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Decision Content

A-645-76
Attorney General of Canada (Applicant)
v.
Raymond Keith Jones (Respondent)
Court of Appeal, Pratte, Ryan and Le Dain JJ.— Ottawa, March 17 and June 30, 1977.
Judicial review — Public Service — Labour relations — Downward job classification — Red-circled — Whether or not paid in accordance with collective agreement — Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, s. 28 — Conversion and Post-Conversion Pay Regulations, T.B. 669255, (May 25, 1967), ss. 2, 4(1), 5(1), 6(1) — Public Service Employment Regulations, SOR/67-129, s. 41(3).
This section 28 application is to set aside the Chief Adjudica tor's decision allowing the respondent's grievance. Respondent, his position reclassified downward and his salary red-circled, sought reinstatement of his classification and a retroactive upward adjustment of his salary. The issue is whether or not the employee had been paid in accordance with the applicable collective agreement.
Held, the application is allowed. One purpose of clause 32.05 of the collective agreement is to provide that, in determining the pay of employees appointed to positions reclassified because of a post-conversion review, the special problems that arise will be dealt with as per the Conversion and Post-Conversion Pay Regulations even though there might be inconsistent provisions in the Public Service Terms and Conditions of Employment Regulations. Another purpose is that employees whose pay may be adversely affected by reappointment to positions with reduced status will be protected by red-circling. In giving effect to these purposes, clause 32.05 is to be construed as referring to the Regulations as a whole, not merely a part of them, and relates only to pay determination. The clause does not purport to limit the power to reclassify positions or to make appoint ments to them.
APPLICATION for judicial review. COUNSEL:
W. L. Nisbet and L. S. Holland for applicant. Maurice W. Wright, Q.C., for respondent.
SOLICITORS:
Deputy Attorney General of Canada for applicant.
Soloway, Wright, Houston, Greenberg,
O'Grady, Morin, Ottawa, for respondent.
The following are the reasons for judgment rendered in English by
RYAN J.: This is an application under section 28 of the Federal Court Act, R.S.C. 1970 (2nd Supp.), c. 10, to review and set aside a decision of E. B. Jolliffe, Chief Adjudicator, which is dated the 4th day of September 1976. The decision was made under a reference to adjudication by Mr. Raymond Keith Jones, the respondent in this case, pursuant to subsection 91(1), paragraph (a), of the Public Service Staff Relations Act'.
Mr. Jones's grievance, the grievance which he referred to adjudication, arose with respect to the interpretation of provisions of certain collective agreements between the Treasury Board and the Public Service Alliance. The bargaining unit to which the agreements applied comprised the employees of the employer 2 "... in the Engineer ing and Scientific Support Group, Technical Cate gory, as described in the certificate issued by the Public Service Staff Relations Board on October 12, 1967". In his grievance, Mr. Jones described himself as being employed in the Construction and Design Section of the Department of Public Works in the Ontario Region. He gave these details of his grievance:
On June 28, 1972 my position was downgraded from EG-ESS-9 to EG-ESS-8.
Effective on that same date my salary was frozen in the existing pay range and from that date until July 2, 1973 I received no economic increases. On June 28, 1972 I was demoted from EG-ESS-9 to EG-ESS-8.
Since November 6, 1972 I have not been paid at the rate of pay to which I am entitled by operation of Article 32 of the 1973-1974 agreement and appendix "A" thereto. [It is not disputed that the reference should be to appendix "B".]
He requested this corrective action:
I now ask that—
(a) I be re-instated at my proper classification of EG-ESS-9 on and from June 28, 1972;
(b) my salary be adjusted upward retroactively to the cor rect rate on and from June 28, 1972.
' R.S.C. 1970, e. P-35.
2 "employer" was defined in the agreements in this way: "Employer" means Her Majesty in right of Canada as represented by the Treasury- Board, and includes any person authorized to exercise the authority of the Treasury Board.
The reference to adjudication was made on August 25, 1975. As the Chief Adjudicator stated in his reasons for decision, the proceeding was required to be continued to its conclusion under the Public Service Staff Relations Act as it stood before the 1975 amendments to the Act became operative on October 1, 1975. He therefore heard and determined the case as Chief Adjudicator.
The Chief Adjudicator said that the case had been termed a test case. Possibly it would be as well to indicate, as did the Chief Adjudicator, why this was so. The Chief Adjudicator wrote:
A superficially similar issue was taken to adjudication in Morency. On June 29, 1973, the grievance was upheld by Adjudicator Abbott, and on January 29, 1974, it was sustained by a unanimous decision of the Board, which concluded with the following statement at pages 49 and 50:
We accordingly find that the adjudicator did not err in law in construing Article 27.02 to mean that the aggrieved employee was entitled to be paid in the current scale of rates set out in Appendix "B" of the collective agreement for the classification of a CR5 prescribed in his certificate of appointment dated April 30, 1969, notwithstanding that the position he occupied as a CR5 was reclassified downward to the lower level of a CR4.
There are differences between Morency and this case. In my view, variations in the employment history of the two grievors are not of real significance. The important distinction is that Morency involved the interpretation or application of what was then Article 27 of the collective agreement in respect of the Clerical and Regulatory Group, while this case turns on the quite different language of an agreement made in 1971 in respect of the Engineering and Scientific Support Group. In particular, the agreement in Morency contained no express reference to the Conversion and Post-Conversion Pay Regula tions, but here there is the reference quoted above.
