Appendix P

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Grievance File Number: 
N00-12-00023
Collective Agreement: 
Urban Postal Operations (2012)
Relevant Articles: 
Appendix “P” and clauses 39.02, 39.03 and 39.06
Date referred: 
Thursday March 31 2016
Status: 
Referred
Arbitrator: 
Burkett

Statement

The Canadian Union of Postal Workers submits that the Corporation has failed to abide by Appendix “P” of the collective agreement by not maintaining the ratio of regular full-time hours in violation of paragraph 1 (b) of this Appendix.

Further, the Corporation failed to create and maintain the required number of regular full-time positions, as set out in paragraph 2 (d), to achieve, and then maintain, the aforementioned ratio.

The CUPW submits that this was a deliberate and calculated violation of the collective agreement by the employer intended to thwart the intent and spirit of Appendix “P” and clauses 39.02, 39.03 and 39.06 of the collective agreement.

Corrective Steps Requested

Should the parties fail to reach an agreement, the CUPW will ask the arbitrator to instruct the Corporation to meet without delay its obligation to establish and maintain the ratio of regular full-time hours at 78%.

To achieve this we will ask the arbitrator to further instruct the Corporation to stop eliminating full-time positions for as long as the ratio is not met and to immediately create the number of full time positions required to ensure the ratio is met, and then maintained throughout the year.

The CUPW will also ask the arbitrator to order that the Corporation fully compensate and make whole all employees deprived of wages and benefits by the aforementioned violations of the collective agreement.

We will also request that the arbitrator award appropriate punitive damages for the deliberate and calculated staffing actions of the employer to violate the collective agreement and, in doing so, thwart the intent and spirit of Appendix P and clauses 39.02, 39.03 and 39.06 of the collective agreement.

The CUPW also reserves the right to amend the grievance and request any other corrective action that may be appropriate under the circumstances.