[1993] OLRB REP. SEPTEMBER 849
3309-90-R Brewery, Malt & Soft Drink Workers, Local 304, Applicant v. MDS Health Group Limited, Responding Party
BEFORE: R. 0. MacDowell, Alternate Chair, and Board Members J. A. Ronson and D. A. Patterson.
APPEARANCES: J. Cameron Nelson for the applicant; David Corbett, T. McMann and Sandra Lemon for the responding party.
DECISION OF THE BOARD; September 2, 1993
I
This is an application for certification.
The parties are agreed that the application is timely, and that the applicant is a trade union within the meaning of the Act.
The parties are not agreed on the description of the unit(s) of the company's employees appropriate for collective bargaining.
The union is seeking to represent employees working at 25 Leonard Avenue, which is one of a number of MDS locations in Metropolitan Toronto. The union proposes two bargaining units of those employees: one comprising all full-time employees working at 25 Leonard Avenue, and a second comprising all part-time employees (i.e. less than twenty-four hours per week) working at 25 Leonard Avenue. The union does not seek to represent employees working at any other location.
The union submits that its proposed units are "appropriate" for collective bargaining, even though there may well be broader employee groupings which would also be appropriate. The union urges the Board to accept its proposed "site-specific" units so that it can gain a foothold in the company's organization. In the union's submission, ease of organization and employee self-determination should override the employer's concern about fragmentation. The union acknowledges that its proposed units represent a small subdivision of the company's organization and workforce in Metropolitan Toronto. However, the union maintains that it is not required to organize the broadest or most comprehensive bargaining units - only appropriate ones - and, in the union's submission, its two proposed units meet that test.
The company replies that the sub-division of its work force proposed by the union is not appropriate for collective bargaining purposes. In the company's submission, the unit(s) of employees appropriate for collective bargaining should encompass all of its employees at its various locations in the Metropolitan Toronto - not just the small group working at 25 Leonard Avenue. A "full-time" and "part-time" distinction may be sustainable on this broader basis, but not within one of a number of similar workplaces. In other words, while the union proposes a full-time unit and a part-time unit confined to a single location, the company proposes a full-time unit and a part-time unit defined on a Metro-wide basis.
In the alternative, the company asserts that, at the very least, the bargaining units should encompass the three locations (which includes 25 Leonard Avenue) where workers perform what the company describes as "home-care" functions. This is an administrative sub-division within its organization that has somewhat different work characteristics and might, for that reason, be treated as a group. However, from the company's perspective, this is very much an "alternative" submission, involving bargaining units only slightly more attractive than those proposed by the union. The company's principal position is that orderly collective bargaining demands bargaining units that are Metro-wide. Anything else would produce an unduly fragmented bargaining structure with adverse consequences for the employer and the employees. In the company's submission, geographic location does not provide a sound labour relations basis for subdividing the employer's organization for collective bargaining purposes.
The facts are not in dispute.
II
MDS Health Group Limited ("MDS") provides medical testing and laboratory services across Canada. It is one of a number of companies that provide such services. The tests are prescribed by physicians, whose patients either visit a convenient MDS location to have the testing done, or make arrangements for an MDS employee to visit them in their homes, or in the institution where the patients reside. MDS has one hundred and forty locations in Ontario.
In Metropolitan Toronto, MDS has a main reference laboratory in Etobicoke, together with twenty-six other locations scattered across the municipal area. Every MDS location has, at a minimum, a "specimen collection centre" ("SCC") where patients attend, and specimens are taken by trained phlebotomists. Some SCC locations also have a testing laboratory.
Of the twenty-seven MDS locations in Metro, eighteen consist solely of a walk-in SCC, and of these, nine are very small, having only one employee (phlebotomist). Seven locations have both an SCC and a laboratory facility, where specimen analysis is done. Finally, three of the SCC's have a contingent of mobile phlebotomists who make the home visits to which we have already referred. The SCC at 25 Leonard Avenue is one of these. The others are 2425 Dundas Street and 1371 Neilson Road.
