27 January 2022 Volume 3/22 with selected Decision Summaries for the week ending Friday, 21 January 2022.
Consultation: The future of online proceedings
Decisions of the Fair Work Commission
Other Fair Work Commission decisions of note
Fair Work Commission Addresses
As a result of the COVID-19 pandemic the Fair Work Commission moved to holding conferences and hearings online. As the world gradually returns to a ‘new normal’, the Commission is considering what approach we should take to online proceedings into the future.
The President has published a discussion paper on the future of online proceedings at the Commission.
We are seeking feedback on:
● any issues with how online hearings and conferences are currently used
● any benefits of how online hearings and conference are currently used
● users’ experiences with, and perceptions of, online hearings and conferences at the Commission.
Learn more: The future of online proceedings
Any comments or feedback on the discussion paper should be emailed to consultation@fwc.gov.au by close of business on Friday, 11 February 2022.
The summaries of decisions contained in this Bulletin are not a substitute for the published reasons for the Commission's decisions nor are they to be used in any later consideration of the Commission's reasons.
Summaries of selected decisions signed and filed during the week ending Friday, 21 January 2022.
1 |
ENTERPRISE AGREEMENTS – dispute about matter arising under agreement – vaccine mandate – s.739 Fair Work Act 2009 – application by Construction, Forestry, Maritime, Mining and Energy Union – Mining and Energy Division (CFMMEU), Communications, Electrical, Electronic, Energy, Information, Postal, Plumbing and Allied Services Union of Australia (CEPU) and 'Automotive, Food, Metals, Engineering, Printing and Kindred Industries Union' known as the Australian Manufacturing Workers' Union (AMWU) (unions) for Commission to deal with a dispute in accordance with dispute settlement procedure in various enterprise agreements – on 7 October 2021, BHP Group of Companies notified employees of a site access requirement that required employees to provide evidence of vaccination against COVID-19 as condition of entry to Queensland coal mines and related sites – conferences were held at the Commission in December 2021 and January 2022, after which the unions and respondents agreed to a Consultation Plan, whereby employees and their representatives could provide feedback on the site access requirement so the respondents could consider same before making a final decision on whether to introduce the site access requirement – after the Consultation Plan process, the unions accepted that all issues in dispute had been resolved except that the unions maintained that the site access requirement was invalid due to the rights of employees under the Privacy Act 1988 and their rights to bodily integrity – the parties sought a recommendation from the Commission in the form of an answer to the question: 'Is the Site Access Requirement a lawful and reasonable direction or not, having regard to (1) the Privacy Act and (2) the right to bodily integrity?' – Commission noted the decision in Mt Arthur Coal [[2021] FWCFB 6059] considered a site access requirement that was essentially in the same terms as that in the present case – AMWU submitted that the Full Bench in Mt Arthur Coal did not make findings on the Privacy Act and bodily integrity issues – Commission noted that 'Matters foreshadowed by the Full Bench [in Mt Arthur Coal] have eventuated including the increase in infection rates as borders open, exacerbated by the spread of the more infectious Omicron strain' – Commission also noted added difficulties of access to PCR and rapid antigen testing, and that it was 'strongly arguable' that such testing 'could at best, supplement, rather than replace vaccination' – noted that positive cases of COVID-19 had been detected at the respondents' Queensland mines – in the present case, CFMMEU and CEPU contended that employees' consent to provide sensitive information (namely, vaccination information) is vitiated by the threat of discipline or termination of employment – relied on Lee v Superior Wood – Commission rejected that argument and distinguished Lee v Superior Wood on its facts, finding that it was of limited relevance in the circumstances of this case – Commission concluded that the practical effect of the site access requirement is to pressure employees to surrender their rights under the Privacy Act by providing the respondents with sensitive health information about their vaccination status – Commission held that the pressure created by the site access requirement is not coercion or economic duress that vitiates employees' consent to provide vaccination information – 'economic duress requires conduct that goes beyond what the law is prepared to countenance as being legitimate or unconscionable conduct or conduct of a similar kind' [Crescendo Management P/L] – unions proposed an alternative method of verifying vaccination status, namely allowing employees to use the QR Check-in App displaying a green tick, to gain entry to sites – Commission rejected this proposal and found it would cause significant disruption to the respondents and employees – Commission found the unions' proposal would place all persons at the worksite at risk because it would be more susceptible to human error and the respondents, having no record of whether a worker's vaccination status had been verified, could not be sure that the site access requirement was being met – concluded that the site access requirement did not contravene the Privacy Act and was not unlawful on that basis, and was not unreasonable having regard to privacy or bodily integrity issues – Commission found that the answer to the question was 'Yes, the Site Access Requirement is a lawful and reasonable direction having regard to the Privacy Act and the right to bodily integrity'. | |||
