2017 CIRB Single Employer decision

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2017 CIRB Single Employer decision

#1 Post by NewCommercialPilot » Sat Feb 03, 2018 9:56 am

ALPA has announced they will seek a common employer designation from the CIRB regarding WJ and S, and concluded a recent message with the following statement: "This raises the question of who the true employer of Swoop really is."

I raise the above statement to direct your attention to the fact that the case law is well established regarding a common employer ruling from the CIRB. There are no secrets. Both WJ (and hence S) and ALPA and their respective legal teams are well aware of the hurdles involved. That established, it is not enough, as the MEC chair intimates, to prove who the "true employer" of Swoop pilots is. You can, of course, ignore the following post. If you like supporting lost causes and prefer to spend your time saying "wowzy wowzy woo woo" then by all means stick your head in the sand, your fingers in your ears, and your career aspirations wherever one puts such things. But you cannot ignore reality forever.

And if I am correct that a common employer challenge will be unsuccessful, what is ALPA's back up plan? What is your back up plan?

As always, there is an alternative to futility, and that is the decertification of ALPA. Stay tuned for more information in the coming months. Activity is occuring far from public view, but more than that I cannot say.

The following decision will show you why a common employer application will be unsuccesful. I do sympathize with ALPA. For political reasons they do have to show that they are attempting to remedy the situation vis-à-vis WJ and S.

From the CIRB's decision, here are some facts that share a nexus with the WJ and S situation. I have highlighted in red what I think are the relevant talking points but I encourage you to read the decision in its entirety to understand what is at stake, and call BS the next time you smell/see/hear/step in it. I suggest one could view Bell Canada as WJ and BEV (Bell ExpressVue) as S.

p.s. If anyone is triggered by the color red, please let me know and I will change the font colour.

I know some of you will want to offer me some money for doing all this work but it really isn't necessary. I consider the pursuit of knowledge truth a sufficient remuneration for my time.

Your Humble WingNut

Johannes Schwalbe

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[4] Bell Canada and BEV are companies under federal jurisdiction that carry on their business in the sector.

[47] Bell Canada and BEV do not challenge the fact that they are associated or related businesses and that they have common control of their businesses. Therefore, for the purposes of the present application, it is not necessary to conduct a detailed analysis to determine whether the objective criteria necessary for a single employer declaration are present. The only question regarding the application for a single employer declaration is whether the Board must exercise its discretion to grant this application.

[49] Under section 35 of the Code, the Board has the discretion to declare that two companies are a single employer. This section states the following:

35 (1) Where, on application by an affected trade union or employer, associated or related federal works, undertakings or businesses are, in the opinion of the Board, operated by two or more employers having common control or direction, the Board may, by order, declare that for all purposes of this Part the employers and the federal works, undertakings and businesses operated by them that are specified in the order are, respectively, a single employer and a single federal work, undertaking or business. Before making such a declaration, the Board must give the affected employers and trade unions the opportunity to make representations.

(2) The Board may, in making a declaration under subsection (1), determine whether the employees affected constitute one or more units appropriate for collective bargaining.


[50] However, the Board must be satisfied that five criteria have been met in order to make a single employer declaration. These conditions are set out as follows in Murray Hill Limousine Service Ltd. et al. (1988), 74 di 127 (CLRB no. 699): 2017 CIRB 852 (CanLII)

1. two or more enterprises, i.e., businesses,
2. under federal jurisdiction,
3. associated or related,
4. of which at least two, but not necessarily all, are employers…
5. the said businesses being operated by employers having common direction or control over them.


[51] As stated earlier, the employer acknowledges that the five criteria are present in this case. In light of the evidence provided by the parties, the Board is satisfied that Bell Canada and BEV are federal employers and that they constitute two or more associated or related businesses that operate under common control and direction. Consequently, the Board acknowledges that the five criteria have been met in this case, as agreed by the parties.

