SPECIAL LARD OF ADJUSTNEITT 110 506


                THE ORDER OF RAILROAD TELEGRAPHERS ,.an D

                V8. ' Wi,'

                MISSOURI PACIFIC RAILROAD CODIPANY' 1,0~

                      Roy R. Ray, Referee ~'".L ,y~ ',y


        STAMMJT OF GTABI: t, Q ;~' _".,- .


"Claim of the General Committee of The Order of Railroad Telegraphers, on the Missouri Pacific Railroad (Gulf District) that:

      1. Carrier violated and continues to violate scope Rule 1, Rule Q, Paragraph (C) and (D) and Rule 3$ of the Telegraphers' Agreement when on October 9, 1961, it required and permitted and transferred the handling of less-thancarload freight shipments from the Agents at the following points in Texas,

      namely, Edinburg, Ed Couch, Harlingen, hiissiccz, Lyford, Pharr, Mercedes,'

      McAllen, Raymondville, LaFeria, Weslaco, Alamo, Rio Grande City, Donna,

      San Juan and Hidalgo, to the Missouri Pacific Freight Transport Company

      truck drivers for handling (delivering; receiving, receipting for and

      collecting monies therefrom) to and from San Benito, Texas, and to and from

      the receivers and shippers of less-than-carload freight in each of the

      points named herein, denying the aforementioned Agents of duties and reve

      nues to which they are assigned.


      2. Carrier shall compensate the Agents at Edinburg, Ed Couch, Harlingen, Liission, Lyford, Pharr, Mercedes, McAllen, Raymondville. LaFeria, Weslaco, Alamo, Rio Grande City, Donna, San Juan, Hidalgo, One Call, two hours at the punitive rate of the. prevailing rate applicable at each station for each transaction affected by the Missouri Pacific Freight Transport Company's

      truck drivers prior to their hours of service, during their meal period and'

      after the hours of service, and One Call at the punitive rate of pay for an

      available extra or idle on rest day telegrapher for each transaction during

      the hours the Agent at each named point is on duty, on each day beginning

      October 9, 1961 and continuing up to and including §he day such violation

      is permitted and until such time Carrier restores the handling of less-than

      carload freight to each of the agencies herein named. Carriers records

      shall be checked in arriving at the correct employee to whom compensation

      is due.


      3. Carrier violated and continues to violate Scope Rule 1 and Rule 3 of the Telegraphers' Agreement when on October 9, 1961, it required and permitted the Missouri Pacific Freight Transport Company truck drivers to act as Caretakers, Custodians, etc., at Val Verde, LaSara, Sebastian, Rio Mondo, Combs,

      ~' Hargill (Texas points) and any other non-agency point, as Carriers records at San Benito, Texas, will show, for handling (receiving, delivering, rece&ptingfOr and collecting monies therefrom) on less-than-carload freight to and from San Benito, Texas, and to and from the receivers and shippers of less-than-carload freight at each of the points named herein, or to any other point the records may disclose, denying and depriving employees under


I
saik 5'0b
AI'IIIRD N0. 27
DOCIM-T 110. 27 PACE 2

      the purview of, the TelegrapheraP Agreement duties to which they are assigned by Agreement.


      Carrier shall compensate the Extra or idle on rest day telegraphers who were available, as the Carriers records will show, eight (8) hours at the pro rata prevailing telegraphers rate, for each transaction affected by the Missouri Pacific weight Transport Companyts truck drivers on each day beginning October 9, 1961 and continuing up to and including the day such violations are permitted and until such time Carrier restores the handling of less-than-carload freight at each of the non-agency points to those to whom it rightfully belongs under the purview of the Telegraphers Agreement."


      OPIITION Or BOARD:


This Docket comprises two separate claims. The first charges that Carrier violated Rules 1(Scope), 4(C) and (D) and 38 of -the Agreement, when on October 9, 1961, it transferred the handling of LCL freight shipments from Agents at certain named stations to HUT (now MPTL) truck drivers for the handling (delivering, receiving, receipting for and collecting monies therefrom). The second claim alleges that Carrier violated Rules I and 3 of the Agreement, when on October 9, 1961, it required or permitted V3iPTL truck drivers to act as caretakers, custodians, etc. at certain named and unnamed non-agency points for handling LCL freight ($g~'a'~,gy receiving, receipting for and collecting monies therefrom).

Employes contend that prior to October 9, 1961, the handling of LCL shipments was solely the responsibility of the Agents at the stations involved; that YPTL delivered the LCL freight to the Agent at the station where it was unloaded and that he had complete charge of pick-up and delivery service to the patrons; and that beginning on October 9, 1961 Carrier required MPTL truck drivers to assume all responsibility for handling LCL direct to the patron, receipting for freight picked up and delivered.

