Plumbers Local Union No. 412

National Labor Relations Board - Board Decisions

Jul 21, 1980

250 N.L.R.B. 863 (N.L.R.B. 1980)

PLUMBERS. I.()CAI. UNION N() 412
United Association of Journeymen and Apprentices
of the Plumbing and Pipe Fitting Industry of
the United States and Canada, Local Union No.
412, AFI,-CIO and The Zia Company. Case
28-CD-187
July 21, 1980
DECISION AND ORDER
BY CHAIRMAN FANNING AND MEMBERS
Pi NFII. O AND) TRUESDAI FE
On April 9, 1980, Administrative Law Judge
James M. Kennedy issued the attached Decision in
this proceeding. Thereafter, Respondent filed ex-
ceptions and a supporting brief, and the Charging
Party filed a brief in opposition to Respondent's ex-
ceptions.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the Na-
tional Labor Relations Board has delegated its au-
thority in this proceeding to a three-member panel.
The Board has considered the record and the at-
tached Decision in light of the exceptions and
briefs and has decided to affirm the rulings, find-
ings, and conclusions of the Administrative Law
Judge and to adopt his recommended Order.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor Re-
lations Board adopts as its Order the recommended
Order of the Administrative Law Judge and
hereby orders that the Respondent, United Associ-
ation of Journeymen and Apprentices of the
Plumbing and Pipe Fitting Industry of the United
States and Canada, Local Union No. 412, AFL-
CIO, Albuquerque, New Mexico, its officers,
agents, and representatives, shall take the action set
forth in the said recommended Order.
DECISION
STATEMENT OF THE CASE
JAMES M. KENNEDY, Administrative Law Judge: This
case was heard before me at Albuquerque, New Mexico,
on October 30, 1979,1 pursuant to a complaint issued on
August 24 by the Regional Director for the National
Labor Relations Board for Region 28, and which is
based upon a charge filed by The Zia Company (herein
called Zia) on August 15. The complaint alleges that
United Association of Journeymen and Apprentices of
the Plumbing and Pipe Fitting Industry of the United
States and Canada, Local Union No. 412, AFL-CIO
(herein called Respondent), has engaged in certain viola-
tions of Section 8(b)(4)(D) of the National Labor Rela-
tions Act, as amended (herein called the Act). Laborers'
I All date, hereini refer to 1'74) unle. thcrx ki,, r Ilhcalcdi
International Union of North America, Local 16, Al I.-
CIO, was permitted to intervene as an interested party.
Isstr r:s
Whether or not Respondent's work stoppages of May
23 and August 14 had an object of coercing Zia and/or
its wholly owned subsidiary, I.os Alamos Constructors,
Inc. (herein called LACI), to reassign certain sewxer pipe
installation to employees represented by it rather than by
employees represented hy l.aborers' Local 16. If so. I
must also decide whether the Regional Director fol-
lowed the correct procedure by issuing the instant com-
plaint or whether he should have issued on behalf of the
Board a notice of hearing under Section 10(k) of the
Act.
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, wvere filed on
behalf of Zia and Respondent. The General Counsel filed
a letter containing points and authorities: L.aborers Local
16 did not file any written argument.
Upon the entire record of the case, and from my ob-
servation of the witnesses and their demeanor, I make
the following:
FINDIN(iS OF FACI
I. THE EMPI.OY R'S BUSINESS
Respondent admits Zia and LACI are New Mexico
corporations providing maintenance and construction
support to the U.S. Department of Energy's Los Alamos
Scientific Laboratory in Los Alamos. It further admits
that during the past year, in the course and conduct of
its business, this single, integrated business has purchased
and received goods and materials valued in excess of
$50,000 from suppliers outside New Mexico. According-
ly, it admits, and I find, that Zia and LACI are engaged
in commerce and in a business affecting commerce
within the meaning of Section 2(2), (6), and (7) of the
Act.
