Reluctantly, I concur in the result reached by the majority. I write separately to express my concern that application of a limitation period of six years, rather than six months, will seriously undermine state and federal policies favoring the prompt resolution of labor disputes.
In its analysis, the majority concludes that the six-year period generally applicable to contract actions1 is the appropriate limitation period to apply to this plaintiff’s action to "enforce” a labor *13arbitration award. However, this case involves more than a simple breach of contract or a straightforward refusal to comply with an arbitration award. Plaintiff’s cause of action arises out of a collective bargaining agreement between his union and his employer. The agreement establishes a grievance procedure designed to effect the prompt resolution of disputes.2 Such a procedure is in keeping with a state policy that discourages long delays in the resolution of labor disputes.
When it adopted the labor mediation act,3 our Legislature stated:
It is hereby declared as the public policy of this state that the best interests of the people of the state are served by the prevention or prompt settlement of labor disputes .... [MCL 423.1; MSA 17.454(1).]
This act encourages use of arbitration in the settlement of disputes by providing that an agreement to arbitrate "shall be binding upon the parties,”4 and stating that the arbitration award "shall be enforceable at law or in equity as the agreement of the parties.”5
Concern at the state level for rapid resolution of labor disputes is consistent with established policy at the federal level. In DelCostello v Int’l Brother*14hood of Teamsters, 462 US 151; 103 S Ct 2281; 76 L Ed 2d 476 (1983), the United States Supreme Court rejected the application of an extended state contract limitation period in an action arising from a collective bargaining agreement that provided for grievance resolution through arbitration.6 The Court explained:
"This system, with its heavy emphasis on grievance, arbitration, and the 'law of the shop,’ could easily become unworkable if a decision which has given 'meaning and content’ to the terms of an agreement, and even affected subsequent modifications of the agreement, could suddenly be called into question as much as [three] years later.” [462 US 169, quoting United Parcel Service, Inc v Mitchell 451 US 56, 64; 101 S Ct 1559; 67 L Ed 2d 732 (1981).]
Recognizing the importance of stable relationships in the workplace and the need for finality in a collectively bargained grievance procedure, the Court elected to apply the six-month limitation period of § 10(b) of the Labor-Management Relations Act, 29 USC 160(b),7 ''a federal statute of *15limitations actually designed to accommodate a balance of interests very similar to that at stake here . . . DelCostello, 462 US 169.
In Samples v Ryder Truck Lines, Inc, 755 F2d 881, 888 (CA 11, 1985), the United States Court of Appeals for the Eleventh Circuit applied the Del-Costello rationale to an employee’s action to enforce a labor arbitration award. The court found Georgia’s six-year contract limitation period inapplicable because "a grievance arising during the term of a collective bargaining agreement bears little likeness to a common law breach of contract claim.” Similarly, in Int’l Ass’n of Machinists v Allied Products Corp, 786 F2d 1561, 1564 (CA 11, 1986), the Eleventh Circuit applied the six-month limitation period to a union’s action to compel arbitration, explaining that Alabama’s six-year limitation period for contract actions "contravenes the federal policy of the prompt resolution of labor disputes.”
As I see it, the same rationale counsels against application of a six-year contract limitation period in the instant case. The defendant did not expressly refuse to comply with the arbitration award. Rather, defendant claimed that because plaintiff filed a workers’ compensation petition shortly after his discharge, he could not be returned to active employment unless he was physically able to work. Defendant insisted that plaintiff should provide statements from the three physicians listed on his petition.8 Whether defendant *16was justified in imposing such conditions may depend upon the interpretation to be given to the collective bargaining agreement. Surely, if a policy of prompt resolution of labor disputes is to have meaning, a relatively short limitation period should govern resort to the courts after exhaustion of a grievance procedure.9
Although the Legislature has taken pains to declare that it is the public policy of this state to encourage prompt resolution of labor disputes, unfortunately, it has failed to provide suitable statutes of limitations for the implementation of that policy.
I agree with the reasoning set forth in Walker-ville Ed Ass’n v Walkerville Rural Communities School, 165 Mich App 341; 418 NW2d 459 (1987),10 *17and I would adopt it in this case if the Legislature had not provided a residual or "catch-all” statute of limitations requiring:
All other personal actions shall be commenced within the period of 6 years after the claims accrue and not afterwards unless a different period is stated in the statutes. [MCL 600.5813; MSA 27A.5813.]
It is at least arguable that MCL 600.5807(8); MSA 27A.5807(8) does not apply in this case because that subsection establishes a limitation period for "actions to recover damages or sums due for breach of contract,”11 whereas this plaintiff primarily seeks reinstatement to his position as a bus driver. However, because I conclude that the residual statute is applicable in any event, I am compelled to agree that plaintiff’s claim is governed by a six-year limitation period.
