Electrical Workers Ibew Local 11 (Choi Engineering)

National Labor Relations Board - Board Decisions

Oct 30, 1985

277 N.L.R.B. 13 (N.L.R.B. 1985)

ELECTRICAL WORKERS IBEW LOCAL 11 (CHOI ENGINEERING)
International Brotherhood of Electrical Workers,
Local 11, AFL-CIO (Choi Engineering Corp.)
and Barrynell Williams . Case 31-CB-6144
30 October 1985
DECISION AND ORDER
BY MEMBERS DENNIS , JOHANSEN, AND
BABSON
On 30 July 1985 Administrative Law. Judge
Richard D. Taplitz issued the attached decision.
The Respondent filed exceptions and a supporting
brief, and the General Counsel filed a brief in op-
position to the Respondent 's exceptions.
The National Labor Relations Board has delegat-
ed its authority in this proceeding to a three-
member panel.
The Board has considered the decision and the
record in light of the exceptions and briefs' and
has decided to affirm the judge 's rulings, findings,
and conclusions and to adopt the recommended
Order.
ORDER
The National Labor Relations Board adopts the
recommended Order of the administrative law
judge and orders that the Respondent , International
Brotherhood of Electrical Workers, Local 11,
AFL-CIO, Los Angeles , California , its officers,
agents, and representatives , shall take the action set
forth in the Order.
I The General Counsel 's request that the Respondent's exceptions be
stricken in their entirety or, alternatively , that certain portions of the Re-
spondent's brief be stricken , is denied.
Julia A. Osborn and Rhonda J. Herry, Esqs ., for the Gen-
eral Counsel.
Davis, Frommer & Jesinger by Allan S . Cohen, Esq., of
Los Angeles , California , for the Union.
DECISION
STATEMENT OF THE CASE
RICHARD D . TAPLITZ , Administrative Law Judge.
This case was tried in Los Angeles, California, on June
12, 1985 . The charge was filed on March 20, 1985, by
Barrynell Williams, an individual . The complaint, which
issued on April 23 and was amended on April 25, 1985,
and at the trial, alleges that International Brotherhood of
Electrical Workers, Local 11, AFL-CIO (the Union)
violated Section 8(b)(1XA) and (2) of the National Labor
Relations Act.
Issue
The primary issue is whether the Union violated the
Act by refusing to refer Williams for employment from
13
its exclusive hiring hall because the Union believed that
Williams was delinquent in dues owed to a sister local.
All parties were given full opportunity to participate,
to introduce relevant evidence , to examine and cross-ex-
amine witnesses , to argue orally , and to file briefs . Briefs,
which have been carefully considered , were filed on
behalf of the General Counsel and the Union.
On the entire record ' of the case , and from my obser-
vation of the witnesses and their demeanor , I make the
following
FINDINGS OF FACT
I. JURISDICTION
Choi Engineering Corp. (Choi), a California corpora-
tion with an office and place of business in San Leandro,
California , is a general contractor in the construction in-
dustry specializing in electrical work. It annually pur-
chases and receives goods or services valued in excess of
$50,000 directly from suppliers located outside of Cali-
fornia . The Los Angeles County Chapter of the National
Electrical Contractors Association (NECA) is an organi-
zation composed of employers engaged in electrical con-
tracting in the construction industry . It represents its em-
ployer-members in negotiating and administering collec-
tive-bargaining agreements with various labor organiza-
tions including the Union . The employer-members of
NECA, collectively , annually purchase and receive in
California goods or services value in excess of $50,000
directly from suppliers located outside of California. The
complaint alleges, the answer admits, and I find that
Choi as well as the employer-members of NECA collec-
tively are employers engaged in commerce within the
meaning of Section 2(6) and (7) of the Act.
The Union is a labor organization within the meaning
of Section 2(5) of the Act.
