Transportation-Communication Union )

Burlington Northern Santa Fe )
Railroad )

STATEMENT OF CLAIM


working rules of the current Clerk's Agreement at Barstow,
California when it improperly removed H.P. Schumacher from
protected status and improperly removed his name from the
Purchases and Materials Management (P&MM) Coast Lines Seniority
Roster effective January 1, 1995: and

(b) H.P. Schumacher shall now be restored to the status of a protected employee and shall have his name replaced on the P&MM Coast Lines Seniority Roster and shall be compensated for any monetary loss deriving from the Mediation Agreement and/or the working rules Agreement, commencing January 1, 1995 and continuing until such violations are corrected, in addition to any other compensation he may have received.


FINDINGS

This Board finds the parties herein are Carrier and Employee within the meaning of the Railway Labor Act, as amended, and that this Board has jurisdiction over the dispute involved herein. The parties to said dispute were given due and proper notice of hearing thereon.


Claimant had a seniority date of April 28, 1977. As such claimant was a protected employee under the terms and conditions of the February 7, 1965 National Agreement as amended effective January 1, 1980.


On December 27, 1990 Claimant last worked a clerical position due to a force reduction, and began receiving the benefits of the protective agreement. It is noted that when the claimant was furloughed there were not any clerical positions left on the seniority district.


On February 25, 1991 Claimant was offered comparable employment as a shop craft laborer under the provisions of Article II Section 4 of the protective agreement. Claimant accepted the offer and was paid a supplemental allowance (the difference between the laborer's rate and the protected clerical rate).

On January 1, 1995, under the provisions of Rule 17A of the Schedule AgFeement the Carrier removed the claimant from the


clerical seniority roster and ceased paying the
rates.

The Organization has progressed the claim

Carrier has violated both the Schedule Agreement as February 7, 1965 Agreement~as amended.


The Carrier takes the position that it properly removed the claimant from the clerical seniority roster under Rule 17A, and that the February 7, 1965 Agreement, as amended, does not supersede the Schedule Agreement. It argues that once the claimant had lost the clerical seniority he was no longer entitled to any benefits of the clerical craft.


The Carrier also argues that when the February 7, 1965 Agreement was amended in 1980 it no longer had to retain clerical employees in service. Therefore, it was proper to furlough the claimant. After the claimant had not worked in the clerical craft for 4 years it was within their right to terminate the "life time" protection of the February 7, 1965 Agreement, as amended.


difference in

alleging the

well as the

Article I Section 1 of the February 7, 1965 Agreement reads:

All employees, other than seasonal employees, who were in active service as of October 1, 1964, or who after October 1, 1964, and prior to the date of this Agreement have been restored to active service, and who had two years or more of employment relationship as of October 1, 1964, and had fifteen or more days of compensated service during 1964, will be retained in service subject to compensation as hereinafter provided unless or until retired, discharged for cause, or otherwise removed by natural attrition. Any such employees who are on furlough as of the date of this Agreement will be returned to active service before March 1, 'i965, in accordance with the normal procedures provided for in existing agreements, and will thereafter be retained in compensated service as set out above, provided that no back pay will be due to such employees by reason of this Agreement. For the purpose of this Agreement, the term "active service" is defined to include all employees working, or holding an assignment, or in the process of transferring from one assignment to another (whether or not October 1, 1964 was a work day), all extra employees on extra lists pursuant to agreements or practice who are working or are available for calls to service and are expected to respond when called, and where extra boards are not maintained, furloughed employees who respond to extra


work when called, and have averaged at least 7 days



Article I as amended reads:





















The apparent reason for the change is that the amendments to the February 7, 1965 Agreement require furloughed employees to apply for Railroad Retirement Board Unemployment Benefits, with the Carrier making up the difference between the protected rate of pay and the unemployment rate. However, both versions limit the number of protected employees that may be reduced to a decline-in-business formula.





was amended to read:

or fails to accept employment
Agreement, or fails to respond
called,- will be suspended until
obtains. a regular position. As of
such position he will be restored

protected employee and protecte regular position occupied on the

status is restored. If an employe is reinstated to service, he will
status of a protected employee a reinstatement. (Emphasis added)

The Carrier argues that the removal

from the seniority roster under Ru resignation. It avers that seniority is

the protective agreement, and when th chest was forever locked.

d e s

as provided in the to extra work when such time as he the date he occupies to the status of a at the rate of the date his protected dismissed for cause be restored to the of the date of his


e

of the Claimant's name

le 17A was a key to the key was lost

in essence a treasures of the treasure

This Board must decide whether the Carrier had the right to terminate the Claimant's seniority under Rule 17, and if so did it have the right to terminate the benefits of the February 7, 1965 Agreement, as amended.




The record is void of any evidence that the Claimant; (1) did not assert his displacement rights within the time limits provided in the Schedule Agreement; (2) waived his displacement rights in writing; or, (3) did not possess sufficient seniority to displace a junior employee.


While the Carrier argues it has terminated numerous employees under Rule 17A, the record is void of any evidence of history of terminating employees who were receiving the benefits of the February 7, 1965 Agreement, as amended. It is clear the claimant is not covered by Rule t7A. Also there is no evidence that the Carrier terminates the seniority of clerical employees who have been promoted to management positions, and who have not worked in the craft for 48 months.



However, even if the claimant were covered by Rule 17A, the Carrier would have had no basis under the protective agreement to terminate ths__ benefits. Claimant had accepted comparable employment in another craft under the provisions of Article II Section 4, which reads:


Article Iv describes the benefits due regular assigned protected employees and supplemental allowance due unassigned protected employees. Section 5 of the article describes when an employee will not be entitled to the supplemental benefits. It reads as follows:


This section clearly excepts those employees accepting comparable employment from suspension of benefits.

Finally, in a similar case before Special Board of Adjustment No. 605, in Award No. 318, Referee Zumas held:






None of the changes in 1980 changed the purpose of the February 7, 1965 Agreement.


The Carrier by its actions has attempted to reduce the "life time" protection benefits of the February 7, 1965 Agreement, as amended, to a four-year benefit. While its arguments may show ingenuity they are sophomoric.


The Carrier has violated the Schedule Agreement when it improperly removed the Claimant from the seniority roster and the February 7, 1965 Agreement, as amended, when it ceased paying the Claimant his supplemental benefit.




Claim sustained. Carrier is ordered to restore Claimant's clerical seniority and reimburse the claimant for all monies withheld within 30 days of this Award.


                Rob t Riche e07, Neutral Member


LL.L~ Broterm n William R. Miller
Carrier Member Employee Member

Dated c2-6 - 129 7