Cleghorn Folding Box Co., Inc.

National Labor Relations Board - Board Decisions

Oct 2, 1967

167 N.L.R.B. 656 (N.L.R.B. 1967)

656 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Cleghorn Folding Box Company , Inc. and United
Papermakers and Paperworkers , AFL-CIO and
Cleghorn Independent Employees ' Union , Party to
the Contract . Case I-CA-5329
October 2, 1967
DECISION AND ORDER
By CHAIRMAN MCCULLOCH AND MEMBERS
FANNING AND BROWN
On July 12, 1967, Trial Examiner C.W. Whit-
temore issued his Decision in the above-entitled
proceeding, finding that the Respondent had en-
gaged in and was engaging in certain unfair labor
practices within the meaning of the National Labor
Relations Act, ass amended, and recommending
that it cease and desist therefrom and take certain
affirmative action, as set forth in the attached Trial
Examiner's Decision. Thereafter, Respondent filed
exceptions to the Trial Examiner's Decision and a
supporting brief, and the General Counsel filed an
answering brief.
Pursuant to the provisions of Section 3(b) of the
Act, the National Labor Relations Board has
delegated its powers in connection with this case to
a three-member panel.
The Board has reviewed the rulings of the Trial
Examiner made at the hearing and finds that no
prejudicial error was committed. The rulings are
hereby affirmed. The Board has considered the
Trial Examiner's Decision, the exceptions, the
briefs, and the entire record in the case, and hereby
adopts the findings, conclusions, and recommenda-
tions of the Trial Examiner, with the following
modification.
The Trial Examiner found that Respondent un-
lawfully assisted and supported the Independent
Union in violation of Section 8(a)(2). We agree.
However, in so finding, we do not rely upon his
finding that Respondent permitted the Independent
Union to solicit dues-checkoff authorizations on
company premises during working hours or to
prepare ballots and conduct an election on company
time , as there is no evidence that Respondent or its
agents were aware of or should have known of such
activities. Without passing on whether each of the
other acts relied upon by the Trial Examiner would
constitute, standing alone, an independent viola-
tion, we are satisfied that when considered in their
totality, they support the conclusion the Trial Ex-
aminer reached.
mended Order of the Trial Examiner and hereby or-
ders that the Respondent, Cleghorn Folding Box
Company, Inc., Lowell, Massachusetts, its officers,
agents, successors, and assigns, shall take the ac-
tion set forth in the Trial Examiner's Recom-
mended Order.'
Delete from par 2(b) that part which reads "to be furnished" and
substitute "on forms provided "
TRIAL EXAMINER'S DECISION
STATEMENT OF THE CASE
C.W. WHI rTEMORE, Trial Examiner - This proceeding
was heard in Boston Massachusetts , on April 12 , 19, and
20, 1967, pursuant to charges filed on February 10, 1966,
and February 13, 1967, by the United Papermakers and
Paperworkers , AFL-CIO, herein called UPP, and a
complaint issued against the Respondent on February 24,
1967. The chief questions presented are whether the
Respondent . ( 1) violated Section 8(a)(2) of the Act by
assisting and supporting the above -named Independent,
and (2 ) violated Section 8(a)(1) by signing a contract with
the Independent to discourage membership in the UPP
and by interrogating and threatening employees. Upon
the entire record , my observation of the witnesses, and
consideration of the briefs filed by all parties represented
as above noted , I make the following:
FINDINGS OF FACT
1. THE BUSINESS OF THE RESPONDENT
Cleghorn Folding Box Company, Inc., is a Mas-
sachusetts corporation, with its principal office and place
of business in Lowell, Massachusetts, where it is engaged
in the manufacture, sale, and distribution of cardboard
cartons.
It annually receives at its Lowell plant directly from
points outside the Commonwealth goods and materials
valued at more than $50,000, and annually ships directly
to points outside the Commonwealth goods and materials
valued at more than $50,000.
The complaint alleges, the answer admits, and it is here
found that the Respondent is engaged in commerce within
the meaning of the Act.
II. THE LABOR ORGANIZATIONS INVOLVED
The answer admits the complaint 's allegations, and it
is here found , that the UPP and the Independent are labor
organizations within the meaning of Section 2(5) of the
Act.
III. THE UNFAIR LABOR PRACTICES
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the Recom-
A. Background
Since the nub of this case is the Respondent's alleged
unlawful assistance to the Independent, it would be well
at the outset to provide some relevant details as to the his-
tory of this "labor organization," as the parties have al-
leged or admitted it to be.
