23:0199(26)AR - Army, Oakland Army Base and AFGE Local 1157 -- 1986 FLRAdec AR
[ v23 p199 ]
23:0199(26)AR
The decision of the Authority follows:
23 FLRA No. 26 DEPARTMENT OF THE ARMY OAKLAND ARMY BASE Activity and AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, LOCAL 1157 Union Case No. 0-AR-896 DECISION I. STATEMENT OF THE CASE This matter is before the Authority on exceptions to the award of Arbitrator Robert C. Schubert filed by the Department of the Army (the Agency) under section 7122(a) of the Federal Service Labor-Management Relations Statute and part 2425 of the Authority's Rules and Regulations. /*/ II. BACKGROUND AND ARBITRATOR'S AWARD A grievance was filed in this case challenging management's determination to contract out certain activities. The grievance alleged that the Activity had violated an agency regulation pertaining to contracting out and several provisions of the parties' collective bargaining agreement. The Union argued that it was deprived of an opportunity to affect the decision of whether to contract out. The Union claimed that if it had been permitted to participate in the procurement process as required by the agreement, it could have precluded the Activity's determination to contract out. The Arbitrator found that the Activity violated the agreement by its failure to provide the Union with a copy of the revised statement of work and a copy of the bid solicitation and by its failure to notify the Union of certain meetings relating to the proposed procurement action. With respect to a remedy the Arbitrator rejected the Activity's argument that to cancel the procurement action the Union had to establish that but for the violations of the agreement, the decision of whether to contract out would have been different. The Arbitrator stated that it was difficult to prove that the violations actually changed the result. Instead, he determined that it was sufficient that the Union had established that it was more likely than not that the decision to contract out would have been different if the Activity had not violated the agreement. The Arbitrator therefore sustained the grievance and, as a remedy, directed the Activity to cancel the procurement action and to reinstate any employees removed as a result of the action to their former positions with backpay. The Arbitrator also awarded the Union attorney fees. III. FIRST EXCEPTION A. Contentions In its first exception, the Agency contends that by finding the grievance to be arbitrable, the award is deficient as contrary to law and regulation. B. Analysis and Conclusions The Authority concludes that the Agency fails to establish that by finding the grievance to be arbitrable, the award is deficient. To the extent that the grievance claimed a violation of the collective bargaining agreement, the Agency fails to establish that the matter of the Activity's compliance with the terms of the agreement was not properly grievable and arbitrable. To the extent that the grievance subjected the disputed procurement action to arbitral review, the Agency likewise fails to establish that the award is deficient. As noted, the Union contended in its grievance that in deciding to contract out the Activity had violated agency procurement regulations. Primarily, the Union also contended that had the agreement not been violated, the Activity's determination to contract out would have been precluded by applicable procurement law and regulation. The Authority has previously indicated that a grievance claiming that a procurement action was not in accordance with applicable procurement law and regulation is grievable and arbitrable under the Statute and is not precluded by law or regulation. See General Services Administration and American Federation of Government Employees, AFL-CIO, Council 236, 22 FLRA No. 84 (1986); Headquarters, 97th Combat Support Group (SAC), Blytheville Air Force Base, Arkansas and American Federation of Government Employees, AFL-CIO, Local 2840, 22 FLRA No. 72 (1986); American Federation of Government Employees, Local 1904, AFL-CIO and United States Army Communications and Electronics Materiel Readiness Command, 16 FLRA 358 (1984); American Federation of Government Employees, AFL-CIO, National Council of EEOC Locals and Equal Employment Opportunity Commission, 10 FLRA 3 (1982) (Proposal 1), enforced sub nom. EEOC v. FLRA, 744 F.2d 842 (D.C. Cir. 1984), cert. dismissed, 106 S. Ct. 1678 (1986) (per curiam). Further, our decision in Congressional Research Employees Association and The Library of Congress, 23 FLRA No. 15 (1986), where we found a grievance challenging a procurement action on the basis of a provision of the collective bargaining agreement not to be arbitrable, is distinguishable. In contrast to that case, the Union in this case is not seeking to enforce a provision which is inconsistent with the Activity's right to contract out. Accordingly, because the grievance challenged the propriety under procurement law and regulation of the disputed procurement action, the grievance was arbitrable. IV. SECOND EXCEPTION A. Contentions In its