Construction, Forestry, Maritime, Mining and Energy Union and Ors v BHP Coal P/L t/a BHP Billiton Mitsubishi Alliance/BMA and Ors | ||||
C2021/8213 and Ors |
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Asbury DP |
Brisbane |
21 January 2022 | ||
2 |
ENTERPRISE AGREEMENTS – dispute about matter arising under agreement – stand down – ss.526, 739 Fair Work Act 2009 – 2 separate applications lodged by the Maritime Union of Australia Division of the Construction, Forestry, Maritime, Mining and Energy Union (MUA) in respect of a dispute with Qube Ports P/L t/a Qube Ports & Bulk (Qube) – s.526 application concerned the stand down of Mr Johnson, an MUA member who is employed as a stevedore to perform work at Qube's operations on Sydney Harbour – s.739 application related to a dispute under the Qube Ports P/L Sydney Harbour Enterprise Agreement 2016 (Agreement) – if the s.739 dispute was determined in the MUA's favour it did not require the s.526 application to be dealt with as it involved seeking the same remedy – question to be determined: 'In the events that have happened and in circumstances where Mr Johnson has been purportedly stood down by the respondent since April 2020 and has been told that he will be stood down potentially indefinitely, is Mr Johnson's position redundant?' – Qube operates ports and provides stevedoring services involving the loading of cargo onto and from ships at over 30 ports throughout Australia, including at the Port of Sydney Harbour (Sydney Harbour) – Sydney Harbour is the only port where stevedoring services relate solely to loading and unloading of cargo from passenger cruise ships – as a result of the COVID-19 pandemic and associated government restrictions, cruise ships have been prevented from entering into Australian waters and at Australian ports since 18 March 2020 – as a consequence, Qube has not been able to service any cruise ships at Sydney Harbour – on 1 April 2020 Qube notified its Sydney Harbour employees that it was activating the 'Negative Circumstances' provisions in subclause 13.2 of the Agreement – clause 13 Economic conditions of the Agreement notes that general stevedoring is subject to impacts from economic peaks and troughs – the clause then deals with what may occur when there is a downturn in work – Mr Johnson was initially 'stood down' in May 2020 under the JobKeeper stand down provisions previously contained in Part 6-4C of the FW Act, and subsequently in December 2020 he was stood down under s.524 – clause 13.3 of the Agreement states that there are 6 listed Steps which 'are to be followed' – Steps 1 to 3 are to be completed within 30 days after which Step 4 is to commence – Step 4 states that it 'will be triggered' if mitigation measures in Steps 2 and 3 have not been effective – for the purposes of Mr Johnson's circumstances Steps 2 and 3 did not resolve his Hours Shortfall – under Step 4, Qube are to declare the number of proposed redundancies required based on the Economics Conditions Data and employees may then express an interest to volunteer for redundancy – Commission found there had been no declaration by Qube of proposed redundancies and Mr Johnson has not been offered a voluntary redundancy under Step 4 – Commission found it clear on the evidence that Mr Johnson's position at Sydney Harbour has not been required to be performed since March 2020 and this position has not changed – Commission found it was not reasonable to have refused a voluntary redundancy for Mr Johnson – Qube submitted that the 'local agreement' reached for employees at Sydney Harbour including Mr Johnson to work at Port Kembla under the Port Kembla enterprise agreement was an effective mitigation measure and that it was Mr Johnson's own decision not to avail himself of this measure that results in his Hours Shortfall – Port Kembla is approximately 95 kilometres from Sydney Harbour – Mr Johnson did not accept the offer to work at Port Kembla and raised a number of issues related to his personal circumstances, including the financial impact that he considered did not make the offer acceptable alternative employment or reasonable for him to work at Port Kembla – Commission was satisfied that the offer to work at Port Kembla was not an acceptable alternate offer of employment – in the period between the cessation of the JobKeeper enabling stand down direction (27 September 2020) and the stand down notice under s.524 of the FW Act (issued on 21 December 2020) the provisions of Step 4 were in operation but were not acted upon by Qube – Commission found Step 4 mandates that Qube take certain actions where the mitigation measures in Steps 2 and 3 have not been effective – such action should have been taken at least in the period immediately following cessation of the JobKeeper enabling stand down direction and well before the standing down of Mr Johnson under s.524 on 21 December 2020 – Commission determined that in accordance with clause 13.3.3 of the Agreement, Qube was required to action Step 4 between the period 30 April 2020 and 21 December 2020 excluding the period when Mr Johnson was subject to a JobKeeper enabling stand down direction – Commission found that during this period Qube failed to comply with Step 4 – Qube are to declare Mr Johnson's position at Sydney Harbour redundant and offer him a voluntary redundancy – no requirement to consider the MUA's s.526 application. | |||
