Concluding employer entitled to judgment as matter of law where employee offered no evidence of number and types of positions available in local job market that did not require heavy or medium lifting
Rejecting employer's contention that it had insufficient notice regarding the potential relevance of a union request for individual insurance claims information because "context is everything," and the employer "put on the table" the concern of growing health care costs
Holding that brevity of parties' negotiations on issue and union's position that it still "had more movement to make" undermine employer's declaration of impasse