Mr Kaplan concluded as follows
Suffice it to say that the evidence amply demonstrates
that the efforts management made were de minimus, at
best Indeed, this conclusion is reinforced by the
fact that there is evidence that the employer made the
exact same efforts (if not more) for a group of
employees to whom it owed no obligation whatsoever By
any measure, holding a job information day, writing
letters, making telephone calls to follow-up, and
attending at meetings does not come close to complying
with this provision of the collective agreement These
are the kinds of actions many employers would take
absent of a legal requirement that it do something
proactive Accordingly, I can only conclude that this
grievance must succeed and I so declare
The decision goes on to set out a number of general
principles including at p 18-19 the principle described as
"first and foremost", that
making reasonable efforts does not mean "every"
effort or "all efforts" It means making efforts that
are reasonable all things considered, and that will,
given that this is a broadly worded clause of general
application, depend on particular circumstances of
individual cases
The decision goes on to state, at p 20, that
the employer must do more than simply inquire
whether the receiving transfer payment agency is
interested in hiring public servants The transfer of
work, the policy indicates, is a negotiated one And
3
negotiation means give and take, not a simple request
without even the obligation - again this case - that
questions be answered
The structure of Appendix 9 indicates, and this purpose
does not appear to be fundamentally in dispute between
the parties, that it was developed to create a
financipl incentive to the employer to place public
servants in jobs that met certain terms with avoidance
of enhanced severance costs, and possibly more, the
benefit to the particular ministries At a minimum -
and, obviously each case will differ - amounts up to
avoided costs should be used as an incentive to secure
jobs for public servants, many of whom, Appendix 9
begins, "served for a lengthy period" It is quite
conceivable that financial incentives could have been
used to overcome some of the difficulties identified in
this case that were said to make it difficult to
directly place PEH employees The fact that the
Ministry has not previously had to enter into
negotiations with a BPS transfer payment agency, and
possibly its union, to give just one example of how it
might give effect to this provision and its reasonable
efforts obligation, does not mean that it should not do
so if its efforts in doing so would, in all the
circumstances, be reasonable
The decision concludes with the following directions
1 The Ministry is directed, in each of the facilities
covered by this award, to hold bi-weekly meetings with
the union to advise the union of its reasonable efforts
and to enter into a dialogue with the union as to how
to best meet its obligations These meetings should
commence immediately
2 The Ministry and the union will meet forthwith in
order to discuss how best to manage the closure of
these facilities in light of the employer's obligations
to make reasonable efforts and the requirement that
employees be surplused on the basis of seniority The
parties may, if they wish, request from the Board the
assistance of a mediator Should the parties prove
unable to agree on a framework within sixty days of the
release of this award, they may return to the Board on
an expedited basis and jurisdiction is specifically
retained to determine this issue
3 The Ministry is directed to negotiate with the
transfer payment agencies the placement of public
4
servants whose jobs will be lost as the result of the
facility closures and work transfers These
negotiations must include the offering of a financial
incentive in accordance with the general principle set
out earlier in this award
4 The Ministry is directed to keep careful records of
all of its surplusing and divestment activities to
date, and of all of its planned surplusing and
divestment activities with respect to each of these
facilities The union is to be provided with copies of
these records
There were some further decisions from Vice-Chair Kaplan,
including a consent order dated August 25, 1997, in which the
Employer agreed, among other things, to attempt to obtain job
offers for employees, to attempt to obtain information from the
agencies about available positions, to post such information in
the facility and to forward the names of persons at the
institution who identified themselves as interested in the
position commencing in the late summer and fall of 1997, the
Employer proceeded with certain actions which, in its submission,
fulfilled its obligations under Appendix 9 of the Collective
Agreement It is the position of the Union that the actions
taken by the Employer are not sufficient to meet its obligations
under Appendix 9 and that the Employer continues to be in
violation of the Collective Agreement
Although the hearing in this matter proceeded over twenty
days, there was ultimately little dispute about the relevant
facts In the course of its renewed efforts in the fall of 1997,
the Employer gave consideration to the timing of reasonable
5
efforts negotiations with the agencies in relation to the
placement process The placement process involves an independent
third party planner who, with the involvement of the facility
staff, the family and the resident to the extent possible,
develops a g~neral service plan The plan is then forwarded to
an agency or agencies viewed as appropriate for the resident
