Number 14 – April, 2008
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Number 14 – April, 2008 |
Environmental Sensitivity and the WorkplaceIn May 2007, the Canadian Human Rights Commission published a paper on “The Medical Perspective on Environmental Sensitivities” written by Dr. Margaret Sears. It outlines that as many as 3% of Canadians have been diagnosed with environmental sensitivities. Beyond this, many more Canadians have some degree of sensitivity to “traces of chemical and/or electromagnetic phenomena in the environment.” Dr. Sears described that there is a broad range of symptoms experienced by people suffering from environmental sensitivities, including neurological impairments, runny eyes, headaches, fatigue, pain, and difficulties breathing or digesting. These conditions may develop gradually as a result of chronic exposure to even low levels of triggers, or suddenly as a result of a more significant exposure. Once an environmental sensitivity occurs, a heightened sensitivity may develop such that the person may experience symptoms in response to a broader range of triggers or at a more significant degree than previously. Some people continue to work despite environmental sensitivity. Others may have certain restrictions as a result of their condition. Still others may be rendered disabled from working. Workers faced with such circumstances should be aware of their rights under relevant human rights legislation as well as their possible entitlements to disability benefits. Human Rights Entitlements and Environmental Sensitivity In Ontario, workers are protected under the Human Rights Code from discrimination based on disability. The term “disability” is broadly defined under the Code. In its website materials, the Ontario Human Rights Commission describes the definition of disability as including environmental sensitivity. Adjudicators in employment-related cases have also interpreted disability or handicap broadly enough to include environmental sensitivity and have determined that workers with such conditions may require accommodation by their employers (e.g., Guibord and Treasury Board (Transport Canada) (1995), 28 PSSRB Decision 12 (December 18, 1995); Halton and Ontario Nurses Association (1991), 18 L.A.C. (4th) 428). Sometimes environmental sensitivities are difficult to diagnose, particularly where the focus of the doctors is on trying to determine the cause of the condition. There may be disagreement among treating practitioners about the actual diagnosis of the condition. What is relevant from a human rights perspective is whether there is legal proof that the person has a disability (Brewer v. Fraser Milner Casgrain, [2006] A.J. No. 625 (Brewer)). Where accommodation is being requested, it is critical that the worker have medical evidence establishing the worker’s restrictions related to the disability and identifying what aspects of the workplace interfere with those restrictions. Examples of requests for accommodation made by persons suffering from environmental sensitivities have included placement in environments with the following conditions: minimal exposure to triggering substances, such as perfumes, tobacco smoke; minimal exposure to fabric usage such as carpet, curtains, or upholstered furniture; guaranteed frequent cleaning routines; alteration of existing ventilation processes and opportunity for additional ventilation; restrictions on the type of cleaning products used in the work area; access to respiratory protective equipment; isolation from visitors to the workplace who may not be aware of or be bound by the workplace scented products policy (e.g., Hutchinson v. Canada (Minister of the Environment), [2003] 4 F.C. 580 (Fed. C.A.); Brewer). Disability Benefits and Environmental Sensitivity There has been no substantial litigation in Canada for entitlement to long-term disability benefits where disability is based on environmental sensitivity. The claimant in a long-term disability case must normally prove that she suffers from a disability that prevents her from working the threshold level established under the policy. Controversy in medical communities about a diagnosis like environmental sensitivity or multiple chemical sensitivity can sometimes undermine a claimant’s attempts to prove she is disabled (e.g., MacDonald v. Sunlife Assurance Co. Of Canada, [2005] P.E.I.J. No. 60 (Appeal division)). However, jurisprudence supports that the onus is on the claimant to prove on a balance of probabilities that she is disabled under the policy. She is not required to have medical consensus on her diagnosis. There may be dispute in the medical community about a particular diagnosis, but the ultimate question is whether there is proof that the person is disabled from working as a result of a medical condition, irrespective of how it is diagnosed. It should also be noted that the cause of the condition is largely irrelevant to most claims for disability insurance benefits. Benefits under collective agreements may sometimes be contingent on the work-relatedness of the condition. In such cases, the additional burden of establishing causation may be placed on the claimant and her union, as was the case in both Nova Scotia Teachers Union v. Nova Scotia (Minister of Education and Culture (Sewell Grievance), [2001] N.S.L.A.A. No. 20 and Nova Scotia Teachers’ Union