second exception, the Agency primarily contends that the Arbitrator's award ordering cancellation of the procurement action is contrary to section 7106(a)(2)(B) of the Statute. B. Analysis and Conclusions In Headquarters, 97th Combat Support Group (SAC), Blytheville Air Force Base, Arkansas and American Federation of Government Employees, AFL-CIO, Local 2840, 22 FLRA No. 72 (1986), the Authority addressed for the first time the remedial authority of an arbitrator in resolving grievances disputing determinations by agencies to contract out agency work. In sum, the Authority held that under the Statute and procurement law and regulation, arbitrators are not authorized to cancel a procurement action. We also held that arbitrators are authorized to sustain grievances challenging a decision to contract out and direct agencies to reconstruct the actions on specific grounds only. Applying our decision in Blytheville AFB to this case, we conclude that the Arbitrator was not authorized either to cancel the procurement action or to sustain the grievance to the extent that it directly challenged the action. The Arbitrator's order that the Activity cancel the procurement action is clearly deficient under section 7106(a)(2)(B) of the Statute. The Arbitrator's order that the Activity reinstate with backpay any employees removed as a result of the procurement action is also deficient because it follows directly from the cancellation. See Naval Air Station, Whiting Field and American Federation of Government Employees, Local Union No. 1954, 22 FLRA No. 102 (1986). Similarly, without an award of backpay, the Arbitrator's award of reasonable attorney fees is likewise deficient. See U.S. Army Missile Command, Redstone Arsenal, Alabama and Local 1858, American Federation of Government Employees, AFL-CIO, 18 FLRA No. 50 (1985). We also find that the Arbitrator was not authorized to sustain the challenge to the disputed procurement action and could not have properly directed reconstruction in this case. The Union essentially claimed that had the agreement not been violated, it might have been able to preclude, in accordance with procurement law and regulation, the Activity's determination to contract out. However, the Arbitrator stated that it was difficult to prove that but for the violations of the collective bargaining agreement, the decision to contract out could not have properly occurred and that it was sufficient to conclude that more likely than not the decision to contract out would have been precluded. Accordingly, his award sustaining the challenge to the procurement action is deficient. We decided in Blytheville AFB, slip op. at 6, that an arbitrator can sustain a challenge to a procurement action and order reconstruction only on the basis that the agency failed to comply with mandatory and nondiscretionary provisions of applicable procurement law or regulation. Since the Arbitrator made no such specific finding in this case, he was not authorized to sustain the grievance to the extent that it directly challenged the procurement action, and he could not have properly directed reconstruction. We note, however, that nothing in Blytheville AFB precluded the Arbitrator from finding, as he did, that the Activity violated the agreement by its failure to provide the Union with a copy of the revised statement of work and a copy of the bid solicitation and by its failure to notify the Union of certain meetings relating to the proposed procurement action. Nor was the Arbitrator precluded from sustaining the grievance to the extent of the claimed violations of the agreement and from awarding a proper and appropriate remedy for that violation. Because the Arbitrator awarded a remedy for this violation without the guidance that has now been provided by Blytheville AFB, we find that the award should be modified to provide an appropriate remedy. The Activity bargained and agreed to these provisions as part of the collective bargaining agreement. We admonish the Activity to abide by these provisions and will order a remedy accordingly. V. DECISION For the reasons stated above, the Arbitrator's award is modified to provide as follows: The grievance is sustained to the extent of the claimed violations of Article XXIX of the applicable collective bargaining agreement. The Activity shall cease and desist from failing to comply with the requirements of that article. Issued, Washington, D.C. August 15, 1986. /s/ Jerry L. Calhoun Jerry L. Calhoun, Chairman /s/ Henry B. Frazier III Henry B. Frazier III, Member FEDERAL LABOR RELATIONS AUTHORITY --------------- FOOTNOTES$ --------------- (*) The Agency also requested a stay of the Arbitrator's award which request the Authority granted. The Union filed an opposition to the Agency's exceptions and stay request. The Union subsequently filed a request for oral argument concerning the Authority's Order granting the Agency's request for a stay of the award. Because no basis is presented for reconsidering, by oral argument or otherwise, the Authority's Order granting the stay, the Union's request is denied.