Various factors come into play in determining the choice of
agency, including proximity to family or facilities, the
placement of other residents and the philosophy or religious
orientation of the agency In certain instances choice is
effectively limited, for example in situations where proximity to
family is the priority concern and there is only one agency in
the geographical location in which the resident's family resides
When an agency has been chosen, the Ministry will then make the
necessary funding and transfer arrangements The agencies
receive funds from the Employer on the basis of services
provided, pursuant to service contracts which are renewed on an
annual basis It was determined that agencies would be
approached about employment opportunites for OPS employees after
placement had been finalized The Employer considered and
rejected the idea of dealing with the agencies on resident
placement and employment opportunities at the same time
Similarly, negotiating the placement of residents subject to the
agency agreeing to hire staff was rejected While these latter
two approaches were viewed as having a greater potential for
obtaining jobs for displaced employees, they were viewed as
6
undesirable from the point of view of the resident, placing the
resident's interests secondary It was the Employer's position
that the interests of the residents in obtaining their desired
placement should be unfettered and it was not prepared to veto
placement on. the basis of an agency's position on hiring
displaced OPS employees
Mr B Low and Mr T Magee testified regarding the actions
taken by the Employer pursuant to the Board's June 2, 1997
decision Meetings were established with the Union as directed
A template was established for negotiations and training was
provided The Employer retained the services of Mr F Collict,
who has extensive experience in labour relations, to assist Ms
J Geisberger, a negotiator from Management Board, also had
extensive involvement in the matter Previously, the hiring of
OPS employees was one of a number of items on the agenda for a
meeting with the agencies as a group This time, meetings were
convened with each individual agency The template established
for the negotiations with the agencies contemplated the offering
of a financial incentive to the agencies to hire OPS employees,
contacting union representatives as necessary and following up
with agencies to determine how to overcome any barriers to
obtaining jobs that were identified
At the outset of the meetings with the agencies, it became
apparent that there were formidable obstacles to attaining the
7
objectives of the process The wages paid by the transfer
agencies were, virtually without exception, considerably lower
than those paid to employees in the OPS Another major barrier
was opposition to giving displaced OPS members preference for
full-time po~itions over part-time employees already working at
the agencies Where the agency was unionized, collective
agreements gave preference to current employees for new
positions Where the agencies were not unionized it was common
that there was a policy providing for the hiring of current
employees There was also opposition to recognition of seniority
for OPS employees as this was viewed as disadvantaging current
employees Evidence was adduced in relation to one agency,
Pathways, where OPS service and seniority was given some
recognition, however Ms M Lamb, executive director of Pathways,
testified that there was nothing that could have been offered
which would have compelled her to give OPS employees an advantage
over current employees with respect to seniority as it relates to
job security In her view, such action would have been damaging
to the morale of her current employees and thus damaging to her
organization Representatives of unions representing employees
of the agencies, including OPSEU, were clear and adamant that
they would not consent to displaced OPS members being given
preferential treatment relative to the employees that they
represented The agencies were also generally unwilling to give
OPS employees an advantage over other applicants, although there
were some exceptions Pathways, for example, did agree to hire
8
exclusively from the OPS and that in cases of relative equality
of the applicants, they would be hired on the basis of their OPS
seniority In a number of instances, families and residents were
involved in hiring decisions Certain agencies required a
particular r~ligious or philisophical commitment In certain
instances, no new positions would be created, for example where
there was already an opening or the needs of the new client could
be met by existing staff In some instances there were laid off
employees with recall rights who would fill any new positions
resulting from the transfer of residents from the institutions
There were few instances in which OPS employees identified
themselves as candidates for the positions that were posted in
accordance with the protocol agreed upon by the parties Aside
from the fact that the pay of the positions was generally
considerably less, many of the positions were outside the
geopraphical area of the facilities, making the positions
understandably undesirable
The financial incentive offered by the Employer, ultimately
based on the savings of severance at the OPS rates, was not an
effective incentive Some agencies viewed it as "morally
offensive" While the Union's position was that the financial
incentive that was offered was less than that contemplated by Mr
Kaplan's award, on the basis that there were additional amounts
contemplated by the direction to offer saved costs, it was