[52] That said, it is not sufficient for a party to demonstrate that the five criteria are present. It must also demonstrate to the Board that the declaration is justified for labour relations purposes. The underlying principles of this purpose were described as follows in S.V.N. Enterprises Ltd., doing business as S & K Trucking, 2003 CIRB 219:

[54] The Board will only grant a declaration under section 35 if the declaration will serve a labour relations purpose. The Board’s decision in Air Canada et al. (1989), 79 di 98; 7
CLRBR (2d) 252; and 90 CLLC 16,008 (CLRB no. 771) provides useful guidance when considering whether a labour relations purpose would be served by a single employer declaration:
The purpose of section 35 has always guided the exercise of the Board’s discretion in these matters. That purpose is aimed at preventing the undermining or evading of bargaining rights through corporate or business arrangements (see British Columbia Telephone Company and Canadian Telephones and Supplies Ltd., supra; and Beam Transport (1980) Ltd. and Brentwood Transport Ltd. (1988), 74 di 46 (CLRB no. 689)). Section 35 is not aimed at enhancing existing bargaining rights (British Columbia Telephone Company and Canadian Telephones and Supplies Ltd., supra). Its purpose is remedial in nature. It is designed to ensure that employers only distinct in appearance do not succeed in circumventing their obligations under the Code by resorting to corporate restructuring or other types of business arrangements: “... It was, after all, to prevent a management from escaping collective bargaining obligations owed under one corporate entity by transferring work to another controlled entity that Parliament put section 133 [now section 35] into the statute. ... (Bradley Services Ltd. et al. (1986), 65 di 111; 13 CLRBR (NS) 256; and 86 CLLC 16,036 (CLRB no. 570), pages 126; 272; and 14,432)”

Section 35 is not aimed at exempting a bargaining agent from having to organize an otherwise genuinely distinct group of employees. In some cases, the issuance of a declaration by the Board may have that effect, but that is not its purpose. When the Board addresses the issue of discretion, the question ceases to be whether common control exists; it becomes whether common control contributes to the erosion of bargaining rights. (pages 118–119; 271; and 143,098; emphasis added)


[53] Thus, the purpose of section 35 is to prevent two or more businesses from concealing the true nature of the relationship between the employer and its employees. At the outset, the analysis of section 35 relied on its remedial nature, which resulted in an analysis that sought to prevent the erosion of its representation rights or to prevent an employer from disregarding its obligations under the Code by transferring its activities from one company to another nonunionized company (Télébec ltée, 2004 CIRB 300, paragraph 65). Thus, the union correctly argued that the Board expanded the scope of this provision by recognizing other labour relations purposes that could warrant a single employer declaration. In this regard, the Board stated the following, in Certen Inc., 2003 CIRB 223:

[126] The single employer declaration under the Code was originally considered as having a remedial purpose to prevent the erosion of the representation rights of a bargaining agent, or to prevent an employer from disregarding its obligations under the Code by transferring some of its activities to non-unionized employees, or by other means. The purpose of section 35 is not less valid today, but has been expanded to enable remedial action in situations where the five criteria are met, and the structure of bargaining units has become obsolete, bargaining units are no longer appropriate, or the configuration of bargaining units has given rise to inter-union jurisdictional conflicts. Irrespective of the peculiar circumstances of each case, the consistent purpose the Board has sought to achieve in deciding whether to issue a single employer declaration is the maintenance or enhancement of sound labour relations. More recently, the Board made the following comments in Air Canada et al., [2000] CIRB no. 78; and 2000 CLLC 220-059:

[34] In consideration of the recommendations of the Sims Task Force, the precise wording of the statute which was adopted and the Board’s experience in labour relations, the criteria actually expressed in the statute or implied in its context should be viewed as the defining or limiting criteria for a declaration. A careful consideration of section 35 and section 18.1 in their present statutory context leads the Board to conclude that a broader basis for the exercise of its discretion is required. The Board considers that rationalization of bargaining units which will promote sound labour relations and which will prevent disruption caused by inter-unit conflicts is an appropriate labour relations purpose to make a section 35 declaration. In this case, a single employer declaration is appropriate in order to rationalize the CUPE CAIL and CUPE ACC bargaining units. (pages 18; and 14,508; emphasis added)

[54] By applying this broader scope of section 35, the Board recognized, in certain circumstances, that an appropriate purpose was the rationalization of unit structures that promote sound labour relations. That said, each case must reflect a need to promote the objectives of the Code, and although other objectives are possible, the main purpose of section 35 remains preventing the erosion or fragmentation of bargaining rights (TELUS Communications Inc., 2004 CIRB 278; and City West Cable & Telephone Corp., 2011 CIRB 590).