The Test Case Memorandum
The distinction between Morency and this case is clearly reflected in the Memorandum of Understanding (Exhibit 21) arrived at between the employer and the Alliance on January 30, 1975, whereby, after one year of review and discussion, the parties achieved settlement of numerous pending grievances, but failed to settle many others. It will be seen in paragraphs 3 and 4 of the memorandum about to be quoted that the employ er agreed to concede a large number of cases resembling that of Morency, but it was also agreed that in relation to red-circling grievances where the applicable agreement made specific refer ence to the Conversion and Post-Conversion Pay Regulations, a "grievance selected by the parties" would be taken to adjudica tion. This reference, that of Mr. Jones, is of course the one selected.
The Chief Adjudicator quoted the memorandum of understanding in its entirety, but I will quote only its opening words and its paragraphs 3 and 4:
This Memorandum of Understanding between the Treasury Board of Canada and the Public Service Alliance of Canada sets forth certain conditions in respect of the incumbents of positions which are classified downward and certain undertak ings respecting grievances arising out of red-circling actions.
3. With regard to all red-circling grievances other than those excluded by the preceding paragraph arising from red-cir cling action where the employee was subject to a collective agreement that did not contain specific reference to the Conversion and Post Conversion Pay Regulations, the Trea sury Board has agreed:
(a) to reinstate the grievor retroactively to the classifica tion held by him immediately prior to the red-circling action;
(b) to pay the grievor retroactively at the rate of pay provided in the collective agreement for the classification held by him immediately prior to the red-circling action, effective from the date on which he was red-circled;
(c) to apply the provisions of this Memorandum of Under standing to all grievors referred to in this paragraph, effective the date of the signing of this Memorandum of Understanding.
4. With regard to grievances arising from red-circling action where the employee was subject to a collective agreement which contained specific reference to the Conversion and Post Conversion Pay Regulations at the time of red-circling action, it is agreed that a grievance selected by the parties will be taken before an adjudicator to resolve the question of whether the Employer had the right to red-circle employees who were subject to collective agreements that contained specific reference to the Conversion and Post Conversion Regulations. The parties reserve all right to appeal the decision of the adjudicator in this matter, but agree that the ultimate decision rendered will be applied to all grievances arising from red-circling action where the employee was subject to a collective agreement which contained specific reference to the Conversion and Post Conversion Regulations at the time of red-circling action. In this regard the Employ er agrees not to contest the question of timeliness of these outstanding grievances.
Despite its importance as a test case, the Chief Adjudicator stated, and I agree with him, that for present purposes, "... the issue is simply whether or not one employee has been paid in accordance with the provisions of the applicable collective agreement." This Court is concerned with the question whether the decision of the Chief Adjudicator in substance allowing Mr. Jones's grievance should be set aside.
The Chief Adjudicator, in his reasons for deci sion, said:
At issue is Mr. Jones' pay entitlement following the reclas- sification of his position at a lower level. From September, 1968, to June, 1972, his position (numbered P.W.-OTO-71) had been classified EG-ESS-9, and he was paid according to the scale for that level specified in the first, second and third collective agreements between Treasury Board and the Alliance in respect of the Engineering and Scientific Support Group, made effective on May 22 and July I, 1969, and May 10, 1971. With effect on June 28, 1972 (while the third agreement was in force) the position occupied by him was reclassified EG-ESS-8 with the same number, P.W.-OTO-71. For some time, however, Mr. Jones was not paid according to the scale then specified for that level, the EG-ESS-8 level. Instead, he was "red-circled" and placed in what is known as a "holding range." The meaning or effect of these terms simply is that he continued to receive his former rate (which happened to be $15,303 per annum, the maximum at that time of the EG-ESS-9 range) but did not receive any of the negotiated increases for the EG-ESS-9 range which became effective with the making of new agreements later in 1972 and in subsequent years. Thus Mr. Jones continued to be paid at the rate of $15,303 per annum until July 2, 1973, when he received an increase to $15,490, being the newly-negotiated maximum rate for the EG-ESS-8 level.
To understand the issues involved in the case, it is helpful to go back to the time when Mr. Jones entered the Public Service and to follow his vari ous appointments over the years, and also to note certain significant changes in the law relating to employment and collective bargaining in the Public Service that occurred during that time.
Mr. Jones was first employed in the Public Service in 1961. From then until August 31, 1966, he was promoted several times. Effective Septem- ber 1, 1966, he was promoted to a position classi fied as Technical Officer 4. According to the statement of facts agreed upon by the parties for the purpose of the adjudication, Mr. Jones's "class and grade on appointment was also Technical Officer 4." Effective September 1, 1967, Mr. Jones was appointed to a position classified as Technical Officer 6. "The Grievor's [Mr. Jones's] class and grade on appointment to this position was Technical Officer 5 and he was paid at that rate.... Effective September 1, 1968, the Grievor was promoted to Technical Officer 6. He thereby acquired the class and grade of appointment that corresponded to the classification of the position to
which he had been appointed effective September 1, 1967".
It is significant that the parties, in their agreed statement of facts, recognized that an employee may be appointed to a position which is classified at a level that differs from the employee's personal class and grade. This becomes important when one comes to consider the terms of the collective agree ments involved in this case.
On March 13, 1967, two new statutes relating to the Public Service came into force, the Public Service Employment Act 3 and the Public Service Staff Relations Act 4 , and the Civil Service Act' was repealed. The Financial Administration Act was also amended 6 . A purpose of these enactments was to introduce a new system of collective bar gaining into the Public Service. Before these changes, the power of appointment to the Public Service was by and large vested in the Civil Ser vice Commission, as was the authority to classify positions in the Public Service. After the changes, the power to appoint or to provide for appointment to the Public Service was vested in the Public Service Commission, the successor to the Civil Service Commission, and the authority to classify Public Service positions was vested in the Treasury Board, as was personnel management, including the determination of terms and conditions of employment in the Service. Determination of the terms and conditions of employment is, of course, subject to the provisions of the Public Service Staff Relations Act in relation to collective bargaining.