II. THE I ABOR ORG(ANIZATION INVOI VEI)
Respondent admits, and I find, that both it and Labor-
ers Local 16 are labor organizations within the meaning
of Section 2(5) of the Act.
ill. THE Al .I.EGED UNFAIR I ABOR PRACTICFS
Zia has been the principal support contractor for the
Los Alamos Laboratory since 1946 when the laboratory
operated under the auspices of the U.S. Army Corps of
Engineers. In 1953 it created its subsidiary LACI as a
construction arm, pursuant to an Atomic Energy Com-
mission directive, to meet certain legal requirements of
the Davis-Bacon Act. These two entities (herein jointly
called the Company) have been continuously occupied as
the support contractors for the laboratory since that time
regardless of which Federal agency or department man-
aged it. Among other things. the Companl operates the
utilities systems used at the laboratory, including all elcc-
250 NLRB No. 137
8Xh
DECISIONS OF NATIONAL LABOR RELATIONS BOARD
tric generator, water and natural gas systems, and the
sanitary sewers. The Company's headquarters and oper-
ations center are located on the laboratory grounds in
buildings owned by the Department of Energy. Between
Zia and LACI the Company has collective-bargaining
agreements with 12 different unions. It has had contrac-
tual arrangements with Respondent and Laborers Local
16 since approximately 1947.
It appears from the testimony of William Francis, now
Zia's deputy manager, but during the time of the inci-
dents in question its chief of technical area division, that
LACI is constantly engaged in various construction pro-
jects on laboratory property. The work involved in this
case is the installation of certain sewer pipe in lateral
connections between mains and newly constructed build-
ings or additions. Francis testified that in recent years
LACI, on the average, has excavated and installed pipe
in at least one lateral sewer line per month. He says that
although there have been some minor exceptions, LACI
has consistently assigned the work of connecting nonme-
tallic sewer pipes to its employees represented by Labor-
ers Local 16 and the connection of metallic pipes to
members of Respondent. In addition, he says, Respond-
ent's members have always been assigned the work of
actually connecting the pipe to the building.
According to Francis, beginning in late 1978 Respond-
ent's stewards began insisting that the work of connect-
ing nonmetallic pipe in sewer laterals properly belonged
to workmen represented by Respondent.
In April 1979 the Company was scheduled to install a
150-foot clay sewer line. Prior to the commencement of
that project, Francis advised his craft section that the in-
stallation of the sewer line was to be assigned to the La-
borers. On March 29 he followed that oral directive with
a written memorandum to the assistant superintendent of
the Company's craft section. A copy of that memo was
sent to Toby Pacheco, an International representative of
the Laborers Union. On the following day Francis sent
another memo to his engineering department advising
them of the assignment, asserting that the assignment was
in accord with longstanding practice and directing the
engineers to be consistent with it, as granting some of
the work to Respondent's members "causes nothing but
problems."
As directed, the work was assigned to employees rep-
resented by the Laborers. The Company commonly em-
ploys a large number of pipefitters. In early April the pi-
pefitters engaged in a walkout which lasted 4 or 5 days.
There is no direct evidence that the April work stoppage
by Respondent's members was directly connected to the
work assignment discussed above, but Francis said the
only dispute of which he was aware was the question of
who was to install the clay pipe. Sometime in late April,
after that walkout had ended, a meeting was called by
Francis' superior, Deputy Manager T. J. "Tom" Cook,
which was attended by Cook, Francis, representatives of
the Laborers Union, and representatives of Respondent,
including its business manager, Carl Smith. Francis testi-
fied that Cook attempted to obtain an agreement be-
tween Respondent and the Laborers regarding the instal-
lation of nonmetallic pipe. He said representatives of
both unions claimed the work, saying it was "traditional-
ly" theirs. When no agreement was reached, Cook told
both Unions that if they did not reach an agreement he
intended to submit the dispute to the Impartial Jurisdic-
tional Disputes Board (IJDB) to which all parties were
bound and to utilize its decision as precedent for future
work. 2
On May 17 Francis called Respondent's steward,
Steve Bowman, and Laborers steward, Ernest Martinez,
to his office and advised them of an upcoming nonmetal-
lic sewer lateral job saying the Company intended to
submit the question of jurisdiction to the IJDB but in the
meantime was assigning the work to the Laborers.
Bowman protested it as a misassignment.
On May 23, 75 of the pipefitters represented by Re-
spondent stopped working at various jobs around the
laboratory and went to another lateral sewer line project
(one different from the one discussed on May 17) and en-
gaged in a confrontation with the laborers working on
that job. Francis and Cook went to the site to determine
what was happening and spoke to Bowman. He told
them it was a misassignment; that the work should have
been assigned to Respondent's members. During the
course of the stoppage individual pipefitters stated they
were there "to learn how to lay pipe from the laborers."
