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In Central Okanagan School District No. 23 v. Renaud [1992] 2 S.C.R. 970, the Supreme Court of Canada said there are two aspects to the union’s duty to accommodate: a positive duty to facilitate the accomplishment of a workable accommodation, such as cooperating with the employer and the employee seeking the accommodation; and a negative duty not to impede any reasonable efforts by the employer or the employee in the accommodation process, such as ensuring that the collective agreement did not unreasonably obstruct the search for an accommodation.