Attached to this decision and marked "Chart A", is a visual representation of MDS locations throughout Metropolitan Toronto. The chart identifies the street address, the mix of functions or facilities present at each site, and the reporting relationships of the employees working there. The chart also indicates the geographic proximity of the various locations and, incidentally, shows what the bargaining structure would look like if each location were found to be a separate bargaining unit. Since the nine single-person SCC's could not, in law, be site specific bargaining units (see section 6(1) of the Act), these locations would have to be grouped together, or associated in some fashion with other more populous locations. However, even if the Board were to reject the full-time/part-time distinction urged upon us by both parties, the union's proposal could produce a highly fragmented bargaining structure, with well over a dozen bargaining units and possibly many more.
As will be seen from the chart, the SCC's are geographically distributed throughout Metropolitan Toronto; moreover, the facilities vary in size and complexity. It is quite common for employees at one site to report to managerial personnel based somewhere else. For example, the mobile phlebotomists at 25 Leonard Avenue report to a supervisor at 2917 Bloor Street, where their work orders originate. The employees in the SCC at 360 College Street (which is two blocks away from 25 Leonard Avenue) also report to 2917 Bloor Street. So do the employees at 2698 Dundas Street. There is one supervisor for these three locations. By contrast, employees at 750 Dundas Street (which is across the street from 25 Leonard Avenue) report to 2425 Bloor Street.
The chart illustrates the geographic distribution of MDS locations and their rough proximity to each other, however, as counsel explained, there is nothing particularly significant or valuable about the location itself. An SCC is not a grocery store, a theatre or a factory. The SCC's are situated in their present locations because of favourable lease arrangements. That is why there are two SCC's across the street from one another, and a third SCC only a couple of blocks away. These locations can be, and have been, moved or combined, depending upon the organizational needs of MDS and the economics of the real estate market. As counsel put it: there is no "magic" in a particular location or street address.
The network, as a whole, must blanket Metropolitan Toronto, but particular locations and functions are not fixed. For example, at the time the certification application was filed, there was a lab facility at 25 Leonard Avenue which has since been moved elsewhere. The evidence does not disclose whether one of the six existing satellite laboratories was once at 25 Leonard and has been moved to its present location, or, alternatively, whether the lab functions formerly performed at 25 Leonard have been shifted to one or more of the other satellite laboratories and/or the main laboratory in Etobicoke, or whether those lab functions were merely discontinued. For present purposes, it does not matter. The point is: the organization is fluid and flexible.
Although there are now seven laboratories in Metropolitan Toronto (including the big one tn Etobicoke) not all laboratories are equipped to perform all required testing. A specimen procured in one area of the city will not necessarily be tested at the closest laboratory, and may be tested at more than one lab before the results are transmitted to the recipient. There is a regular flow of work, back and forth, between SCC's and one or more labs - hence the need for a large number of couriers, and the need for telephone co-ordination of the home-care phlebotomists attached to 2425 Bloor Street, 25 Leonard Avenue, and 1371 Neilson Road. The company employs approximately thirty-two couriers to carry samples and related documentation between the SCC's and the various labs.
The MDS facilities vary in size from the nine locations with (currently) only one employee, to the main reference laboratory in Etobicoke with approximately two hundred and seventy-five employees. The main lab and office complex employ about two-thirds of the company's employees in Metropolitan Toronto. At 25 Leonard Avenue, there are now approximately twenty employees. The parties have agreed that "for the purposes of the count" there were eighteen full-time workers and three part-time workers at the time the application was made. The mix of full-time and part-time employees seems to fluctuate somewhat.
Apart from the clerical and technical employees in Etobicoke, there are several categories of employees working at the company's twenty-six other locations. Among these are SCC employees called "phlebotomists", who are typically assigned to a specific SCC location to collect specimens from patients who attend at that location. They also collect patient information and prepare specimens for testing at one or more labs. Other phlebotomists ("home-care" or "mobile" phlebotomists) collect the same material from patients in their homes, and, as we have already noted, are associated (currently) with one of three SCC's in Metro Toronto. After the specimens are procured by the phlebotomists either from the patient visiting the SCC or a phlebotomist visiting the patient, phlebotomists transcribe relevant information on a requisition form for the laboratory technologists, and arrange for delivery of the specimens to the appropriate laboratory.
The home-care phlebotomists attached to 25 Leonard Avenue can reasonably regard that location as their normal base of operations; however, the testing requisitions which generate their work are actually funnelled through a district co-ordinator at 2917 Bloor Street. Hard copies are sent by courier and are supplemented by verbal instructions if there are changes to be made.