II. THE ALLEGED UNFAIR LABOR PRACTICES
A. The Sequence of Events
1. The hiring hall
NECA and the Union are parties to a collective-bar-
gaining agreement entitled "Inside Wiremen 's Agree-
ment" which covers the wages, hours, and other terms
and conditions of employment for certain electrical em-
ployees . The agreement is effective by its terms from
June 1 , 1983, through May 31 , 1986. About February 22,
1984, Choi executed a "Letter of Assent" with the Union
binding it to the terms and conditions of employment of
that agreement . Article 4 of the collective-bargaining
agreement sets forth an exclusive referral procedure as
follows:
Section 4 .01. In the interest of maintaining an ef-
ficient system of production in the Industry , provid-
ing for an orderly procedure of referral of appli-
cants for employment , perserving the legitimate in-
I The unopposed motion of the General Counsel , which was annexed
to her beef, to correct the transcript of the record is granted. The motion
has been added to the exhibits as G.C . Exh. 14
277 NLRB No. 8
14 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
terest of the employees in their employment status
within the area and of eliminating discrimination in
employment because of membership or non-mem-
bership in the Union , the parties hereto agree to the
following system of referral of applicants for em-
ployment.
Section 4.02. The Union shall be the sole and ex-
clusive source of referral of applicants for employ-
ment.
Section 4.03. The Employer shall have the right
to reject any applicant for employment.
Section 4.04. The Union shall select and refer ap-
plicants for employment without discrimination
against such applicants by reason of membership or
non-membership in the Union and such selection
and referral shall not be affected in any way by
rules, regulations , bylaws, constitutional provisions
or any other aspect or obligation of Union member-
ship policies or requirements . All such selection and
referral shall be in accord with the following proce-
dure.
Section 4.05. (a) The Union shall maintain a reg-
ister of applicants for employment established on
the basis of the Groups listed below . Each applicant
for employment shall be registered in the highest
priority Group for which he qualifies.
Journeyman Wireman
GROUP I. All applicants for employment who
have four or more years ' experience in the trade,
are residents of the geographical area constituting
the normal construction labor market , have passed a
journeyman wireman 's examination given by a duly
constituted Inside Construction Local Union of the
IBEW or have been certified as a journeyman wire-
man by any Inside Joint Apprenticeship and Train-
ing Committee and who have been employed for a
period of at least one year in the last four years
under a collective bargaining agreement between
the parties to this agreement.
GROUP II. All applicants for employment who
have four or more years' experience in the trade
and who have passed a journeyman wireman's ex-
amination given by a duly constituted Inside Con-
struction Local Union of the IBEW or have been
certified as a journeyman wireman by any Inside
Joint Apprenticeship and Training Committee.
GROUP III. All applicants for employment who
have two or more years ' experience in the trade, are
residents of the geographical area constituting the
normal construction labor market and who have
been employed for at least six months in the last
three years in the trade under a collective bargain-
ing agreement between the parties to this agree-
ment.
GROUP IV. All applicants for employment who
have worked at the trade for more than one year.
The Union maintains hiring halls at several different
locations . The dispatches are coordinated by the various
dispatchers who use headphones to communicate be-
tween the different locations . The procedure at the
hiring halls is to fill job openings with group I applicants
until the pool of group I applicants at the hall is exhaust-
ed. At that point the job is called out and group II appli-
cants can apply for it. The group II applicant who is
highest on the list is entitled to the job. There is a physi-
cal posting of available jobs and in addition a computer
system is used.
2. Williams' attempt to use the hiring hall
Barrynell Williams is a member of Local 130 of the
International Brotherhood of Electrical Workers, AFL-
CIO. Local 130, which is located in Louisiana , is a sister
local of the Union. In 1980 Williams completed the ap-
prenticeship course conducted by Local 130 and met all
the other requirements needed to qualify for journeyman
status . In mid-December 1984 Williams moved from
Louisiana to the Los Angeles area and on December 21,
1984, he registered on the Union 's out-of-work list. At
that time he gave the Union a traveler 's letter from
Local 130, other information relating to his membership
status, and a paid -up dues receipt for December 1984. He
was placed on the group II out -of-work list. He was on
that list at all times material herein . The parties have
stipulated and I find that Williams was at all times eligi-
ble for placement on the group II hiring list.
Williams reported to the dispatch office almost every
day throughout January, February, and the first part of
March 1985 . His physical appearance was necessary be-
cause an applicant had to be present at the hall to bid on
a job.
On March 12, 1985, Williams was present at the hall
for the dispatch. About 10:40 a.m. the Choi job was an-
nounced . As with all jobs to be dispatched it was listed
on a posted computer printout sheet and displayed on a
lighted board which listed the jobs numerically. As a job
is taken the lights on the panel board go out, which
means that it is no longer available.