The Public Service Staff Relations Act, S.C. 1966-67, c. 72, in section 2, paragraph (r), defined the term "occupational category" as follows:
2....
(r) "occupational category" means any of the following categories of employees, namely,
(i) scientific and professional,
(ii) technical,
(iii) administrative and foreign service,
3 S.C. 1966-67, c. 71; the current citation is R.S.C. 1970, c. P-32.
S.C. 1966-67, c. 72; the current citation is R.S.C. 1970, c. P-35.
5 S.C. 1960-61, c. 57.
6 An Act to amend the Financial Administration Act, S.C. 1966-67, c. 74.
(iv) administrative support, or
(v) operational,
and any other occupationally-related category of employees
determined by the Board to be an occupational category;
"Occupational group" was in turn defined, in paragraph 2(s), in this way:
2....
(s) "occupational group" means a group of employees speci fied and defined by the Public Service Commission under subsection (1) of section 26;
Apparently in preparation for the new system of collective bargaining, the Civil Service Commis sion had undertaken, as mentioned in subsection 26(2) of the Act, a program of classification revi sion. The Public Service Commission was required by subsection 26(1) of the Act to specify and define the occupational groups within each occu pational category so as to comprise within them all employees of the Public Service in respect of whom Her Majesty, as represented by the Trea sury Board, is the employer. By virtue of subsec tion 26(2), the groups were to be specified and defined on the basis of the grouping of positions and employees, according to their duties and responsibilities, under the program of classification revision that had been undertaken by the Civil Service Commission prior to the coming into force of the Act. The Public Service Commission was required to complete this task within fifteen days after the coming into force of the Act, and was to publish in the Canada Gazette notice of the occu pational groups specified and defined by it. This notice was published in the Canada Gazette on March 20, 1967, one week after the Act was proclaimed in force.
It was necessary to convert Public Service posi tions, as they stood before the adoption of the new classification system, into positions classified in accordance with the new system, a responsibility vested in the Treasury Board. Presumably as an instrument for making adjustments in pay that might become necessary or desirable as a conse quence of the conversion of positions, Treasury Board, on May 25, 1967, adopted the Conversion and Post-Conversion Pay Regulations'. The cir cumstances in which the Regulations were to apply were described in section 2 as follows:
7 T.B. 669255, May 25, 1967.
2. These Regulations shall apply to the conversion of positions and employees to new groups and levels, and where necessary may be applied retroactively to employees converted to the Administrative Support and Administrative and Foreign Ser vice Categories; to alterations in conversion; and to post-conver sion reclassification.
In connection with the conversion of positions to the new classification system, the Regulations appear, on their face, to have envisaged problems arising at the conversion stage itself and during a closely-related adjustment stage. Sections 4 to 12 of the Regulations appear to relate to problems arising immediately on conversion, and sections 13 to 17 to problems arising for reasons directly related to conversion. Sections 18 and 19, on the other hand, have to do with matters that may arise in connection with a subsequent reclassification of converted positions following an audit or review 8 .
8 Sections 6, 7, 18 and 19 of the Regulations are particularly pertinent to this case and are, accordingly, reproduced below: Pay Entitlements for Employees Appointed to Positions Having a Lower Classification
6. (1) Notwithstanding subsection (1) of section 63 of the Public Service Terms and Conditions of Employment Regu lations, an employee who is appointed, other than at his request or by demotion, to a position with a lower maximum rate of pay than the maximum rate of the position he held, shall be entitled to be paid for services rendered
(a) the remuneration applicable to the position held by him in the new classification and pay plan;
(b) the scale of rates applicable to the position held by him on that date in the former classification and pay plan; or
(c) the scale of rates applicable to the position held by him in the new classification and pay plan immediately before the appointment to another position in the new classifica tion and pay plan;
whichever has the highest maximum rate.
(2) The entitlement referred to in paragraph (c) of subsec tion (1) of section 6 above shall not apply to an employee on the date of a demotion in the former class or level or on the date of an appointment to a lower level in the former class which was requested by the employee.
7. The entitlement referred to in paragraphs (b) and (c) of subsection (1) of section 6 shall continue until such time as the maximum rate for the employee's position, or any posi tion to which he may have been transferred having the same maximum rate as his position, or the maximum rate of any higher position to which he may later be appointed, is
(Continued on next page)
It will be recalled that on September 1, 1967, Mr. Jones had been appointed to a position classi fied as Technical Officer 6, although his personal classification was Technical Officer 5, a personal classification he retained for a year until he was personally promoted. The Technical Officer 6 position held by Mr. Jones was one of seventy- eight similar positions, all of which were classified as Technical Officer 6, and all of which formed part of Job DPW-272. On July 24, 1967, all of the Technical Officer 6 positions in Job DPW-272 were evaluated by point rating for the purpose of converting them to the new plan of classification for the EG-ESS Group. This evaluation was based on a common or "lead" job description. The point rating given to these positions placed them at level 9 of the EG-ESS Group.