.Aside from the merits Employes contend that Claim IIo. 2 should be sustained as presented due to the failure of Carrier to comply with the time limit provisions of Article V, Section 1(a) of the Agreement. This Section requires Carrier, in case of disallowance of a claim, to give notice in writing within 60 days to the person who filed the claim, stating the reason for such disallowance.

Carrier contends that the part of Claim No. 1 for the punitive rate was not progressed on the property; that Claim No. 2 and part of Claim No. 1 are for unnamed claimants and do not comply with Article V of the 1954 Agreement. As to the merits, Carrier denies any violation of the agreement. It says that the work in question here does not belong to Employes by virtue of the Scope Rule; that the work has never been assigned to the Agent except in special cases where Carrier has contracted with him as an individual to perform the pick-up and delivery service. Carrier asserts that for a long time prior to October 9, 1961, the truck drivers had
SbR sate
AMABD 110. 27
DOCKET 1,10. 27 PAGE 3

delivered LOT, freight to -the consignee direct rather than depositing it in the freight house at the local agency. Furthermore, it contends that truck drivers did not perform any service at the named stations on and after October 9, 1967. that they had not performed prior to that time, nor that had not been performed by contract draymen for many years. It argues that the only change made on October 9, 1961 was the transfer of certain clerical duties to San Benito, including the preparation of freight bills on all LCTr shipments for which bills had not been prepared at the point of origin, and the receiving from the truck drivers of monies which they had collected. Carrier points out that the claim is not for this but only for delivering, receiving, receipting for freight and collecting monies, all of which the truck drivers had been doing for many years without protest from Emr ployes.

We turn first to the procedu:·al questions. Employes say that the letter of Sluparintendent Parker, dated November 21, 1961 was not a notice of disallowance of Claim No. 2 since it specifically referred only to Claim No. Land did not mention Claim ITo. 2. They also say that Assistant General Manager Walkers letter of December 21, 1961 does not comply with the time limit provision of Article V, Section 1(a) because it was not addressed to the District Chairman who filed the claim. We cannot agree with the Employesf position as to Parker's letter of November 21st. In our view it must be considered a denial of Claim I1o. 2 as well as Claim 1do. 1. Although the first paragraph of the letter refers only to Claim No. 1, the second paragraph says: "I do not agree that the rules incorporated in your letter were violated in this case, see no basis for claims as presented and your request that agents listed be compensated and work restored to Agents in question and instructions to hTFT truck drivers be rescinded is respectfully declined." Note the use of the plural c3, ig~. Employee apparently considered the letter as a denial of both claims, since 3.n his letter of December 4, 1961,, General Chairman Phillips appealed to Assistant General I`ianager 11a71er from Parker to decision as to both claims. After Wal'ker's letter of December 21, 1961 denying the appeal, and specifically discussing Claim i1o. 2, General Chairman Phillips again appealed both claims.

Uhile we consider the letter of November 13th as a denial of Claim No. 2, we might call attention to the .fact that at no time while the claims were being proceased on the property nor in the submission to this Board did Employes ever raise any question as to the time Limit provisions. It was raised for the first time at the hearing. ldhile in prior awards we have sustained procedural objections raised on the property or in the submission, we are not disposed to consider any matter . including a procedural. objection, which is raised for the first time at the hearing. We,therefore, feel that Employest objection is not well taken.

As to Carrier's procedural objection concerning unnamed claimants, we need only refer to our prior awards in which we have said that .!art. V, Sec. 1(a) does not require that claimants be named but only that they be easily and clearly identifiable by reference to Carrier's records. Here we think the requirement is satisfied and therefore reject Carrier's contention.
S(3 R Sib
AWARD 140. 27
DOCIM-T 110. 27 PAGE I,,

Ile proceed to a consideration of the claims on their merits. The claims charge that Carrier transferred the handling of LGLfreight to hfTL truck drivers in violation of the agreement. Handling, as used in the claims includes: "delivering, receiving, receipting for and. collecting monies therefrom." fn their submission Iflnployes charge that Carrier transferred work formerly performed by the Agent at individual stations to the clerical .force at San Benito, But in their claims Employes failed to complain of the preparation of waybills at San Benito or the receipt of money by the clerks at San Benito from the truck drivers and for this reason at the hearing this part of the claim was abandoned. Employ's agreed that the claim was narrowed to the matter. of truck drivers issuing receipts for freight picked up,and far monies collected. The question to be decided, therefore, is whether the issuing of. such receipts was work which belonged exclusively to the telegraphers at the stations involved.