abundantly clear from the evidence that to be effective, a
,.-
9
financial incentive would have to consist of either an extremely
large one time payment or, more likely, a commitment to increased
funding on a permanent basis The predominant view of the
agencies was that in order to provide displaced OPS employees
with comparaple salaries it would require sufficient funding on
an ongoing basis to compensate their current employees, as well
as displaced OPS employees, at those rates
All agencies receiving residents did come to agreements with
the Employer, the terms of which were set out in confirming
letters The agreements provided for the posting of positions at
the facilities that were closing A number of agencies were
amenable to job shadowing and visits from OPS employees Mr
Leeb made reference to there being only one instance of an offer
made pursuant to the terms of an agreement between the Ministry
and an agency, the terms of which did not meet the criteria of
l(b) of Appendix 9 Ultimately, the position was not accepted by
the individual In one instance, the job competition was delayed
by an agency in order that the OPS employees would be surplussed
and thus there would be no issue as to their entitlement to
receive their full surplus entitlement by virtue of having
accepted a position, although, ultimately, a number of OPS
employees were to be hired There is reference in the
documentary evidence to other instances of jobs being offered,
however there was no dispute that the results of the undertaking
in relation to obtaining jobs for displaced OPS employees were
10
extremely disappointing
There were three aspects to Mr Leeb's submissions He
argued that the Employer did not do what it set out to do in
relation to reasonable efforts In particular, with respect to
the matter of providing a substantial financial incentive which
would allow wages to increase across the board and, thus, most
likely would provide an effective incentive for the agencies and
their unions, Mr Leeb emphasized that senior Ministry officials
could have, but did not, seek Cabinet approval for increased
funding As well, it was submitted that the Employer's actions
pursuant to its reasonable efforts obligation did not comply with
Mr Kaplan's initial decision Mr Leeb also argued that the
actions of the Employer simply do not meet the objective standard
of reasonable efforts considered in light of the important
employment interests in issue He submitted that the ultimate
result could not have been what the parties bargained for and
contrasted the outcome in this case with the outcome in other
divestures As well, Mr Leeb emphasized the Employer's role in
funding the agencies and its effective decision making power in
relation to placement arising from its ability to determine
whether it would fund a resident in the chosen agency In his
submission the Employer should have, but did not, utilize the
bargaining power that it possessed in order to compel the
agencies to agree to terms more favourable to the displaced OPS
employees
11
In his submissions, Mr Loewen emphasized that the Employer
is dealing with the transfer of individuals who are among
society's most vulnerable Accordingly, it was argued, the
Employer acted most appropriately in determining at the outset
that the choice of the individual resident must be given priority
and should not be in any way intertwined with the reasonable
efforts issue It was submitted that the other two alternatives
considered would potentially result in inappropriate incursions
into the resident's freedom of choice with respect to placement
It was further argued that there was no justification for a
conclusion that such an approach would have a different result
In this regard, Mr Loewen emphasized Ms Lamb's testimony that
there was nothing that the Ministry could have done to persuade
her to recognize seniority of OPS employees in a manner which
would put current employees at a relative disadvantage in
relation to job security He also submitted that the cost of
what might constitute a meaningful incentive goes far beyond that
contemplated by the reasonable efforts obligation and argued that
reasonable efforts do not include an obligation to provide
substantial funding to increase existing wage rates Mr Loewen
also emphasized the difference between the actions of the
Employer which gave rise to the conclusion that the reasonable
efforts obligation had not been complied with and its subsequent
actions which are the subject of this proceeding In his
submission, the Employer has fulfilled its obligation to make
12
reasonable efforts pursuant to Appendix 9 of the Collective
Agreement
The question of what constitutes reasonable efforts is, as
noted in th~ excerpt from the Board's June 2, 1997 decision
reproduced at the outset of this decision, to be determined on
the basis of the particular circumstances that present themselves
in connection with a divesture of operations As noted in that
decision, as well as a number of other decisions of this Board,
the reasonable efforts obligation does not require the Employer
to make all possible efforts However, the obligation to make
reasonable efforts must be interpreted in light of the very
significant employee interests at stake
I agree with Mr Loewen that that the approach of the
Employer in the second round was markedly different from that at
the time of the events giving rise to Mr Kaplan's award Rather
than this matter simply being one of a number of items to be
discussed with a group of agencies, a centralized strategic
approach was developed, expertise in negotiations was sought and