In order to avoid the possibility of physical violence,
Cook directed the laborers to be removed from the
ditch. Francis and Cook told the pipefitters to return to
their jobs saying the Company would take the matter up
with the IJDB. Cook also told them the Company in-
tended to use the IJDB decision as a precedent for future
nonmetallic pipe installation. The laborers stopped work-
ing pursuant to the directive and for approximately half
an hour the pipefitters milled around, then returned to
their jobs. The entire incident lasted approximately an
hour and a half.
On the following day the Company submitted the
project discussed on May 17 to the IJDB asserting it was
assigning the work in question to the Laborers. On June
8 the IJDB notified all parties that "there is no basis to
change the contractor's assignment" but also stated that
its decision was "predicated upon particular facts and
evidence before it regarding this dispute and shall be ef-
fective on this particular job only."
On July 11 Respondent's business agent, David Rivera,
charged the Company with violating article XIX, section
3, subsection C, of Respondent's collective-bargaining
agreement. That clause is a work jurisdiction clause stat-
ing that employees represented by Respondent are enti-
tled to install "all sewers and/or waste lines from the
buildings to the main sewer .... " Rivera asked the
Labor Management Conference Committee (LMCC),
created by that contract, to hear the charges. On July 12
the director of the Mechanical Contractors Association
of New Mexico notified the Company that a hearing had
been scheduled for July 17 on Respondent's charges.
2 Thc Impartial Jurisdictional Disputes Board is a body set up under
Ihe auspices of tile AFL CIO's Building and Construction Trades De-
partment and the Associated General Contractors of America The col-
lective-bargaining agreements betleen the Company and both Unions
prosvide that jurisdictional disputes are tl he submitted to the IJDB. See
art IV of the I.ACI-I ocal Iti agreemenl and art. Xll sec 8 ofapp A to
the Iroject Agreement betwreen Zia/l.ACI and Respondent
6h4
PLUMBERS. LOCAL UNION NO. 412
Cook replied by letter dated July 12 declining to attend
on the ground that the alleged violation was a jurisdic-
tional dispute between Respondent and the Laborers
Union and advising that the matter had been settled by
the IJDB award of June 8. A copy of that award was
transmitted with his letter.
The minutes of the LMCC meeting of July 17 show it
unanimously found that LACI had violated Respondent's
contract as charged and directed LACI to comply with
the jurisdictional article of the contract describing sewer
installation work as Respondent's.
On August 14 the Company scheduled a meeting with
Respondent's business manager, Smith, and his staff re-
garding another matter. Smith testified that his business
agent, Rivera, and Cook had just "evolved" the meeting.
Whatever its original purpose, the discussion actually
centered around Respondent's claim that LACI was vio-
lating the sewer work clause of its contract with Re-
spondent and Smith wanted to know what the Company
intended to do about it. According to Francis, Smith
claimed the work for Respondent and asked Cook if he
intended to abide by the LMCC award. Cook said he did
not; that he intended instead to abide by the decision of
the IJDB. Smith then told the company officials that on
the following morning Respondent was going to with-
hold the services of its membership. Smith agrees with
Francis here, but adds Cook offered to settle the entire
dispute on the basis of a "joint crew," a proposition
which Respondent had long opposed. 3 He rejected that
offer. The meeting ended on Smith's statement that Re-
spondent intended to engage in an immediate work stop-
page. Immediately thereafter, Smith sent Cook a tele-
gram saying, in essence, that because the Company was
in violation of the sewer work clause and because it was
refusing to comply with the LMCC directive Respond-
ent considered all contractual remedies as having been
exhausted. Therefore, said Smith, further noncompliance
with the LMCC award was "tantamount to having no
agreement" and Respondent was advising its members
not to report to work on Wednesday, August 15.
Neither Francis nor Smith was certain whether there
was actually a specific sewer pipe installation job to be
performed at that time. I assume, therefore, there was
not. However, it is fair to say, in view of Francis' testi-
mony that such projects occurred on at least a monthly
basis, that one was surely to be done, and such a project
could reasonably be expected to present itself shortly. In
any event Respondent's members followed Smith's
"advice" and a work stoppaqe began on August 15 and
continued until Auqust 31 when it was enjoined under
Section 10(1) of the Act by the United States District
Court for the District of New Mexico.