A Classification Revision Form, signed on Janu- ary 28, 1969, by "J. Clarke" for the Chief, Person-
(Continued from previous page)
equivalent to or higher than the maximum rate to which he is entitled. Similarly, where an employee is being paid in a scale of rates with a maximum rate higher than the normal maximum for the performance pay scale for his position, the entitlement to the higher pay scale shall continue until such time as the normal maximum for his position is equivalent to or higher than the maximum rate to which he is entitled, or until he is paid at an exceptional merit rate equal to or higher than the maximum rate to which he is entitled.
Reclassification Following Audit or Review of Post-Conver sion Actions
18. Where, as a result of audit or review, a converted position is found to be underclassified, it shall be reclassified to a higher level on an effective date to be determined by the competent classification authority, taking into consideration the date on which the current duties and responsibilities were assigned to the position, and the rate of pay and increase date of the employee on appointment to that higher level shall be calculated in accordance with section 66 and section 71 of the Public Service Terms and Conditions of Employment Regulations.
19. Where, as a result of audit or review, a converted position is found to be overclassified
(a) the employing department shall be notified of the correct lower classification and if, within a period of sixty days the duties and responsibilities of the position have not been altered to justify the existing classification, the posi tion shall be classified at the lower level with effect from the date on which the sixty-day period commenced, and
(b) the employee holding the position in that lower level shall be paid in the manner described in paragraphs (b) and (c) of subsection (1) of section 6 of these regulations.
nel, Ontario Region of the Department of Public Works, and purporting to be approved on January 30, 1969, by the "Civil Service Commission", shows that Mr. Jones's position (P.W.-OTO-71) was converted from Technical Officer 6 to EG-ESS-9. The form also shows that the effective date of conversion was July 1, 1967, that EG-ESS-8 was his personal grade and class during the period from July 1, 1967 to August 31, 1968, reflecting the period during which he was paid as a Technical Officer 5, and that thereafter it was EG-ESS-9. Mr. Jones was informed by a letter, sent to him on or about May 16, 1969, that his appointment to the position he then held had been approved at level 9.
A collective agreement between the Public Ser vice Alliance and the employer was signed on May 22, 1969, covering the bargaining unit of which Mr. Jones was a member. Three other collective agreements were in turn operative during the period with which we are concerned. It is agreed that the pay articles of these agreements included these clauses appearing within Article 32 of the agreement which became effective on May 10, 1971:
ARTICLE 32 PAY
32.01 Except as provided in Clauses 32.02, 32.03, 32.04 and 32.05, the terms and conditions governing the application of pay to employees are not affected by this Agreement.
32.02 An employee is entitled to be paid for services rendered at:
(a) the pay specified in Appendix "B" for the classification of the position to which he is appointed, if the classification coincides with that prescribed in his certificate of appoint ment, or
(b) the pay specified in Appendix "B" for the classification prescribed in his certificate of appointment, if that classifica tion and the classification of the position to which he is appointed do not coincide.
32.05 The pay of employees resulting from conversion to the new classification and pay plan effective July 1, 1967, will be governed by the Conversion and Post-Conversion Pay Regulations.
It may be noted that, under section 40 of the Public Service Staff Relations Act, an employee organization, certified as the bargaining agent for a bargaining unit, has the exclusive right to bar gain collectively on behalf of the employees in the bargaining unit and to bind them by a collective
agreement. Also, by virtue of section 54 of the Act, the Treasury Board may enter into a collective agreement with the bargaining agent for a bar gaining unit applicable to employees in the unit. Section 58 provides that, subject to the Act, a collective agreement is binding upon the employer, on the bargaining agent, and on the employees in the bargaining unit.
It is not in dispute that, when Mr. Jones's position was converted from Technical Officer 6 to EG-ESS-9 and that when his appointment in that position at level 9 was approved, there was no reason to red-circle him. It appears that he was paid, under clause 32.02 of the collective agree ment, as an employee whose position classification coincided with the classification prescribed in his certificate of appointment, that is to say, with his personal classification.
A_ memorandum dated April 8, 1971, from R. O. Mitchell, who was described as Chief, Classifi cation & Compensation, was sent to the Chief, Personnel Administration, Western Region. The memorandum is headed: "Review—Territorial Technical Officers, Job DPW 272—EG-ESS-9". It reads:
1. Job DPW 272 contained a total of 78 Technical Officer 6 positions which were converted EG-ESS-9 with a point rating of 196-196-075-146(36-30-50-30)-058-0671. Evaluation was based on a Questionnaire prepared for Position PW-WW1-48, now PW-514-630.
2. Review of the EG-ESS Conversion resulted in 29 positions, in this job, being re-evaluated at a lower level in the Group. There are now 44 positions remaining in Job DPW 272 as EG-ESS-9; five positions were abolished subsequent to conversion.
3. In view of the results of the Review of Conversion, in relation to Job DPW 272 the duties of all positions, vacant or filled, remaining in this Job as EG-ESS-9 will be up-dated and submitted for review to this Headquarters by June 30, 1971. The up-dated duties and responsibilities will be reviewed and evaluated by a Headquarters Review Committee established for that specific purpose. Regions must also advise Headquar ters of positions in which down-grading would result in "red- circling" of the incumbent.
4. The following are attached:
(a) List of Positions remaining in Job DPW-272 as EG-ESS-9
(b) Position Duties and Working Conditions on which Con version was based.
Mr. Jones signed a Department of Public Works Position Description form, dated July 23, 1971.
The descriptive title of the position, appearing in the form, is "Territorial Officer". The position number is given as PW-411-401, and the "present position classification" is entered as EG-ESS-9. "K. Jones" is typed in the heading to the form as the "name of incumbent", and the "certified group & level of incumbent" is shown as EG-ESS-9. Mr. Jones, in signing, certified that the form contained " ... an accurate and complete description of the duties of my position. ..." Mr. Jones's supervisor also signed the form immediately under the words: "The above description is an accurate and com plete statement of duties assigned to the position effective July 1, 1971 ... and are being performed by the employee ...."
