National Grievance File

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.

Canada Post Corporation (CPC) is in violation of the collective agreement and of the Letter Carrier Route Measurement System (LCRMS) as a result of its refusal to include in the letter carriers’ workload actual tasks performed in loading and unloading vehicles effective as of the date of implementation of the new routes.

The Corporation refuses to pay retroactively from the date of implementation the letter carriers who performed these tasks.

Employees who have successfully completed the Apprenticeship Training Program are to be paid at the maximum MAM-11 Apprentice hourly rate of pay until they obtain a MAM-11 position and are to remain members of Group 3. The Employer has violated the Collective Agreement by unilaterally reclassifying these employees upon their successful completion of the Apprenticeship Program, not paying them at the appropriate wage rates, returning them to the classification they previously held prior to their apprenticeship and wrongfully deleting positions from the bargaining unit.

In doing so Canada Post has violated Articles 13, 40, 53, Appendix “A”, Appendix “T” and all other related Articles as well as the past practice.

Additionally, Canada Post is estopped from taking such actions in light of the prior representations to the affected employees and the Union that employees who successfully complete the Apprenticeship Program would remain members of Group 3. 

Commercial Pickups

In restructuring the routes of motorized letter carriers who perform commercial pickup duties, the Corporation is violating the provisions of the collective agreement.

Specifically, contrary to the provisions of the collective agreement, and more specifically those of Chapters 7 and 16 of the LCRMS and Chapter 5 of the MSCWSS, the Corporation is failing, in the case of certain routes, to combine scheduled commercial pickups and on-demand commercial pickups within a daily delivery window.

Further, contrary to the provisions of the collective agreement, and more specifically those of Chapters 7 and 16 of the LCRMS and Chapter 5 of the MSCWSS, the Corporation is assigning on-demand commercial pickups to certain routes without assigning the scheduled commercial pick-ups to those same routes.

In addition, contrary to the provisions of the collective agreement and, more specifically, to those of Chapters 7 and 16 of the LCRMS and Chapter 5 of the MSCWSS, the Corporation is not evaluating the service time allowance for on-demand commercial pickups using data from a 12-month volume base (excluding July, August and December) obtained from the “PICK” system, but is only using data from the two-week sampling.

Further, contrary to the provisions of the collective agreement and, more specifically, to those of Chapters 7 and 16 of the LCRMS and Chapter 5 of the MSCWSS, the Corporation, in the case of some routes, is determining time values for on-demand commercial pickups based on pickup time data for the entire installation, rather than data from the route.

Finally, contrary to the provisions of the collective agreement and, more specifically, to those of Chapters 7 and 16 of the LCRMS and Chapter 5 of the MSCWSS, the Corporation, in the case of certain routes, is not allocating unscheduled working time.