3 A "joint crew" is not the same as a "composite crew" in which em.
ployees of competing crafts are placed on a disputed job and are paid
their respective craft rates. The joint crew discussion here, according to
Smith, meant that the Company wished to create a new classification of
worker and pay that job holder a separate rate. Presumably laborers
would earn more than under the Laborers contract and pipefitters would
earn less than they would have under the Pipe Fitters contract. I find no
merit to Respondent's claim that this is evidence that the Company "cre-
ated" the dispute in order to force Respondent to accept the "joint crew"
concept.
IL'. I.EGAIt ANAI YSIS AND CONCLUSIONS
The threshold question here is whether or not Re-
spondent's work stoppages of May 23 and August 15 in-
duced or encouraged individuals to refuse to perform
work and/or threatened or coerced the Company where
in either case an object was to force the Company to
change its assignment of sewer lateral installation work
from its employees represented by Laborers Local 16 to
employees represented by Respondent. I conclude and
find that both the May 23 and August 15 stoppages had
that objective. There is no evidence in this record that
there was any other dispute. Such work had been as-
signed to the Laborers in March. An attempt to resolve
Respondent's claim was made in late April to no avail.
On May 17 the Company again advised both Unions that
it intended to make another assignment to the Laborers.
On May 23, 75 pipefitters left their jobs elsewhere at the
test site and went to a ditch where laborers were en-
gaged in such work. The pipefitters explained they were
there to "learn" how to do it; their steward asserted that
the work was a misassignment and properly belonged to
Respondent's members.
After the Company filed a petition for resolution of
the dispute vis-a-vis one particular sewer lateral and suc-
ceeded in persuading the IJDB to approve its assign-
ment, Respondent charged LACI with violating the
sewer work clause in the jurisdiction paragraph of its
collective-bargaining contract. Upon obtaining a favora-
ble ruling from the arbitration board established by that
contract (and without the participation of the Laborers'
Union which was not a party to that agreement in any
event), 4 it announced that because the Company would
not abide by that award it considered the collective-bar-
gaining contract terminated and caused a second work
stoppage on August 15.
Clearly this adds up to both inducement of individuals
to withhold services and restraint and coercion of the
Company to achieve a proscribed object, here to force a
reassignment of the sewer work to Respondent's mem-
bers. Ets-Hokin Corporation, 154 NLRB 839, 842 (1965),
and Young Plumbing & Supply, supra.
Respondent defends that it was privileged to engage in
this activity because the Company had breached its
agreement and since that resulted in a de facto cancella-
tion of the contract it was not obligated to provide em-
ployees to work. That argument overlooks the underly-
ing reasons for the "breach." Assuming that there was a
breach of contract by the Company, it does not follow
that the breach privileged conduct violating Section
8(b)(4)(D). Ets-Hokin, supra,' Young Plumbing & Supply,
supra. The work assignment object is at the bottom of
this dispute and by characterizing it as a contract dispute
Respondent cannot insulate itself from Section
8(b)(4)(D).
The Union also argues it was simply attempting to pre-
serve work opportunities for its membership. There are
I Since the LMCC proceeding did not include Laborers Local 16, that
body does not qualify under Sec. 10(k) as a tribunal competent to deter-
mine jurisdictional disputes Sheet Mfetal Workers International A4ssocx-iaoion
AFlL-CIO, and Local Union No. 418 (Younq Plumbing & Supply, Inc ). 209
NL.RB 117711974}
8h5
I)1 C'ISI()NS ()0 NA II()NAI. I A()R RELA TI()NS BI()ARI)
some circumstances where such all object has been held
to be outside the prescription of Section 8(b)(4)(D).
However, those cases all involve work which had solely
been performed by employees represented by the claim-
ing union and where it could not be said that two groups
were competing for the work. ' Unlike those cases, how-
ever, there is no factual claim here that the work in
question had always been performed by Respondent's
members and Respondent was only attempting to recap-
ture work given to laborers who had never before done
it. On the contrary, this is the classic situation where two
unions have traditionally performed similar work. Even
if the Company here has occasionally assigned a pipefit-
ter to do it, that does not negate the fact that laborers
have traditionally done it, too. Accordingly, I am unable
to conclude that Respondent's work preservation defense
has any merit here. In any event, that is a defense which
should properly be brought to the attention of a compe-
tent disputes adjustment body under Section 10(k) of the
Act.