A classification action form, dated March 30, 1972, signed by H. J. Traynor, Classification Offi cer, and headed "Treasury Board Secretariat", relates to the reclassification of position Number PW-411-401. The form shows that the point rating of the position had changed from 671 to 597, and that the position had been changed from the previ ous group and level EG-ESS-9 to group and level EG-ESS-8, effective June 28, 1972. Under the heading "Remarks", it is stated: "This action results from Audit Board Review of positions in Job DPW 272, converted EG-ESS-9, and not reviewed in the Post-Conversion period ending December 31, 1969, nor subject to any classifica tion review subsequent to the date of conversion, July 1, 1967." It seems clear from this notation that this reclassification was not a conversion, nor was it a consequence of a review during the post- conversion period; it resulted from a review by the Audit Board (whatever that may have been) of positions in Job DPW 272 that had previously been converted to EG-ESS-9. So far as I can tell, it was a reclassification as a result of the sort of audit or review contemplated by section 19 of the Conversion and Post-Conversion Pay Regulations. It may have been a consequence of the review mentioned in the memorandum of April 8, 1971 from Mr. Mitchell to the Chief, Personnel Administration, Western Region, although that memorandum states: "The up-dated duties and responsibilities will be reviewed and evaluated by a Headquarters Review Committee established for that specific purpose."
A further step was taken in carrying the reclas- sification through to completion. A "Certificate of Appointment" was issued. It contained both the recommendation of Mr. Jones's appointment to the reclassified position and an approval of the appointment. This action seems to have been based on the view that, for purposes of appointment, a Public Service position is not merely a position with a number; it is a position within an occupa tional group so that, if the classification of a position is changed from one occupational group to another or from one level to another level within an occupational group, the position itself changes and the incumbent must be reappointed to what is considered to be the new position. This view of the effect of a reclassification on a position is reflected in certain of the materials before us. Section 4 of the Regulations, for example, provides in subsec tion (1) that:
4. (1) Where a new group is established ... and an employee is appointed to a position in such a group, he shall be paid on the effective date of that appointment at the rate of pay that is nearest to but not less than the rate of pay he is entitled to receive on that date.
Subsection 5(1) provides that:
5. (1) ... the first increase in pay following the appoint ment referred to in section 4 shall be calculated as if that appointment constituted a transfer from the position held on that date in the former class and grade....
Section 6, quoted above, refers in subsection (1) to:
6. (1) ... an employee who is appointed ... to a position with a lower maximum rate of pay than the maximum rate of the position he held ....
And section 18, also quoted above, refers to
18. ... the rate of pay and increase date of the employee on appointment to that higher level ...
where a position is reclassified to a higher level. It is also of some significance that subsection 41(3) of the Public Service Employment Regulations 9 provides in part as follows:
9 SOR/67-129.
41....
(3) This section and section 12 do not apply where the appointment of a person is made from within the Public Service without competition
(a) to a reclassified position held by that person immediately prior` to the reclassification,
and in such cases there shall be deemed to be no person whose opportunity for advancement has been prejudicially affected.
I mentioned earlier that Mr. Jones's position, at the time he was a Technical Officer 6, had been converted to EG-ESS-9 effective July 1, 1967, and that Mr. Jones had been notified by letter in May 1969 that his appointment to the position he then held had been approved at level 9. In connection with the conversion of the positions to the EG-ESS Group, a memorandum dated July 8, 1969, en titled "Conversion of and Pay Implementation for Engineering and Scientific Support Group Posi tions", and signed by C. A. Smith, Director, Per sonnel Administration, was sent to the Regional Chief, Personnel Administration. It contains this paragraph:
This is to advise you to proceed with incumbent pay action on CSC 245's for positions converted to the EG-ESS group. This action is to be based on the original conversion decision with the one exception—those positions which, as a result of a subsequent review, were re-evaluated at a higher level. For the latter positions the higher level will be recognized as the converted level. The level to be paid will of course be governed by the level at which the PSC is prepared to certify the incumbent.
I have put in italics the words I find significant for present purposes.
On July 18, 1972, a personnel action form, the "Certificate of Appointment" mentioned above, was issued in respect of Raymond Keith Jones. Its effective date was June 28, 1972. The form describes itself as a "Certificate of Appointment— Type 4". The Public Service Staffing Manual defines a Type 4 appointment as: "The appoint ment of an employee to a lower level of the occupational group." In space 14 of the form appears the entry:
Group and level before effective date
(a) of employee EG-ESS-9
(b) of classification decision EG-ESS-9
In space 18 is the entry:
Group and level as of effective date
(a) of classification decision EG-ESS-8
(b) of appointment EG-ESS-8 (paid as EG-ESS-9)
In space 38, under "Remarks", appears the notation:
Mr. Jones is to be maintained in the Holding Range of $13,464 to $15,303 in accordance with the Conversion and Post Conver sion Regulations—articles 19 and 6.
The completed form shows that the appointment was recommended by W. D. McKee, Manpower Planning & Development Officer, DPW, 25 St. Clair Avenue E. It was approved by E. Cruick- shank, Staffing Officer, P.S.C., Ottawa, Ontario.
It is thus apparent that at least the attempt was made, not only to reclassify Mr. Jones's position, but also to appoint him to the reclassified position. For reasons that appear more fully toward the end of this judgment, I am of the view that this attempt succeeded in producing a new certificate of appointment.