[55] There is no doubt that the Trio initiative has led to a wider integration of customer services offered by Bell Canada and BEV. It is also not disputed that the customer service employees and technical support employees at BEV and at Bell Canada essentially perform similar duties that are interchangeable between the two companies. However, the question that arises in the present case is whether the circumstances warrant the Board’s exercise of its discretion to promote an objective of the Code.

[57] It should be noted that in its single employer application, the union alleged that the collective rights of the bargaining unit for Bell Canada’s clerical employees had been eroded, because there were job losses caused by the transfer of duties and positions to BEV, a nonunionized company. When the Board is required to assess the presence or absence of erosion, it must examine the layoffs or alleged changes to working conditions in their overall context (Télébec ltée, supra). Evidence of layoffs or erosion of working conditions for the members of the applicant union is not sufficient in itself to warrant a declaration, because these changes can very well be independent of structural or organizational transformations brought about by restructuring. It is important to note that the objective is to assess the economic situation in its overall context or the potential impact on the bargaining nit that the union seeks to protect through its single employer application.

[79] Nonetheless, even though the BEV employees do not have the same working conditions as Bell Canada employees, this cannot in itself constitute a valid reason for issuing a single employer declaration. The BEV employees recently decided to be represented by the union and to begin collective bargaining with the employer. The union will therefore have to negotiate the working conditions with the employer. The purpose of section 35 of the Code is not to improve a union’s situation or to have rights granted to it that it does not already have.
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Re: 2017 CIRB Single Employer decision

#2 Post by digits_ » Sat Feb 03, 2018 10:05 am

Don't [54] and [79] contradict each other?

The purpose is to not erode bargaining rights, but at the same time it's not its purpose to give the union more bargaining power? Then what is its purpose?
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Re: 2017 CIRB Single Employer decision

#3 Post by Snagmaster E » Sat Feb 03, 2018 10:05 am

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8CE4A3CC-FD3A-439E-8997-AE1E08EC6A79.jpeg (53.77 KiB) Viewed 3488 times
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Re: 2017 CIRB Single Employer decision

#4 Post by rudder » Sat Feb 03, 2018 10:47 am

“The BEV employees recently decided to be represented by the union and to begin collective bargaining with the employer. The union will therefore have to negotiate the working conditions with the employer. The purpose of section 35 of the Code is not to improve a union’s situation or to have rights granted to it that it does not already have.”

This is the fundamental difference between the case cited and WJ/SWOOP.

ALPA will quite properly argue that SWOOP is an alter ego created for the purpose of evading the obligation to bargain in respect to the ULCC initiative. The SWOOP employees are all ‘at will’ employees and therefore have no such bargaining rights (yet).

Everybody has to take steps to protect their position but it is still in the parties interest to settle the matter now rather than through litigation. However, it takes two to tango.
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Re: 2017 CIRB Single Employer decision

#5 Post by DropTanks » Sat Feb 03, 2018 6:59 pm

. Edited
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Re: 2017 CIRB Single Employer decision

#6 Post by NewCommercialPilot » Thu Feb 08, 2018 10:26 am

hey
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Re: 2017 CIRB Single Employer decision

#7 Post by skybaron » Thu Feb 08, 2018 11:16 am

Isn’t common employer status also being sought for Encore and WestJet as well?
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Re: 2017 CIRB Single Employer decision

#8 Post by Longtimer » Fri Feb 09, 2018 12:20 pm

ALPA Takes Legal Action Against WestJet and WestJet Encore

https://www.newswire.ca/news-releases/a ... 68123.html
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Re: 2017 CIRB Single Employer decision

#9 Post by Dizzy D » Fri Feb 09, 2018 1:53 pm

NewCommercialPilot wrote:
Sat Feb 03, 2018 9:56 am
ALPA has announced they will seek a common employer designation from the CIRB regarding WJ and S, and concluded a recent message with the following statement: "This raises the question of who the true employer of Swoop really is."

