Case Number: TUR1/457(2005)
18 October 2005
CENTRAL
ARBITRATION COMMITTEE
TRADE
UNION
AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992
SCHEDULE
A1 - COLLECTIVE BARGAINING: RECOGNITION
DECISION ON WHETHER THE
APPLICATION IS VALID FOLLOWING
THE
DETERMINATION OF THE BARGAINING UNIT
The Parties:
ATL
and
Wycliffe College
Incorporated
Introduction
1. The Association of Teachers & Lecturers (ATL), (the
Union) submitted an application dated 10 June 2005, to the CAC that it should
be recognised for collective bargaining by Wycliffe College Incorporated (the
Employer) for a bargaining unit consisting of “all teaching staff” at Wycliffe
College comprising The Senior School, The Preparatory School and Pre-Prep
Department in Gloucestershire.
2. In
accordance with section 263 of the Trade Union and Labour Relations
(Consolidation) Act 1992 (the Act), the CAC Chairman established a Panel to
deal with the case. The Panel consisted
of Professor John Purcell, Chairman of the Panel, and, as Members, Mr George
Getlevog and Mr Bob Purkiss. The Case
Manager appointed to support the Panel was Miss Maverlie Tavares and, for the
purposes of this decision, Nigel Cookson.
3. In a decision promulgated 4 July 2005 the Panel accepted the
Union’s application and, as no agreement had been reached on the bargaining
unit, subsequently invited both Parties to supply the Panel with, and exchange,
written submissions relating to the question of determining an appropriate
bargaining unit. A hearing was held on 16 September 2005. The Panel,
after careful consideration of the Parties’ oral and written submissions,
decided that the appropriate bargaining unit should be all teaching staff at
Wycliffe College including supply teachers on zero hours contracts, science
technicians with classroom responsibilities and teaching assistants, comprising
The Senior School, The Preparatory School and Pre-Prep Department in
Gloucestershire, but excluding the Gap Students and Heads of the College and
the Preparatory School. The determined
bargaining unit differed from the bargaining unit proposed by the Union in its application by the
inclusion of Supply Teachers, Teaching Assistants and Science Technicians.
4. As the
determined bargaining unit differed from that proposed by the Union, the Panel is
required by paragraph 20 of Schedule A1
to the Trade Union and Labour Relations (Consolidation) Act 1992 (the Schedule)
to determine whether the Union’s application is valid or invalid within
the terms of paragraphs 43 to 50 of the Schedule.
Case
Manager’s membership and support check
5. To
assist the determination of the two admissibility tests under paragraph 45(a)
and 45(b) of Schedule A1, namely whether 10% of the workers in the determined
bargaining unit are members of the Union and whether a majority of the workers
in this bargaining unit are likely to favour recognition of the Union, the
Panel instructed the Case Manager to carry out checks on the level of union
membership within the determined bargaining unit and the number of workers who
had indicated support for recognition of the Union for the purposes of
collective bargaining.
6. The
Parties agreed that the Employer would supply to the Case Manager a list of the
names of workers within the determined bargaining unit and that the Union would
supply to the Case Manager a list of its union members within that unit and a petition
in support of the Union to
enable a comparison to be undertaken. The
Employer provided a list of 162 workers, which was received by the CAC on 29 September 2005. On 30 September 2005 the Union lodged
with the CAC a list of 43 union members in the determined
bargaining unit and a petition with 108 signatures supporting recognition of
the Union. It was explicitly agreed with both Parties
that, to preserve confidentiality, the respective lists and petition would not
be copied to the other party and that agreement was confirmed in a letter from
the Case Manager to both Parties dated 26 September 2005. The Panel is satisfied that the checks were
conducted properly and impartially and in accordance with the agreement reached
with the Parties.
7. The
result of the membership and support check showed that there were 162 workers
in the bargaining unit of whom 38 were members of the Union,
giving a membership level of 23.46%. The
Union’s petition of 108 signatures ran
to 10 A4 sheets with each carrying the following proposal:
“We
the undersigned support the Recognition of ATL in their application for the
establishment of Collective Bargaining for the Teaching Staff at Wycliffe College”.