Finally, Respondent argues that the Board is without
jurisdiction to hear this matter because no award under
Section 10(k) has been issued. That assertion is only par-
tially accurate. All parties here are bound by their col-
lective-bargaining agreements and both Unions are
bound by their membership in the Building and Con-
struction Trades Department of the AFL-CIO to submit
jurisdictional disputes to the Impartial Jurisdictional Dis-
putes Board for resolution. Section 10(k) expressly pro-
vides that the National Labor Relations Board shall de-
termine such disputes unless the parties have an agreed-
upon method for the voluntary adjustment of that dis-
pute. In this case the Regional Director had no need to
issue a notice of a 10(k) hearing because the parties had
an agreed-upon method to settle the dispute. Indeed, on
May 24, the Company invoked those procedures. I rec-
ognize that the IJDB's resolution of that dispute did not
extend to every lateral sewer the Company may decide
to install. Nonetheless, the parties still have that method
available and should be utilizing it. I do not need to
decide, nor does the Board, the merits of that dispute.
Section 8(b)(4)(D) empowers the Board to prohibit con-
duct having an illegal object. Therefore, it is immaterial
to the instant complaint whether or not the IJDB's June
8 award is properly to be construed as precedent on
future Zia/LACI jobs. Likewise it is immaterial to deter-
mine whether or not the IJDB's rules are excessively re-
strictive as Respondent claims. The parties have agreed
upon that body as a method to adjust these disputes and
accordingly are bound to use it. All the Board need do
next is to determine whether or not Respondent has en-
gaged in conduct prohibited by Section 8(b)(4)(D). See
Electrical Workers Local 26, IBEW, AFL-CIO (McClos-
key & Co.), 147 NLRB 1498 (1964); Operating Engineers
Local Union No. 3, etc. (Hansen's, Incorporated), 192
s See, for example, Highway Truckdriver d& Helpers. Local 107, IBT
(Safieway Storec Incorporated). 134 NLRB 1320 (1961); International Long-
ihoremnen's and Warehoutemeni' Union Local 8 (Waterway Term inal Com-
pany). 185 NLRH 186, reversed 467 F2d 1011 (9th Cir. 1972): Teanmreri
Local Union Nso 676 (Shell Chemical Company), 199 NLRB 683 (1972):
Seatrle Building & Contvruction Trades Council, AFL-CO., et al (Seattle
Olymnpic llrl CompanL). 204 N LR B 11 26 (1973).
NLRB 139 (1971), reaffirmed 199 NLRB 726 (1972); and
International Association of Bridge. Structural and Orna-
mental Iron Workers Local 10, AFL-CIO (Vincent Metal
Works), 215 NLRB 153, 154, fn. 7 (1974). Since I have
reached that conclusion supra, it follows that Respondent
should be ordered to cease and desist from such activity.
Upon the foregoing findings of fact and upon the
entire record in this case, I make the following:
CONCL USIONS OF LAW
I. The Zia Company and its wholly owned subsidiary
Los Alamos Constructors, Inc., are employers engaged
in commerce within the meaning of Section 2(2), (6), and
(7) of the Act.
2. The Respondent, United Association of Journeymen
and Apprentices of the Plumbing and Pipe Fitting Indus-
try of the United States and Canada, Local Union No.
412, AFL-CIO, and Laborers' International Union of
North America, Local 16, AFL-CIO, are labor organiza-
tions within the meaning of Section 2(5) of the Act.
3. By inducing and encouraging individuals employed
by The Zia Company and/or Los Alamos Constructors,
Inc., to engage in work stoppages on May 23 and August
15, 1979, in the course of their employment by refusing
to perform services, and by canceling its collective-bar-
gaining agreement, all with an object of forcing or re-
quiring Zia and/or LACI to reassign certain sewer in-
stallation work, Respondent engaged in activity pro-
scribed by Section 8(b)(4)(i)(D) and by the same activity
restrained and coerced Zia and/or LACI within the
meaning of Section 8(b)(4)(ii)(D).
