~1~1~ts~Jl~'>J) !ilJ·~Tiilf'·'~',ZasC`)11J_11'D


SECU1')1) .TJ_LV.Lr X43 Docket ,;o, 7? j (_rL


The Second Division c0?7.S'! ^st2CL of the regular members arid in addition RCfC'ruC TbeUCJnrc -i. O'Brien when award was rendered.

Sheet Metal 7 k" r.s' Ii:tCr?1nt'ional

.E)1,~. 'L"~lJL-.r:..i~

( Tiisocur'i. L5ci'f'ic f:aiLr<oz(3. C;xFs,-pany

171 r~·t~_ . C _a.'m of

                                  075, HWY thk"!,


,,,I rl K. F. Prater c~,Ot (8) Von= each a-

The Second Division of 'l'?1. AdjT7S°_...E... Board, -,'on the whole yecor& W.

The carrier or carriers aua the cqolnjf~: or ea-ic,~)J(-,-,-es dispute are .. iyiC't''L.._ r (.'_ y - t" _ c , 0-7 Ohio

                              Y


    This Division O-1' the Adjla-,JWiC'.i;t, .hC`u.·.?'.3_ Ii~L:_. jurisdiction over the d:L:"' _ ....


1:`lVOiVt'u i1L.Y'e:L71.

    W:C"(`'J1E,' a to said dispute T.'rel'C. given C).:CLr' T1C)`v:i C.'.e C'' l1('.e'.?":!..Ia;; thereon.


    The instant E'1.^7_'a, yiOL;7',_.'SC:C1. by the Sli'·'-'F`'i: ;`-'i:'.-f. ,C)1'1':C`)° , ~'.'l'O;~C '.?A1f:!:A,

                                      i,

                i ,..

011 J't'ty ~~1~ _(_9r(FJ, th.^. t_ v1'.i;`i.::4t a,,.iQTl:'C1 ,5;`o f:leC'i;'_"aC:i.C..._,.. ~nC: work of

Track, North T:s:Giu__ took. .:i'._a'?s...._. T1'=,_ work -.YTVOV . ._d the O: ,_ ..'O'=11V .'T,1.T!',

·e= - n; yn '1.1,. . . .._ ..·C .'o?;._1.°116.0. coil and L'14 J.r:;t..,_L.i._.(..I n.'_

of d, 17C.V',r CC5i1T4_W'E's._;01' 1t'...G_ , ,,.. __. Wf,.1'.. .,u ., . -.. L1:.. O! ,`c:t' 't:0 adapt the

Z.11 Tit31;:!T1:' those .t'.v?d-LuCLt;'.IO!": j:?°'.. Wt'C`'_.:!.ci_..1'!;.. fit, cLit arid _JL:L-)-e_-

this pipe, `t:.:. E7_t::__._.c'a?-'.-, cn·rr.ec'.t~i i;i.u_ van,xW'e ,:;,-. _ rC> t_:_ st.iio,, rul?clt
vT1,,s,'ur.; ' - iF ' unit ,.~.d i:ilt;,5't-'d with ":~_.-"Cad:z r'. :?;, on the three-ton u,:. .-CD'`ht,0:_i:
_.L7_. un 'cl' _ , '. ;z _', _
FO2'M I Award No. 7579
Page 2 Docket No. Y337-T
2-10-SM- 48

    The Cawrie.r :contends that the claim should. he dismissed under Rule

31-(b) of the contral_=Li nr; '. qweemant , cl.rv _ning that the orr,ani'cation failed
to appeal the decision of the h Aster On1-un ic Mllin .-i-xty d3.~,_ys i roan the
date of hi_ declination o1" the cla0-- Rule 31(b) reads, ire pert;.ner!t·3.'t,
as .follows:

        t'(b) 1f a, disallowed cla.ir, or ~ri_e`c%e~tl.ct;: is to be

        appealed, such appeal must b E: 1n writing r',nd :IT sla

        be taken with'-,. 60 days -_'ron the rC^t?',..:-G of notice

        of and ti i

        f' d1S:~t._1.. ..1G and representative >:y_ the


                              _ i ; n 1

        Carrier shall br, T[j.Lt,l':__ :i7_ Lia writing .,, within that

        time of the of dc-cisllo--1.7~


The record contains 11o ._,. Unce that the ~'~1' ·.Yl-, I<.-G~.C~YI V.I_a~.",~:;.<1 I~l!!_-a 31(h)

.c. t, _ M_ A, _ O' _·1'' _ t io'n I.;' .).'ttt. _ d nted iii: 'te~i.,. _

- 1975, _r· %lv :. ..7" ._mhanl.c it;.V,:l's declination of the ul.-,?'.. i _
certainly n within ·0 .. fron. "_.'(: t O- Carrier's notice
,_l ,...llowanca. The c'_... ..:3 ..a.. ther_.:. _e. i.l. d "s required b' h.uK

31(b)· and is p_`opci.l.·', iJufh. e. this TDnna for Thuc we will
,r_
              1.):.oc aua to the n_w - .3 t,: ow: (-__ _. c ~. . I ..:,


    r, - .. ,_ . ,_ in to t1r,


    _ p,_ _ ·A- C (;:_,.~._.C' .'G-C!'.c=C' '.'!'iiY',. .',~,.i.~_(.. ..C.'.i._ - r


              reads, i11 perthsAt pnI`;. a3 -'Ul1C'.;,...