The check of the petition
showed that it had been signed by 75 of the 162 workers, which is 46.3% of the
bargaining unit. Of those 75
signatories, 22 were members of the Union (13.58%) and 53 were non-members (32.71%). No additional checks were carried out to
verify the information supplied by the Parties.
A report of the result of the check of the membership level and support
for recognition was circulated to the Panel and the Parties on 30 September 2005. Both Parties
were then invited to supply comments relating to the validity tests and the
membership check report.
Union’s comments
8. The Union, in a letter dated 30 September 2005 that
accompanied its membership list and petition and so prior to the production of
the Case Manager’s report, commented that it was disappointed that the Panel
considered it necessary to re-apply the validity tests. In its application the Union had defined the bargaining
unit as “all teaching staff” at the College and it suggested that the bargaining
unit as determined by the Panel was not materially different in that it
comprised “all teaching staff at Wycliffe College”. The Union submitted that the Panel had merely refined which
groups of staff were within the stated bargaining unit. Nevertheless the Union was confident that the
current level of membership and the extent of support within the bargaining
unit satisfied the requirements of the Schedule. Firstly, it submitted, all of its informal
soundings over many months had suggested a strong majority of teaching staff
supported the application. It referred
to the petition it had collected in March 2005 when it had originally thought
that the bargaining unit comprised 125 workers and the fact that 63% of these
workers had showed support for the Union by signing the petition. Secondly, the Union referred the Panel to its
own conclusion in paragraph 13 of the acceptance decision wherein it had
concluded that, even based on the Employer’s figure of 185 workers, it was more
likely than not that a majority of the workers would be likely to favour
recognition of the Union. The Union submitted that there were
no significant factors that should lead to the Panel to arrive at a different
conclusion now. Thirdly, the Union referred to the petition it
had conducted as evidence towards the test under paragraph 45(b). It explained that it had gathered 108
signatures in a 4 day period by informally approaching staff in the school
common rooms. It observed that many of
the teaching staff were not present during this period and therefore could not
be asked for their views and suggested that the actual number of teaching staff
who would support recognition of the Union would be substantially higher than this figure.
9. The Union understood that the Employer had objected to this
method of measuring support and described it as “unreliable”. The Union acknowledged that it was, given the time constraint,
essentially informal but that it had initiated the petition specifically in
response to a suggestion by the Case Manager as being a tangible method of
showing support which had apparently been utilised, and considered relevant, in
other recognition cases.
10. The Union, when invited to comment on the result of the check
of membership and support in the determined bargaining unit, informed the Case
Manager that it had nothing further to add to its comments set out in its
letter of 30 September 2005.
Employer’s
comments
11. In a letter dated 4 October
2005
the Employer reiterated points it had made in an earlier email to the Case
Manager. It set out its complaints as
follows:
·
“The petition was
of “All Staff” which disregarded the Panel’s changes to the composition of the
bargaining unit;
·
The petition was
conducted without any attempt to explain its purpose;
·
The wording of
the petition was an inaccurate description of the Union’s
application; and
·
Names in support
of the petition were “collected” in a very public way.”
These points had been
previously raised in an email dated 30 September
2005
to the Case Manager. In this email the
Employer also expressed concern on behalf of the union members as to the Union’s mandate for the action it
was taking, the Employer having been informed that the full membership within
the bargaining unit had not met for a number of years.
12. In its letter of 4 October 2005 the Employer acknowledged that
it was clear that the Union satisfied the test under paragraph 45(a) in that at
least 10% of the workers in the determined bargaining unit were members of the
Union but not the second test as a majority of the workers were not members of
the Union. The Employer asked that a
ballot be held so that it could put to the workers a balanced case in
sufficient detail and in enough time for them to consider options for consultation
with management on an unlimited agenda.
Considerations
13. The Panel is satisfied on the evidence available that the
application is valid in terms of the tests laid down in paragraphs 44 and 46 to
49 of the Schedule, namely that there is no existing recognition agreement in
force, that there is no competing application and that there has been no
previous CAC application in respect of the new bargaining unit. The remaining tests before the Panel are
whether, in accordance with paragraphs 45(a) and (b) of the Schedule, 10% of
the workers constituting the new bargaining unit are members of the union and whether
a majority of those workers would be likely to favour recognition of the Union
as entitled to conduct collective bargaining on behalf of the bargaining unit.