Upon the basis of the foregoing findings of fact, con-
clusions of law, and the entire record in this proceeding,
and pursuant to Section 10(c) of the Act, I hereby issue
the following recommended:
ORDER 6
The Respondent, United Association of Journeymen
and Apprentices of the Plumbing & Pipe Fitting Industry
of the United States and Canada, Local Union No. 412,
AFL-CIO, Albuquerque, New Mexico, its officers,
agents, and representatives, shall:
I. Cease and desist from engaging in or inducing or
encouraging any individual employed by The Zia Com-
pany and/or Los Alamos Constructors, Inc., to engage
in a strike or refusal to perform services or to threaten,
coerce, or restrain Zia and/or LACI, either directly or
by canceling collective-bargaining agreements, with an
object of forcing or requiring either of those two em-
ployers to assign sewer lateral installation work to em-
ployees who are represented by Respondent rather than
to employees who are represented by Laborers' Interna-
tional Union of North America, Local 16, AFL-CIO.
2. Take the following affirmative action necessary to
effectuate the policies of the Act:
6 In the event no exceptions are filed as provided by Sec. 102.46 of the
Rules and Regulations of the National Labor Relations Board, the find-
ings, conclusions, and recommended Order herein shall, as provided in
Sec. 112.48 of the Rules and Regulations, be adopted by the Board and
become its findings. conclusions, and Order, and all objections thereto
shall be deemed wDaived for all purposes
P11 UlMIIRS. I()OCAI. UNI()N N() 412
(a) Post at its offices and meeting halls in Albuquer-
que, New Mexico, copies of the attached notice marked
"Appendix."7 Copies of said notice, on forms to be pro-
vided by the Regional Director for Region 28, after
being duly signed by an authorized representative of Re-
spondent, shall be posted by Respondent immediately
upon receipt thereof, and be maintained by it for 60 con-
secutive days thereafter, in conspicuous places, including
all places where notices to members are customarily
posted. Reasonable steps shall be taken by Respondent to
ensure that said notices are not altered, defaced or cov-
ered by any other material.
(b) Deliver to the Regional Director for Region 28
signed copies of said notice in sufficient numbers to be
posted by The Zia Company and/or Los Alamos Con-
structors, Inc., and Laborers' International Union of
North America, Local 16, if willing.
(c) Notify the Regional Director for Region 28, in
writing, within 20 days from the date of this Order, what
steps Respondent has taken to comply herewith.
I In the event that the Board%' Order is enforced by a Judgment of a
United States Court of Appeals, the w'ord% in the notice reading "Posted
by Order of the National I.abor Relations Board" haill read "Posted Pur-
suant Io a Judgmenl of ihe Uniled States Court of Appealt Enforcing an
Order of the National .Ilhbor Rlclil on, Board"
APPEND)IX
No Iici TO EMPI OY IIS ANI) MEMBI-.RS
POSTIii) HB ORI)I R 01 IFll.
NX I IONAI LABOR RFI AI IONS BOARI)
An Agency of the United States Government
After a hearing at which all sides had an opportunity to
present evidence and state their positions, the National
Labor Relations Board found that we have violated the
National Labor Relations Act. as amended, and has or-
dered us to post this notice.
To: All employees of The Zia Company and Los
Alamos Constructors, Inc.
To: All members of United Association of Journey-
men and Apprentices of the Plumbing and Pipe
Fitting Industry of the United States and Canada.
Local Union No. 412, AFL-CIO
To: All members of Laborers' International Union
of North American, Local 16, AFL-CIO
We hereby notify you that:
WE WIL t NOT engage in strikes, work stoppages,
or refusals to perform work and wE WII. NOT
induce, encourage, or threaten persons to do those
things, whether directly or by canceling our collec-
tive-bargaining contract, where an object of such
conduct is to force The Zia Company and/or Los
Alamos Constructors, Inc., to reassign sewer lateral
installation work from employees represented by
Laborers' International Union of North America,
Local 16 AFL-CIO, to employees represented by
us.
UNIT-I) ASSOCIATION OF JOURNEYMEN
AND APPRENI ICS 01 IFHE PLUMBING AND
PIPE FIrr'iNG INDUSrRY OF THE UNITED
STA1TIS AND) CANADA, LOCA. UNION No.
412, AFL-CIO