Construction, Forestry, Maritime, Mining and Energy Union v Qube Ports P/L t/a Qube Ports & Bulk | ||||
C2021/3780 and Anor |
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Bull DP |
Sydney |
19 January 2022 | ||
3 |
TERMINATION OF EMPLOYMENT – valid reason – flexible working arrangement – ss.387, 394 Fair Work Act 2009 – applicant employed by Australian Federal Police (AFP) – duties involved updating social media content – in around 2017, applicant was diagnosed with some health issues – pursuant to medical advice, applicant had his workstation relocated within AFP headquarters – in March 2020, applicant made further request to relocate again for health reasons – this request was accompanied by medical advice recommending relocation, or failing that, a work from home arrangement – shortly after making this request, applicant began working from home due to COVID-19 lockdowns – continued to work from home until he took a period of personal leave – on his return in January 2021, applicant continued to work from home without approval – respondent made multiple attempts throughout January-March 2021 to contact applicant, requesting applicant attend office and engage with a workplace rehabilitation provider – applicant did not reply to respondent's entreaties, refusing to return to office, and failed to return calls and emails – on 29 March 2021 respondent wrote to applicant to issue a formal direction to attend work – the letter noted s.40 of the AFP Act 1979 and clause 8.3 of the AFP Commissioner's Order on Professional Standards, that a failure to comply with the direction could result in disciplinary action up to and including termination – despite the formal direction, applicant did not attend the office and continued to work from home – an email exchange between applicant and respondent followed, wherein respondent alerted applicant to the breach of the 29 March 2021 direction and again attempted to direct applicant to attend the office – after making repeated reiterations of the direction throughout April to no effect, on 28 April 2021 respondent sent a letter to applicant advising respondent was considering terminating applicant's employment pursuant to s.28 of the AFP Act, on the basis that he had continually failed to comply with the lawful direction which required him to physically attend the office – on 13 May 2021 applicant responded, contending he had a lawful right to work from home due to his disability – attached to his response was a medical certificate attesting to his condition and advocating work from home – on 25 May 2021 the respondent issued a notice of termination for failure to comply with a lawful direction – before the Commission, applicant argued he had a legal entitlement to flexible work due to his disabilities such that any directions to attend the office, and any termination for failure to do so, were unlawful – respondent contended the directions were lawful and reasonable – Commission observed it was well established that a failure to follow a lawful and reasonable direction may constitute a valid reason for dismissal – held the respondent's directions were lawful and reasonable – noted 10 occasions when applicant failed to comply with a direction – concluded applicant's refusal to attend workplace amounted to a refusal to comply with a lawful and reasonable direction and constituted a valid reason for his dismissal – found applicant notified of the reason for dismissal and given opportunity to respond – concluded termination was not harsh, unjust or unreasonable – application dismissed. | |||
Lubiejewski v Australian Federal Police | ||||
U2021/5233 |
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Dean DP |
Canberra |
17 January 2022 | ||
4 |
TERMINATION OF EMPLOYMENT – incapacity – mandatory vaccination – s.394 Fair Work Act 2009 – unfair dismissal application – applicant provided personal care assistance to residents at aged care facility – respondent implemented mandatory COVID-19 vaccination policy, which reflected requirements of a public health order issued by New South Wales Government – public health order prohibited employees of aged care facilities from entering such facilities as of 17 September 2021, unless they received one dose of a COVID-19 vaccine or had an exemption, such as where a medical practitioner certified a medical contraindication – in the period leading up to 17 September, respondent gave employees a COVID-19 vaccine exemption request form, to be completed if they wished to seek exemption due to medical contraindication or conscientious objection – applicant did not give evidence of vaccination, complete the exemption request form, or raise a medical contraindication – instead, applicant wrote to respondent on 29 August raising various concerns including that the public health order was unlawful and invalid, and that respondent's request for medical information was in breach of the right to privacy in the Privacy Act 1988 – respondent replied in writing on 1 September that applicant could make an exemption request – by further letter dated 2 September, applicant raised various concerns – by reply letter dated 6 September, respondent said it considered applicant's correspondence to be a conscientious objection; advised there were no alternative options for applicant's continued employment; and invited applicant to show cause why her employment should continue – applicant sent letter dated 7 September which raised many of the same issues addressed in earlier communications – on 13 September, applicant advised by email that she did not consent to face to face communication and expected a written response – on 15 September, respondent sent applicant