I raise the above statement to direct your attention to the fact that the case law is well established regarding a common employer ruling from the CIRB. There are no secrets. Both WJ (and hence S) and ALPA and their respective legal teams are well aware of the hurdles involved. That established, it is not enough, as the MEC chair intimates, to prove who the "true employer" of Swoop pilots is. You can, of course, ignore the following post. If you like supporting lost causes and prefer to spend your time saying "wowzy wowzy woo woo" then by all means stick your head in the sand, your fingers in your ears, and your career aspirations wherever one puts such things. But you cannot ignore reality forever.

And if I am correct that a common employer challenge will be unsuccessful, what is ALPA's back up plan? What is your back up plan?

As always, there is an alternative to futility, and that is the decertification of ALPA. Stay tuned for more information in the coming months. Activity is occuring far from public view, but more than that I cannot say.

The following decision will show you why a common employer application will be unsuccesful. I do sympathize with ALPA. For political reasons they do have to show that they are attempting to remedy the situation vis-à-vis WJ and S.

From the CIRB's decision, here are some facts that share a nexus with the WJ and S situation. I have highlighted in red what I think are the relevant talking points but I encourage you to read the decision in its entirety to understand what is at stake, and call BS the next time you smell/see/hear/step in it. I suggest one could view Bell Canada as WJ and BEV (Bell ExpressVue) as S.

p.s. If anyone is triggered by the color red, please let me know and I will change the font colour.

I know some of you will want to offer me some money for doing all this work but it really isn't necessary. I consider the pursuit of knowledge truth a sufficient remuneration for my time.

Your Humble WingNut

Johannes Schwalbe

*********************************************************************************************************************************************************************************************************************************

[4] Bell Canada and BEV are companies under federal jurisdiction that carry on their business in the sector.

[47] Bell Canada and BEV do not challenge the fact that they are associated or related businesses and that they have common control of their businesses. Therefore, for the purposes of the present application, it is not necessary to conduct a detailed analysis to determine whether the objective criteria necessary for a single employer declaration are present. The only question regarding the application for a single employer declaration is whether the Board must exercise its discretion to grant this application.

[49] Under section 35 of the Code, the Board has the discretion to declare that two companies are a single employer. This section states the following:

35 (1) Where, on application by an affected trade union or employer, associated or related federal works, undertakings or businesses are, in the opinion of the Board, operated by two or more employers having common control or direction, the Board may, by order, declare that for all purposes of this Part the employers and the federal works, undertakings and businesses operated by them that are specified in the order are, respectively, a single employer and a single federal work, undertaking or business. Before making such a declaration, the Board must give the affected employers and trade unions the opportunity to make representations.

(2) The Board may, in making a declaration under subsection (1), determine whether the employees affected constitute one or more units appropriate for collective bargaining.


[50] However, the Board must be satisfied that five criteria have been met in order to make a single employer declaration. These conditions are set out as follows in Murray Hill Limousine Service Ltd. et al. (1988), 74 di 127 (CLRB no. 699): 2017 CIRB 852 (CanLII)

1. two or more enterprises, i.e., businesses,
2. under federal jurisdiction,
3. associated or related,
4. of which at least two, but not necessarily all, are employers…
5. the said businesses being operated by employers having common direction or control over them.


[51] As stated earlier, the employer acknowledges that the five criteria are present in this case. In light of the evidence provided by the parties, the Board is satisfied that Bell Canada and BEV are federal employers and that they constitute two or more associated or related businesses that operate under common control and direction. Consequently, the Board acknowledges that the five criteria have been met in this case, as agreed by the parties.