        ttSllM 1'.. :,Z Wo-rharsf .'or= .... .t., consist of 411re .ding. brazing, connection '.?1,7. '1.1 sCOnn^(;t7_ of air, WAS"a .. ,

          . ,r

          s , o-i.~!_ arrci _.r(t_:w.:n i;i.pc;s . . .


pursuant to third T_;_." tV notice, the intcrna'hional DraC0CYtloud of
ElCc· Y n si,;bmi, .-ion eGH·eVi-11; i·'.. : i:, the ...n: __ ?'_1 C='vz.`Gio:.
    uY_Cal . ';0jr' ~s.~S M i . ~ _

was propcrly 8.,- s :i 'rnad. to C::: glny-., of the _,_~._e~ G3-'__C' _?1' ,. C~1^;~,.i'j: 'aua-er thc'-i 3°
Classification W. - 7_ , trod a t'.:anty-1'1ve. 'u'ar hisibry a.l Elect·ra _ _ :n;>
            0 . '

              Work =~_ .=:~,_1~. ~,

perf'orr:in; this di_>:~('`ced T;u3°.'...

    The Carrier contends that work 5?

                      wori. which re`_uA._ .,_, the assen-_oliy,':~c.

d.i sase,.pr of C:oC:l1 , . M~S, 'J, 'e ~'p;ti !_ _.S tO br· a.6s_ d and
      3,~l ~~ as; ;~c-1 - ~ .'r'2 3- 1-" ';'?,'~W_(~'~


d_LscSserbled, i)"...,.::1C._ l]'j ;:-.,_,.. pract?C I!',lec-trcl._.11t. nark. _I;1 ,`,nof their position, C . icr cZ.,as ::con: ._ r_-.__n .._.,_ 1':c.. , T

involved tH cw._,. -t~:..,._ :,i_L;. ... ~fJJ_'J~CL in th: ... _.'·T~'G ...'.i;3.f?U:%C . J`! t_~.-G A1',-~rd
concerned dispute ',, is"cl"l`cUr' or rp~rlq _'%,&n coils MY. «.
    lis^, r'-ch`n M,-Lh - -M jack. Tba C ._. ....)r a.lr o cu'ltends Mt


the practica rc- i" M .. U140 0n 0:` Of' -.. _ rh G'';. ,_'.c, : .·_._ ndevices b!_-ten t.. -t:h.
h, ' j 1, &~.s wic . _ _ ,11024 ks . ._ back as

1950. As an e.. nle of thn% practice, t."_. Q , . . _ rotors to a letter
    F" b Shop _~: ..'1.:T.~ ._ _., jo`? :t ,. olm V.'.wi;e. _.:!.i.- _ _ j, 1_, . ,

    .,_ .ht,l -3' C"` _;,~'~ v,r'U Shout , 't;_. 1 ',',nthurs' M_.,.!. 0_ .imnn. The Vurcl


                :3, 1950 lc't-i,ar stat< , ira Part, m. -i u:1dnw. ,

T'ox'in 1 fw:ard_ T,io. 7579
Page 3 t T ~J,~ r,
                                        PQi'..h(; V No. `(13.~ i "!

                                        2-M1'-i il i- ~ 7(j


        "The servicing, maintaining and repairing o!' electric drinking fua:rtain.^, at Fort;, I,1ttle IC~;:._ :hop:; v,_' U_ be handled _.n 2"2cordancu .r i'th past prueiiCe, '1.C,'. Electrician Craft will ;rn.iilf;ain arid repair all electrical en_;pme=nt, compressors, will also connect and. disconnect refrigeration lines ard wu.tC;'_'. Supply lines inside ca;b'J tn-c . . . r`


It i:; the Carrier's ,)r; ;.tiorl that the letter o_° March 2, 3950 sets forth. the practice on water coolers and that this practice was thcreafter
                                  ., .. -tj~_f:

claim an c.17_ cooling C'LC'v:LCCS. Tj:<) f;<11:'I'7f;1:' O.J_"o asserts that
m itr )ro. ''_' ke, , ( ~Ci1· . at the punitive rate a: sought for
<' :i.In. :'L=:aa .oz':v~ioc, `n _x
em;~..Io,'eN ~~i!o .peribr~..,=d non at the suy'h c_I_ R:ir,lcca_.

    The Sheet ·r_ r.. cl0n, assert that

    ,h i,t-. =.; °) b i o . to l..`)':..._ 1:%ur,, __%nt t:) 1';1_1_L C ')7. C_a3sifica't _C?il

    "`(lY°, '11 !. ,.na , a ,"rl er contends that a ,.t practice llas be( w,

    `lbl"1=^_. ,.ht;r'_> y this _JIt f?'..._ been p'rforned 1.); l..iZ·_ E_I_4'l:ricians>


t ·. e. _ Cho '1 d pu_'l.` ._. t'hn Ausi-.anl, U5'-_7.t'_ , .>_) C ontC' ,

that the work as properly LcsAnncd to .r. - ·. 7 ; a

              ·`a 3~ r'r''. (''. o._ A .rh._'J: m-. _.t_, ns': that U_ _


is swe !°:ms dC'cidwd 1.?? '?t^I<)^Y"(7 Go. 6924 b_'tu'eon the ....'t?.e p. rtii=.. U,`C'`LCi.