167 NLRB No. 93
CLEGHORN FOLDING BOX COMPANY 657
Competent and credible evidence establishes that in
name only, and the fact that the Respondent signed a con-
tract with it shortly after the UPP began genuine or-
ganization of the some 200 employees, is there any
material difference between the Independent and a
"Committee" of departmental representatives, ap-
parently set up by the Company sometime in the late
1950's. Neither documentary nor oral evidence indicates
precisely when or how this "committee" came into being,
but in 1959 the Respondent issued to employees a
pamphlet entitled "Benefits Received by Employees of
the Cleghorn Folding Box Company, Inc.," which in-
cluded a brief section directing that the committee should
be composed of one representative from each of five de-
partments, limiting "meetings" to three a year, and stating
that committee members would be paid for time at such
meetings.
It appears reasonable to infer that the committee was
actually a creature of management, since it was claimed
as one of the "benefits" bestowed, and in the absence of
any credible evidence of self-organization on the part of
the employees themselves. There is in the record a dearth
of credible evidence as to how, if at all, the committee
functioned from 1959 to about June 1964, when new
management, but not new ownership and control, of the
Company was effected. The Company continued to be a
wholly owned subsidiary of Prince Macaroni Manufac-
turing Company, one Joseph Pellegrino being the chief of-
ficer of each. Since 1964 the new manager has been Phil-
lipe Charat.
There is conflict in testimony as to a certain speech
made by Pellegrino in June 1964, when he announced to
assembled employees that Charat was taking over as the
new manager. A former employee, Miller, on direct ex-
amination claimed that Pellegrino in effect asked the em-
ployees "to form a committee." On cross-examination,
however, he admitted that he would not deny that Pel-
legrino merely said that he understood there was a "com-
mittee" in existence. Charat's testimony is supported by
that of others that the company head in fact referred to
the existence of the committee, not the formation of one.
Under the circumstance of Miller's uncertainty, and the
probabilities inherent in the situation as above described,
I do not believe that the company head on this occasion
asked employees to set up a committee. There is no
evidence that the committee as a company "benefit," as
described in the 1959 pamphlet, was ever rescinded or
disavowed, and it seems reasonable to suppose that Pel-
legrino , as head of the concern, was aware of its ex-
istence , even if dormant.
In October 1964, the department representatives began
to hold meetings with Charat and at least another member
of management about once a month, and minutes were
kept-not by the committee, but by the personnel
director of the Company. No documentary evidence'
shows that there had been any such meetings before Oc-
tober 1964.
Without encumbering this Decision with a review of all
details appearing in the series of minutes, introduced into
evidence either by General Counsel or the Respondent,
it seems enough to say that a wide variety of subjects
were covered at the meetings from October 1964 through
December 1965 from a departmental request for adjust-
ment of the "inequality of wages" (to which management
agreed "in steps" over a period of time), to one represen-
tative's request for a vent and a mirror for the "men's
room," which the Company said would be "ordered."
Throughout this period, and until the latter part of
December 1965, the committee never held general
meetings with employees or, so far as the record shows,
any meetings of the representatives except with manage-
ment present. It never collected dues, had no officers,
bylaws, treasury, or even a name. And no membership,
unless the one employee from each department serving as
its representative at meetings with management may be
considered to have been a "member."
It was this informal group of departmental representa-
tives which, late in December 1965, suddenly assumed a
name, chose officers from among themselves in the
presence of management, and within a few days was
given a written contract, granting it exclusive bargaining
rights, by Charat, already signed by him. It was this con-
tract which the Regional Director, in February 1966,
found to be a bar to an election sought by the UPP, which
had begun organization of the Respondent's employees
shortly before the hasty signing of the contract with the
Independent.
B. Unlawful Assistance to the Independent
The complaint alleges six separate and specific ways by
which the Respondent unlawfully assisted and supported
the Independent. It does not, however, claim company
domination, although the historical facts, related above,
might well sustain such contention.
