In Bourne, we held that interrogation which does not contain express threats is not an unfair labor practice unless certain "fairly severe standards" are met showing that the very fact of interrogation was coercive.
Holding that since consultant based in Indiana rendered services to company based in Pennsylvania, "no more was required to put [the consultant's] activities within interstate commerce" and therefore within the Board's statutory jurisdiction under NLRA § 10 (citing Reliance Fuel Oil Corp., 371 U.S. at 226-27, 83 S.Ct. 312)