xcerpted from the Steward's Handbook

Basic Points to Remember In Preparing Your Case

1. In preparing your case remember -- if you don't have facts to back your case, you don't have a case.
2. Make sure that every statement of fact raised by management is checked thoroughly before you attempt to answer it.
3. When a contradiction in statement of facts exists, try to obtain clarification from witnesses and/or other members.
4. Get all the facts into the case at the earliest possible step in the grievance procedure.  Do not attempt to withhold pertinent information until the third or fourth step. It is important to try to settle the grievance as close to the source and as soon as possible.
5. Support your facts and contentions, if possible, by contract language, previous adjudication/arbitration awards and past practice.
6. Recheck your case to make sure the 7 W's have all been answered.  Remember many adjudicators/arbitrators will reject new issues at an adjudication/arbitration hearing. For example, if you have grieved and presented arguements for denial of leave, you cannot then allege harassment on the same grievance at adjudication/arbitration level.
7. Recheck the contract carefully.
8. Before approaching the supervisor, determine the extent of authority.  Even if there is only limited authority, discussing the matter with the supervisor first will increase self confidenceand defuse any resentment between the partieswhich could  create future difficulties.
9. If you can't reach a settlement with the supervisor then proceed to the next stage, but tell the supervisor you are doing so and keep the member informed about what you and the Union are doing.
10. Keep complete written records of information and actions.  This will provide valuable resource materials in the Local for future cases and will be necessary if the grievance must be transmitted to higher levels.

Basic Points to Remember In Presenting Your Case

1. When you and the supervisor meet to discuss a complaint or grievance, you are of equal status. You are the union representative and the supervisor is management's representative.
2. In presenting the case to management, never say "I contend" "It is my position", say "It is the Union's position", or "The position or contention of the Union is ….".
3. A good chronology to follow in presenting your case is to:
   1.  State the facts.  Raise no contentions, simply tell the story of what happened.
   2. Answer all the contentions raised by management to date, whether they are verbal or written.
   3. You can now advance your position raising the proper contentions relative to the contract, previous adjudication/arbitration awards, past practice etc.
4. Anticipate the employer's objections.  Try to figure out ahead of time management's responses to the  complaint and be prepared to give the right answers to any objections. Management may have information about the grievance that you don't have, no matter how carefully you collected the facts. Calmly request clarification and listen carefully to the answers. Even when you don't agree with their point of view, it is good psychology to let them talk and get it off  their chest.
5. Let management talk. Be a good listener.  Many Stewards talk themselves out of a case by not knowing when to listen and when to talk. It is up to management to prove that their action or lack of action is right.  Don't be afraid to ask why. Demand to be heard without interruption when it is your turn to carry the ball. Give them the facts.  If they disagree, don't retreat.  Agree on whatever facts you can and then explain carefully the exact issue or issues on which you disagree.
6. Stick to the point.  Management may try to sidetrack you by leading  the discussion off into some other issue.  It is best to let them talk themselves out, but don't be diverted from the main issue. When they have finished, bring them back to the facts of the individual grievance at hand and when you talk, stick to the issue.
7. Don't lose your temper.  Few people can think straight when they are mad. It is okay for the other side to get mad, but you stay cool.
8. Don't bluff.  It won't help your image or the Union's because you might not be able to carry it off.
9. Don't discuss personalities. Stay away from discussing personalities as much as possible. Avoid using general arguments and belittling remarks which have nothing to do with the grievance at hand.
10. Know when to stop talking. Once management agrees with you on a grievance, don't continue to hash it over.  Don't gloat and brag about your victories, but that doesn't mean you can't inform the members that we won the grievance.  Whatever the outcome, be sure to advise the grievor of the results as soon as possible.

The Steward and the Grievor

You, as a Steward, will attend the complaint/grievance hearing as the Union representative. The member may attend the hearing as the grievor.By taking the grievors with you, they are able to check the supervisor's story as the case is presented and testify on their own behalf where necessary. They will also gain confidence in you and in the Union. When both the Steward and the grievor attend the hearing, it shows a united front.

When you are accompanied by the grievor explain how you will handle the case and answer any questions the grievor may have before the hearing. This will avoid any disagreements during the presentation of the case. Don't make any promises as to the settlement of the grievance.

On some occasions, it will be necessary for you to present the case by yourself. This will occur if the grievor and the supervisor are antagonistic or if the work force is scattered rather than all in one area. If you present the case alone, report back to the grievor as soon as possible, tell the grievor of the action taken and the outcome. Be prepared to answer any questions the grievor may have.

It is never a good idea for grievors to process their own grievances.  The collective agreement is not the property of any one member and should be handled by a representative of the union -- the Steward.  A grievance processed by an individual may result in a settlement which will hurt the rights of all the members in the future.

By law, the PSAC must represent all members in the bargaining unit. Failure to do so could result in charges being laid against the union.  Thus, it is doubly important for the union representative to be involved in the solution of grievances.