Paragraph 45(a)
14. The Case Manager’s check established that 23.46% of the
workers in the bargaining unit were members of the Union and this figure was not
disputed by the Employer. Accordingly, the
Panel is satisfied that at least 10% of the workers in the determined bargaining
unit are members of the Union, and that the Union has met the admissibility
test as set out in paragraph 45(a) of the Schedule.
Paragraph 45(b)
15. The second issue for the
Panel to consider is whether, under paragraph 45(b), a majority of workers
constituting the bargaining unit would be likely to favour recognition of the Union as entitled to conduct
collective bargaining on behalf of the bargaining unit. The Panel reminds the Parties that this is
not a definitive test of support and that, for this test to be met, the Panel
must only be satisfied that a majority of the workers in the bargaining unit
would be likely to favour
recognition. It is not, as suggested by
the Employer, a test as to whether the Union has majority membership
within the bargaining unit. The Union
relies on its petition as evidence that this test is satisfied. The petition was signed by 46.30% of the
workers in the bargaining unit. If the
test of a majority of workers being likely to favour recognition of the Union were a matter of simple
arithmetic, then it would only require the signatures of a further seven more
workers to show a numerical majority. The
Union has explained the
circumstances as to the origin of the petition in that it was conducted over a
short period of time after the Panel had determined the bargaining unit in this
matter. The Union submitted that it had not
had the opportunity of approaching a number of the workers given the time
constraint and that it was of the opinion that support for the Union was substantially higher
than demonstrated by the result of the petition.
16. Conversely, the Employer questions the
validity of the petition for the reasons given in paragraph 10 above. However, the Panel, having considered the
points made by the Employer, finds that it is not persuaded by its
arguments. Whilst the petition may have
been addressed to “all staff” and referred to collective bargaining without
specifically spelling out the core topics, namely pay, hours and holidays,
nonetheless the Panel is of the view that this is not sufficient to devalue the
currency of the petition for the purpose of this test. The Panel asks itself whether the signatories
would have understood the implications of signing the petition. Having looked to the proposal on the document
the Panel is satisfied that they would have known that, by signing the
petition, they were signalling their support for recognition of the Union
by the Employer. Whilst a petition, as a
method of indicating support, has been termed “unreliable” by the Employer, it
is however accepted by the CAC as a valid indicator of the views of the
individuals within a bargaining unit in the absence of any evidence to the
contrary.
17. The Union, in its
letter of 30 September 2005,
claimed that the petition was initiated specifically to a suggestion from the
Case Manager as being an immediate and tangible method of showing support. Whilst it is not for the CAC Case Manager to
instruct a party to an application as to how it should conduct its case
nonetheless they are often called upon to advise the Parties as to CAC
procedure. In this case the advice was
simply a reflection of that given in the CAC’s Guide for the Parties where,
when addressing the question as to whether a majority of workers would be
likely to support recognition of a Union, the guide states that a possible
example as to the sort of evidence a party could provide would be a petition
from workers. The Union expressed
disappointment that the Panel felt that it was necessary to apply the validity
tests but the Panel notes that this is a legal requirement under paragraph 20
of the Schedule.
18. The Panel having
considered the views of both Parties and the evidence submitted, is satisfied
that, on the balance of probabilities, a number of the workers that the Union was
unable to canvass during the short period it gathered its petition would also be
likely to favour recognition of the Union and, bearing in mind that it would
have taken only a further seven signatures for the Union to have demonstrated
an arithmetical majority, the Panel has arrived at the conclusion that the
majority of workers in the determined bargaining unit would be likely to favour
recognition of the Union and therefore the test under paragraph 45(b) is also satisfied.
Decision
19. The decision of the Panel is that the
application is valid for the purposes of paragraph 20 of the Schedule and the
CAC will therefore proceed with the application.
Panel
Professor John Purcell
Mr George Getlevog
Mr Bob Purkiss
18 October 2005