This ends the rather lengthy review of the back ground material. As I indicated previously, the Chief Adjudicator allowed Mr. Jones's grievance in its essentials. I quote him:
In the result, this grievance succeeds. The changes in Mr. Jones' pay entitlement recorded in Exhibit 13 were contrary to the provisions of the applicable collective agreement. He is entitled to the retroactive adjustment of his salary on the basis of the same status in respect of pay which he enjoyed immedi ately prior to June 28, 1972. In other words, he should receive the salary he would have received if the group and level of his position and his personal classification had continued to be treated as EG-ESS-9 after June 28, 1972. Thus, he should be paid the increase in the EG-ESS-9 maximum rate which became effective on November 7, 1972, and also subsequent increases for that group and level agreed to by the parties.
As I understand him, the Chief Adjudicator was of opinion that the Regulations had no relevance in determining Mr. Jones's pay after the reclassifica- tion of his position. This was so because, in the Chief Adjudicator's view, clause 32.05 applies only to the determination of pay resulting from conver sion and by implication excludes the Regulations from the determination of pay resulting from reclassification. It followed, in his opinion, that the
reclassification of Mr. Jones's position (whatever other consequence it may have had) and the cer tificate of appointment issued to him in respect of the reclassified position (whatever its precise nature may have been and whatever other conse quences it may have had) were of no consequence in fixing his pay. For purposes of clause 32.02, Mr. Jones's certificate of appointment continued to be the document by which he was appointed to the EG-ESS-9 position in 1969.
The issue before us is whether the Chief Adjudicator erred in law in interpreting the collec tive agreement as he did.
It seems to me that there are two questions to be answered. The first is this: for the purpose of determining Mr. Jones's pay after his position was reclassified from EG-ESS-9 to EG-ESS-8, was his certificate of appointment the letter he received in 1969 informing him that he had been confirmed in the EG-ESS-9 position, or was it the personnel action form issued on July 18, 1972, the "Certifi- cate of Appointment—Type 4"? The other ques tion is whether, if his certificate of appointment was the personnel action form, he was entitled to the red-circling protection afforded by section 19, paragraph (b) of the Regulations.
Clause 32.02 of the agreement, despite its com plex wording, seems clear enough: an employee is to be paid at the rate specified in Appendix "B" as being applicable to the classification prescribed in his certificate of appointment. In this case, the employer obviously treated Mr. Jones's certificate of appointment as the personnel action form issued on July 18, 1972. The classification prescribed in it was: EG-ESS-8. The employer did not, however, reduce Mr. Jones's pay. The position was taken that, because of clause 32.05, Mr. Jones was en titled to the red-circling protection afforded by section 19, paragraph (b) of the Regulations. Indeed, the personnel action form stated that this was so.
The Chief Adjudicator was of the view, as already indicated, that the employer was wrong in proceeding in this way: the employer should have ignored the personnel action form and kept paying Mr. Jones at the rate applicable to classification EG-ESS-9, not because of red-circling protection,
but because that was the classification specified in his certificate of appointment before his position was reclassified.
Clause 32.05 is not free from doubt. Its wording is awkward. What, for example, does it mean when it says: "The pay of employees ... will be governed by the Conversion and Post-Conversion Pay Regu lations"? All other things being equal, the pay of employees must be determined by clause 32.02. "Governed by" surely means no more than that the Regulations must also be applied when, in the situation specified in the clause, pay is being determined.
And what is the significance of the following words appearing in the clause: "... resulting from conversion to the new classification and pay plan effective July 1, 1967 ..." ? Does the clause mean what the Chief Adjudicator said it means? Or does it mean that the Regulations are to be applied, along with clause 32.02, in determining the pay of employees appointed to positions reclassified fol lowing a post-conversion audit or review as well as the pay of those appointed to converted positions?
It is appropriate, in seeking the correct interpre tation of the clause, to look to relevant circum stances at the time the agreement was first made and at the time of its renewals. It is also appropri ate to search for the purposes of the clause and to consider the consequences of different readings.
What is now clause 32.05 was included in the first of the collective agreements covering the EG-ESS Group, the agreement effective in May 1969. This agreement was apparently made shortly after the conversion of the Technical Officer posi tions to the new system of classification. In the letter of May 1969 notifying Mr. Jones that his appointment had been approved, after the conver sion of positions, at level 9 in the Engineering and Support Group, the Chief, Personnel Administra tion, stated that: "When negotiation of the collec tive agreement is completed, and we receive notice of the new wage rates, they will be implemented and you will be advised."
It is not surprising that express mention was made in the new agreement of the provisions in the
Regulations dealing with the problems that would in all probability arise in respect of pay changes consequent on conversion. Again, I quote from the reasons of the Chief Adjudicator:
The conversion of a position from a classification under the old system to a new group and level—and designation—under the new plan was certain to raise difficult questions as to the pay treatment of incumbents. The formulae for resolving such questions were set out by Treasury Board in the Conversion and Post-Conversion Pay Regulations, adopted on May 22, 1967, to which reference was made in many of the collective agreements concluded in the ensuing period.
Clause 32.05 was also included in the agree ments signed on June 4, 1971 and on December 19, 1972. Both of these agreements were signed well after the impact of conversion. This is itself a circumstance supporting the interpretation of the clause as covering reclassification as well as conversion.