It must be emphasized that all phlebotomists have substantially similar skills, qualifications and duties, whether they are regularly stationed at a particular SCC, or alternatively are working "out of' a particular SCC but spending most of their time "on the road". All phlebotomists complete a community college or similar training program in phlebotomy, and associated skills such as electrocardiology. The work of a phlebotomist is the same, wherever s/he does it.
According to Sandra Lemon, the supervisor of "home-care", the phlebotomists at 25 Leonard Avenue interact with data entry clerks and sorters who process, package, and label, the sample for shipment to the appropriate location, as well as record any special transportation, location, testing, or reporting information. It is not clear from Ms. Lemon's testimony whether these ancillary personnel are regularly or permanently at 25 Leonard Avenue, or at 2917 Bloor Street where testing requisitions originate, and from which "home-care" duties are administered by a telephone co-ordinator. She testified that "home-care functions" include those of sorters, but not data entry persons; moreover, she said that at the time the application was made, she "borrowed" data entry personnel from Bloor Street, although now they were "her own". This interrelationship of persons and functions is typical of various parts of the organization.
The mobile phlebotomist ends his/her day by sorting, planning and routing the collections or testing that s/he is to do the following day. They divide their time between "paper work" duties at their home base (for example, 25 Leonard Avenue) and collection duties on the road. However, there is regular checking by telephone with the home-care co-ordinator to update and revise testing requisitions - which in the case of the mobile phlebotomists attached to 25 Leonard Avenue, means regular checking with 2917 Bloor Street. At the present time, there are thirty-six full-time and part-time mobile phlebotomists based at the three locations noted above. The mobile group is responsible for covering all of Metropolitan Toronto which has been divided into three distinct geographic territories, with a common overall supervisor.
Over the past five years home-care phlebotomists have been managed as a unit under one manager or supervisor (currently Sandra Lemon). The supervisor of home-care is located at 2917 Bloor Street. Ms. Lemon visits all locations with some frequency (i.e. at least once a week).
All home-care phlebotomists receive the same policy and procedural instructions from the supervisor of home-care who exercises effective managerial authority over them. However, the SCC phlebotomists may also report to managerial personnel who are off site. The locations are not isolated or independently managed. Performance evaluations, salary increases, recommendations concerning hiring, promotions, termination and granting time off, and so on, are conducted by managerial personnel for their assigned employee group, irrespective of the location in, or from which, the employee works from time to time, or the usual location of the supervisor. The policies and processes are the same.
The laboratory staff are employed in six Metro locations in addition to the main lab in Etobicoke. These employees test the specimens collected by the phlebotomists either from home visits or walk-in patient referrals. The laboratory staff have community college or university training as lab technologists and are typically assigned to a specific laboratory location - although, as noted, there was once a laboratory at 25 Leonard Avenue which has now been transferred or absorbed elsewhere in the system. The lab staff consists mainly of certified Registered Technologists who work with lab technicians and other para technical staff. There may be an on-site "senior technologists" who acts as a technical resource person, however these individuals do not exercise managerial functions, and as in the case of the SCC's, neither the source of work, nor the reporting relationships focus on the particular location where the employee happens to be working. Management is typically off-site, and work is transferred back and forth between labs as necessary.
Normally the phlebotomists do not have the appropriate training to work in the laboratory. Unlike the laboratory technologists, they are not certified or registered. However, most lab technologists are trained in phlebotomy, and because they have this training, they assist in the SCC's from time to time. Technologists can, and occasionally do, perform the work of phlebotomist. The job territories overlap.
All employees are attached to a particular location - even the couriers. To this extent, they have a regular place of work - even the home-care phlebotomists who are regularly "on the road". Should an employee wish to change to another location, she/he may request a transfer and/or apply for a vacancy at another location. Vacancies are advertised in a "positions available" list which is distributed and posted at all locations every week. At the present time, movement of this kind can occur without impediment, because the terms and conditions of employment (seniority based or otherwise) are standardized across Metropolitan Toronto. In other words, there is a common pool of work opportunities within Metropolitan Toronto within which employees currently have a degree of choice. Similarly, MDS can now shift employees, or work, from one location or work group to another, as business dictates, without impediment.