Summarized, these six factors of alleged assistance by
the Respondent are, in order of time: (a) from August
through December 1965, preparing the minutes of the
meetings ; (b) on January 11, 1966, executing a col-
lective-bargaining agreement with the Independent,
and since then maintaining it, which recognizes the Inde-
pendent as the exclusive bargaining representative of all
employees in a unit of production and maintenance
workers, although the said Independent had never been
selected, orally or in writing, by a majority of such em-
ployees, as their bargaining representative; (c) in Janua-
ry, through its own attorney, drafting and preparing dues-
checkoff authorizations for the Indpendent; (d) also in
January permitting solicitation among employees of their
signatures upon such authorizations, on its premises and
during working hours; (e) permitting -Independent
representatives to hold meetings on company time and
property; and (f) in March 1966, permitting the said
representatives to prepare ballots and conduct an election
on its premises during working hours.
Allegation (a) is fully sustained by documentary
evidence and the testimony of Katherine Monson, per-
sonnel director. Monson entitled such documents as
"Minutes of Cleghorn Meeting," plainly an indication
that these meetings with departmental representatives
with company officials were considered as company busi-
ness. A quick review of the minutes fails to reveal a single
mention of the "committee" as a whole, but only
"requests" made by an individual from some department
and management's reply.
Allegation (b) is admitted, in part, by the answer: the
facts of a contract and exclusive recognition. The answer
specifically denies that such recognition was granted at a
I According to Charat he "believed" there may have been an "infor-
mal" meeting between June and October, but he admitted that the "prac-
tice of acquainting" themselves "with the facts," presumably by having
the personnel manager prepare minutes , did not begin until October
658 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
time when the Independent did not represent a majority
of the employees. At the hearing, however, the Respond-
ent neither made any claim that the Independent did
represent a majority nor offered any testimony or other
evidence to rebut testimony from the Independent's own
president, adduced by General Counsel, establishing
that: (1) the Independent had no authorizations from any
employees designating it as their bargaining agent, and (2)
the Company never asked for proof of such authoriza-
tions. In his brief counsel for the Respondent states:
It is submitted that on the basis of the evidence the
employer recognized and entered into a collective
bargaining relationship with the representative of a
majority of employees in an appropriate unit in 1959
and that the relationship continued without challenge
by any other union until January 17, 1966. There has
been no evidence submitted by General Counsel to
support his allegation to the contrary.
It is apparent, then, that the Respondent would have it
found that the Independeht, a name adopted late in
December 1965, was and is a mere continuation of the
group of departmental representatives permitted by
management to come to it occasionally, down through the
years, with requests and that this group represented "a
majority of employees" simply because over that long
period of time no outside labor organization had sought to
represent the employees.
An error in computation remains an error, whether or
not challenged for a day or a century. And I am not aware
that the Board or the courts have held that majority status
is attained by mere declaration of management.
General Counsel amply established that the so-called
committee never was a labor organization in the generally
accepted sense of the term, although within the legal
definition, and that it never had any "members," dues, or
meetings of employees. No records were ever kept, ex-
cept by management itself of its meetings with depart-
mental representatives. While it was obviously impossi-
ble for General Counsel to call as witnesses all present
and former employees, from 1959 on down to January
11, 1966, to ascertain if any or a majority of them had
ever authorized the "committee" to represent them,
orally or in writing, the historical facts adduced by him
plainly warrant the inference, here drawn, that at no time
before signing the contract did the "independent" or the
"Committee" represent an uncoerced majority of the
Respondent 's employees, in any unit.2
General Manager Charat's claim that there existed a
"collective bargaining agreement" with the Independent
before the one executed in January 1966, is without the
slightest support of documents or other credible
evidence. "It was not in writing," he admitted, "but there
was one." There is no doubt that there had been, and after
1964 continued to be, a unilateral agreement by the Com-
pany to permit departmental representatives to meet oc-
casionally with management, but such agreement plainly
is no "collective bargaining" contract.
As to allegation (c) there is no dispute that after the sig-
ning of the contract, counsel for the Respondent prepared
and drafted a dues-deduction authorization text for the
"Independent." Employee Carrier, who testified that he
was chosen to be "president" by other department
representatives at the time they decided to adopt the
name "Independent," also testified that the "company at-
torney" prepared the dues-authorization text, and the
only change he and others made in it was to alter the dues
of 25 cents from "weekly," as in counsel's text, to "quar-
terly." It appears that even the representatives objected
to paying more than a dollar a year for their privilege.
This authorization slip, its text in evidence, for the first
time in any document for signature by an employee,
refers to "membership" in the Independent. The Re-
spondent offered no evidence as to how many employees,
if any, ever signed this slip. The number would be im-
material , in any event, as proof of majority status on
January 11, 1966, since the form itself was not prepared
until after the contract was signed.