When the Choi job was announced , no one from
group I put in for it and it became available for group II
applicants . Williams was the only group II applicant who
applied for that job. He went to the dispatch window
where the dispatcher, Louanne Ryerson , contacted the
other hiring halls over her headset and verified that his
number was the lowest one of the group II Applicants
seeking the job . She then made an announcement that
the Choi job was filled by Williams and she further an-
nounced that the dispatch was closed for the day. The
dispatcher then told Williams that Business Representa-
tive Douglas Cooley would have to complete the dis-
patch form and that Williams would have to fill out cer-
tain forms because it was his first dispatch from the hall.
Ryerson asked Williams his dues receipt . Williams re-
plied that he had his receipt from the Louisiana local for
February and that he had mailed in his payment for
March dues about February 26 but he had not yet re-
ceived his March receipt . At that point Union Business
Representative Douglas Cooley came to the dispatch
window . 2 It was his decision to make whether a person
2 Cooley was the business agent responsible for dealing with matters
concerning referral and dispatch on March 12
ELECTRICAL WORKERS IBEW LOCAL II (CHOI ENGINEERING)
went out on a job if there was a problem concerning a
dispatch .3 Cooley also asked for the dues receipt and
Williams repeated the same he had told Ryerson. He
gave Williams a receipt from Local 130 showing that he
had paid his dues through February 1985.4 Williams said
that if Cooley would call the Louisiana local, it would
tell him that his dues were paid through March . Cooley
agreed to made the call.
Cooley then called Williams' home local . He was told
by someone at that local that they had not received any
money from Williams for March . He then went back to
Williams and said that the home local was not in receipt
of the money . Williams said that he would call the local
himself and that there had to be some mistake because he
had mailed his dues late in February.
Within the next 5 minutes Williams called his home'
local and spoke to Buck Hammond , an assistant business
representative . He explained the situation to Hammond
who switched his call to Janice , the secretary who han-
dles dues payment . Williams asked her about the dues
and she said that the dues were not paid for March. He
told her that there had to be some mistake because he
had mailed it in . She asked him to hold while she looked
through some letters on her desk , and then said she had
found it and that his dues were current . Williams then
spoke to Local 130's assistant business agent Eddy Cretin
and asked him to call the Union back immediately to tell
them that his dues were current , because he was trying
to get to work. Cretin agreed to do so.
Shortly thereafter Union Business Manager Floyd
Henke received verification from Williams ' home local
that a mistake had been made and that Williams ' dues for
March had in fact been paid . Henke relayed that infor-
mation to Cooley.
About an, hour after Williams had initially applied for
the job , he again approached the window and -spoke to
Cooley. Cooley told him that Cretin had called back to
let them know his dues were current . Williams asked
whether he would get the job and Cooley replied that
Williams would not be sent out that day because the
computer had already been shut down . According to
Cooley the person doing the clerical work had already
started making the selections and updating the names on
the list for the next day. Cooley said that he had spoken
with the business manager and they had decided not to
send him out. Ryerson then came to the dispatch
window with a slip in her hand and asked whether Wi-
liams was going to be dispatched that day or not . Cooley
said that he was not. Cooley also said that if Williams re-
turned the next day there would be no problem with his
going to work.
Williams returned to the hall on March 13 and saw
that the Choi job was once again posted . The job was
given to a group I applicant and he did not have an op-
portunity to bid on it.
Cooley testified that the hiring hall rules require that
an applicant for referral must have a paid-up receipt in
a I find that Cooley was an agent of the Union.
4 Dues for Local 130 are payable in advance on the first of each month
for that month. Though they are due on the 1st they are not considered
delinquent until the 15th of the month.
15
his possession at the time of dispatch . He also averred
that local members pay dues of $21.80 a month whether
the member works or not but that a traveler does not
pay any hiring hall fee until he actually goes to work.
In his testimony Cooley admitted , and I find , that Wil-
liams was the next up for referral for the Choi job and
that the reason he was not given the job was because
Cooley believed he was not current in his dues to the
sister local.