There is an interchange of employees between work locations and job functions. Laboratory technologists perform phlebotomy from time to time in an SCC at their own regular location, or elsewhere. In cases where coverage is not available in a particular location, SCC phlebotomists cover at other locations for unexpected or short absences and vacation during the off season. Long-term absences (i.e. for pregnancy leave and/or long-term illnesses) are generally covered by the hiring of temporary help, or by offering more hours of work to other employees from that location or from other locations. These arrangements are facilitated by the relative proximity of locations within Metro, and by the interchangeability of employees, and work. During the heavy vacation period "float" employees may be hired to cover vacation absences at a number of locations - although presumably part-timers can do the same. The single employee locations naturally require an employee from another location to relocate whenever the incumbent employee is absent.
The home-care/mobile phlebotomists cover other locations from time to time. There is also an on-call service for holidays and week-ends, which covers all of Metropolitan Toronto. For the extended call service, a home-care phlebotomist from 25 Leonard Avenue covers for the areas normally covered by 25 Leonard Avenue and 1371 Neilson Road. A home-care phlebotomist from 2425 Bloor Street covers the west end of the city.
The home-care/mobile phlebotomy group draws upon employees from laboratories and SCC's at other locations with some frequency. The business records indicating employee interchange do not provide a complete picture because, heretofore, there has been no need to keep records of where particular employees work, or for how long, or what precisely was done. The payroll records do not indicate changes in location because location has not been relevant to the employees' terms and conditions of employment. Nor is the work geographically rooted, or inevitably linked to a particular SCC location.
Nevertheless, the company's records do confirm that there is a regular interchange of employees between the company's various locations. For example, in representative periods, laboratory employees and phlebotomists from 208 Bloor Street West have come to work, temporarily, as mobile phlebotomists at 25 Leonard Avenue. Conversely, laboratory employees, (when there were such) at 25 Leonard Avenue went to work at 208 Bloor Street. The evidence also discloses interchange back and forth between 25 Leonard Avenue, 2415 Bloor Street, and 360 College Street, as well as between "mobile" or "home-care" collection duties, and similar duties undertaken by phlebotomists stationed on site. There is also interchange between functions and locations other than 25 Leonard Avenue, the union's proposed bargaining unit. During their temporary transfer to the home-care group at 25 Leonard Avenue, transferees attend at that location to collect their assignments, and report to the manager of home-care in the same way as the other mobile phlebotomists do.
The evidence indicates that interchange is typical of this organization - although of course each individual spends most of his or her time at one location, so that, on a percentage basis, the amount of work done by "outsiders" is a small percentage of the total hours worked at any particular location. But there is regular movement into, and out of, what the union proposes as the unit of employees appropriate for collective bargaining. The union's proposed bargaining unit perimeter does not enclose a rigid grouping of individuals, or a fixed body of work, which, as we have already noted, is readily transferable to other locations, as is the SCC itself. The lab formerly at 25 Leonard Avenue is one example of this, but, as counsel pointed out, with three locations within a couple of blocks, it would be relatively easy to combine, modify or rearrange work arrangements or workers; moreover, favourable leasing opportunities might make that desirable. The union claims that this does not create insuperable collective bargaining problems; however, one is left to wonder about the individual normally stationed at 25 Leonard Avenue who nevertheless spends hours, days or weeks working elsewhere in the system, or the individual normally situated elsewhere, who spends hours, days or weeks working at 25 Leonard Avenue. At the present time, this kind of mobility, shifting of work, and shifting of employee work assignments, is undertaken without impediment, because there are uniform terms and conditions of employment across Metropolitan Toronto. It does not matter where the phlebotomist works.
At the present time, there is nothing to distinguish the wages, benefits, or working conditions of employees at 25 Leonard Avenue, from the wages, benefits or working conditions of employees at other locations in Metropolitan Toronto - including the location across the street and the one around the block. There is a standardized system applicable to all employees. Rates of pay are based upon the job that the individual is doing (phlebotomists, laboratory technologists, etc.) and are uniform across Metro, with established pay bands for each position. All phlebotomists are paid within the same band wherever they work, and whether they are normally stationed at a particular SCC, or work as a mobile phlebotomist performing "home-care" duties. Likewise, laboratory employees are paid in the same way wherever they work. Geography is irrelevant for these employment purposes.
There is one centralized payroll system which provides a direct deposit to the employee bank accounts. Full-time staff are paid an annual salary. Part-time staff are paid on an hourly basis. All staff are eligible to receive merit increases as part of their annual salary review.