[52] That said, it is not sufficient for a party to demonstrate that the five criteria are present. It must also demonstrate to the Board that the declaration is justified for labour relations purposes. The underlying principles of this purpose were described as follows in S.V.N. Enterprises Ltd., doing business as S & K Trucking, 2003 CIRB 219:

[54] The Board will only grant a declaration under section 35 if the declaration will serve a labour relations purpose. The Board’s decision in Air Canada et al. (1989), 79 di 98; 7
CLRBR (2d) 252; and 90 CLLC 16,008 (CLRB no. 771) provides useful guidance when considering whether a labour relations purpose would be served by a single employer declaration:
The purpose of section 35 has always guided the exercise of the Board’s discretion in these matters. That purpose is aimed at preventing the undermining or evading of bargaining rights through corporate or business arrangements (see British Columbia Telephone Company and Canadian Telephones and Supplies Ltd., supra; and Beam Transport (1980) Ltd. and Brentwood Transport Ltd. (1988), 74 di 46 (CLRB no. 689)). Section 35 is not aimed at enhancing existing bargaining rights (British Columbia Telephone Company and Canadian Telephones and Supplies Ltd., supra). Its purpose is remedial in nature. It is designed to ensure that employers only distinct in appearance do not succeed in circumventing their obligations under the Code by resorting to corporate restructuring or other types of business arrangements: “... It was, after all, to prevent a management from escaping collective bargaining obligations owed under one corporate entity by transferring work to another controlled entity that Parliament put section 133 [now section 35] into the statute. ... (Bradley Services Ltd. et al. (1986), 65 di 111; 13 CLRBR (NS) 256; and 86 CLLC 16,036 (CLRB no. 570), pages 126; 272; and 14,432)”

Section 35 is not aimed at exempting a bargaining agent from having to organize an otherwise genuinely distinct group of employees. In some cases, the issuance of a declaration by the Board may have that effect, but that is not its purpose. When the Board addresses the issue of discretion, the question ceases to be whether common control exists; it becomes whether common control contributes to the erosion of bargaining rights. (pages 118–119; 271; and 143,098; emphasis added)


[53] Thus, the purpose of section 35 is to prevent two or more businesses from concealing the true nature of the relationship between the employer and its employees. At the outset, the analysis of section 35 relied on its remedial nature, which resulted in an analysis that sought to prevent the erosion of its representation rights or to prevent an employer from disregarding its obligations under the Code by transferring its activities from one company to another nonunionized company (Télébec ltée, 2004 CIRB 300, paragraph 65). Thus, the union correctly argued that the Board expanded the scope of this provision by recognizing other labour relations purposes that could warrant a single employer declaration. In this regard, the Board stated the following, in Certen Inc., 2003 CIRB 223:

[126] The single employer declaration under the Code was originally considered as having a remedial purpose to prevent the erosion of the representation rights of a bargaining agent, or to prevent an employer from disregarding its obligations under the Code by transferring some of its activities to non-unionized employees, or by other means. The purpose of section 35 is not less valid today, but has been expanded to enable remedial action in situations where the five criteria are met, and the structure of bargaining units has become obsolete, bargaining units are no longer appropriate, or the configuration of bargaining units has given rise to inter-union jurisdictional conflicts. Irrespective of the peculiar circumstances of each case, the consistent purpose the Board has sought to achieve in deciding whether to issue a single employer declaration is the maintenance or enhancement of sound labour relations. More recently, the Board made the following comments in Air Canada et al., [2000] CIRB no. 78; and 2000 CLLC 220-059:

[34] In consideration of the recommendations of the Sims Task Force, the precise wording of the statute which was adopted and the Board’s experience in labour relations, the criteria actually expressed in the statute or implied in its context should be viewed as the defining or limiting criteria for a declaration. A careful consideration of section 35 and section 18.1 in their present statutory context leads the Board to conclude that a broader basis for the exercise of its discretion is required. The Board considers that rationalization of bargaining units which will promote sound labour relations and which will prevent disruption caused by inter-unit conflicts is an appropriate labour relations purpose to make a section 35 declaration. In this case, a single employer declaration is appropriate in order to rationalize the CUPE CAIL and CUPE ACC bargaining units. (pages 18; and 14,508; emphasis added)

[54] By applying this broader scope of section 35, the Board recognized, in certain circumstances, that an appropriate purpose was the rationalization of unit structures that promote sound labour relations. That said, each case must reflect a need to promote the objectives of the Code, and although other objectives are possible, the main purpose of section 35 remains preventing the erosion or fragmentation of bargaining rights (TELUS Communications Inc., 2004 CIRB 278; and City West Cable & Telephone Corp., 2011 CIRB 590).