It may be of assistance, in determining the purpose and scope of clause 32.05, to advert to a suggestion made to us in connection with the relationship between clauses 32.01 and 32.05. It was suggested that the words in clause 32.01, ".. the terms and conditions governing the application of pay to employees ..." include the terms and conditions governing the application of pay con tained in the Regulations. It was then suggested that a purpose of clause 32.05 was to limit the application of the Regulations, so included by clause 32.01, to the determination of the pay of appointees to converted positions. This would have been a strange way of achieving the purpose. I would have thought, if that were the purpose, that clause 32.05 would have provided in so many words that the Regulations would not apply to appointments to reclassified positions. But that is not what the clause provides. It provides affirma tively for matters that would already be covered by clause 32.01 if that clause incorporated the Regu lations by its reference to "the terms and condi tions governing the application of pay to employees".
My own view is that the words quoted from clause 32.01 do not refer to terms and conditions appearing in the Regulations. They refer to terms and conditions governing pay appearing principal ly, if not exclusively, in the Public Service Terms
and Conditions of Employment Regulations' 0 .
This reading enables one to make sense of the exception expressed in clause 32.01 as it relates to clause 32.05.
To mention quite another matter, it is signifi cant that, if the Chief Adjudicator were right in his reading of clause 32.05, an employee who might be appointed to a position reclassified to a higher level would not be entitled to the higher rate of pay to which clause 32.02 would otherwise entitle him. It seems unlikely that the parties would have intended this consequence.
With these various considerations in mind, I conclude that the purposes of clause 32.05 are to provide that, in determining the pay of employees who are appointed to converted positions or to positions reclassified because of a post-conversion audit or review, the special problems that may arise will be dealt with in accordance with the Conversion and Post-Conversion Pay Regulations even though there might be inconsistent provisions in the Public Service Terms and Conditions of Employment Regulations, and that employees whose pay may be adversely affected by being reappointed to positions reduced in status in the process of reclassification will be protected by red-circling. I interpret clause 32.05 as giving effect to these purposes.
In the course of reaching my conclusion, I gave very careful attention to what might be considered a more literal meaning of the words of the clause itself, the meaning which the Chief Adjudicator gave to them. Having in mind, however, the con text of the clause, its purposes, and the conse quences of the different interpretations, I have construed it as referring to the Regulations as a whole and not merely to part of them. I interpreted the clause within the total context of the pay article".
I would add that it does not seem to me to be a purpose of the clause to isolate the wage determi nation of employees appointed to reclassified posi tions from the administrative provisions of the Conversion and Post-Conversion Pay Regulations as they relate to pay or from their red-circling
10 T.B. 665757 (SOR/67-118, as amended).
" See E. A. Driedger, The Construction of Statutes
(Toronto, 1974), at p. 2.
safeguards. Nor does it seem to me to be a purpose of the clause to require the employer, in determin ing an employee's pay, to disregard his current certificate of appointment and look to a certificate that has been replaced by it.
Even if I were of the opinion that the clause should be interpreted so as to limit it to the pay determination of employees appointed to converted positions and so as, by implication, to make the Regulations inapplicable to the pay determination of employees appointed to reclassified positions, I would not reach the same conclusion as did the Chief Adjudicator on the consequences of that reading.
The clause relates only to the determination of pay. It does not purport to limit the power to classify positions or to make appointments to them. It deals with the pay consequences of such actions.
There is no doubt that Mr. Jones's position was reclassified. Authority for the reclassification was supplied by paragraph 7(1)(c) of the Financial Administration Act 12 . Paragraph 19(a) of the Regulations imposed a duty to reclassify the EG-ESS-9 position to EG-ESS-8 because, as a result of the audit or review, it had been found to be overclassified. The reclassification had no consequence so far as the determination of Mr. Jones's pay was concerned. Clause 32.02 of the agreement makes that clear. The question of a change in Mr. Jones's pay did not arise until he was reappointed to the reclassified position by the personnel action form issued on July 18, 1972. Au thority for the reappointment was derived from the Public Service Employment Act and Regulations made under it, not from the Conversion and Post- Conversion Pay Regulations. The pay consequence of the issuance of the new certificate of appoint
12 R.S.C. 1970, c. F-I0. Paragraph 7(1)(c) provides:
7. (1) Subject to the provisions of any enactment respect ing the powers and functions of a separate employer but notwithstanding any other provision contained in any enact ment, the Treasury Board may, in the exercise of its respon sibilities in relation to personnel management including its responsibilities in relation to employer and employee rela tions in the public service, and without limiting the generality of sections 5 and 6,
(c) provide for the classification of positions and employees in the public service;
ment would have been determined in accordance with clause 32.02 of the agreement without the protection of red-circling if paragraph 19(b) of the Regulations were excluded by clause 32.05. It seems to me that the narrow reading of clause 32.05, a reading that would restrict it to appoint ments to converted positions, would have deprived him of that protection. This is, to me, an indication that the broader reading is the more likely one.
I now summarize. Mr. Jones's position had been converted from Technical Officer 6 to EG-ESS-9; he had been notified of that conversion; he had been informed by letter that his appointment to level 9 of the converted position had been approved; he was paid for some three years in accordance with the provisions of subclause 32.02(a) of the agreement on the basis that his classified position and his personal position coin cided; his converted position was reclassified from EG-ESS-9 to EG-ESS-8; his appointment to the EG-ESS-8 position was approved by the personnel action form (certificate of appointment)—Type 4, signed by E. Cruickshank, Staffing Officer, Public Service Commission, the form issued on July 18, 1972; this form constituted Mr. Jones's certificate of appointment for purposes of clause 32.02 of the agreement; the Regulations are applicable by virtue of clause 32.05; Mr. Jones was accordingly entitled to the protection afforded by the red-cir cling provision in paragraph 19(b) of the Regula tions; and his salary was determined and paid by the employer with proper regard to these circumstances.