v. King’s County District School Board (Van Zoost Grievance), [1996] N.S.L.A.A. No. 6. Benefits under the Workplace Safety and Insurance Act for Environmental Sensitivity Arising out of the Workplace Claims for benefits under the Workplace Safety and Insurance Act have generated much more jurisprudence. Such claims have had mixed results. Put simply, entitlement to benefits under the legislation will only be paid where it may be proved that the disabling condition arose out of the course of employment. In other words, there must be some proof that the workplace substantially contributed to the development of or exacerbation of the disabling health condition. A key difficulty in such cases is establishing proof of a triggering exposure, particularly because many people in the workplace may have no reaction to the exposure even though one or a few people with environmental sensitivities are disabled by it. A further difficulty in establishing the workplace as the significant contributing factor in such cases is that claimants’ symptoms often do not cease on removal from the workplace environment. The question becomes, then, whether the triggers causing the reaction are in the workplace, only in the claimant’s home, or in the environment more broadly. The Workplace Safety Insurance Appeals Tribunal (WSIAT) is the final level of decision-making under the legislation. WSIAT has reviewed claims asserting environmental sensitivity from a number of perspectives. For example, it has reviewed claims based on a diagnosis of Multiple Chemical Sensitivity (MCS), which several WSIAT panels have described as a controversial diagnosis in medical communities. The Tribunal has also reviewed claims citing conditions such as respiratory illness or asthma based on workplace exposures or assertions of environmental issues or sick building syndrome. A medical discussion paper dated April 2007 was prepared for the WSIAT on "Idiopathic Environmental Intolerance". A key theme in the paper is the medical controversy and lack of information about the condition, as well as the debate about whether the condition is primarily physiological or psychological. In addressing the controversies, the author outlines that MCS is not a recognized disease with demonstrable pathology. Since the release of this discussion paper, there have been at least two successful appeals to WSIAT based on claims related to MCS. The panel in each case determined that the debate between the physical and psychological origin of the condition was not determinative of entitlement to benefits under the legislation. The WSIAT has distinguished between the need for medical certainty and the need for proof on a balance of probabilities when approaching the issue of causation in such cases. Entitlement to benefits is not contingent on consensus of medical opinion. For the most part, the WSIAT will consider several factors in environmental or multiple chemical sensitivity cases, including the following:
Medical experts called by the WSIAT in cases based on MCS, environmental sensitivity, and sick building syndrome cases have tended to have expertise in occupational exposure or respirology. Many of these experts point to the controversy in the medical community over the nature of MCS and related diagnoses as medical disorders. Consistent with the discussion paper outlined above, some of the main reasons for the controversy are that the diagnosis is made where patients demonstrate a variety of commonly-experienced symptoms, which they relate to very low levels of chemicals in the environment. Normal mechanisms of toxicology often cannot account for the development of severe symptoms in the face of exposures to such low levels of concentration. Where several possible contributing factors are identified (such as viral infections, unrelated surgery, etc.), entitlement under the Workplace Safety and Insurance Act will be denied, if the panel determines that such other circumstances or conditions are the more likely contributing factors as compared to workplace exposures (e.g., WSIAT Decision 800/95). The WSIAT has awarded entitlement to benefits for environmental sensitivities after approaching the illness from both an acute exposure perspective and from a disablement perspective. In some cases, an acute reaction to specific chemical exposures has then developed into a more generalized response in every instance of exposure (e.g., WSIAT Decision 1888/05). In other cases, the Tribunal has been open to a disablement approach, which does not focus on a sudden or acute reaction but recognizes that MCS can develop over time as a result of extended exposure to low levels of chemicals (e.g., WSIAT Decision 2934/01). Examples of some of the key barriers to the success of such claims include the following: a medical history with other medical conditions having similar symptoms, prior psychological conditions giving rise to similar symptoms, inconsistent reporting of symptoms between medical practitioners, lack of proof of a workplace exposure, proof only of low level exposures not generally considered sufficient to establish causation, symptoms persisting even after the worker’s absence from the environment, or delayed onset of symptoms following exposure to the environment at issue. However, the adjudication of these cases is very much a case-by-case approach. For example, even though the above factors have precluded entitlement in some cases, the Tribunal has not refused entitlement where some of these same factors have been involved. For example, some panels focussing on MCS as a non-organic condition have emphasized that the existence of pre-existing conditions such as allergies or outside personal stressors will not eliminate the chances of entitlement. Even where those non-compensable factors have been significant contributors to the disabling condition, at least one panel has accepted that entitlement may still be granted as long as the workplace exposure was also a significant contributing factor (e.g., WSIAT Decision 453/04. Environmental sensitivity is not new, but the medical and legal investigations