As to allegation (d) Carrier's testimony contains
sustaining proof. He admitted that he distributed these
deduction forms and picked them up in his department
during working hours.
As to allegation (e) competent proof that management
permitted use of its premises for meetings of Independent
representatives is found in the testimony of Recording
Secretary Newton, who admitted that the representatives
were allowed by management to use its conference room
for meetings.
Finally, as to allegation (f), Newton admitted that early
in March 1966, the Company's office manager gave her
permission to post election notices near the timeclocks.
Carrier admitted that he prepared ballots for his depart-
ment on paper obtained from the Company and mimeog-
raphed with its permission in the company office, and that
the election was conducted during working hours. This al-
legation is clearly sustained by testimony of the Inde-
pendent's own officers.
In summary, I conclude and find that each of the
specific allegations of the complaint as to the Respond-
ent's unlawful assistance to and support of the Independ-
ent is sustained by the preponderance of credible
evidence, much of it documentary or uncontradicted.
C Signing of the Contract as Unlawful Interference,
Restraint , and Coercion
The complaint alleges that the Respondent's execution
of the January 1966 contract was not only in violation of
Section 8(a)(2), but also in specific and independent viola-
tion of Section 8(a)(1) of the Act. General Counsel con-
tends that it was entered into "to discourage membership
in or activity on behalf of the UPP, the Charging Union,
thereby depriving employees of their Section 7 rights to
select their own bargaining agent.
The principal factor required to reach the conclusion
sought by General Counsel, of course, is company
knowledge of the existence of an organizing campaign by
UPP before it so precipitately signed a contract with the
Independent. That the UPP in fact began openly to cam-
paign among the employees in mid-December 1965, is
established by credible and undisputed evidence. Carrier,
above identified as Tiead of the Independent when that
name was adopted on December 28, 1965, admitted that
he knew of the campaign and the distribution of leaflets
at the plant . General Manager Charat , a most vacillating
and unimpressive witness, at first flatly denied that at any
time had he "become aware" of "organizational activity"
by any other "union" than the "Independent." Later he
admitted that he knew of "material" being "distributed"
L In passing, I cannot avoid noting the obvious inconsistency in
testimony elicited by the Respondent's counsel from Charat to the effect
that the "practice" set up by the Company in 1959 was not followed in
1964 and thereafter, and the same counsel's argument in his brief that the
recognition and dealing with the committee has been continuous, and
therefore valid, since 1959
CLEGHORN FOLDING BOX COMPANY
in December 1965, and that he knew "Mr. Moore," UPP
representative, was distributing leaflets. Almost im-
mediately thereafter, however, he changed his testimony
again, and claimed that it was not until "the latter part of
January" when he "was made aware" of such distribu-
tion. A former foreman, Dragoli, a witness called by the
Respondent shortly after Charat had testified, bluntly
declared, when asked if he knew that the UPP "was try-
ing to organize the plant late in December, early Janua-
ry," that "If anybody didn't know it, I think they were a
little on the stupid side." I do not adopt the foreman's
characterization as applied to Charat, but prefer the more
reasonable and accurate conclusion that the general
manager knowingly gave false testimony when he denied
knowledge of UPP activity in December 1965.
It is concluded and found that management was well
aware of the fact that UPP was organizing before signing
its agreement with the Independent.
While there is, of course, no direct evidence that the
sudden adopting of the name Independent, the selection
of officers by the committee representatives from among
themselves, and the submission of proposals for a written
contract were prompted by management suggestion or
urging, in order to set up a barrier to the UPP organiza-
tional drive, several undisputed facts warrant that in-
ference. Such facts include: (1) none of the minutes in
evidence show that either the "committee" or the "Inde-
pendent" ever asked for a contract; (2) Secretary New-
ton admitted that the "committee" members selected of-
ficers for the Independent in the presence of company of-
ficials; (3) Charat admitted that the "skeleton" of the
contract was drafted by counsel for the Respondent, and
the "final contract" was drafted by Mrs. Monson, the per-
sonnel director; (4) Carrier, head of the Independent,
said that the contract "in final form" was handed to him
for his signature by Charat, after the general manager had
already signed it; and (5) management never asked for
proof of majority status. And since there was no "mem-
bership" meeting at least until April 1966, it is plain that
the contract, drafted and signed by management, was
never submitted to employees generally for their ap-
proval.