[55] There is no doubt that the Trio initiative has led to a wider integration of customer services offered by Bell Canada and BEV. It is also not disputed that the customer service employees and technical support employees at BEV and at Bell Canada essentially perform similar duties that are interchangeable between the two companies. However, the question that arises in the present case is whether the circumstances warrant the Board’s exercise of its discretion to promote an objective of the Code.

[57] It should be noted that in its single employer application, the union alleged that the collective rights of the bargaining unit for Bell Canada’s clerical employees had been eroded, because there were job losses caused by the transfer of duties and positions to BEV, a nonunionized company. When the Board is required to assess the presence or absence of erosion, it must examine the layoffs or alleged changes to working conditions in their overall context (Télébec ltée, supra). Evidence of layoffs or erosion of working conditions for the members of the applicant union is not sufficient in itself to warrant a declaration, because these changes can very well be independent of structural or organizational transformations brought about by restructuring. It is important to note that the objective is to assess the economic situation in its overall context or the potential impact on the bargaining nit that the union seeks to protect through its single employer application.

[79] Nonetheless, even though the BEV employees do not have the same working conditions as Bell Canada employees, this cannot in itself constitute a valid reason for issuing a single employer declaration. The BEV employees recently decided to be represented by the union and to begin collective bargaining with the employer. The union will therefore have to negotiate the working conditions with the employer. The purpose of section 35 of the Code is not to improve a union’s situation or to have rights granted to it that it does not already have.
It’s my understanding that case law doesn’t apply when it comes to common employer status. Every request goes in front of a tribunal and is looked at with “fresh” eyes and ears. Please correct me if I’m wrong, I’m definitely not a lawyer.
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Re: 2017 CIRB Single Employer decision

#10 Post by JBI » Fri Feb 09, 2018 2:32 pm

NCP: Pilots with no legal training practice law just as well as lawyers with no flight training fly airplanes. (bede excluded :lol:)
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Re: 2017 CIRB Single Employer decision

#11 Post by flyinhigh » Fri Feb 09, 2018 3:30 pm

JBI wrote:
Fri Feb 09, 2018 2:32 pm
NCP: Pilots with no legal training practice law just as well as lawyers with no flight training fly airplanes. (bede excluded :lol:)

LOLOL, that made me laugh hard.
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Re: 2017 CIRB Single Employer decision

#12 Post by plhought » Sat Feb 10, 2018 9:32 am

NewCommercialPilot wrote:
Sat Feb 03, 2018 9:56 am
I know some of you will want to offer me some money for doing all this work but it really isn't necessary. I consider the pursuit of knowledge truth a sufficient remuneration for my time.
It's always funny to see someone discover CanLii.

Oooo you're so special. You've learned how to use an online search tool. You've done something first year poli-sci students learn in their first week inbetween basket-weaving electives and trips to the liquor store.

Even if you've had the most cursory academic exposure, you'd at least know how to cite these cases correctly and provide links to the judgement. Not pretend to others you are using those flight-benefits (or wing-suit?) to high-tail to some deep underground library in Ottawa - flipping through thousands of binders of fiche.

It's pretty evident you aren't even using the tool very well. You're random thread on CanJet 'Hugs' and others make it pretty evident. Throwing in some labour buzzwords and airline names into search box doesn't qualify as legal research.

Do yourself a favour and do what real legal nerds do for fun on CanLii - Type in "admiralty law" or "freeman on the land". Read those judgements. Much more entertaining.
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