. BEFORE

PUBLIC LAW BOARD NO. 954







                            AND STEAMSHIP CLERICS, FREIGHT

                            HANDLER, EXPRESS AND STATION EMPLOYES


' v.

                              THE LONG ISLAND RAIL ROAD COMPANY


                    STATEMENT OF CLAIM :

                    1. The Carrier violated the established practice, understanding and provisions of the Clerk's Agreement, particularly, the Scope Rule, Rules 4-A-7, 9-A-1, 9-A-2, among others, Memorandum of Understanding No. 2 and Agreement No. 47, when it assigned, required or permitted established Chauffeur work to be performed by a laborer (E. F lynn) who


    ' has no seniority rights and is not covered by the Scope of the Clerk's


                    Agreement.

                      2. This work shall be returned to the Employes covered by the Scope of the Clerk's Agreement upon whose behalf the Agreement was made in accordance with the provisions of the Railway Labor Act to perform this work.


' 3. The Carrier shall pay Chauffeur Buckley for each Monday of
                      every week, effective June 13, 1966, and Chauffeur L. Walker for each

                      Wednesday of every week, effective June 15, 1966, eight hours pay at the

                      rate of time and one half and for each day thereafter this chauffeuring work

                      is performed by other than employes covered by the Clerks' Agrecn,.ent


            . until such time as the violations are corrected.

                        . PL <r3 95y


                    4. The Carrier shall pay Chauffeur E. Blank for each Tuesday, Thursday and Friday of each week, effective June 14, 1966, four hours, overtime at the rate of time and one half and for each day thereafter this carting and chauffeuring work is performed by other than employes covered by the Clerks' Agreement and until such time as the violations are corrected.

                    5. The Carrier further violated Rule 4-D-1 when it failed to comply with its own provision, reason and understanding (letter dated October 26, 1966) for extending the time limit of the claim.


                    JURISDICTION

                    This Board (Public Law Board No. 954) was duly established by Agreement of the parties, executed April 25, 1972, as provided for in Public Law 89-456 (80 Stat. 208) and in compliance with Regulations promulgated by the National Mediation Board by authority of said statute (F. R. Doc. 66-1245 1). The aforementioned Agreement is incorporated herein by reference thereto.

                    The "AWARD NO, -' in the caption of this and all subsequent cases within the jurisdiction of this Board represents the order of issuance


S,, of the AWARD. The "Case No. " which appears in parenthesis under
                    the "AWARD NO.-'identifies the case as listed in Attachment "A" of

                    the April 25, 1972 Agreement of the parties.

                    The Board in its consideration of each dispute is by statute required to confine itself to issues timely raised by either party in the course of usual handling of disputes on the property. Railway Labor ACT (RLA) Sec. 3, First (1). As to issues which satisfy that test the parties in paragraph (9) of this Agreement establishing the Board, have stipulated that each of them may, either orally or in writing, present evidence that


                                      -2-

                  is material and relevant to the issues timely raised on the property; and, the Board is authorized "to require the production of such additional evidence ... as it may desire from either party."

                  The parties have waived the time limitation prescribed in paragraph (10) of their April 25, 1972 Agreement within which the Board was to "render an award within thirty (30) days after the close of hearing of each claim."


                  OPIN IO,\T OF BOARD:

                  This dispute, on April 10, 1967, was referred by petition of BRAG

to the Third Division, National Railroad Adjustment Board as provided for
in RLA, Sec. 3, First (i). Each party filed with the Division a Submission
and a Rebuttal to the Submission of the other. In its Submission, Carrier
alleged that International Brotherhood of Electrical Workers (IBEW) had a
third party interest in the dispute; and, the Division was without jurisdic
tion to consider the dispute on its merits in the absence of notices to IBEPI
with right to intervene. The Division, under date of August 6, 1971, served
notice on IBE\7 of the pending dispute and informed it of its statutory right
to: (1) file a written Submission; and, (2) be heard at an oral hearing set
.sue for September 14, 1971. IBEPI filed a Submission on September 14, 1971.
                    Neither Carrier nor BRAG entered an appearance at the oral hearing. On

                    September 23, 1971, the Executive Secretary of the Adjustment Board

                                                            I

                  forwarded a copy of the IBEW Submission to Carrier and BRAG and

              . i

              . informed them that each would be allowed until October 26, 1971, to sup

              plement its original Submission to embody the involvement of IBEZY. Each

              did. Thereafter, on May 11, 1972, Carrier and BRAC, jointly, exercised

              1

              the statutory right (RLA, Sec. 3, Second) to withdraw the instant dispute

              from the Third Division and four others (Dockets CL 1Si27, 18375, P'.323

              ' I


                                      _3_

                          PLG C15t/


and 18739) for referral to this Public Law Board -- all of which disputes

are docketed with this Board.
On June 16, 1972, this Board served notice on 1BEW that: (1) the Board would hold hearing on June 28, 1972; and (2) it "will be allowed to participate in said hearing in accordance with the directives of the National Railroad Adjustment Board." IBEW did not appear at the hearing.
We find that LEEW, as an alleged third party in interest, was full, afforded due process as prescribed in T. -C. E. U. v. Union Pacific R. Co. , 385 U. S. 157 (1966).