of the condition continue to evolve and inform each other. We anticipate
increasing recognition of the condition in a variety of legal contexts,
including accommodation and disability benefit entitlement. Update on Workplace ViolenceThe latest news stemming from the Dupont Inquest concerns the divergent reactions to the recommendations of the Coroner’s jury – demonstrating, in our view, that the implementation process requires persistent and networked support from those working in the affected sectors. Over the next few issues of Update for Professionals, we will provide progress reports on the jury recommendations which concerned, specifically, issues around violence at work as these have a widespread impact on workplaces generally. Read the original jury recommendations here. Background Facts Lori Dupont was a Registered Nurse and member of the Ontario Nurses' Association (ONA) working at Hotel-Dieu Grace Hospital in Windsor, Ontario. In 2005 she was murdered by her former partner, Dr. Marc Daniel. Daniel, an anaesthesiologist at Hotel-Dieu Grace, then killed himself by lethal injection. Throughout the subsequent 10-week Inquest, the jury heard evidence about the history of Daniel's abusive conduct at work, the culture of physician dominance at the hospital, the systemic problem of "disruptive behaviour" on the part of physicians generally, and the physician governance structure under the Public Hospitals Act. On February 1, 2008, media reports stated that the Hotel-Dieu Grace Hospital Board of Directors refused to publicly endorse all 26 recommendations made by the Coroner’s jury. But the same newspaper clarified a few days later that the hospital was in fact committed to implementing 13 of the 26 recommendations – those which specifically apply to either Hotel-Dieu Grace or hospitals in Ontario generally. Meanwhile, over at Windsor Regional Hospital, the Board of Directors agreed at a public meeting on February 7, 2008 to send a letter to the Ontario Hospital Association endorsing the full set of recommendations. A combination of an influx of decisions ordering penalties for harassment and bullying at work, coupled with top-down, preventative legislative efforts and a more bottom-up impetus for internal change to corporate culture, seem to be making a difference at last in the struggle for safe workplaces. Legislative Efforts Infusing Health and Safety Law with the Language of Violence Prevention New Democrat MPP Andrea Horwath introduced Bill 29, Occupational Health and Safety Amendment Act (Harassment and Violence), 2007. It passed its first reading on December 13, 2007. This bill was first proposed back in 2005. It proposes a substantial update to the current health and safety regime, which lags behind more progressive laws targeting workplace harassment and violence in other provinces. We are pleased to see that harassment and violence are defined in a way to include psychological or non-physical acts, such as threatening or aggressive statements. The Act attempts to captures work-related harassment or violence as:
This definition is broad enough to capture abusive behaviour between co-workers occurring offsite. The list of protected parties is also fairly extensive. Bill 29 also includes a number of duties that are triggered when an employer has reason to believe that harassment or violence has occurred or is likely to occur, including specific duties to ensure that further harassment or violence is prevented or stopped; to, where necessary, take steps to remove the source of the harassment or violence from the workplace; and, to contact police when appropriate. Importantly, the Bill would also change the powers of the Ministry of Labour Inspectors, so that the Inspectors could investigate work refusals based on actual or threatened harassment or violence. According to its current internal policy, the Ministry of Labour will not respond to calls from employees refusing to work due to workplace violence in the same way as it would respond to refusals based on hazards posed by a malfunctioning machine or equipment; rather, they are treated as “complaints”. At the moment, the Act and its enforcing Ministry does not consider a person (a dangerous co-worker, client, or person on the premises) as a “physical condition of the workplace that is likely to endanger”. Work refusals are a step up from complaints, because the employer is required to investigate incidents immediately and in the presence of witnesses. The worker can continue to refuse the work if he or she has reasonable grounds for believing that the work continues to be unsafe, even after the