There is little dispute about the key facts . The Union
operates an exclusive hiring hall . Williams was eligible
for group II status pursuant to the rules of that hiring
hall and on December 12, 1984 , he was on the out-of-
.work list in that category . When the Choi job was called
for dispatch on that day , no one from group I and no
one from group II other than Williams applied for the
job. Williams was the next up for referral for that job
and the reason he was not given the job was because
Cooley , who was in charge of the hiring hall, believed
that Williams was not current in his dues to the sister
local. An hour later when Cooley was informed that his
belief was mistaken and that Williams in fact was current
in his dues to the sister local, Cooley refused to correct
the mistake . Williams was not referred to the Choi job.
B. Analysis and Conclusion
The Board has previously considered situations that
were for all practical purposes identical to those in the
instant case . In Operating Engineers Local 370 (AGC of
America), 224 NLRB 641, 645 ( 1976), a union refused to
refer an applicant for employment because the applicant
was delinquent in his dues payments to a sister local. The
administrative law judge found a violation in a decision
which read (224 NLRB at 645):
An exclusive hiring hall gives a great deal of au-
thority over the hiring process to a Union , but such
authority is not in itself violative of the Act.lo
However, under such a hiring hall system , a union
cannot lawfully refuse to refer an applicant because
of security clause.' 1 A union may lawfully refuse to
refer an applicant in a situation where that union
could , pursuant to a lawful union-security clause,
require immediate discharge of that employee for
failure to pay dues under a contract governing his
employment, 12 but the applicant cannot be required
to pay back dues for a period when dues were not
validly required as a condition of employment.) 3
Referral cannot lawfully be refused because an ap-
plicant is not a member of or current in his dues
with a sister local of the same International as the
referring union. l4
10 Local 357, International Brotherhood of Teamsters Chauffeurs
Warehousemen and Helpers of America [Los Angeles-Seattle Motor
Express] v. NLRB, 365 U S. 667 (1961).
11 Seafarers International Union of North America. Atlantic.
Gulf, Lakes & Inland Waters District. AFL-CIO (Isthmian Lines
Inc.), 202 NLRB 657, enfd 496 F 2d 1363 (C.A 5, 1974). In addi-
tion, referral may be conditioned on the payment of a reasonable
nondiscriminatory hiring hall fee Boston Cement Masons and As-
phalt Layers Union No. 534 (Duran Maguire Eastern Corp.), 216
16 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
NLRB 568 (1975). However, there is no such issue in this case as
Bailey paid all the "dobie" fees required of him.
12 Mayfair Coat & Suit Co ., 140 NLRB 1333 (1963).
is Cf. Fishermen & Allied Workers' Union, Local 33, Internation-
al Longshoremen 's and Warehousemen 's Union (S G. Guiseppe Fish-
ing, Inc.), 180 NLRB 851 ( 1970), enfd . 448 F .2d 255 (C.A. 9, 1971).
14 Cf. International Brotherhood of Electrical Workers. AFL-
CIO, Local 648 (Foothill Electrical Corporation), 182 NLRB 66
(1970), enfd . 440 F.2d 1184 (C.A. 6, 1971), International Brother-
hood of Electrical Worker, AFL-CIO, Local 82 (National Electrical
Contractors Association, Dayton, Ohio Chapter), 182 NLRB 59
( 1970), enfd . 440 F.2d 1184 (C.A. 6, 1971).
The Board adopted the administrative law judge's deci-
sion in an unpublished order. The administrative law
judge's decision was however reported in the supplemen-
tal decision and order of the Board cited above.
A similar conclusion was reached by the Board in
Bricklayers Local 8 (California Mason Assn.), 235 NLRB
1001 (1978), where a union was found to have violated
the Act by refusing to refer an applicant from its hiring
hall because the applicant had not paid a fine imposed by
a sister local . In that case a majority of the Board 's panel
also found that the Union had violated the Act by failing
to represent the applicant fairly. See also Teamsters Local
519 (Rust Engineering), 275 NLRB 433 (1985); Operating
Engineers Local 825 (Building Contractors of New Jersey),
272 NLRB 186 (1984); Laborers Local 135 (Bechtel), 271
NLRB 777 (1984).