                  FACTS

The Claim was filed with Carrier's Chief Mechanical Officer on August 8, 1966, with statement of "Position of Employes" as follows:

        The employes contend that the chauffeuring and carting of material between Morris Park Shops and the Dunton Electric Annex has always been performed by the Chauffeurs covered by the Scope of the Clerk's Agreement. Laborer E. Flynn [covered by IBEW Agreement, who has no seniority rights and is rot covered by the Scope of the Clerks' Agreement, picks up material, Monday to Friday of every week, at Morris Park Shops, and delivers it to Dunton Annex where lie is assigned to work.


        The employes further contendthat this chauffeuring of material between Morris Park and Dunton Annex was done once before, approximately two years ago by other personnel at Dunton Annex, not covered by the Clerks' Agreement, and was stopped immediately by a meeting between your assistant Mr. E. DeCeck and Local Chairman F. Denzin.


        The employes further contend that we do have chauffeurs going between Morris Park and Dunton Annex.


        P-ra Zranh (U) of the Scone of the Clerks Agreement reads as follov:s: Positions and v:orh comine within t he Scone of this at_.recment belonn to the employes covered thorobv and nothim, in this a_rce- ment shall be eonstrund to nrrmit the removal of

        posilin-ie. and v;-nrh %rori the a nnlic!tiea of these rules, - .

        except by a,~r~·-mer` bet-~·e-.n tho parties si··ratorv -

        hereto . (Emphasis supplied.)

        - 4 -

. PL(3 q5W

                            Please advise payroll date in which this claim will be paid.


                            In the event you do not agree to the payment of this claim, please consider this notice in accordance with the provisions of Memorandum of Understanding INTO. 4, that you will set a date within (10) days of the date you receive this letter for the purpose of discussing this claim.


                          The Chief Mechanical Officer, in reply to the Claim, made


                      admission as to the right to perform the involved work; and, denied the


                      Claim on September 16, 1966:


                            Your position that the chauffeuring and carting

                            of material between Morris Park Shoes an d the -

                            Dunton Electric Annex has always been performed

                            by the chauffeurs covered by the s cone of the Clerks'

                            Agreement is true and correct , and to further sub

                            stantiate your position, the carrier did create a


' position of chauffeur and did hire a truck for the
                            purpose of carting material from Morris Park to

                            Brooklyn Electric Car Shop. .


                            The contention that E. Flynn who has no rights under the scope of the Clerks' Agreement is chauffering and carting material hetween Morris Park and Brooklyn Electric Car Shop every day is not supported as the carrier maurtains a chauffeur and truck for this specific detail.


                            On the basis that the carrier is carting material in accordance with the provisions of the Agreement, your claim on behalf of the three named claimants is denied. (Emphasis supplied. )


                          On October 4, 1966, BRAC, in compliance with Rule 4-D-1 (h),


                      submitted to Carrier an "Ex-Parte Statement of Facts":


                            The Carrier admits that the chauffeuring and carting of material between Morris Park Shops and Dunton (Brooklyn) Electric Annex, has always been performed by the chauffeurs. (See Carriers denial of September 16, 1966)


                            The Carrier denies that E. Flynn, or any other personnel at Dunton Electric Annex, who have no rights under the Scope of the Clerks' Agreement is chauffeuring material between Morris Park and Dunton (Brooklyn) Electric Annex. This is incorrect, as a check of the records of (lie Gateman at

      . PL B c754


        Morris Park Shops and the records of the Stores Attendants at Morris Park Storeroom, show that E. Flynn and/or other personnel from Dunton Electric Annex, come into the shops in theirpri- vate cars to pick-up material, Monday to Friday, every week.


        Chauffeur E. Blanks carts finateiall between Morris Park Shops and Dunton((Brookly~ Electric Annex on Tuesday and Thursday.


          Chauffeur Buckley is on his relief day, Monday.