    In the ,.ilnt,` .;t claim the unui'_ 7 nvo.L'doC! CLic'C'.unnccti ng V.° :1 'reon 1'-_5

piping :Leon cO.P1'.._sO:'. to cOndensor r'-..il. ie.l.acin the C°C :nssorr un..
ua ·,.,, .i-·iitt ;, r I .ori - , nrions i_.: ,.__ of co _ plpc.
rU' ~ the ~ ^ '~- -19' applies to th.e sevvic:. , _~ ,. _ ~':i_,
1'..''J~i.~y,~ ~.;~t,`t'..,. `t'..,..;~t,`t'. .,.'.,. 3~1~ .r..,.C':~ ~1 w'~, ''1 . ,. 1. .... ...
and ^ ~ ~c._ic' :~._'1_ i1=` fc)- i,utWnw c?.', 1.0i.~'C: T·:i'l;i; __ :~:' > ;i;.~.~:
r.Ol 'Er')l.d~ir_y7Y..( of ~> of `~__C'~%..
Such llor-. !:T~.~_^, riot inyC1lvcd in the ins'tIIt, dispute. T`urtilop::ore. the _o..,

1~C~ 111'° - ~-l2t ri also d'.st_Y:-,.u_...:wbJ.e fro?ll ti-_:G ~rC)r°_~ j.r~irC'L'\,..',.i_
n~v...v ~C~vI~..~r._C~ `, JCi, ~, r is ,
1n the ;ln,rtaub claim. -l-Ll j`,%rv'arcd 10. b; _ , an, elec'twic l.:.)1 ...1s nonaccteed
refrif;c 1'...t:l-nE calls :;';~:.. C' _ ;r'c'~,1 '~ mach:Zne <-d . c;~'ovcd. tb'u coils. The Board there col . o c'Gl;y hoid that `Gi!'i.;: i3_.S 1';C`:._~ reservc'.Q to tY_e Electrician Craft by virtue of the Utter auted Lurch ?3, l`::5':>. ;?o;cvcr, the' work invol;'°_.. hcrc, , ! .E'. replacing c3. c;oA'>rF:_:or on a. three (3) toe?. air-conditioning unit, 1.'=s not covercd by UK Utter.

      1.F' `tni.i; manifestly clear that the work involved in the ins'tan):,

claim C')1St'i11:-il:i:fh.k~_L.. from the woe".: Waf; was involved _i1 either Award
No. 6924 on T·':_. 'Wholca's letter of Enra,'h 23, .TP50. _ln fact, LLe wait ..:1
        ";, claurly br,i nj` '-. r..j. _ \t..-;R iNtal do''kErs U_.1:)· _ the py,o'.R ien,_


of ale C > > rlr- ';< '-. Hula `- Sheet
C_1 _`~?.~ ~.'ri~r'i_~l'R t
    W ~`(' of We C:o_i._'i~t, ~_ 1'e_ ' ~G, ~. -

Classification of W"., folk, 1 _.cls nr_f'c, Hates t.hAi; vi:e norh o'·,. r ... f!_ttl. .:.
_c.aa.a,_ t ) i' b ....1._. connecting and di.connecl·1n; C'.. air, _.-,1.er!

gas, oil and . Ucam r_p.a s 7.. recoSW ii'd as r,i1~L:'li i4;ti,3,.f. >'·7Y'...~.W',,~ ~'~CJ=ii.
              .c


                                            r.

    In the i tlatnrl't claim, cmp7_oye. ; c;-._ the 1?:Lo a L rl cian S c rL_ L d-i'NcoS- A:.._..__

the :T)."(,'On <'".^.> ,t: _.:1Yi;. .`!''..,..`i 't1!_. ccw1;?rC's^._!)r 't:) cni!doilsnr co115. char"cCL u;: ._
            ... ,. .i_

j orn 1 !ward No. 7579
loge 4 Docket Io. 7337-,,

                                            1,1111 IS 7,i_ < ,7a


Connecting the now C'c?'_-:TkeS SGr. imle 97 of the cOYltrol7AE Aj'_rEEment
,.i
E::s:C1~.2C1.'l~;v' covers thE' piping uF%I'_r involved _.._ the 7__:.1'v'):Lt 'd7_shu-Ge, and
                            r ,,

aC'.COk'd7T?Ely, 'Lt belongs tO the Sheet Metal Workers.

Therefore, na2m)ch ds the C3.a7mants wcre deprived of work contractually reserved `1UwTi T)57 RZ),iu 97, we shall ,sustain t)?7:"G (1) of tho claim a`> '',7C Y' Findings. However, ii keeping with T1urcraus s".;arils of this and otlw1' Divisions of the Adjustment r=; ._n we find ti,at the pro rn;>;. rate i: the
- `R' 7'° - ' f . 'rte`- such an the one au hand 1`,}'_et'C: wit.~i'"~'. 4''t'..> Tl;:"l4 l.)t,'a.(1t~...=`~_. `Ii):ur i;'E~ "?'::~_ s_.cGnin i"3.>''i, (2) U3.' the An'!n at tile pYJ ruta rate, and not 8;i: the j[3UT?J.t1:Ve i'aGe as clalm_d..

                        T ;T R I)


    C1o,_.n, (a) sta>;'c~;i n<--d .