As was held in Electrical Workers IBEW Local 11
(LA. Chapter of NECA), 270 NLRB 424, 425 (1984),
which involved the same union as in the instant case:
The Board has held that a union which operates
an exclusive hiring hall must represent all individ-
uals who seek to utilize the hall in a fair and impar-
tial manner.' The labor organization conducting
such an operation has a duty to conform with and
apply lawful contractual standards in administering
the referral system, and any departure from the es-
tablished procedures resulting in a denial of employ-
ment constitutes discrimination which inherently en-
courages union membership . This discrimination
constitutes a violation of Section 8(b)(1)(A) and (2)
of the Act.8
7 Plumbers Local 725 (Powers Regulator), 225 NLRB 138, 143
(1976).
° Id. at 143; Operating Engineers Local 513 (S J. Groves & Sons
Co.), 199 NLRB 921, 922 (1972).
In the instant case the Union refused to refer Williams
to the Choi job because it wrongly believed that Wil-
liams was delinquent in his dues to a sister local. As indi-
cated above such a refusal to refer is unlawful even
where the applicant in fact has not paid dues to a sister
local. Here the Union's conduct was particularly harsh.
Williams was current in his dues to the sister local. The
sister local was the one which made the mistake and the
Union refused to correct the inequity even though it
knew that the mistake had been made. Williams was in
no sense a "free rider." He was abiding by all of the le-
gitimate hiring hall rules. The Union has neither an equi-
table nor a legal defense. 5 I find that the Union violated
Section 8(b)(1)(A) and (2) of the Act by refusing to refer
Williams to the Choi job on March 12, 1985, because the
Union believed that Williams was delinquent in dues
owed to a sister local.6 Iron Workers Local 433, 272
NLRB 530 (1984).
CONCLUSION OF LAW
By refusing to refer Williams to the Choi job on
March 12, 1985, because the Union believed that Wil-
liams was delinquent in dues owed to a sister local, the
Union violated Section 8(b)(1XA) and (2) of the Act.
REMEDY
Having found that the Union engaged in unfair labor
practices within the meaning of Section 8(b)(1)(A) and
(2) of the Act, I recommend that it be ordered to cease
and desist therefrom and to take certain affirmative
action designed to effectuate the policies of the Act.
It is also recommended that the Union make Williams
whole for any loss of earnings suffered on and- after
March 12, 1985, by reason of the Union's unlawful refus-
al to refer him to work. The amount of backpay shall be
computed in accordance with the formula set forth in F.
W. Woolworth Co., 90 NLRB 289 (1950), together with
interest as provided in Florida Steel Corp., 231 NLRB
651 (1977).' It is recommended that the Union be or-
dered to make Williams whole for any rights he would
have accrued from any employment relationship improp-
erly foreclosed him through the Union's unlawful con-
duct and that the Union credit Williams with the hours
he would have worked but for the discrimination, in de-
termining his eligibility for class I status in the hiring hall
referral system.
As the unlawful conduct of the Union indicates a pur-
pose to limit the lawful rights of applicants for employ-
ment, I recommend that the Union be ordered to cease
and desist from operating its exclusive hiring hall in such
a manner as to cause or attempt to cause any employer
subject to the Board's jurisdiction to deny employment
to any employee or applicant for employment because of
lack of union membership or payment of union dues,
except to the extent permitted by Section 8(a)(3) of the
Act.8
° In its brief the Union argues that it did not violate the law because it
did not deviate from its traditional policy of requiring travelers to show a
paid up receipt from a sister local. Rather than a viable defense, the
Union has shown that its traditional policy is unlawful. The Union also
argues that the dues receipt is needed so that an applicant can be proper-
ly identified. Here Williams had a dues receipt for February and there
was no problem with identification . In addition , Cooley admitted that he
did not refer Williams because he believed Williams was not current in
his dues to the sister local. There was no evidence that Williams failed to
properly identify himself.
° Williams did not make use of the hiring hall appeals mechanism.
However , contractual grievance procedure is not mandatory because the
interest of the employee is clearly in conflict with that of the Union."
Iron Workers Local 433 (RPM Erectors), 266 NLRB 154 fn. 1 (1983).
Board deferral is not appropriate . Teamsters Local 519 (Rust Engineering),
supra.
7 See generally Isis Plumbing Co., 138 NLRB 716 (1962).
° In Electrical Workers IBEW Local 11 (L.A. Chapter of NECA), 270
NLRB 424, 425 (1984), the Board found that the same union had operat-
Continued
ELECTRICAL WORKERS IBEW LOCAL 11 (CHOI ENGINEERING) 17
It is recommended that the Union be ordered to pre-
serve and, on request, make available to the Board or its
agents for examination and copying, all records pertain-
ing to employment through its hiring hall and all records
relevant and necessary for compliance with this recom-
mended Order.