Rules ¢(c) and (d) and 38, relied upon by Employes, have no bearing on the question involved here. 4(c) merely saya the classification of employee as to occupation is indicated in Rule 38 where rates of pay and classification are listed. 4(d) deals with the matter of changing classification and there is no charge in this case that changes in classification resulted from Carrier's action. Rule 3 likewise is not pertinent to Claim No. 2. 7t applies only where caretakers or custodians are employed at stations where agencies have boon abolished. In this case it cannot be seriously contended that the truck drivers were employed at the non-agency stations. This leaves only the Scope Rule as a foundation for the claims. And the issue is whether under their Agreement, Employes have acquired the exclusive right to perform the work of receipting for monies and freight. Employ's have relied upon the principle that all work at one man stations belongs to employes covered by the Telegraphers? Agreement. fuis argument could not be used to support Claim kTo. 1 in its entirety because only about half of the stations are one man stations. Furthermore, the principle applies only to work assigned by Carrier to the station and regularly performed by the Agent. It has no application to nonagency stations closed by Carrier with authority of the Railroad Commission.

Employes, however, assert that at the stations in question, this work had always been performed by the agent prior to October 9, 1961. In this connection they say that prior to that date, the truck drivers delivered the freight to the freight house of the local agency from where the Agent had -the responsibility for its delivery to the consignees. On the other hand, Carrier says that for many years prior to October 9, 1961 the truck drivers had delivered the freight direct to the consignees and received monies therefrom. What are the facts?

Trails there are some conflicting statements as to the situation prior to October 9, 1961, a preponderance of the evidence, including that in the submissions and that supplied by the parties subsequent to the hearing, does not support Em ploy's' position. we believe the evidence fairly tends to establish the following:

when pickup and delivery service was first instituted by Carrier in the early thirties, Carrier entered into contracts with local firms in cities and towns; to perform the service of picking up shipments at the shippers' doors and taking

    :quern -seaVIr 4seqq. Sq psxeAoo saoaxaf oq. exeq uoTq.senb utT Slxoa aqq. 9aAX6eat ATrvOTSFasds tote sdocs sqq. 2uTpttToul. sq.aemsax2p , sxoqdnxa~ eqq. To uopTnoxd otl


                            eva'fpaF3 2aplorgos aqq, e3lvm en Axemmtls UT


    °sOTJ,Fo oq.Tusa treg etlq oi- Slooq q.F xooq. uoTqroq.s VooT oqq. q.,e qaeSH 9111. oq. q.T 2aT31n 30 paeVuT q.nq -C-rsnoTaaxd euop peq sq se onP AuOm pe4OatToo PH °seTxaeTT -ep a3lva oq. aos[d s, oanDTea00 oq. q.O3xW 4aaa 4nq eaopms wool q.,e dae~s oq. paaa 4ou

    pTp eq o4Tuag ures qJa1 xae.Txp aqn uatm =nTVTxo jo quTod eqq. qx paxridoxd ueeq .pu peq sTTFq qO'a

. Fi M3 V'~U3mdTtls qDq rjur UT STTFq qq2Fax3 Oq4 Pexedaxd oq.Faag >g pe mlxeTo
°Oq.Taeg uas 0.1 paslapuaxq. SIM suoT4'ep 0114 ncoxj pus o4 squatudrqe oq. SUTTGTax saxnpeo
-oxd TeoTxaTa pu>G 2uTqanoaoa Tre qaqa. ssfl axeq paaToxuT suoTqXqa aqq. Paq.oejje q.F
    sa ZMJ os UT T96T `6 xeqoq.op anT4oadTo xaTxxep dq epem ega qoTqa agasqo aqy


      °xsq.qXm 9114 uo q.aeTTG ST qOTqm quamaax2s rleu a 01-UT

      paxeWa SO-ETxna aqq. uaqrl Z56T(. Paaxdbapgra Pine peqsTMeq.se TTen sao-l aOTq.Otrxd aqy

      °T96T ©4uT TF4an q.T q.noqu peuTe,Ldmoo xmOU sefioTdmg taxout xo sxeaC OZ sg qottm we

      Xoeq BuTO2 sova~uoo xapan paqsTE suoTq.e$

        s aqq. 3o gnvm q.e quameexDlt 1 s.xaqd-eaaTes eqq. epTeq.no suosxad osaulq. .Aq psmxojaed 2aTSq em qxom eta q9noq',qV °uoTq.eTOTe

        pe,9aM aqq. ,To aqep aqq. oaojeq fuOT 0OTnxes eTtlq. 2uTaxojxad axan sxeATxp 3lonxq.

    glagr Acre aem-6eaP TeOOT otlq. q.nqq 9110119 4T q.tOtlq. ST OTq4 3O 9JtreOUFURTB OW, °peq.oeT Zoo saTaom puv do pa,4oTd 4,q2Taxj Ioj sq~dTeaeg 3o svuenssT °a°T 4eseo aTq,4. uT enssT

    UT xaqtq:em etlq. 2a-FxaaoO suo-fcTAoxcI ecres eq STreTq.aa99a pt;q IMg1I q4TM apam q.F TIOTqM

      qeqq. pu-e aataxbxp -EI3OOT qq.Frl aprrm ao-Exxep qoTqn q.OgxquoO tuxoj pxeptreq.s etly