employer’s investigation. An Inspector is mandated to come to the workplace to investigate the refusal. The Inspector would be empowered to order that the person who is the source of the violence or aggression be removed from the job, until the investigation is complete. At the end point of the investigation, the Inspector would be able to order the employer – a hospital or any other workplace in Ontario – to “make such arrangements” determined to be necessary to prevent future occurrences. Bill 29: http://www.ontla.on.ca/web/bills/bills_detail.do?locale=en&BillID=1938 Ontario’s Domestic Violence “Law” The latest in a series of recent efforts to prevent and at least curb the effects of violence between intimate partners, Bill 10, the Lori Dupont Act (Domestic Violence Protection), 2007, passed its first reading on December 5, 2007. It was timed to coincide with the International Day for the Elimination of Violence against Women (November 25). Progressive Conservative MPP John O’Toole worked with the Dupont family and others to try draft this Bill and have it repeal the Domestic Violence Protection Act, 2000. Bill 10 appears to be a near replica of the existing Domestic Violence Protection Act. Some may remember this legislation as the one championed by then-Attorney General of Ontario Jim Flaherty. At the time, however, it was heavily criticized by both police and women’s advocates. As a result, it was passed but never implemented. The bill re-introduces the “intervention order” and the “emergency intervention order”. Where the application for the peace bond failed Lori Dupont, the intervention order would be granted if the court is satisfied that domestic violence has occurred and that a person applying may be at risk of harm. An intervention order would be tailored to specific circumstances and could, amongst other features, restrain the named party from attending or entering any place regularly attended by the person making the application, including a place of employment. The named respondent could also be ordered to stay a certain specified distance from the applicant. An intervention order could also be granted on an emergency basis by the court, a designated judge or a justice. The key factor, in addition to the factors that the court would weigh in a regular order, is whether the person at risk would require the order on an urgent and temporary basis. Breaches of either order would results in charges under the Criminal Code. Bill 10 contemplates a future date when emergency intervention orders would be available 24 hours a day, and seven days a week throughout Ontario. The bill imposes stricter timelines throughout the entire process, so that these applications for protection do not get clogged in the system. Bill 10: http://www.ontla.on.ca/web/bills/bills_detail.do?locale=en&BillID=1927 Health Services Integration must Protect Bargaining Rights, OLRB rulesThe Ontario Nurses’ Association (ONA) has won on yet another front in the evolution and interpretation of the Public Sector Labour Relations Transition Act, 1997 (PSLRTA). In Ottawa Fertility Centre Inc. (January 10, 2008) the Ontario Labour Relations Board (OLRB) has ruled that the PSLRTA should be interpreted broadly to protect nurses’ and other health care workers’ bargaining rights during a restructuring in the health care sector. In reaching this decision, the OLRB held that:
Previously, the OLRB had ruled that there is “no doubt” that PSLRTA is intended to apply to restructuring in the health sector. In Central Care Corporation (July 31, 2007) the OLRB broadly interpreted the application of PSLRTA to restructuring in the health services sector in general, and to restructuring under the Local Health Services Integration Act (LHSIA) in particular. But the question remained; what happens when a service delivered in a hospital is privatized and moved to a location outside of the hospital? This is exactly what happened in Ottawa Fertility Centre Inc. The Ottawa Hospital Fertility Clinic was a division of the Ottawa Hospital. At the end of 2005, the doctors at the Hospital Clinic decided to leave because of a need for more space than the Ottawa Hospital was able to provide in a timely way. The doctors opened The Ottawa Fertility Centre Inc. in a new location. They offered the same mix of insured and uninsured reproductive medical services. The doctors used the exact same equipment they had been using at the Hospital Clinic. Most of the employees of the Ottawa Hospital’s Fertility Clinic were hired at the new clinic, albeit as “new employees.” Even the files, embryos, and sperm of the patients of the Hospital Clinic were transferred to the Fertility Centre with the Hospital’s assurance that it would “assist in a smooth transition.” Outwardly, the Fertility Centre appeared to be exactly the same as the Hospital Clinic. However, the Fertility Centre argued that it was an "independent health facility" and nothing was, in fact, “transferred.” They argued that the equipment, which was of no use to the Hospital once the doctors had left the Hospital Clinic, was sold to the Fertility Centre at fair market value; that none of the employees were transferred; and the patients' records, embryos and sperm, which were the property of the patients, followed them with their consent. The Ottawa Hospital emphasized that it did not "own" the work of