                          Claim (>) Pusfunnd at the p.-'o rata rVe of psy. r - -r r vt 1 r`, ~, ;~ .i ,l~f`J~ :>~_ '~j)


                            ,K - <- v


        yi .R_ .' y . .A_

A-nest: _,.=.'C`t~t.i`.~ _.,~'C:U~y

        l,, :,-' r~

        Nation& ts...7...i.'GaEa_ l'_C1.ji~_.>~;?o,nt :. ~u _.CJan't%.


        ._. _ .__. . _.~ ! _ __. `~.__'.~'~r' __e__ 'i_ ,_


^'~^1'...i:il:rt-' _ ~e· rrasuh AUV1N,t-a1.o`,ie. Assis-.a?'t

      `'c Tl._l -~o)lN, s, this 23th d-av of junE;-

Dated ~, Chicago, -. . , 1973.

CARRIER NHS' DISSENT TO SECOND DIVISION AWARD 7579

(Referee Theodore O'Brien)


This decision is erroneous and in derogation of our functions and jurisdiction under the Railway Labor Act.
The dispute in this case involved the utilization of electrical workers to remove a compressor from an air conditioner for examination and to determine whether the compressor should be repaired or replaced. The compressor was, based on their evaluation, replaced, and incidental to this work was certain piping work as outlined on page 1 of the award. The Petitioner made it clear, during both the Referee Hearing and the Panel Argument, that they were laying claim to the piping work involved in connection with this process. For the following reasons, we register a vigorous dissent. I. The Referee Hearing Pursuant to the request of Petitioner, a Referee Hearing was scheduled and Petitioner was represented by a Vice President. While we realize that in arguing cases, emotions sometimes naturally show and such feelings affect the presentation of a case, we believe the conduct of the Petitioner during the hearing departed from a normal, emotionally driven argument to a point where it affected the rationality and objectivity of the
                      2


majority in reaching a decision. In fact, it seems to us that apparently, this conduct was aimed at coercingly influencing the neutral member of the Board. While we are reluctant to make such an allegation, the fact that the Board several times requested the Petitioner's representative to control himself and once requested him and all parties to leave the hearing room for an executive session seems to confirm our opinion that this behaviour was not that expected of a labor relations professional. Again, we do not fault the Petitioner for vigorous and skillful pursuit of his case, but suggest strongly that in this case, such an objective could have been pursued without the conduct employed.
II. This Claim was Clearly Barred by the Time Limits and Should
Have Been Dismissed on this Basis.
During the handling of the claim on the property and before this
Board, Carrier maintained steadfastly to the position that the
Petitioner had failed to timely appeal this dispute under the
provisions of Article V of the August 21, 1954 National Agreement.
The facts in regard to this matter were that Carrier's terminal
master mechanic declined the claim on July 10, 1975. Thereafter,
the Organization's General Chairman did not file an appeal of this
claim until September 10, 1975 - which was the post mark on the
                        3


envelope enclosing the appeal letter. September 10, 1975 Was beyond the sixty (60) day period provided for in Article V for the appeal of grievances and the claim should have been dismissed solely on this basis, without considering the merits. Carrier's presentation to bhe Hoard, and decisions furnished the Referee, decisively pointed to the fact that in disputes such as this, the date of post mark governs. For example, in Third Division Award 14965, Referee George Ives held:

    "Awards have held that the Carrier must stop the running of the time limit by mailing or posting the notice required within the 60 days of the date that the claim was received. (Award 11575 and Second Division Award 3656). Here, the Oarrier responded to the appeal within the sixty day period and the dispute is properly before us on its merits."


Award 11575 of the Third Division (Hall):

    "Article V of the Agreement dated August 21, 1954 was agreed to for the purpose of expediting the progressing of claims or grievances. With that in mind, certain time limits were provided for. In 1 (a) of Article V it is quite evident that it was the intention of the parties that the 60 day time limit provided for would start to run from the day claim was received and filed by the Carrier--that, obviously would be the first time that the officer of the Carrier would have knowledge of it. Proceeding further in our consideration of 1 (a), it clearly appears that the Carrier mast stop the running of the time limit of 60 days by notifying within the 60 day limit whoever files the claim of the disallowance of same. That can be accomplished by mailing or posting the notice required within 60 days of the date that the claim was received. The employe presenting the claim then, under 1 (b) would have 60 days to appeal from the officer's decision from the date of the receipt of the notice of disallowance."

Notwithstanding the foregoing, the Majority considered the date of September 8, 1975, the date the letter was written appealing the case, as the date of the appeal. In the face of evidence of the postmarked letter envelope - which was dated September 10, 1975 - this conclusion was clearly erroneous under the authority cited the Referee. Time limits, like other provisions of the agreement, must be applied as they are written - they are not subject to an interpretation based on equity: Second Division Award 6383 (Lieberman):

"On September 23, 1970, the General Chairman wrote to the District Master Mechanic ...and we find that this letter constituted a claim under Rule 34 (a). There was no reply from the Carrier disallowing the claim within the sixty day period following its receipt, as required by the Rule. Time limit rules in collective bargaining agreements are as significant as axr other rules; they must be interpreted literally and followed exactly by both parties. This Board has held on many occasions that failure to abide by such time limit rules is sufficient reason for either rejecting or affirming claims without reaching the merits. (See Awards 2268 and 5693, for example). For the reasons indicated above, we therefore sustain the claim." Third Division Award 19663 (rent):

    "It is clear from the record that the claim for compensation was not timely filed by the Organization as it was filed sixty-one days after December 12, 1969, and was filed with the wrong officer of the Carrier.