      °Z `oII mTvTO uT POTOFT S9TOaeDYD peCOTO oqq. 3o qsom 4e pug OT 'op; tscaTp UT pa"FT suoT4aq.e aqq. go ztloj qnq UP 'WO pemxO.Txad Supq sim oaTnxas eqq. T96T `6 xaqo,~o0 Oq. xoTxa ·-fsrltrg apuexp ova stlq. 4tloqBnoxqq. (pssolo pus uado) suoTq.sq.s snoTxen

    .pa exoop 1 soauixsuoo pure , exedclTtlc oqq. q.v (pexeeTCap qq2Texj xOTT pnoaTTOO eaTUOm

    xog pue do pa31OTd 4q9Tej:,T xo x sq#emax 2aTnssT 2uTptllouT) sOTaxas raO-'LTTGP pua

    do SIoTd sTtlq. P3mxOSxed ae.aq Zj;dfj JO cxahTaP P02tx~ exne,C Squaiaq. at:qj. exom xod


    °darIap

    spMx0 OTg aqq. uT suoTq.ePs TV ~OOUt sapnTOUF Mill. eT qoTqh `096T TIT ZOtaOat! Pure L56T

    UT q.oexTaoD psqppgrosuoo Tal.,DT a fiq, pepesxedne aaeq su?tl sTqL °saoT4sq.s 3o xaqmnu aparoT a VaTaww0 GPM ctrl ts4OZ3xquOO Tt?npTAFpuq aqq. jO Atrem 2trgpesxadns °q.ouxq.uoo pa4Mp'-105U03 'e '4/56T uT gaTaaT2eg ^euo-9'4tlq.o .ieTnOFq~md 11.x1 aOu.xss LxeaTTep pag do

    . -SIoTd aqq. utxojxed oq. 7yll.I qq.pa eq.Mxquoo TntipTATPu-9 oquy. xaque oq ae.3eq pun eaoTq.aq.s emos qa uautaxp q.aOXq.aoo BaTxnoas fijrnOTjj-:cp suT.nuq Stan IOTXXVD .10.1seexer[q, t-r,.p:oTjG

    °aeTxrep Aq psarlo II-Toqt. uoTqrrxodxoo aq.r~xudas a e7: q.Z °.ZOTxxvo uoulmoo &-ejitj2Tq aqq. xaeO UP 913 656T uT aocq.exado ut3Gaq pun $E6'C uT PszTaz,Vxo owl (T,LXI tnou) yaarr


    °xeTxxep lq Pnea2Tsap Ws2v uOTqeq.s atlq. Oq. xeRO &euom eqq. Peuxnq. pug TTTq esaedxa

    91% no anoqs nunome atlq. po4OeTpo Aqq. `paaeaFTOP 4t12TaxT tto anp axed as2xOqo uaqrj

    pure do pe3loTd qq2Taxj, xoj sq.cdTaoox sxaddTtle 9A-e2 uamfxp q.Oaxquoo aseqy °saeu2Te

    -uoo sqq. oq. suoT"q.s aq:l cao.1U cquamdTqs 7071 VaTxaeTTop pure uoTq.aq.s 91111. oq, metlq.


      5 Ova Lz °0fI S'WIOOd

      Lz ° 0cl QHt'JAV


                                                    clqs Id <D5

SdR Std
NTIAARD 110. 27
DOCKET ITO. 27 PACE 6

(2) The Employes have not shown that through tradition, custom and practice, Telegraphers have acquired arty exclusive right to the issuance of receipts for freight picked up or monies collected at the stations involved;

(3) Employes have not shown. that prior to October 9, 1961, 1·:PTL drivers delivered LCL freight to the Agents at -the stations where it was ur4oaded and from' where the Agents had the responsibility for delivery to consignees.

(4) Over a long period of years, Carrier has had this service (issuance of receipts) performed by local draymen and MPTL truck drivers at most of the stations involved without any protest from Employes;

(5) Nothing in the Agreement forbids Carrier from assigning this type of work to persons outside the Telegraphers) Agreement;

(6) The only change in the method of operation which occurred on and after October 9, 1961 was the issuance of freight bills at San Benito and the return of monies collected to San Benito.

Since Employes have failed to prove any violation of the Agreement, the Claims must be rejected.

      FI1IDLSCS. That the Agreement was not violated.


                            AMARD


      Claims denied.


                  SPECLIL BOARD OF ADJUSTf$EIIT 110. 506


                    Roy ~ R~ ; Chairman


    1-1.2

    a. Bobo - Employe Member Member G. W. Johnsoh Carrier Member


St. Louis, Missouri December 13, 1963 File 279-249