the Hospital Clinic. It had no ability to force the doctors to stay, and when they withdrew their services, the Hospital Clinic had little choice but to close. Together, the Hospital and Fertility Centre argued that the PSLRTA was not designed to apply to the creation of new, private enterprises. Rather, they argued that the PSLRTA was designed to focus solely on hospitals and secondary health service support, such as laundry and food service functions. ONA argued that the Ottawa Hospital got out of the business of providing assisted reproductive treatments. The key elements that had provided that service at the Hospital Clinic were transferred to Fertility Centre, the very sort of rationalization of health care services the PSLRTA was designed to address. The appearance of the transaction on paper did not matter; what mattered was the appearance and actual delivery of the health services in question. The OLRB agreed with the ONA. Section 2 of the PSLRTA states that it applies to “employer[s] whose primary function is ... the provision of services within or to the health services sector.” The OLRB held that if the Ontario Legislature wanted the PSLRTA to apply to health service integrations only within hospitals then it could have been more specific and could have chosen much narrower language. Instead, the OLRB found that “the Legislature intended for the PSLRTA to have a broad application and it chose to focus on the consequences of changes in how service is delivered, rather than on the cause or on authors of the change.” Thus, health care employers cannot avoid their obligations to their workers through complex paper transactions between two or more willing parties working together. With this decision, unionized health care workers and their rights are now better protected from the ongoing changes and restructuring in Ontario’s health care system. Ontario College of Teachers revokes member’s teaching certificate after findings of professional misconductBy Muneeza Sheikh In a recent Ontario College of Teachers decision, the Discipline Committee of the Ontario College of Teachers revoked the teaching certificate of a member after finding that he was guilty of professional misconduct. The member was employed by the Peel District School Board from 1974 until 1997, at which time his employment was terminated by the Board. This case concerns the member’s conduct between 1979 to 1996, during which time he was publically involved in perpetuating beliefs and values that were contrary to the principles of multiculturalism and tolerance fundamental to his employment with the Board and as a member of the Ontario College of Teachers. For example, the member co-founded and was the research director for an organization that espoused intolerant and discriminatory beliefs and values. The member also spoke publically at various events where he attacked Canada’s policy of multiculturalism and championed in support of a racist ideology. The member received numerous warnings and reprimands that his conduct was clearly disrespectful to the principles of multiculturalism and ethno-cultural equity adopted by the School and the Board. The parties took differing positions on the relevance of the off-duty conduct. The member’s position was that his conduct was off-duty conduct and that he had the right to be involved in expressing his political or religious views on his own time outside the classroom. The College took the position that the off-duty conduct of the member was relevant because of the impact it had and was likely to have on the confidence of the public in the teaching system. The College also stated that teachers that were engaged in the type of conduct that the member was engaged in should not be allowed to continue in the teaching profession as such conduct went against various Board-developed policies. These policies speak to the multicultural nature of the community and allow students and other community members to feel that their diversity is valued by the Board. The College did not contest the fact that the member fulfilled his duties as a teacher. However, his public activities were inconsistent with the fundamental “core values” outlined in the Education Act. Although the Committee recognized that teachers can have a private life
that is not subject to special scrutiny, the school the member taught
at was very multicultural and was strongly impacted by the member’s
activities. The Committee made clear that the views that the member expressed
had a negative impact on the education system, created a poisoned school
environment and the actions were inconsistent with the values of the teaching
profession. In terms of penalty, the Committee ordered the Ontario College of Teachers
to revoke the member’s certificate in addition to ordering that
the findings and order of Committee be published in summary with the member’s
name in the official publication of the College, Professionally Speaking/Pour