Rather than allow a wide disparity to develop in the treatment of similar claims presented by public and private employees, I urge the Legislature to address this issue and to provide a more appropriate period of limitation in keeping with its stated policy of encouraging expeditious resolution of labor disputes.
Boyle, J., concurred with Griffin, J.MCL 600.5807(8); MSA 27A.5807(8).
The collective bargaining agreement establishes a four-step grievance procedure. In step one, the employee "promptly” must give oral notice of the grievance to his immediate supervisor. If the employee receives an unsatisfactory response, a written grievance may be submitted within fifteen days. If a satisfactory response is not received within seven days, the grievance proceeds to step three: written submission of the grievance and a hearing before the university review committee. The fourth step is submission of the dispute to an arbitrator and requires notification within twenty-eight days of an unsatisfactory answer at step three.
MCL 423.1 et seq.; MSA 17.454(1) et seq.
MCL 423.9d(2); MSA 17.454(10.3X2).
MCL 423.9d(4); MSA 17.454(10.3X4).
The DelCostello Court considered the application of state contract statutes of limitation to federal "hybrid § 301” actions, in which the employee sues the employer under § 301 of the Labor-Management Relations Act, 29 USC 185, alleging a breach of a collective bargaining agreement. Because most such cases involve a collective bargaining agreement that designates the union as the employee’s sole representative, the employee must also allege a breach of the union’s duty of fair representation in order to avoid an exhaustion of remedies defense. See Vaca v Sipes, 386 US 171, 177-186; 87 S Ct 903; 17 L Ed 2d 842 (1967). In such a case, "[t]he employee may, if he chooses, sue one defendant and not the other; but the case he must prove is the same whether he sues one, the other, or both. The suit is thus not a straightforward breach-of-contract suit under § 301 . . . but a hybrid § 301/fair representation claim . . . .” DelCostello, 462 US 165.
Section 10(b), governing unfair labor practice charges in the National Labor Relations Board, provides in part "[t]hat no complaint shall issue based upon any unfair labor practice occurring more than six months prior to the filing of the charge with the Board . . . .” 29 *15USC 160(b). Our public employee relations act, MCL 423.201 et seq.; MSA 17.455(1) et seq., contains a virtually identical provision governing proceedings in the Michigan Employment Relations Commission: "No complaint shall issue based upon any unfair labor practice occurring more than 6 months prior to the filing of the charge with the commission . . . .” MCL 423.216(a); MSA 17.455(16)(a).
In a May 4, 1987, letter, the university stated its position:
*16This informs you and Mr. Rowry that Mr. Rowry has been reinstated, but that Mr. Rowry has a petition pending under the Worker’s Compensation Act in which he alleges that he is, and has been, unable to work because of an "aggravated hernia condition, blood pressure and ulcer condition.” He also alleges as of December 1, 1986 his disablement is continuing. . . .
As a result, and under these circumstances, the University is in no position to return Mr. Rowry to active work status until such time as his medical condition permits. This determination will be made in the same manner as all other similar type cases.
One possible objection to enforcing a six-month limitation period in actions to enforce an arbitration award is that one party may simply fail to comply with the award, hoping that six months will pass before an action is brought to enforce it. However, I would hold that a cause of action to enforce an arbitration award will normally not accrue on the date the award is issued, but at the time "it becomes evident that one of the parties is violating or ignoring the decision.” United Mine Workers of America, Dist 4 v Cyprus Emerald Resources Corp, 681 F Supp 271, 278 (WD Pa, 1988).
In Walkerville, the panel adopted a six-month limitation period in an action to enforce a labor arbitration award, explaining that "[a] six-month period is part of pera; it effectuates the state’s express policy in favor of the prompt resolution of labor disputes in the public sector.” 165 Mich App 345. The panel also considered application of MCR 3.602(1), which provides a one-year limitation period for judicial confirmation of arbitration awards rendered under Chapter 50 of the Revised Judicature Act, MCL 600.5001 et seq.; MSA 27A.5001 et seq. *17165 Mich App 344. However, the panel found MCR 3.602 inapplicable because the Legislature has provided that chapter 50 "shall not apply to collective contracts between employers and employees or associations of employees in respect to terms or conditions of employment.” MCL 600.5001(3); MSA 27A.5001(3). See also Badon v General Motors Corp, 679 F2d 93, 98-99 (CA 6, 1982).
Cf. Schneider v Fox, 73 Mich App 595, 597; 252 NW2d 530 (1977).