I adopt the succinct summary of counsel for the UPP
in his brief:
Obviously the Independent is an empty shell, a con-
tinuation of the Employees' Committee under
another name designed for the sole (and thus far suc-
cessful) purpose of enabling the Employer to defeat
UPP's representation petition by claiming a contract.
The preponderance of credible evidence sustains that
allegation of the complaint noted at the beginning of this
subsection.
D. Other Interference, Restraint, and Coercion
Despite that foreman's denial, I credit the testimony of
employee Garcia to the effect that Foreman Dragoli in
early January 1966 asked him if he "was working for the
outside union" and warned him that if the UPP came in
the employees would "have to work harder." That
Dragoli knew of the organizational efforts has been
established heretofore by his own testimony.
It is concluded and found that such interrogation and
threat constituted independent interference, restraint, and
coercion when considered in the light of other unfair labor
practices found.
659
IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES UPON
COMMERCE
The activities of Respondent set forth in section III,
above, occurring in connection with its operations
described in section I, above, have a close, intimate, and
substantial relationship to trade, traffic, and commerce
among the several States and tend to lead to labor
disputes burdening and obstructing commerce and the
free flow thereof.
Upon the basis of the foregoing findings of fact and
upon the entire record in the case, I make the following:
CONCLUSIONS OF LAW
1. UPP and Independent are labor organizations
within the meaning of Section 2(5) of the Act.
2. By assisting , contributing support to , and interfering
with the administration of the Independent , the Respond-
ent has engaged in and is engaging in unfair labor prac-
tices within the meaning of Section 8(a)(2) and ( 1) of the
Act.
3. By interfering with, restraining , and coercing em-
ployees in their exercise of rights guaranteed by Section
7 the Respondent has engaged in and is engaging in unfair
labor practices within the meaning of Section 8(a)(1) of
the Act.
4. The aforesaid unfair labor practices affect com-
merce within the meaning of Section 2(6) and (7) of the
Act.
THE REMEDY
Having found that the Respondent has engaged in un-
fair labor practices I shall issue a Recommended Order
requiring the Respondent to cease and desist therefrom
and take certain affirmative action designed to effectuate
the policies of the Act.
RECOMMENDED ORDER
Upon the basis of the above findings of fact and conclu-
sions of law, and upon the entire record in the case, and
pursuant to Section 10(c) of the Act, it is recommended
that the Respondent , Cleghorn Folding Box Company,
Inc., its officers , agents, successors , and assigns, shall:
1. Cease and desist from.
(a) Assisting , contributing support to, or interfering
with the administration of Cleghorn Independent Em-
ployees' Union or any other labor organization of its em-
ployees.
(b) Recognizing the Cleghorn Independent Em-
ployees' Union or any successor thereto as the represen-
tative of any of its employees for the purpose of dealing
with the Respondent concerning grievances, labor
disputes, wages , rates of pay, hours of employment, or
other conditions of employment , unless and until said or-
ganization has been duly certified by the Board as the ex-
clusive representative of such employees.
(c) Giving effect to any and all contracts or agree-
ments, supplements thereto or modifications thereof, or
any superceding contracts with the Cleghorn Indepen-
dent Employees ' Union , or any successor thereto, unless
and until said organization has been duly certified by the
Board as the exclusive representative of such employees.
(d) Interrogating its employees with respect to their
membership in, or activities and desires on behalf of,
United Papermakers and Paperworkers , AFL-CIO, or
310-541 0 - 70 - 43
660 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
any other labor organization or threatening them with
reprisals therefor.
(e) In any other manner interfering with, restraining,
or coercing its employees in the exercise of their right to
self-organization, to form labor organizations, to join or
assist United Papermakers and Paperworkers,
AFL-CIO, or any other labor organization, to bargain
collectively through representatives of their own choos-
ing and to engage in other concerted activities for the pur-
pose of collective bargaining or other mutual aid or pro-
tection as guaranteed by Section 7 of the Act, or to refrain
from any or all such activities except to the extent that
such right may be affected by an agreement authorized by
Section 8(a)(3) of the Act, as modified by the Labor-
Management Reporting and Disclosure Act of 1959.