        Chauffeur L. Walker is on his relief day, Wednesday,


        (Ed. note: The three named chauffeurs are Claimants lierein.~


    Carrier's "ex-parte statement of facts," dated October 20, 1966,


states:

        The Carrier created a chauffeur's position and hired a truck for the purpose of supplementing the regular truck assigned to Dunton Electric Car Shop and Brooklyn Electric Car Shop approxurately two years ago. The requirements of Brooklyn Electric

        Car Shop were such that the additional truck made -

        deliveries each week of material from the Morris

        Park Store Room. Requirements of service are

        such that a truck assignment of five days a week to

        Brooklyn Electric Car Shop cannot economically be

        supported, therefore, this truck is used to supply

        material to other areas.


        The use of other than emnlovees covered by the scope of the Clerks' A;recment 1=as been the practice over many years. (Emphasis supplied, )


    Following a meeting on October 26, 1966, Carrier, under date of


January 19, 1967, wrote to BRAC's General Chairman:

        At the aforesaid meeting, you were advised that the Assistant to the Chief Mechanical Officer was making a check: as to how much material was being transported by. other than chauffeurs. This study proved that the amount of material being transported is negligible and, further,- that other than Miscellaneous Forces (Chauffers) have been used on occasion to transport material from one shop to another for many years, without protest. (Emphasis supplied. )

                                              PLC 95N


                              In view of the foregoing, there is no basis for

                            this claim and it is, accordingly, denied.

                    From the above history of the,case as handled on the property, by and between Carrier and BRAC, we find the only defenses proffered by


Carrier were:
1. IBEN Laborer, Flynn, did not chauffeur and
cart material between Morris Park and Brooklyn
Electric Car Shop " every ddj;" -
· 2. A "truck assignment of five days a week to
Brooklyn Car Shop cannot economically be sup
' '.
` ported;"

                              3. Past practice: Employes other than BRAC chauffeurs have for " many years " performed the work involved;" and

                            4. The material being transported by other than

                            BRAC chauffeurs "is negligible It


                                FINDD;GS AS TO APPLICATION


                                  OF BRAC AGREEMENT ._

                    1. Paragraph (a) of the Scope Rule, standing alone, is general in nature. But, paragraph (b) of that Rule is specific. ( NOTE: Paragraph (b) is quoted in the BRAC's Claim of August 8, 1966, supra )-

                    2. The weight of authority of Third Division, National Railroad Adjustment Board case law compels a finding that when the Scope Rule of an agreement encompasses "positions and work" that work once assigned by a carrier to employes %,,!thin the collective bargaining unit thereby becomes vested in employes within the unit. and may not be removed "except by agreement between the parties;"

· P L1g q5y

                      3. Carrier admits that chauffeuring and carting of materials between Morris Park Shops and the Dunton Electric Annex "hues always" been performed by chauffeurs covered 6y the scope of the BRAG Agreement (see, Chief Mechanical Officer's denial of Claim dated September 16, 1966, supra . Therefore, in the unequivocal language of paragraph (b) of the Scope Rule, the identified work may not be removed from the scope of the Agreement except by agreement of the parties -- no agreement was fashioned relative to the instant dispute;

                      4. Carrier's defense that the work performed by IF3EW Laborer, Flynn, was "negligible" is found wanting for two reasons: (1) the defense is an affirmative one -- Carrier had the burden of proof which it did net satisfy by material and relevant evidence of probative value; and (2) even if proven it would estallish, only, that it had assigned work reserved to BRAG chauffeurs (Scope Rule, paragraph (b)) to an employe stranger to the BRAC Agreement. The magnitude and frequency of work unilaterally wrongfully removed from the Scope of the BRAG Agreement is not a justifiable defense;

                      5. Carrier's alleged defense of past practice fails for the following reasons: (1) a Scope Rule such as paragraph (b) in the BRAG Agreement is not ambiguous in the light of the case law o£ the Third Division, National Railroad Adjustment Board; (2) parole evidence is admissible, material and relevant in the interpretation o£ an ambiguous provision of an agreement only to arrive at the intent o£ the parties; or, to find history, tradition, custom exclusivity of contractual investment of right to work under a scope rule general in nature -- paragraph (b) of the confronting Scope Rule is specific;


                          6. The economic consequences of a bona fide contract are not

                                          PL (3 951


              material, relevant or of persuasive value before a forum charged with its interpretation and application. If a party to a collective bargaining agreement finds, by experience, that as to it the term(s) are economically onerous, the remedy is collective bargaining. This Board is without jurisdiction to entertain such an argument and resolve it by fiat.