There is a common package of employee benefits for all eligible employees (i.e. those working more than twenty-four hours per week). There is no distinction based on work location or work function. Vacation entitlements are the same for everyone, and are based upon years of service. Uniforms or uniform allowances are available to all lab staff, and to all phlebotomists, whether mobile or stationed at a particular SCC. However the phlebotomists doing home-care duties, "on the road", receive a travel allowance.
Part-time employees are not eligible for benefits. Their vacation pay is paid annually.
There is a standard work week of thirty-seven and one half hours for all phlebotomists and laboratory staff, wherever they are located and whatever their particular functions may be. Overtime is paid at time and a half for all workers. The amount of overtime depends upon the needs of a particular location.
The SCC's are generally open from 7:30 a.m. to 9:00 p.m., depending on the needs of the patients and the physicians in the locations. Similarly, the laboratories are generally open from Monday to Friday and Saturday mornings, depending upon the patient and physician needs. Work scheduling is adjusted to meet these requirements, using part-time employees as necessary. Mobile phlebotomists generally work Monday to Friday starting at 7:30 a.m. and finishing about 3:00 p.m. - again whatever their location might be.
III
The issues posed by this case are not new. In fact, the case is so similar to an earlier one involving a Toronto competitor of MDS, that the earlier decision is worth reproducing at length. In Cybermedix Limited, [1979] OLRB Rep. Aug. 743, the Board wrote:
The respondent operates a medical testing laboratory service. It has some seventeen locations in Metropolitan Toronto, some of which are specimen collection centres, some of which do both collecting and testing and one of which also includes administrative offices. The union requests certification for a bargaining unit of all employees of the respondent in Metropolitan Toronto with the exception of office and clerical employees. The respondent submits that each location should be a separate bargaining unit or that~ alternatively, the employees should be grouped in six separate bargaining units. A further alternative put forth in the respondent's reply is that two bargaining units be established, one being comprised of its central laboratory at 78 Oakdale Road, Downsview, with all other employees falling within a residual unit.
Counsel for the respondent requested that the Board appoint a Labour Relations Officer to inquire into the composition of the bargaining unit. The employer wanted to establish in evidence that there was no interchange of employees between the locations and that the functions of immediate supervision and hiring were confined either within the separate locations or several small groups of them. For those reasons it submitted that a number of separate bargaining units should be established. At the hearing Counsel for the respondent stated that if there were a regular interchange of employees the respondent would agree to the Board's usual municipality-wide bargaining unit for all of its locations in Metropolitan Toronto.
The interchange of employees between two or more locations is but one of a number of factors considered by the Board in its determination of an appropriate bargaining unit. The Board must determine whether there is a substantial community of interest among employees in a proposed bargaining unit. It therefore considers the nature of the work performed, the conditions of employment, the skills of employees, the employer's administrative framework, the geographic circumstances of the respondent's operation and the functional coherence and inter-dependence of the employees in its several locations. (Usarco Ltd. [19671 OLRB Rep. Sept. 526.)
In this case the employees in the respondent's various locations exercise the same skills and perform the same kind of work under similar conditions of employment within the tiered framework of a single administration. They all work within Metropolitan Toronto, an area which the Board has determined to be an appropriate geographic designation for a multi-location service enterprise. (The Goodyear Service Stores 65 CLLC, ¶16,018.) And it is clear from the representations before the Board that in the collecting and testing which they perform, all of the employees are, to a substantial degree, functionally inter-dependent.
When an employer operates a number of essentially similar service outlets within a municipal area it is, generally, not most conducive to collective bargaining to parcel the employees within that area, all of whom have similar bargaining interests, into a series of fragmented bargaining units. The possibility that some of the bargaining units might be represented by one union, some by another, while others may have no union representation at all can lead to invidious results for the employees, for the unions concerned and for the employer. Absent compelling reasons to the contrary in that situation a single bargaining unit of all employees with the municipality is generally the most rational and viable bargaining unit. (See The Goodyear Service Stores, supra, and cf. Fotomat Canada Limited [1979] OLRB Rep. Apr. 306.) There may be considerations of industrial relations policy such as employee access to collective bargaining and the ability to organize for the purpose of union representation which may override the Board's normal aversion to fragmentation. (See McDonald's Restaurants of Canada Limited [1974] OLRB Rep. Oct. 755; Ponderosa Steak House [1974] OLRB Rep. Nov. 7; Canada Trustco Mortgage Company [1977] OLRB Rep. June 330) but those concerns do not apply in the instant application.