    This Board has held in the past that claims that are filed

    late or claims that are filed with the wrong officer of the,

                        5


    of the Carrier are not procedurally correct and must be dismissed."


Third Division Award 21018:

    "It is Well established that a Claim which has not been progressed in accordance with the Agreement does not meet the requirements of the Railway Labor Act and this Board lacks jurisdiction to consider it. In one of a large number of Awards on this subject, Awards 12767, we said:


      '...the Hoard finds that in order to have avoided the time limitations, the Organization must have filed its appeal before midnight on January 31, 1960, and the claim is therefore barred.'


    Similarly, in this case, the Organization was simply at least one day too late. The inescapable conclusion is that the Board has no jurisdiction over this dispute."


Third Division Award 18352:

    "We have consistently held that an employe who has failed to initiate action within the time limitations fixed in an agreeis barred from initiating an action at a later date. Satisfaction of identified action within the fixed agreed upon time limitations is mandatory as to each of the parties. Time limitations set by contractual agreement have the same force and effect as those found in statutes and court rules - a party failing to comply by non-feasance finds himself hoisted by his own petard."


Third Division Award 21996 (Sickles):

    "Quite recently, this Division adopted Award 21873 which cited, with favor, Award 21675. There it was determined that:


      '...time limit provisions are to be applied as written by the parties and that any deviation from this principle would amount to rewriting the parties' Agreement, which no third party is empowered to do.'

                      6


      III. This Claim Should Have Been Denied or Dismissed on the Basis of Past Practice at this Point on Carrier's System and on the Basis of Previous Decisions of This Board involving these Same Parties and Same Location.

There was in evidence in this case a letter of March 23, 1950 from Carrier's then Shop Superintendent at North Little Rock, Mr. Whelan,, addressed to the local. chairmen of the Sheet Metal Workers and the Electricians which read as follows:

                    "North Little Rock - March 23, 1950 File 2801 Mr. W. J. Lyons Mr. S. B. Shock


      Confirming verbal instructions in meting in my office with Electrician Craft (Messrs. Lyons, Smith & Driskill) and Sheet Metal Worker Craft (Messrs. Shock, Roebling and Hammonds) present:


      The servicing, maintaining and repairing of electric drinking fountains at North Little Rock Shops will be handled in accordance with past practice, i.e.,, Electrician Craft will maintain and repair all electrical equipment, compressors, will also connect and disconnect refrigeration lines and water supply lines inside cabinet in performing this work and to remove and replace coils. (Emphasis added)


      Sheet Metal Workers Craft will maintain and repair all sheet metal work, will repair coils when necessary to remove and will also gas the boxes when necessary.

                      Isl John Whalen"

      It will be noted that this letter addressed itself to the


problem of who would perform work on electric drinking fountains
                        7


at North Little Rock Shops, and Mr. Whalen resolved this matter with the two local chairman by assigning the work "...in accordance with past practice." Thus, the letter of understanding, while addressing itself to the immediate problem of water coolers, resolved the matter on the basis of past practice, to wit:
"Electrician Craft will maintain and repair all electrical equipment, compressors, will also connect and disconnect refrigeration lines and water supply lines inside cabinet in performing this work and to remove and replace coils." The record of this case contained no evidence that either the Sheet Metal Workers or Electricians had ever protested this letter or any contents thereof. The record did contain evidence submitted by Carrier and the Electrical workers that such work had been assigned to them for the past 27 years, and the record also contained reference to Second Division Award 6924, involving these same parties and same location. In that case, Referee Zumas wrote:

      "This is a claim by a sheet metal worker that arose when an electrician assigned to the Electrical Shop at North Little Rock disconnected refrigerating coils from a degreasing machine and removed the coils. The Sheet Metal Workers contend that this was work belonging to that Organization.


      There is no question that the electrician melted the solder joints to remove the coils and resoldered the joints to reconnect the coils; no repair work was performed on the coils themselves."

4 r

After quoting the March 23, 1950 letter from Mr. Whalen,, supra, Referee Zumas affirmed the past practice at North Little Rock and found that it applied to this dispute. Again, we emphasize that the work in dispute was performed on a degreasing machine, and not an electric drinking fountain. In conclusion, Referee Zumas held:

      "Carrier contends that there has been a past practice of long standing to divide the work on cooling devices between sheet metal workers and electricians. Evidence of such practice is a letter addressed to the local chairman of the two crafts dated March 23, 1950 that reads as follows:


Under the circumstances, the Board finds that the claim is with
out merit and must be denied." (Underscoring supplied)
It will be noted that the decision of Referee Zumas recog
nized that the past practice at North Little Rock was in relation
to "cooling devices" - plainly and simply, nothing more and nothing
less. If an air conditioner is not a good example of a cooling
device, then we submit a total loss as to what is.
As we said, there was nothing in the record which indicated
that either organization party to the march 23, 1950 letter took
any exception, whatsoever, to the past practice referred to therein
or to the allocation of work accomplished therein. To take the
first exception to it some twenty years thereafter is clearly not
                        9


timely and does not refute or set aside the past practice which has, just like the written terms of a labor contract, become a part of the agreement between the parties. This point was well recognized by Referee Zumas in Award 6924 and should have been followed here. During the Referee Hearing, there were various statements concerning the personality of Mr. Whelan and the intent of his March 23, 1950 letter which were made by Petitioner. Not only were these statements without support from the record, but they also did not deny the existence of the past practice.
In summery, nothing was presented which could have established that (1) the past practice did not exist and (2) that Award 6924 was erroneous or was not controlling in this case - and we reiterate - that decision covered the very same work as was involved here - albeit on a different type of "cooling device".
This being the case, the Majority should have recognized the past practice, as affirmed in Award 6924. The principle of "Res Judicata" was clearly applicable, as was called to the Referee's attention, and should have been followed:

      Fourth Division Award 993 (Ferguson):


      "The Carrier on its part argues res judicata. From a


      review of the record, we believe that the instant claim

                        10


      contains the elements to support the argument, i.e., the same parties, base their present demand for the same relief, on the same facts, and the same contractual rights as were raised in Docket No. 823, Award No. 830.


      We are of the opinion that we do not have, and should not assume, the power to try the same issues again or to declare a previous award to be in error. Such a ruling would destroy the entire purpose of the Railway Labor Act and would nullify the final and binding provisions of Section 3 First (m)."

See also Third Division Awards 18315 (Criswell), 20455 (Blackwell),, 20542 (Eischen) and 21184 (Lieberman). The decision in Award 7579 was erroneous: (1) We had no jurisdiction to consider the merits since it was barred by the time limits and (2) the findings on the merits were wrong and without foundation in light of the clear past practice and the findings of Award 6924. We again register our vigorous dissent,

- &. - 4~

    .W. Goh


    . K. cke


G.H. Vernon

    - (~._ - Nkm -

J.E. Mason o
                LABOR MMBER' S RESPONSE TO CARRIER MEMBERS'

                DISSENT TO AWARD NO. 7579, DOCKET NO. 73? 7-T


In reviewing Carrier Members' dissent to Second Division ,ward IVo. 7579 we find there are so many discrepancies arid downright fictitious statements that we have no recourse but to go on record and refute their dissent.
Under Item 1 captioned "The Referee Hearing", Carrier referring to the Vice President of the Sheet Metal Workers states:

              "While we realize that in arguing cases, emotions sometimes naturally show and such feelings affect the presentation of a case, we believe the condu^t of the Petitioner during the hearing departed from a normal, emotionally driven argument to a point where it affected the rationality and objectivity of the majority in reaching a decision. in fact, it seems to us that apparently, this conduct was aimed at coerc-i ng? y influencing the neutral number of the Board.---"

The Vice President referred to is Mr- Richard E. Martin arid as a pont of information Mr. Martin not only worked as a sheet metal wor)~;er for this Carrier at North Little Rock, Arkansas, but served as Local Chairman, Vice General Chairman and Gneral Chairman over a period of: some twenty--odd years and because cEhis first-hand ;:nowledge of the work in question there was no one better qualified to present our case to the Board.
if he did display emotion it was to defend cur case against the prevaracations being submitted by Carrier representatives as fact. The only reason we can see for Carrier objecting to Mr. Martin's presence at the hearing was because they were well aware that he was the most knowledgeable adversary to oppose their try try convince the Board to take work which rightfully belonged to~ the Shcet Metal Workers and literally give it to another craft (electricians).
In Item II Carrier Members continue, as they did in their Submission and Rebuttal, to contend that this case was barred by the time limit and go into a long dissertation involving quoting of numerous awards in various cases to try to substantiate their plea. However, while these awards would be valid in the specific cases quoted, they would have absolute-ly no bearing in the instant case. We are confident, as we are sure the Carrier Members are, that the Board, including the neutral member, looked very closely at this aspect of the case and reviewed thoroughly the correspomdence file to make sure that no discrepancy occurred and that there was absolutely no violation of the time limit rule (Rule 31). In our opinion, Carrier Members cry of complaint concerning Rule 31 can be considered as nothing more than a hope that they could have the case dismissed on that basis because they knew that the rules of the agreement and past practice supported every contention of the Employes that this was work belonging to them and to no one else. Under Item III of their dissent Carrier Members again quote Shop Superintendent John Whalen's letter of March 23, 1950, intimating that Mr. Whalen's letter is the Magna Carta of the electricians' right to the work. Nothing could be further from the truth. Sheet Metal Workers were never signatory to such an agreement because they would never consent to giving their work to another craft, and we refer you to the Memorandum of Agreement of November 1, 1955, copy attached, entered into by thc=n Chief Personnel Officer for Missouri Pacific Railroad, Mr. T. Short,, General Chairman of Maintenance of Way Employes, Mr. C. L. Lambert, and Mr. Richard E. Martin, then General Chairman for Sheet Metal Workers, arid we direct your specific attention to section (g), which reads:

                          2

                                  LABOR MEMBER'S RESP014SE TO CARRIER

                                  MEMBERS' DISSENT TO AWAf r?~ 7579

                                  (DOCIrET N0. T 3~-r)

                              "(g) "Plumbing Work'°------This term covers work in connection with sanitary installations, such as water and soil pipes, baths, wash basins, water closets, urinals, hot water and drinking water facilities and their fittings - or work normally performed under the supervision or a registered plumber. (Sheet Metal Workers will do all the "maintenance work in connection with drinking fountains, such as cleaning and r blowing of coils, installing new or repaired coils, removing, repairing or replacements to outside coverings or casings. Maintenance of Way forces will maintain cold water and drain pipe to drinking fountains, also install, remove or replace any drinking fountain. This will not prevent. the Sheet Metal Workers from disconnecting drinking fountains to make necessary repairs and to make connections after the repairs are made)."