2. Take the following affirmative action which will ef-
fectuate the policies of the Act:
(a) Withdraw and withhold all recognition from the
Cleghorn Independent Employees' Union or any succes-
sor thereto as the representative of any of its employees
for the purpose of dealing with the Respondent concern-
ing grievances, labor disputes, wages, rates of pay, hours
of employment, or other conditions of employment, un-
less and until the said organization has been duly certified
by the Board as the exclusive representative of such em-
ployees.
(b) Post at its Lowell, Massachusetts, plant copies of
the attached notice marked "Appendix."3 Copies of said
notice, to be furnished by the Regional Director for Re-
gion 1 , after being duly signed by the Respondent's
representative, shall be posted by Respondent im-
mediately upon receipt thereof, and be maintained by it
for 60 consecutive days thereafter, in conspicuous places,
including all places where notices to employees are
customarily posted. Reasonable steps shall be taken by
Respondent to insure that said notices are not altered,
defaced, or covered by any other material.
(c) Notify the Regional Director for Region 1, in writ-
ing, within 20 days from the receipt of this Decision, what
steps have been taken to comply herewith.4
APPENDIX
NOTICE TO ALL EMPLOYEES
Pursuant to the Recommended Order of a Trial Ex-
aminer of the National Labor Relations Board and in
order to effectuate the policies of the National Labor
Relations Act, as amended, we hereby notify our em-
ployees that:
WE WILL NOT assist, contribute support to, or in-
terfere with the administration of the Cleghorn Inde-
pendent Employees' Union or any other labor or-
ganization of our employees.
WE WILL NOT recognize the Cleghorn Indepen-
dent Employees' Union, or any successor thereto, as
the representative of any of our employees for the
purpose of dealing with us concerning grievances,
labor disputes, wages, rates of pay, hours of employ-
ment, or other conditions of employment, unless or
until the said organization has been duly certified by
the Board as the exclusive representative of such em-
ployees.
WE WILL NOT give effect to any and all contracts
and agreements, supplements thereto or modifica-
tions thereof, or any superseding contracts with the
Cleghorn Independent Employees' Union or any
successor thereto, unless and until the said organiza-
tion has been duly certified by the Board as the ex-
clusive representative of our employees.
WE WILL withdraw and withhold all recognition
from the Cleghorn Independent Employees' Union,
or any successor thereto, as the representative of any
of our employees for the purpose of dealing with us
concerning grievances, labor disputes, wages, rates
of pay, hours of employment, or other conditions of
employment, unless and until said organization has
been duly certified by the Board as the exclusive
representative of such employees.
WE WILL NOT interrogate our employees with
respect to their membership in, or activities and
desires on behalf of, United Papermakers and Paper-
workers, AFL-CIO, or any other labor organization,
or threaten them with reprisals because of such mem-
bership, activities, and desires.
WE WILL NOT in any manner interfere with,
restrain, or coerce our employees in the exercise of
their right to self-organization, to form labor or-
ganizations, to join or assist United Papermakers and
Paperworkers, AFL-CIO, or any other labor or-
ganization, to bargain collectively through represen-
tatives of their own choosing and to engage in other
concerted activities for the purpose of collective bar-
gaining or other mutual aid or protection as guaran-
teed by Section 7 of the Act, or to refrain from any
such activities except to the extent that such right
may be affected by an agreement authorized by Sec-
tion 8(a)(3) of the Act, as modified by the Labor-
Management Reporting and Disclosure Act of 1959.
Dated By
CLEGHORN FOLDING Box
COMPANY, INC
(Employer)
(Representative ) (Title)
This notice must remain posted for 60 consecutive
days from the date of posting and must not be altered,
defaced, or covered by any other material.
If employees have any question concerning this notice
or compliance with its provisions, they may communicate
directly with the Board's Regional Office, 20th Floor,
John F. Kennedy Federal Building, Cambridge and New
Sudbury Streets, Boston, Massachusetts 02203,
Telephone 223-3300.
9 In the event that this Recommended Order is adopted by the Board,
the words "a Decision and Order" shall be substituted for the words the
Recommended Order of a Trial Examiner" in the notice In the further
event that the Board's Order is enforced by a decree of a United States
Court of Appeals, the words "a Decree of the United States Court of Ap-
peals Enforcing an Order" shall be substituted for the words "a Decision
and Order "
In the event that this Recommended Order is adopted by the Board,
this provision shall be modified to read "Notify said Regional Director,
in writing, within 10 days from the date of this Order, what steps Re-
spondent has taken to comply herewith "