obtained, a process for ongoing communications with the Union was
established, a financial incentive was offered and a protocol for
the posting for and identification of interest in job
opportunities was established While Mr Leeb is correct in
pointing out that there were instances in which the Employer did
not convene additional meetings and it did not identify solutions
13
to the barriers that were identified, as it commited to doing at
the outset, I am ultimately compelled to the conclusion that this
was not as a result of a de minimus or perfunctory approach, as
Mr Leeb suggests, but rather, as a result of a recognition that
the barrier~ were formidable and that any action which might have
overcome the barriers that were present were actions beyond that
contemplated by the reasonable efforts obligation
The understandable reluctance on the part of agencies to
agree to anything that would have diminished the rights of
existing employees, along with the adamant response of the unions
representing employees of the agencies, including OPSEU, to a
similar effect, created a formidable barrier to job
opportunities, aside from the issue of recognition of OPS
seniority in relation to those opportunities
It was clear from the evidence that the monetary incentive
offered was not an effective incentive and that a truly effective
monetary incentive would have been an extremely large one time
payment or, more likely, a permanent commitment to significantly
increased long-term funding of the agencies Such a commitment
may well have influenced the agencies and the unions representing
their employees to view the objectives of the reasonable efforts
process in a more favourable light However, I am not persuaded
that the Employer was agreeing to assume this kind of financial
commitment in assuming the reasonable efforts obligation
r
14
contained in Appendix 9 An interpretation of the reasonable
efforts obligation which would require the Employer to
substantially increase the funding to agencies on a permanent
basis, essentially restructuring the existing wage economy of the
agencies on p significant scale, would not, in my view, be
reflective of the agreement that was reached between the parties
Given that the quantum of the incentive required is clearly well
beyond the ambit of what in Mr Leeb's submission constitutes
saved severance costs and thus, in its most liberal
interpretation, the ambit of Mr Kaplan's decision, I am unable
to accept Mr Leeb's submission that the Employer's failure to
seek additional funds for the incentive constituted a violation
of its reasonable efforts obligation It is therefore
unnecessary for me to decide whether the Employer's determination
as to what constituted saved severance costs was correct
Mr Leeb argued that in determining that the matter of job
opportunities for displaced OPS employees would be raised only
after transfers had been finalized, the Employer failed to employ
the bargaining power available to it in dealing with the agencies
and thus failed to fulfill its reasonable efforts obligation In
my view, the Employer's justification for its approach on the
basis of the interests of the residents being paramount is
understandable Moreover, even if the Employer were to have
attempted to conduct itself with the agencies in this manner, I
am not persuaded that there is any real likelihood that the
I
15
ultimate result would have been different I have the same view
with respect to the suggestion that the Employer ought to have
wielded its power in relation to the renewal of contracts in its
dealings with the agencies to advance the interest of displaced
OPS employee~ It was readily apparent from the evidence that
the traditional market assumptions in relation to motivation were
not present The mandate of the agencies is not expansion or
profit A more aggressive approach on the part of the Employer
in its dealings with the agencies would not have overcome the
fundamental barriers to job opportunties for OPS employees
affected by this divestment and thus is unlikely to have changed
the ultimate result
I fully agree with Mr Leeb that the ultimate result of the
Employer's efforts in this instance is striking, both in absolute
terms and in the context of the favourable opportunities that
exist for employees affected by divestments in other areas of the
public service However, after reflecting on all of the evidence
in light of the authorities provided to me and the submissions of
the parties I am unable to conclude that the Employer has failed
to fulfill its obligation to make reasonable efforts pursuant to
Appendix 9 of the Collective Agreement The reasonable efforts
obligation is applicable to a large variety of circumstances
across the public sector and those different circumstances will
compel different results The result in this instance arises
from the very unusual circumstances existing here To effect a
16
change in the result would require actions on the part of the
Employer that are well beyond what is contemplated by the
agreement of the parties that the Employer would make "reasonable
efforts"
.
There was an issue between the parties as to whether
accepting a position with an agency which has entered into a
reasonable efforts agreement which does not meet the Appendix 9,
1 (b) criteria affects the employee's entitlement to severance
payments This matter was alluded to but not fully argued In
the event that this issue remains in dispute, the matter may be
dealt with by any Vice-Chair upon request to the Registrar
Dated at Toronto, this 24th day of November, 1998
m!uJVt 1
s L stewart - Vice-Chair