Carrier Members also contend that at no time did the Sheet Metal Workers or Electricians ever protest Mr. Whalen's letter. Since it was not a bona fide agreement and since the Sheet Metal Workers never agreed to such allocation of work, there was no need at that point in time to make protest, however, when the Carrier tried to make Mr. 4halen's letter an instrument of agreement the Sheet Metal Workers vigorously protested.
On Page 7 of their dissent Carrier Members again insist that Second Division Award 6924 involved a case parallel to the instant case. Again, nothing could be further from the truth. Award 6924 involved vapor cones - not air conditioning, which is the work involved in Award 7579. The ruling of the Board in Award 7579 was correct as it was in companion Awards 6774, 6775, 6776 and 6777.
On Page 8 and 9 of their dissent Carrier Members again refer to Mr. Whalen's letter and in conjunction with what we said previously we wish to reiterate that Mr. Whalen's letter did not constitute an agreement of any kind and while it referred to water coolers it in no way

                          - 3 - LABOR MEMBER'S RESPONSE TO CARRIER

                          MEMBERS' DISSENT TO AWARD 1,10. 7579

                                          funrvf:T ijn °7 i1 r-q,-'s

referred to air conditioners.

In summary we

wish to state:

    1) This case was timely progressed in line with Rule 31 of the agreement.


    2) Award 6924 upon which Carrieg relies so heavily has no bearing whatsoever in the instant case - that award involved vapor cones - not air conditioning;


    3) Mr. whalen's letter has no effect on the instant case because it was never agreed to by the Sheet Metal Workers - also his letter referred to water coolers - not air conditioners;


4) Awards 2898, 6774, 6775, 6776, 6777 and now Award
    7579 clearly establish beyond all question that

    this is work belonging to Sheet Metal workers;


    5) The ruling by the Board in Award 7579 i in all way correct.


r.,

m. J. Cullen
Labor Member

LABOR MEMBER'S RESPONSE TO CARRIER
MEMBERS' DISSENT TO AWARD NO.. ?579
(DOCKET NO. 7337-T)
              tEMORANDUI-I OF UNDrI~i1 STANDING

              Between th~:

              MISSOURI PACK ,.7 R"-" .:OLD COii.," A'JY

              BROTHERHOOD OF 1IAI 1_uA,_ OF :JAY 1 ,

              BROTHERHOOD :LOYES

              and

              SHEET 1-TTAL WORKERS DITLRNATIONAL ASSOCIATION


To eliminate disputes between employes represented by the Brotherhood of Maintenance of Tay Employes and those represented by the Sheet iletal Workers International Association based on allocation of work, it is agreed:

        1, From date of this M-IORANDUM, pipe work is not to be allocated accord ing to so-called past practice.


        2, From date of this 1M,I0RANDUM, pipe work twill be allocated in the following manner:


    (A) Shops and enginehouses t,There Sh^et T"etal ,Jorkers are employed,


        to Original installations and removals in

        case of abandonment of all or a part of

        pipe line systems -----_--.__-_--_------_---___---_---_--_ iloftJ


                                                    Forces

            (Original. installation or abandonment of a part of a pipe line system as referred to herein does not include connections or extensions from the mainsystem to machines, e';c,, b,x.t refers to original installation of an. extension of the main system or removal in case of abandonment of a part of the main system.

            A drop which supplies only one unit, such as a machine, pump or vat, shall not be considered as a part of a pipe line systems

            A drop from a pipe line system to an individual unit, such as a machine, pump or vat, is work that is to be performed by sheet metal workers, but this shall not include the tee or other outlet where connection is to be made to the pipe line system ..her. the same is put in at the time of original installation, or extension of the pipe line system, which is work of maintenance of way

. employes,
            It is further understood that where a crop comes off the pipe line system wad a number of units, such as machines, pumps or vats should be connected to it, they will be considered the same as one unit connected to the drop. In other words, if the drop cor~li.ng off the rain line systc-i does not form a continuation of the pipe line system it trill be considered sheet metal workers work regardless of the nt1mbcr of units that are connoted to the drop),

2

All maintenance, replacements. and relocations inside of buildings - above ground or floor

__..___________- Sh, P-iet21 I%Ikrs,

    (The language all maintenance, replacements and relocations inside of buildings - above ground or floor line is intended to mean: That any and all such mentioned work shall be done by Sheet ioietal :-Jorlcers, except work below ground, which will be done by the Iiaintenance of Way Forces).


