Permitteringer på gang?

01 Apr 2014

De siste månedene har media hatt utallige oppslag om permitteringer i fiskeindustrien og forholdet til NAV. Regelverket om dagpenger oppleves svært uforutsigbart, og medfører at en hel næring opplever utrygghet. Men når har arbeidstaker krav på dagpenger ved permittering?

Regelverket har vært gjenstand for flere endringer bare det siste året. Bestemmelsene er til dels kompliserte og vanskelig tilgjengelig. Praktiseringen hos myndighetene har ført til tilfeldigheter og lite tilsiktede løsninger. Seneste eksempel er innstrammingen ved årsskiftet hvor NAV informerte om at det var innført ”lik praksis” over hele landet for tildeling av dagpenger under permittering. Dette førte til store utfordringer for fiskeindustrien nærmest over natten. På dette tidspunktet var det allerede aktuelt med permitteringsvarsel til mange hundre ansatte.

Et negativt svar på søknad om dagpenger kan medføre et betydelig tap for mange ansatte. Den ansatte sender i god tro inn søknad om dagpenger. Tiden går og NAV gir avslag med følgende begrunnelse:  ”Du er ikke permittert på grunn av mangel på arbeid eller andre forhold som arbeidsgiver ikke kan påvirke. Du fyller derfor ikke vilkårene for rett til dagpenger”.  Den ansatte henvises til å fremme klage. Måneder med saksbehandlingstid kan påregnes.

Usikkerheten om retten til dagpenger fører til at arbeidsplasser i fiskeindustrien blir lite attraktive. Media omtalte for ikke lenge siden saken hvor fast slakteriansatte i Marine Harvest ikke fikk utbetalt dagpenger fordi arbeidsgiver etter sigende burde ha planlagt tilgangen til arbeid bedre.

Slik fungerer dessverre ikke hoveddelen av fiskeindustrien – råstofftilgangen vil variere og kan være uforutsigbar. Media omtalte da også NAVs håndtering av Marine Harvest- saken som ”absurd”. Men hva må til for å unngå lignende situasjoner fremover?

 

Permitteringsinstituttet

Permittering er en midlertidig ordning der arbeidstaker er pålagt arbeidsfritak og arbeidsgiver samtidig fritatt fra sin lønnsplikt. Arbeidsforholdet består og det forutsettes at arbeidsstansen kun er midlertidig. Hvis det er på det rene eller overveiende sannsynlig at situasjonen vil bli permanent, skal oppsigelse brukes. Arbeidsgiver skal gi melding til NAV ved permittering eller oppsigelser av mer enn 10 ansatte.

Permittering er i svært liten grad basert på lovbestemte regler. De fleste bestemmelsene baserer seg derfor på en rekke tariffavtaler. Mest kjent er hovedavtalen mellom LO og NHO. Bestemmelser etter mønster av hovedavtalen har utviklet seg til ulovfestede regler og sedvane og vil være retningsgivende også for virksomheter som ikke er bundet av tariff.

For at permittering skal kunne benyttes kreves det saklig grunn. Grunnlaget må kunne knyttes til bedriften, ikke arbeidstakeren. Nødvendige kostnadsreduksjoner, også lønnskostnader, kan være grunnlag for permittering. Forutsetningen ligger i at behovet vil være av midlertidig art. Eksempler på saklig grunn kan være: ordremangel, fulle lager, praktiske arbeidshindringer, ulykker m.v. Arbeidsgivers meldeplikt ved masseoppsigelser og permitteringer følger av arbeidsmarkedsloven § 8 og arbeidsmiljøloven § 15-2.

Ved valg av hvem som skal permitteres skal ansiennitetsprinsippet i utgangspunktet legges til grunn. Den sist ansatte skal altså som hovedregel permitteres først. Det er imidlertid slått fast at avvik kan skje på bakgrunn av bedriftens saklige behov.

En bedrift som vurderer å gå til permittering, har plikt til å drøfte dette med de tillitsvalgte i bedriften. Det skal føres protokoll fra møtet. Protokollføringen blir sentral i den saksbehandlingen som senere skal skje ved søknad om dagpenger hos NAV.

Før permittering kan iverksettes må arbeidstaker varsles om dette. Varslingsfristen er vanligvis 14 dager. Ved permittering skal arbeidsgiver normalt betale lønn i en arbeidsgiverperiode på 20 arbeidsdager. Innenfor fiskeindustrien gjelder imidlertid ikke arbeidsgiverperioden på 20 arbeidsdager, og arbeidsgiver er derfor fritatt lønnsplikt fra dag en.

Permitteringsvarselet skal være skriftlig og bør inneholde den permittertes navn, varsel om permittering, årsak til permittering, permitteringsgrad, angivelse av aktuelt tidsrom og oppfordring om å ta kontakt med NAV så snart som mulig for å fremme søknad om dagpenger.