              Carrier raised no issue on the property as to the measure of compensation prayed for in paragraphs 3 and 4 of the Claim.


                  For the foregoing reasons we flied and hold that Carrier violated

                                                        I

                                                        i

              and violates paragraph (b) of the Scope Rule when it assigned or assigns'


' the work herein involved to an employe not within the collective bargaining`

              unit of the BRAC Agreement. 1'7e, therefore, will sustain paragraphs 1,


              2, 3 and 4 of the Claim; and, will dismiss paragraph 5 of the Claim.


                          THE THIRD PARTY ISSUE


                  IBEW, third party herein, alleges and prays is its Submission:


                    We submit that the Carrier properly assigned the Electrical Workers to perform the disputed work and that the work is covered by the Agree-

          , ment between The Long Island Rail Road Company

                    and System Federation No. 156, International

                    Brotherhood of Electrical Workers. (See Car

                    rier's Exhibit A) which reads in part as follows:


                        ARTICLE III - DIFFERENTIAL FOR CERTAI\ E\:PLOYEES


                                                        I

                        Effective with the signing of this agreement, a differential of thirteen cents (13f per hour will be granted to Electricians in gangs who meet the necessary requiremei.ts of New York State Motor Vehicle Bureau and who are required , incident to their regular duties, to operate motor trucks. (Emphasis supplied.)


                    We, therefore, request that your Honorable Board find that the Carrier did properly assign the work in dispute to the employes of the Electrical Workers' Craft.

                                        PL e) C?-5y


              Carrier argues that: (1) the above quoted Article III of its Agreement with MEW vests MEW. employes with a contractual right to perform the work involved in this dispute; and, (2) the Article stands as proof that BRAC employes do not have exclusive right to work.

              Article III of the I33EIV Agreement does not vest the work therein described in IBEW employes. It is merely an undertaking of compensation contractually due an IBEW employe if he is "required ... to operate motor trucks."


                  Carrier may require any of its employes to perform work of any


` ' nature -- crossing craft and class lines -- so long as the work is not
              patently dangerous or its performance by the assigned employe is barred

              by law. The assigned employe, if grieved, must comply with the Carrier's

              directive and seek his remedy through the grievance procedures.

              Article III of the IBEW Agreements stands only as proposition of compensation for work specified therein which Carrier may require an IBEW employe to perform; not a vesting in MEW employes of contractual right to the work.


                                                        In the railroad industry employes are often assigned to work not i


              covered by the job assignment or not within the scope of their collective

              I bargaining agreement. Such assignments often come into being because of exigencies faced by a carrier. When such assignments are made, Carrier takes a calculated risk in that it may fiend itself contractually obligated to compensate the employe assigned for the work performed; and, in addition, pay another employe, contractually eligible, for work not performed by him but as to which he had a contractual vested right. Cf. T-C. E. U. v


              Union Pacific R. Co. , 385 U. S, 157 (1961), -


                  An elementary principle of contract construction is destructive of


                                - 10 -

                          PL 6 q5 L/


IDEW's contention. Article III of its agreement provides a measure of compensation when one of the employes covered therein is "required ... to operate motor trucks." It is uncontroverted that IDEW laborer, Fly,,, used his private automobile to pick up materials from Morris Shops Storeroom and delivered them to Dunton Shops Annex. Q. E. D. : (1) Flynn eras not required "to operate motor trucks"; (2) use of an employe's private automobile is not within the contemplation of Article III of IBEW's, Agreement.
We find that IBEW, third party intervenor, has no contractual right, on behalf of its members, to the work involved in this dispute. But, if employes covered by its Agreement are "required ... to operate motor trucks" then, regardless as to what craft or class of employes may have a contractual right to such work, the.IBEW employe assigned has a contractual right to be compensated as provided in Article III of the IBEW Agreement. We, therefore, on the record before us, will deny MEW Is plea that the Board "find that the Carrier did properly assign the work in dispute to the employes of the Electrical Workers' Craft.

                  AWARD


        1. Paragraphs 1, 2, 3 and 4 of the Claim are


                                          I

          sustained.


        2. Paragraph 5 of the Claim is dismissed.

          3. The third party plea of IDEW is not supported by the Agreement between it and Carrier. It is denied.


                  ORDER


Carrier is hereby ordered to make effective the AWARD, supra, asof the date of its issuance shown below.

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tI. Dorsey,~Ghairman Neutral Member

H.IvI, Chancey v;fce .i. J. Yard
Carrier Member

Employe Member

Y~ f
Issued at Washington, D. C. this ///Ilaay of ,t,/t' ' ,: 1972.