3. All. installations, Maintenance, replacements,
    relocations., and removals outside of buildings

    above and below ground, and inside buildings


below ground or floor line

- IIofI,,t Forces

All installations, maintenance, replacements, relocations and removals of a1_1 pluribing wor'_; in connection trite heating plants, drinking water supplies, vrashroorns, anal toilet facilities, wherever 1 ocated ---____.._..-....___....__..,._- ilof;lr Forces

5, (a) The making, when done in shops, repair,
    maintenance and installation of all heating


units and their appurtenances after i:ainten
ance of `:!ay Forces have installed the main

pipe line system

Sh. iietal ~,sIkrs_

(b) The installation of heating units and their appurtenances in new construction where no Sheet iietal Workers are employed -------- IIofGJ Forces

(B) _Porr er plants at St. Louis, Ihzno,, Poplar Bluff. DeSoto,
      Para nould, ~:cGF:iiee, i:onroe, Alexandria, Little _Itock,

      North Lyttle Roc"-', 5e dalia, ~Ita.nsas City, Csavratar.ie

      Omaha,


      1. ( a) All pipe work in pourer plant buildings


except lead caulked cast iron pipe and
fittings, and all underground lines

{b) Installation and maintenance of lead caulked cast iron pipe and fitt~.ngs, all

underground nape lines and plur:lbing covered in (A-4)

___-__ Sh. I-Ietal Wkrs,,

IIofLJ Forces
      2. All installations, maintenance, replace:.ients,

        relocations and removals outside buildings -------- Hofd Forces


(C) Al l points other than at poi,,Ter plants,, slues and
      en inchou se s ,


1, All installations, -maintenance, replace:aents.,

relocations and renovuls

3m

iof ;l Forces

This a.,!reeinent is not to be construed as beinE; in conflict with tine me-;orancu:~ of .^.pril 'j, 190, covering -uze natter of ins tal'_a'c:i.onj re:'.oca-ti_on, re;)air5.n:; and testing, of ory-on-acetylene facilities i n the s'_ions at =ans as City (.'ast mot to:as )' Sedalia, St. Louis, Oe,`~o to ane.:~ aorta Litrle : :ocl:,

Intern re tati_on o~° "~'errns uses in this : :ernorandurs,

~~lloT
'ji p s anc~ :~n3_nehouses"

(b) " Below ~ round or floor

level"---___.,__....__--__.._____

- ;Jithin shop 7.,rounds or iochanical facilities. ~u~i'.ir.~s, such as bac:=shops, diesel s.TOps, roundhcmses, tea: Jcpta boil c'~.r,~: or an:,r
additions, partitions oi, c,-tensions
to such bui' di n~s where ),eci:anica:. forces axe e_r,)lo,)Ted, but this dcas not include oil-ice boil din~sf store rooms or buildings in ,4iich . 'aintenar:ce of :~ ~r forces are euployed. This ~c,-111 not -)--event the Sheet e,,. ,~ fro:i -ocxiorninrr work
i : ~~_ '.'lUT _Ei _
an space set apart in 'our:! c'd.y,s to
house the General Foreman or otuer
-mechanical officer s, (It is under
stood that the wording "forces are
e~;i;alo5red" raca.ns in buildings or
d.i.nar i.ly consieered as their re
sp ec rive shops or buiJ_di n~; as
spelled out in interypr e:.ati an)

'Does not °ie_an pines in ')a.semonts
or open troughs in floors,
s

(c) "Out-side of buildings" ------ Ts not to be coj:tr~jec? as being in
conflict' nrit'.z meet ::etal .'or';ers'
aree:uenZ covering work in the
Maintenance of ::~auip:uent Dept;,

(d) "Poi.rer Plants"

(e) "All points other than at --
Power Plants, Shops and
a:,nginehouse s"

lit points speci.fied in 'I:ernorane?tt;~1 is :pelf-exDlanaiory-.

defined as outside of shop grounds or u;echani cal facilities such to freight houses, 6.epots - anc: aa_1 other buildings and pipe work :rot under the jurisdiction of _:echanical Dept,
(f) "Pipe work" ---_---_-----

(g) "Plumb__ing, ?iTork" ---------

This term erabr aces metal pipe, fi~,t:inns, valves, appurtenances, and, coverir;,s therefor, also metal pi--::hanbors and supports, but does not inra.,7de sanitary toilet facilities.

This term co,,,:3rs irork in connection
with sanitary installations, such
as grater and soil. pipes, baths, wash
basins, water closets, urinals, hot
water and drinl-cinz water .facilities
and their fittings - or work norm
ally performed under the sunervi lion
of a registered plilnber. (Sheet
I:etal '!or::er s t-r-ill do all tile nain
tenance wor'_: in connection with drink
in- fountains, such as cleanin- and
blowin- of co2.1s, iz:stal7.ing new or
repaired coils, re::ov lng, rcpa_l_r ing
or replaceaents to outside cov-,rings
or caoins, Ilsatonance of :!a,7 forces
will maintain cold Mater and drain
pipe to drinking fountains, also
install., r e7,tove or replace -jiy drinking;
fountain. This will not prevent
the Sheet .fetal '6,:Torkers from dis
coruiec t;inb drinking fountains to
make necessary repairs and to make
connect-ions after the repairs axe made).

This agreement entered into this 1st day of izove;:ber, 1955, and. shall continue in effect until changed in accordance idth the procedure required by the -,ailway Labor Act.

    This agreement cancels agreement of October 28, 1952,,


For the Employes;

S/ C. L , L anbert
eneral Chairman -
Brotherhood of j':aintenance of 'jay :~zvl oyes.

S R. E. i:artin
General. Chairman -
Sheet iietal .1orkers Inter-
national Association.

Files 24.7-2331; z47-3038; 716-15

For the Carrier

/S/ T. Short
;;hie . I'~ersonne7 Officer