parler profession. Privacy Law and a Union's Entitlement to InformationBy Sharan K. Basran & Elichai Shaffir Over the past few decades, Unions have encountered numerous arguments from employers rooted in privacy law. Most often, this has occurred following a Union's request for particular information, such as its members' names, phone numbers and addresses in order to discharge its duties as the exclusive bargaining agent under a collective agreement. A current example, albeit one with a twist, is seen in Arbitrator Swan's recently released decision in Ontario Power Generation Inc. and The Society of Energy Professionals, unreported, November 23, 2007 ("OPG"), which involved an interpretation of the Personal Information Protection and Electronic Documents Act (PIPEDA). At issue in this case was Article 10(d) of the Collective Agreement which stipulated that Management was to provide to the Society, on a regular basis, a list of all applicants to specified Society-represented positions, whether they were presently represented by the Society or not (and whether employed by the Company or not). In that sense, whereas previous cases have tended to focus on examples where the personal information to be disclosed to the union is that of members of the bargaining unit represented by the union, the present case differed in that its focus was on the Employer's unwillingness to provide relevant information for applicants to positions who were not members of any bargaining unit represented by the Society. In argument, the Society took the position that the information was necessary for the purpose of monitoring compliance with the Collective Agreement provisions dealing with the filling of vacancies for positions within the bargaining unit. The Company took the position that while it had no issue with providing the Society with the names of those Society-represented employees who applied for Society-represented positions, with respect to those persons not represented by the Society, it was unsure of what effect, if any, the federal PIPEDA would have on its ability to provide the names of applicants who were not represented by the Society. The Arbitrator, therefore, had to determine whether PIPEDA restricted the Company from complying with Article 10.3(d) of the Collective Agreement, i.e. whether PIPEDA restricted the Company from disclosing the name of non-Society applicants to Society-represented jobs. Before addressing the Arbitrator's decision in this matter, a quick word
on PIPEDA is in order. That legislation sets out rules and procedures
governing the collection, use and disclosure of personal information by
organizations in various contexts. It applies to personal information
of employees in the federally regulated private sector (airlines, banks,
telecommunications, broadcasting, interprovincial transportation, etc.),
and to every organization that collects, uses or discloses personal information
in the course of commercial activities within a province, whether or not
the organization is federally regulated (more on this below). In OPG,
there was no dispute between the parties that the federal privacy legislation
applied to the federally regulated nuclear component of the Company's
operations. Implications and Conclusion As previously noted, trade unions have long been recognized in labour law as being legally entitled to wide varieties of information relevant to collective bargaining and collective agreements, without the need for express individual consent from each employee. Such information is seen as being necessary for the union to discharge its legal duties in the administration of the collective agreement. That being said, the context of those decisions has centred around a union's request to certain information (such as wage and contact information) for their members. Arbitrator Swan's decision in OPG illustrates that the above-noted principle is not necessarily limited to information pertaining to bargaining unit members. In other words, a union is entitled to all relevant information that is not overly private and that the union requires in order to discharge its duties under a collective agreement and labour law. It should be noted though that in OPG an article within the Collective Agreement directly addressed the Union's entitlement to this information subject to PIPEDA. A final and brief note about PIPEDA. As explained above there was no dispute between the parties in OPG that PIPEDA was applicable legislation in their matter. However, in most instances involving a union not involved in the federal private sector, PIPEDA would likely not be applicable legislation. Even though PIPEDA's reach extends beyond the federal private sector and is applicable in Ontario, it applies only to the collection, use and disclosure of personal information by organizations in the course of commercial activity. Commercial activity is defined in the Act to mean: "any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists". None of those activities aptly describe the normal course of business between a union and employer. As one arbitrator has noted: ""commercial activity" is not so wide-ranging that it encompasses the employment relationship itself and in particular the collection, use and disclosure of personal information within the organization." Regardless of whether or not PIPEDA is applicable legislation in a particular
matter, it should be recognized that analogous privacy interests might
still be asserted by employers so as not to run afoul of privacy laws.
Nevertheless, trade unions should continue to request from employers all
relevant and necessary information in order to discharge its duties in
the administration of the collective agreement.
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