The Alberta Labour Relations Board has ordered three separate groups of AltaSteel grievances consolidated after finding that the employer’s reliance on earlier discipline to justify dismissals linked the disputes. The rulings change how the grievances are assigned for arbitration; they do not decide whether the discipline or terminations were justified.
In United Steelworkers, Local Union No. 5220 v. AltaSteel Inc., 2026 ALRB 119, and the companion decisions 2026 ALRB 120 and 2026 ALRB 121, Vice-Chair William J. Johnson explained orders made on July 21, 2026. The written reasons are dated September 25, 2026. Each application concerned a group of grievances filed on behalf of an unnamed union member.
Earlier discipline was part of the dismissal dispute
The union sought consolidation under section 67.1 of the Labour Relations Code. In each application, the termination letter referred to preceding disciplinary measures in support of dismissal, while grievances challenging those measures remained unresolved. Johnson found that deciding the termination grievance would require the arbitrator to address whether the earlier discipline was valid.
AltaSteel argued that there were no common circumstances. It also warned that different witnesses for different grievances could create confusion and unfairness. If consolidation were ordered, the employer wanted the grievances heard consecutively. The union instead sought a direction that they be heard together.
The board applied its earlier interpretation of the statutory consolidation power: grievances need not be identical. There must be sufficient common legal or factual circumstances for consolidation to address preliminary issues or eliminate unnecessary duplication, with fairness and efficiency kept in view. The reasons apply that existing approach rather than announce a new test.
Here, the employer’s use of progressive discipline supplied the connection. Johnson concluded that consolidation would avoid unnecessary duplication and improve the efficiency of the proceedings, while creating the possibility of lower costs. He did not quantify savings or make an award of costs.
Three groups, with hearing order left open
The first decision consolidated four grievances concerning three suspensions and a termination and assigned them to arbitrator James Casey. The second consolidated four grievances concerning a written warning, a suspension, a suspension pending investigation and a termination, assigning that group to arbitrator Mia Norrie.
The third decision consolidated six grievances and assigned them to arbitrator Mark Asbell. That group included challenges to three suspensions, two grievances concerning an investigation while suspended and an asserted breach of privacy rights, and a termination. The reference to a privacy grievance was a description of the dispute, not a finding that privacy rights had been breached.
Those orders created three separate consolidated groups, not one proceeding combining all fourteen grievances. The collective agreement provided for named arbitrators to receive referrals on a rotating basis. In each decision, the board assigned the group to the arbitrator understood to be next on the rotation list.
Johnson declined to dictate whether the grievances within each group must be heard together or consecutively. He left that question to the appointed arbitrator, whose statutory powers could address the fairness and efficiency of the hearing. Consolidation therefore did not give either side its requested direction on hearing sequence.
The decisions granted procedural relief without resolving the underlying employment disputes. They ordered no reinstatement or compensation and made no findings of misconduct. Nor do these reasons establish what happened in the arbitrations after the July orders.
Sources: 2026 ALRB 119; 2026 ALRB 120; 2026 ALRB 121.