a letter terminating her employment and advising she would be paid in lieu of notice – Commission found respondent had a valid reason to dismiss applicant, because she did not provide evidence of vaccination or medical contraindication and thus the public health order prohibited her from entering her workplace from 17 September, such that applicant was not able to fulfil the requirements of her role from that date – applicant contended that respondent could have stood her down on unpaid leave until the public health order expired – Commission did not consider there would have been any real utility in standing applicant down for an indefinite period, as the absence of a public health order would not have altered respondent's obligation to take reasonable steps to ensure health and safety of employees and the facility's residents, who were vulnerable – Commission did not consider there was any realistic likelihood that respondent would change its policy in the foreseeable future to no longer require staff to be vaccinated – Commission did not accept applicant's contention that she was dismissed because she exercised a right to privacy in relation to her medical information – found that applicant was dismissed because the public health order prohibited her from working and respondent had to comply with that order – Commission found that the public health order required employees seeking an exemption to provide to the facility operator evidence of their medical contraindication – that is, the respondent was required by law to obtain medical information where an individual sought an exemption, and thus the respondent was not in breach of the Privacy Act – Commission noted that once a public health order is in force and applies to a particular workplace, the employer is obliged to comply unless or until the order is declared invalid or unlawful by a court of competent jurisdiction – Commission noted it does not have jurisdiction to determine the validity of a public health order, but Court in Kassam v Hazzard had found that the public health order was not invalid – Commission found that respondent provided procedural fairness to applicant prior to deciding to dismiss her – applicant was not exempt from public health order, and was thus prohibited from undertaking her role as of 17 September, and there were no alternative duties available – found that dismissal was not harsh, unjust or unreasonable and thus not unfair – application dismissed. | |||
Shepheard v Calvary Health Care t/a Little Company of Mary Health Care Limited | ||||
U2021/8839 |
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Saunders DP |
Newcastle |
20 January 2022 | ||
5 |
TERMINATION OF EMPLOYMENT – incapacity – inherent requirements – mandatory vaccination – s.394 Fair Work Act 2009 – application for unfair dismissal remedy – applicant employed since 2018 as electrician across various sites including residential aged care facilities, independent living villages, social centres – advised in May 2020 of requirement to get a flu vaccine to continue to work – had concerns but complied with orders – in February 2021, Western Australian Government issued the Visitors to Residential Aged Care Facilities Directions (No 7) (Direction) – Direction required respondent to take all reasonable steps to ensure employees did not enter residential aged care facility without flu vaccination – in March 2021, respondent issued direction to employees that they would not be able to enter respondent's facilities after 31 May 2021 unless they provided evidence of flu vaccination – applicant told respondent he did not refuse vaccine but wanted respondent to accept liability for any adverse reaction to the vaccine – applicant sent respondent notices with questions – alleged respondent did not address his concerns, refused to accept liability for any damage caused by vaccination, and threatened to his terminate employment if he did not conform with State Government direction – applicant alleged it was unreasonable for respondent to expect annual vaccination if it was not in his contract – applicant claimed respondent would need his consent to terminate employment contract and he did not give that consent – applicant conceded he was provided with an exemption form for his medical practitioner to complete, after raising concerns in May 2021 – respondent stated applicant did not return the exemption form – respondent stated applicant was informed that direction to get flu vaccine was lawful and reasonable and he could not complete his duties without vaccination – respondent alleged there were no vacant roles for applicant to be redeployed into – respondent alleged employment terminated due to applicant's inability to perform inherent requirement of his role – Commission found it an inherent requirement of applicant's employment that he attend residential aged care facilities – found that both applicant and respondent were subject to the Direction and that respondent had no control over the requirement for applicant to be vaccinated – found that none of the exceptions in s.8 of Direction applied to applicant – found that because applicant did not have a current flu vaccination respondent was obliged to take all reasonable steps to ensure applicant did not enter a residential aged care facility – concluded that where respondent was complying with the Direction, which was legally binding on them, their direction to employees to provide proof of flu vaccination by 31 May 2021 was lawful and reasonable – held that applicant's failure to comply with respondent's direction was a valid reason for dismissal, related to his conduct – Commission found that the combination of the Direction and applicant's failure to be vaccinated meant applicant was not able to perform inherent requirements of his job, which was also a valid reason for dismissal, related to his capacity – held that respondent had properly considered alternatives – Commission satisfied that dismissal was not harsh, unjust or unreasonable – found dismissal was not unfair – application dismissed. | |||