Before concluding, I wish to refer particularly to two submissions that were made to us on behalf of the respondent.
It was submitted that the alleged reappointment of Mr. Jones to the reclassified position was a demotion, and that the Public Service Commission lacks authority to demote unless it proceeds under section 31 of the Public Service Employment Act". In purporting to reappoint Mr. Jones, the Commission was obviously not acting under sec-
" Section 31 of the Public Service Employment Act provides:
31. (1) Where an employee, in the opinion of the deputy head, is incompetent in performing the duties of the position
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tion 31: there was no suggestion whatever that Mr. Jones was incompetent in performing the duties of his position or that he was incapable of performing them. It follows, it was argued, that Mr. Jones's reappointment was a nullity, and accordingly that the certificate of appointment issued on July 18, 1972, was not and could not be a certificate of appointment for purposes of the collective agree ment.
In my view, however, the Treasury Board, for the reasons I have given, did have author ity to reclassify the position that Mr. Jones had occupied, the EG-ESS-9 position. I am also of the view that the Public Service Commission had au thority to appoint Mr. Jones to the reclassified position by virtue of section 8 of the Public Service Employment Act and the Regulations made pursu ant to the Act, even though the reappointment was to a position at a lower level. I see nothing in the collective agreement or in relevant legislation or Regulations to limit this authority.
(Continued from previous page)
he occupies or is incapable of performing those duties and should
(a) be appointed to a position at a lower maximum rate of pay, or
(b) be released,
the deputy head may recommend to the Commission that the employee be so appointed or released, as the case may be.
(2) The deputy head shall give notice in writing to an employee of a recommendation that the employee be appointed to a position at a lower maximum rate of pay or be released.
(3) Within such period after receiving the notice in writ ing mentioned in subsection (2) as the Commission pre scribes, the employee may appeal against the recommenda tion of the deputy head to a board established by the Commission to conduct an inquiry at which the employee and the deputy head concerned, or their representatives, are given an opportunity of being heard, and upon being notified of the board's decision on the inquiry the Commission shall,
(a) notify the deputy head concerned that his recommen dation will not be acted upon, or
(b) appoint the employee to a position at a lower max imum rate of pay, or release the employee,
accordingly as the decision of the board requires.
(4) If no appeal is made against a recommendation of the deputy head, the Commission may take such action with regard to the recommendation as the Commission sees fit.
(5) The Commission may release an employee pursuant to a recommendation under this section and the employee there upon ceases to be an employee.
The other submission was that the purported appointment to the reclassified position was not an appointment within the meaning of the Public Service Employment Act or of the collective agree ment because it was not made on the basis of an assessment of Mr. Jones's qualifications. To put it rather more broadly, it was argued that, after the reclassification, the duties required of the occupant of the position were the same as at the time the position was converted; that neither the qualifica tions required nor the qualifications which Mr. Jones had to offer had changed; and that there was no occasion to reassess Mr. Jones's qualifications, nor were they reassessed.
It is to be noted, however, that the memoran dum dated April 8, 1971, from the Chief, Classifi cation & Compensation, to the Chief, Personnel Administration, Western Region, stated in part that "... in relation to Job DPW 272 the duties of all positions, vacant or filled, remaining in this job as EG-ESS-9 will be up-dated and submitted for review to this Headquarters by June 30, 1971. The up-dated duties and responsibilities will be reviewed and evaluated...." It is also to be noted that in the position description, dated July 23, 1971, and signed by Mr. Jones, Mr. Jones's super visor certified the statement as a statement of the duties assigned to the position effective July 1, 1971.
It also seems to me to be unwarranted to assume that the personnel action form issued on July 18, 1972, and approved by a staffing officer of the Public Service Commission, was issued without consideration having been given to Mr. Jones's qualifications to perform the duties of the reclassi fied position. Mr. Jones's satisfactory performance of the duties of the position at level 9 would itself be cogent evidence of his qualifications to perform the duties required at level 8. I am satisfied that the personnel action form issued on July 18, 1972, is Mr. Jones's "Certificate of Appointment" as that term is used in clause 32.02 of the collective agreement.
It was suggested in argument that, to interpret the collective agreement in such a way as to make the Conversion and Post-Conversion Pay Regula tions applicable to the determination of the pay of employees, covered by the collective agreement,
whose positions might be reclassified during its term would be to place them at the mercy of the employer because Treasury Board is the classify ing authority under the Financial Administration Act. It is significant, however, that the respondent did not question that the reclassification was car ried out in good faith, that it was in truth a reclassification. We do not have here any sugges tion of a subterfuge undertaken for the purpose of undermining the collective agreement.
The question whether this Court has jurisdiction to hear this section 28 application was considered. The question was raised because of subsection 100(1) of the Public Service Staff Relations Act which, in its present form, was enacted in 1975 by way of substitution for the previous subsection 100(1) 14 . The decision of this Court in the Attor ney General of Canada v. Public Service Staff Relations Board 15 case makes it clear that we do have jurisdiction.
I would grant the application and set aside the decision of the Chief Adjudicator dated September 4; 1976. I would refer the matter back to him to be decided on the basis that Mr. Jones's grievance be dismissed and the relief he sought denied.
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PRATTE J.: I agree.
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LE DAIN J.: I agree.
14 S.C. 1974-75-76, c. 67, s. 29.
15 [1977] 2 F.C. 663.
 You are being directed to the most recent version of the statute which may not be the version considered at the time of the judgment.