In accordance with the terms of this Settlement Agreement, the parties agree to a full
and final resolution and remedy of the pending dispute involving the Memorandum of
Understanding (MOU}, Re: Clerk Craft Jobs, Arbitrator Stephen Goldberg's April 21,
2017 Award in case number Q10C-4Q-C 15174956, and grievances held pending the
outcome of the issues in the above-referenced national level case as follows:
1. The monetary remedy for the Clerk Craft Jobs MOU will be administered by the
parties at the national level. Within 14 days of the signing of this Settlement
Agreement, the Postal Service will provide the APWU a list of the employees
who were awarded the HR Clerk and Training Technician positions and those
employees who were the successful bidders on the subsequent vacancies, to
include Postal Support Employees (PSEs) converted to career, when applicable.
2. No later than sixty (60) days from the signing of this Settlement Agreement, the
parties will identify the appropriate individual make-whole remedy for those
individuals identified in the list provided in paragraph 1 above,· consistent with the
above referenced Goldberg award, Section 3, pages 18-19. If the parties· are
unable to reach agreement on the appropriate remedy for any individual(s); the
issue(s) will be handled by the parties' Alternative Dispute Resolution Process
(ADRP).
3. Any reversion grievances that were filed at the local level related to subsequent
vacancies created as a result of the posting and filling of the 362 HR Clerk and
Training Technician positions will be processed in accordance with Article 15 of
the National Agreement. If adjudicated in the Union's favor the remedy will
continue with successful bidder/PSE conversion of the reverted position. The
parties at the national level will be responsible for identifying the appropriate
payee and monetary liability. If the parties are unable to reach agreement on the
appropriate remedy, the issue will be handled by the parties' ADRP. Any
outstanding issues in reversion grievances filed at the local level that are not
directly related to the Clerk Craft Jobs MOU Remedy will be subject to the Article
15 grievance-arbitration process.
4. No later than ninety (90) days from the signing of this agreement, the Postal
Service will create a new Clerk Craft job description and qualification standards
related to the handling of various government services. Thereafter, the new job
description and qualification standards notification to the APWU will be provided
in accordance with Article 19 of the National Agreement. The Union reserves the
right to challenge the job description and qualification standards, in accordance
with Article 19.
5. The Postal Service will establish and post a minimum of 54 duty assignments, as
referenced in paragraph 4 above, no later than September 31, 2022
6. Except as provided herein, it is understood by the parties that this Agreement is a
full and final resolution of the grievance and dispute set forth in national case
number Q10C-4Q-C 15174956. Except as provided in paragraphs 2 and 3
above, the Postal Service will be relieved from any further liability concerning
these disputes.
7. The Union has the right to challenge the enforcement of the terms of the
settlement agreement. Those issues will be addressed exclusively via the parties
ADRP.
Additionally, the APWU has a national level dispute regarding the Learning Management
System (LMS) and OAYsis, Case No. Q06C-4Q-C 10278913, which includes the
elimination of Training Technician positions. If the APWU is successful in the
LMS/OAYsis dispute, the fifty-four (54) Training Technician positions created as part of
the Clerk Craft Jobs MOU Remedy case will be deducted from any remedy awarded.
Document Type: Memorandum of Understanding
Craft: Clerk
Arbitrator Name: Stephen Goldberg