Tew v The Bethanie Group Inc. t/a Bethanie Aged Care | ||||
U2021/6794 |
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Williams C |
Perth |
20 January 2022 | ||
Murdoch v Uambi 775 P/L t/a Altschwager Family Funerals | ||
TERMINATION OF EMPLOYMENT – casual – regular and systematic – ss.384, 394 Fair Work Act 2009 – applicant sought remedy for unfair dismissal – respondent submitted applicant had not been systematically employed and therefore did not meet minimum employment period – respondent further submitted that applicant not dismissed – applicant commenced employment as casual assistant funeral director in July 2019 – casual employees required to work when death arose in community and respondent's business was contracted – the last shift that the applicant worked for respondent was in August 2021 – applicant turned down requests for further work in August and September 2021 – applicant's manager emailed applicant at 1:17pm on 3 November 2021 offering to return applicant's personal property (a DVD) and requesting that applicant return her key and vest – applicant took this to mean she had been dismissed – applicant posted about presumed dismissal on personal Facebook account – colleague forwarded Facebook post to respondent – respondent decided on evening of 3 November to remove applicant from employment books and no longer offer shifts due to the Facebook post – respondent did not inform applicant of this decision – Commission noted that, for the purposes of s.384(2) of the FW Act, regular work may be frequent despite being unpredictable and systematic work includes a pattern of engagement occurring as a consequence of business notwithstanding that an employee may not foresee a precise pattern – Commission considered unpredictability of work inherent to the respondent's business, because it was dependent on there being a death in the local community – Commission considered applicant averaged one day per fortnight working for the respondent in final year of employment – Commission considered that applicant was routinely considered for available work and subject to a system for being offered work – Commission satisfied applicant's employment was regular and systematic under s.384(2)(a)(i) despite being unpredictable – in May 2021, applicant was requested to provide evidence of flu vaccination (which she did provide) and had not been informed of any change of working circumstances or performance concerns – Commission satisfied applicant had reasonable expectation of continuing employment on a regular and systematic basis under s.384(2)(a)(ii) – Commission found applicant met minimum period of service – Commission considered that primary purpose of 3 November email was not dismissal – primary purpose was to notify applicant that respondent had found applicant's DVD, and to arrange return of key and vest, and there were operational reasons for asking for return of key and vest – Commission considered that respondent's subsequent decision, after seeing applicant's Facebook post, not to offer applicant further shifts constituted termination of employment despite not being communicated to applicant – Commission found applicant dismissed on the evening of 3 November – jurisdictional objections dismissed – matter remitted to conciliator. | ||
U2021/10185 |
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Anderson DP |
Adelaide |
18 January 2022 |
Andrews v Pradella Developments P/L and Anor | ||
GENERAL PROTECTIONS – dismissal dispute – s.365 Fair Work Act 2009 – application to deal with contraventions involving dismissal – jurisdictional objection – whether applicant was dismissed – applicant alleges he was notified of his dismissal 1 September 2021, effective immediately – respondents assert applicant resigned – applicant applied for leave on multiple occasions but was denied – applicant submits purpose of leave was for medical procedure and recovery – respondents declined leave requests due to project milestone deadline – applicant key contributor to meeting project timeframe – Commission found applicant repeatedly requesting leave did not demonstrate his intention to leave employment contract – Commission found applicant requesting leave and respondents denying requests was not repudiation of employment contract by either party – on 1 September 2021 second respondent advised final leave request denied – second respondent stated they were at an 'impasse' – applicant took conversation to be a dismissal – on the following day, second respondent raised mutual separation as solution – second respondent reiterated mutual agreement to end employment in email of 3 September 2021 with draft Settlement Deed – applicant replied to email indicating termination had occurred on 1 September 2021 – Commission found applicant denied opportunity to actualise his intention to take leave or change his mind – respondents' action was precipitous – respondents terminated applicant before applicant had opportunity to do anything warranting termination – Commission found applicant was terminated at respondents' initiative [Bupa v Shahin Tavassoli] – jurisdictional objection dismissed – application to proceed. | ||
C2021/6053 |
||
Lake DP |
Brisbane |
17 January 2022 |
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