Arbeidstaker kan ha rett til dagpenger under permittering. Dagpenger ved permittering kan oppnås i maksimalt 52 uker. Innen fiskeindustrien gjelder et vilkår om at arbeidstakers arbeidstid må være redusert med minst 40 %

Arbeidsgiver har anledning til å benytte hel eller delvis permittering. Hel permittering fritar arbeidstaker helt for arbeidsplikten, delvis permittering betyr at arbeidstaker arbeider deler av sin stillingsprosent og er permittert resten.

Når permitteringstiden er over, er arbeidstaker pliktig å møte på jobb. Hvis permitteringslengden er ubestemt, vil arbeidstaker i utgangspunktet være forpliktet til å møte på arbeid i løpet av 1-2 dager når arbeidsgiver gir beskjed om det.

 

Rett til dagpenger?

Ikke alle permitterte har rett til dagpenger. Folketrygdloven § 4-7 med forskrift regulerer forholdet. Selv om det er saklig grunnlag for permittering, er det ikke sikkert at permitteringsårsaken gir rett til dagpenger. For at de ansatte skal ha rett til dagpenger, må årsaken skyldes forhold som arbeidsgiver ikke kan påvirke. De ansatte vil for eksempel ikke ha rett til dagpenger dersom virksomheten i alminnelighet kun har arbeid deler av året, og permitterer de delene av året virksomheten ikke har oppgaver – såkalte påregnelige sesongvariasjoner.

Praktiseringen av denne bestemmelsen har i den senere tid medført sterk uenighet mellom arbeidsgiver- og arbeidstakerorganisasjonene og NAV. Både arbeidsgiver og arbeidstakersiden har vært klar på at denne bestemmelsen praktiseres for snevert. Stridens kjerne er muligheten for påvirkning. Hvilke forhold kan arbeidsgiver påvirke?

Innen fiskeindustrien er en prisgitt det råstoffet en får tilgang til. Selv om en til en viss grad kan forutse at det i perioder kan bli vanskelig å skaffe tilstrekkelig råstoff, vil det ofte være usikkert når og hvor, samt avhengig av en rekke faktorer som virksomhetene i mange tilfeller ikke er herre over.

Likevel ble det fra NAVs side lagt opp til en ”lik praksis” og at arbeidsgiverne i langt større utstrekning skulle pålegges ansvaret for denne planleggingen av driften. Det ble ikke tatt hensyn til de særlige forhold som gjelder innenfor fiskeindustrien. Biologien til fisken og andre klimatiske forhold ble ikke hensyntatt.  Resultatet ble at arbeidstakerne sto uten dagpenger.

I et annet tilfelle hadde fiskeribedriften permittert de ansatte på grunn av råstoffmangel. Samtlige ansatte ble permittert, også daglig leder. NAV nektet da alle ansatte dagpenger under permittering. Begrunnelsen var at ved å permittere også daglig leder, arbeidet ikke bedriften for å skaffe arbeid. NAV mente da at arbeidsgiver kunne påvirke årsaken til permitteringene. NAV uttalte generelt at det ble forutsatt at bedrifter som permitterte skulle arbeide med å skaffe arbeid kontinuerlig. Mangelen på råstoff ble det sett bort fra.

Innen fiskeindustrien vil begrensninger slik det fremgår ovenfor, medføre at en bedrift i svært liten grad kan belage sin virksomhet på faste ansatte. Når det oppstår arbeidsmangel vil en i langt større utstrekning måtte gi oppsigelse til sine ansatte Ved oppsigelse gjelder andre vilkår for rett til dagpenger som ofte er gunstigere for arbeidstaker. I tillegg må en påregne flere midlertidige ansatte og innleie av arbeidskraft på bekostning av faste ansatte.

Reduksjon av antall faste ansatte i fiskeindustrien er ikke ønskelig verken fra arbeidsgivers eller arbeidstakers ståsted.

 

Tar grep

Praksisendringen hos NAV ble fanget opp, og arbeids- og sosialminister Robert Eriksson kom raskt på banen. Han har deretter i flere intervju gitt uttrykk for at praktiseringen av regelverket omkring permittering må tilpasses den konkrete situasjon. ”Lik praksis” er med andre ord nullstilt. Han har også tatt til orde for at behandlingen av saker i NAV må forenkles og avbyråkratiseres.

Ved brev av 30. januar 2014 fra departementet til Arbeids- og velferdsdirektoratet gis det nå klar instruks om praktisering av bestemmelser om permittering og dagpenger. Endringene er i kraft fra 3. februar 2014.

