On November 1, 2014, the Public Service Labour Relations and Employment Board (PSLREB) was created. The PSLREB was created when the Public Service Labour Relations Board (PSLRB) and the Public Service Staffing Tribunal (PSST) merged. This PSLRB website is in the process of being phased out in favour of the new PSLREB website. During a period of transition, this PSLRB website will continue to provide archived reports, decisions, and transitional information. Please visit the new PSLREB website for the most recent content.
With respect to the question of reasonable apprehension of bias, there is no dispute that the issue is not whether the members named are actually biased . . . but whether the circumstances could properly cause a reasonably well informed person to have a reasonable apprehension of a biased appraisal or judgment by the member, however unconscious or unintentional it might be.1
[T]he apprehension of bias must be a reasonable one, held by reasonable and right minded persons, applying themselves to the question and obtaining thereon the required information. In the words of the Court of Appeal, that test is “what would an informed person, viewing the matter realistically and practically—and having thought the matter through—conclude. Would he think that it is more likely than not that [the decision-maker], whether consciously or unconsciously, would not decide fairly.”2
1. CNG Transmission Corp. v Canada (National Energy Board),  1 F.C. 346 (T.D.), p. 360-361.
2. Committee for Justice and Liberty v. National Energy Board,  1 S.C.R. 369, De Grandpré, writing in dissent, at page 394. This test was expressly adopted by the Federal Court of Canada with respect to a member of this Board in Scheuneman v. Attorney General of Canada,  2 F.C. 365.