In this case the fact that there may be no substantial interchange of employees between locations and that the functions of hiring and supervision are confined within the locations, even if proved through the inquiry of a Board Officer, would not alter the conclusion that a single bargaining unit would best serve the common interests of the employees concerned. The Board will therefore not order a formal inquiry into the composition of the bargaining unit, there being no prima facie reason to do so, nor depart from its normal policy of adopting a municipality-wide bargaining unit for the employees in the respondent's service outlets and testing facilities.
For the foregoing reasons, the Board finds that all employees of the respondent in Metropolitan Toronto, Ontario, save and except supervisors, persons above the rank of supervisor, office and clerical employees and persons regularly employed for not more than 24 hours per week and students employed during the school vacation period, constitute a unit of employees of the respondent appropriate for collective bargaining.
As will be seen, the circumstances in Cybermedix are virtually identical to those in the instant case. If anything, the circumstances here point even more strongly to a municipal-wide bargaining unit because, in this case, there is an interchange of employees between various locations, supervision is not confined within those locations, and the allocation of work is fluid as between the various SCC's.
Nothing in the Board's jurisprudence since Cybermedix points strongly towards a different conclusion on the appropriate scope of the bargaining unit. Hospital for Sick Children, [1985] OLRB Rep. Feb. 266, may have shifted the Board's focus from the somewhat abstract notion of "community of interest", to the more concrete labour relations problems which might flow from one bargaining unit configuration or another; but Hospital for Sick Children did not involve or endorse fragmentation, and later cases continued to express concerns about the collective bargaining difficulties which arise when a company's organization is subdivided into a number of potentially competing bargaining units, with different conditions of employment, different seniority districts, and so on (see, for example: Kidd Creek Mines, [1986] OLRB Rep. June 736, and more recently, Mobil Chemical Canada Ltd., [1987] OLRB Rep. Apr. 559, and Hornco Plastics Inc., [1993] OLRB Rep. May 411). Clearly, a trade union need not organize the most comprehensive or the most appropriate bargaining unit, and the Board must be careful lest its bargaining unit determinations raise unwarranted obstacles to organizing. But that does not mean that notions of appropriateness or collective bargaining efficacy should be disregarded altogether, or that a union is entitled to any unit it applies for just because, if that unit is not approved, a certificate may not issue. As the Board said in K-Mart Canada, [1981] OLRB Rep. Sept. 1250, it is necessary to consider the circumstances of the particular application before it and "balance the pattern of organization against the disruptive effects of excessive fragmentation". The recent amendments to the Act have not abandoned the concept of "appropriateness"; and, if anything, the legislative treatment of part-time units, and the new power of consolidation, both suggest that excessive subdivision of an employer's organization is undesirable from a collective bargaining point of view.
There is nothing in the particular facts or evidence of this case to establish any unusual obstacles to organizing on a broader basis, either in this industry or for this employer. There is no evidence about the "pattern of organizing" (see K-Mart Canada, supra), nor do the facts establish that the Board's bargaining unit determinations have contributed to unreasonable obstacles to organizing. Cybermedix, a similarly situated competitor of MDS, was organized on a municipal basis, and in a somewhat similar context, another union organized quite a number of municipal clusters of "Fotomat" stores, which like SCC's were spread throughout a municipal area and served as drop-off or servicing points for customers. There is no evidence here that the union made efforts to organize which were hindered by the Board's approach to bargaining units - or even that the union made efforts to organize employees working across the street, or around the block. And the health care sector itself is highly organized - albeit by unions other than the present applicant.
In summary, we see nothing in the circumstances of this case which would prompt us to reach a different conclusion than the panel in Cybermedix.
We find that neither the single location unit proposed by the applicant nor a variation encompassing the home care group constitute an "appropriate" unit for collective bargaining purposes.
It is unnecessary to consider whether some other subdivision of the employer's enterprise would be appropriate.
Having regard to the foregoing, and the level of support demonstrated by the union's documentary evidence of membership, this application is dismissed.
MDS LABORATORIES - METROPOLITAN TORONTO
CHART 'A'