I brevet understreker ministeren at permitteringsordningen er begrunnet ut i fra et ønske om å unngå oppsigelser og å opprettholde nødvendig kompetanse i virksomheter. Han understreker videre at dagpenger under permittering er ment å skulle sikre inntekten til permitterte arbeidstakere i den perioden arbeidsgiver er løst fra sin lønnsplikt.

Han uttaler at dagpenger som hovedregel skal innvilges når det foreligger en gyldig permittering. Ny forskriftsbestemmelse skal tydeliggjøre dette.

Departementet understreker betydningen av enighet mellom partene om at permittering er nødvendig. Denne enigheten skal legges til grunn. I ny forskriftsbestemmelse, § 6-1 andre ledd, er det presisert at vilkårene i folketrygdloven § 4-7 som hovedregel er oppfylt dersom det dokumenteres enighet mellom partene om at grunnlaget for permittering foreligger, og at det på denne måten godgjøres at virksomheten har gjort det som med rimelighet kan forventes for å unngå permittering og at årsakene ligger utenfor det som arbeidsgiver kan påvirke. Bestemmelsen innebærer at det bare er nødvendig å dokumentere enighet om:

–       at det er saklig grunn for permittering

–       at permittering skyldes mangel på arbeid eller andre forhold som arbeidsgiver ikke kan påvirke

–       at arbeidsgiver har gjort det som med rimelighet kan kreves for å unngå permitteringen.

 

Så lenge enigheten er dokumentert, skal det bare unntaksvis gjøres en nærmere vurdering av permitteringsårsaken eller hva som er gjort for å unngå permittering.

Arbeids- og sosialministeren uttaler at departementet legger til grunn at det må kunne innvilges dagpenger etter § 4-7 uten at det stilles krav om at mangel på arbeid må være uforutsett, ekstraordinært eller plutselig. Departementet understreker imidlertid at jo mer forutsigbar mangelen på arbeid er, jo større krav kan det settes til dokumentasjon knyttet til hva arbeidsgiver har gjort for å unngå permittering. Dette kan medføre utfordringer for bedrifter som utelukkende baserer sin virksomhet på mottak av pelagisk fisk.

Selv om partenes enighet skal tillegges stor vekt, er utgangspunktet er at det må vurderes konkret om de særlige vilkårene for innvilgelse av dagpenger etter § 4-7 foreligger. Et vesentlig moment i så fall er permitteringens varighet ut i fra at permitteringsinstituttet er knyttet til en midlertidig situasjon.

Det uttales videre at for å sikre forutberegnelighet er det viktig at det er en tett dialog mellom arbeids- og velferdsetaten og arbeidsgiver og arbeidstaker.

I saker hvor det ikke er dokumentert enighet gjelder strengere regler for dokumentasjon, blant annet på hva arbeidsgiver har gjort for å unngå permittering.

 

Saksbehandlingstiden må ned

Ovennevnte redegjørelse viser hvor viktig den tette dialog mellom arbeidsgiver og arbeidstaker/arbeidstakers organisasjon er når spørsmålet om permittering blir aktuelt. Dersom arbeidsgiver inntar en aktiv holdning overfor arbeidstaker vil en ofte oppnå den nødvendige dialogen slik at enighet om både årsak til permittering og behovet for permittering kan protokollføres. Gjennomgangen viser også at det er særdeles sentralt at arbeidsgiver gjennomfører en nær dialog med NAV og er i forkant av de vurderingskriterier som oppstilles. Rutiner bør på plass og innbefatte både varslingsrutiner, dialogmøte med arbeidstaker og organisasjoner og oppfølging av arbeidstaker i permitteringsperioden.

På denne måten unngår en at tiltrengt arbeidskraft og kompetanse i fiskerinæringen blir stående uten inntekt fordi NAV gir avslag. Vi får håpe at den klargjøring av forskriften som nå har funnet sted kan bli slutten på den utrygge og uforutsigbare situasjonen som mange ansatte i fiskeindustrien har måttet leve med. Tett dialog er ofte løsningen på det meste. Men er det nok? Saksbehandlingstiden må i alle fall ned og det er å håpe at myndighetene tar ytterligere tak for forenkling og avbyråkratisering.

Om forfatteren

Monica Gjerde Sperre
Monica Gjerde Sperre Monica Gjerde Sperre har i nærmere 20 år arbeidet med fiskerirettslige problemstillinger med hovedvekt på arbeidsrett og skipsarbeidsrett. Hun arbeider fra vårt kontor i Ålesund, men har oppdrag i hele regionen Midt-Norge. Hun arbeider med rettslige spørsmål som berører fiskeindustrien hva angår både landanlegg og fiskeflåten. Hun har derfor et godt innblikk i de næringsrelaterte problemstillinger som reises innenfor bransjen både rettslig og politisk.

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