On these findings of fact and conclusions of law and
on the entire record, I issue the following recommend-
ed9
ORDER
The National Labor Relations Board orders that the
Respondent , International Brotherhood of Electrical
Workers, Local 11, AFL-CIO, its officers, agents, and
representatives, shall
1. Cease and desist from
(a) Refusing to refer Barrynell Williams to employ-
ment through its exclusive hiring hall because Williams
owes, or because that Union believes Williams owes,
dues to Local 130, International Brotherhood of Electri-
cal Workers , AFL-CIO.
(b) Operating its exclusive hiring hall in such a manner
as to cause or attempt to cause any employer subject to
the jurisdiction of the National Labor Relations Board to
deny employment to any employee or applicant for em-
ployment because of the lack of union membership or
payment of union dues, except to the extent permitted by
Section 8(a)(3) of the Act.
(c) In any like or related manner restraining or coerc-
ing employees in the exercise of rights guaranteed them
by Section 7 of the Act.
2. Take the following affirmative action necessary to
effectuate the policies of the Act.
(a) Make Barrynell Williams whole for any loss of pay
and other benefits he may have suffered as a result of its
unlawful refusal to refer him to work, in the manner set
forth in the remedy section of this decision.
(b) Preserve and, on request , make available to the
Board or its agents for examination and copying , all pay-
roll records , social security payment records, timecards,
personnel records and reports , and all other records nec-
essary to analyze the amount of backpay due under the
terms of this Order.
ed its hiring hall in an unlawful manner . However, even without that pre-
vious Board finding, it is apparent from record of this case that the viola-
tion stems from a union policy with regard to dues receipts and not to an
individual problem relating to Williams or Choi.
9 If no exceptions are filed as provided by Sec . 102.46 of the Board's
Rules and Regulations , the findings, conclusions , and recommended
Order shall , as provided in Sec. 102.48 of the Rules , be adopted by the
Board and all objections to them shall be deemed waived for all pur-
poses.
(c) Post at its business offices, hiring halls , and meeting
places copies of the attached notice marked "Appen-
dix."10 Copies of the notice , on forms provided by the
Regional Director for Region 31, after being signed by
the Respondent 's authorized representative, shall be
posted by the Respondent immediately upon receipt and
maintained for 60 consecutive days in conspicuous places
including all places where notices to members are cus-
tomarily posted . Reasonable steps shall be taken by the
Respondent to ensure that the notices are not altered, de-
faced , or covered by any other material.
(d) Notify the Regional Director in writing within 20
days from the date of this Order what steps the Re-
spondent has taken to comply.
10 If this Order is enforced by a judgment of a United States court of
appeals, the words in the notice reading "Posted by Order of the Nation-
al Labor Relations Board " shall read "Posted Pursuant to a Judgment of
the United States Court of Appeals Enforcing an Order of the National
Labor Relations Board."
APPENDIX
NOTICE To MEMBERS
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
To all job applicants using our hiring hall , whether or
not members of International Brotherhood of Electrical
Workers, Local 11, AFL-CIO:
WE WILL NOT refuse to refer Barrynell Williams to
employment through our exclusive hiring hall because
Williams owes , or because we believe Williams owes,
dues to Local 130, International Brotherhood of Electri-
cal Workers, AFL-CIO.
WE WILL NOT operate our exclusive hiring hall in such
manner as to cause or attempt to cause any employer
subject to the jurisdiction of the National Labor Rela-
tions Board to deny employment to any employee or ap-
plicant for employment because of lack of union mem-
bership or payment of union dues, except to the extent
permitted by Section 8(aX3) of the Act.
WE WILL NOT in any like or related manner restrain or
coerce you in the exercise of the rights guaranteed you
by Section 7 of the Act.
WE WILL make Barrynell Williams whole for any loss
of pay and other benefits he may have suffered as a
result of our unlawful refusal to refer him to work.
INTERNATIONAL BROTHERHOOD OF ELEC-
TRICAL WORKERS , LOCAL 11, AFL-CIO