Round Hill Foods, Inc.

National Labor Relations Board - Board Decisions

Sep 30, 1985

276 N.L.R.B. 1087 (N.L.R.B. 1985)

ROUND HILL FOODS 1087
Round Hill Foods, Inc. and United Food and Com-
mercial Workers International Union, Local
295, AFL-CIO, CLC. Cases 4-CA-'14043 and
4-CA-12247
30 September 1985
DECISION AND ORDER
DY CHAIRMAN DOTSON AND MEMBERS
DENNIS AND BABSON
On 26 March 1985 Administrative Law Judge
Hubert E. Lott issued the attached decision. The
Respondent filed exceptions and a supporting brief,
the General Counsel filed cross-exceptions, a sup-
porting brief, and a response to Respondent's ex-
ceptions, and the Charging Party filed a brief in
support of, the judge's decision.
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
as modified.2
'ORDER
The National Labor Relations Board adopts the
recommended Order of the administrative law
judge as modified below and orders that the Re-
spondent , Round Hill Foods , Inc., New Oxford,
Pennsylvania , - its officers , agents , successors, and
assigns , shall take the action set forth in the Order
as modified. - -
1. Insert the following as paragraph 1(a) and re-
letter the subsequent paragraphs.
"(a) Refusing to bargain collectively concerning
rates of pay , wages , hours,, and other terms and
conditions of employment .with United Food and
Commercial Workers International Union, Local
295, AFL-CIO, CLC as - the exclusive bargaining
representative of all its employees in the appropri-
ate unit." -
2. Substitute the following for paragraph 2(a).
' In reaching his conclusion that the Respondent's refusal to sign the
collective-bargaining agreement violated Sec 8(a)(5) and (1) of the Act,
the judge rejected certain hearsay testimony regarding employee senti-
ments about the Union . We note that even considering this evidence, the
Respondent did not establish objective considerations sufficient to sup-
port a good -faith doubt of the Union's majority status In addition, we
find it unnecessary to rely on the judge's finding that the Respondent
withdrew the 1982 employee antiunion petition when it withdrew its RM
petition in Case 4-RM-1050
2 We note that the agreed -to collective-bargaining agreement expired
31 January 1985 We shall modify the judge's recommended Order to
accord with precedent in such cases See Worrell Newspapers, 232 NLRB
402 (1977)
"(a) On request, bargain with the above-named
labor organization as the exclusive representative
of all employees in the aforesaid appropriate unit
by executing forthwith the agreed-upon contract
and by honoring and complying with the provi-
sions thereof or, if the Union does not request such
execution, bargain collectively in good faith, on re-
quest, with the Union, as-the exclusive representa-
tive of its employees in the unit found appropriate
and, if an understanding is reached, embody such
understanding in a signed contract. The appropri-
ate bargaining unit is:
All production and maintenance employees
employed at Employer's New Oxford, Penn-
sylvania plant, but excluding the-over-the-road
truck drivers, the live haul crew and all other
employees, guards and supervisors as defined
in the Act."
3; Substitute the attached notice for that of the
administrative law judge.
. APPENDIX
NOTICE To EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
The National Labor Relations ' Board has found
that we violated the National Labor Relations Act
and has ordered us to post and abide by this notice.
WE WILL NOT refuse to bargain collectively with
United Food and Commercial Workers Internation-
al Union , Local 295, AFL-CIO, CLC as the exclu-
sive bargaining representative of all our employees
in the appropriate unit. -
WE, WILL NOT refuse to embody in a signed
agreement any understanding reached with the
Union , or any other exclusive representative of em-
ployees in an appropriate unit with respect to rates
of pay, wages, hours , and other terms and condi-
tions of employment. .
WE WILL NOT in any like or related manner
interfere with, restrain , or coerce you in the exer-
cise of the rights guaranteed you by Section 7 of
the Act.
WE WILL , on request of the aforesaid Union,
execute and give retroactive effect to the collec-
tive-bargaining contract on which agreement was
reached on 17 October 1983 or , if the Union does
not request such execution , WE WILL bargain col-
lectively in good faith , on request , with the Union,
as the exclusive collective -bargaining representative
of our employees in the unit found appropriate,
with respect to rates of pay, wages , hours, and
276 NLRB-No. 114
1088 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
other terms and conditions- of employment, and
embody in an agreement any understanding
reached. The bargaining unit is:
All production and maintenance, employees,
employed at our New. Oxford, Pennsylvania
plant, but excluding the over-the-road truck
drivers, the -live haul, crew and all other em-•
ployees, guards, and supervisors as defined in
the Act.
WE WILL make whole, with interest, our em-
ployees in the bargaining unit described above for
any loss of wages and other benefits they may have
suffered by reason of our failure to sign and effec-
tuate all terms of the above agreement.
ROUND HILL FOODS, INC.
Bruce G. Conley, Esq., of Philadelphia, Pennsylvania, for
the General Counsel.
Jon W. Tryon -Esq. and Gary Mekhionni, ; Esq. (Tryon,
Friedman & Espenshade), of Lancaster , Pennsylvania,
for the Respondent.
Ira H. Weinstock Esq.,--of Harrisburg , Pennsylvania, for
the Charging Party.
DECISION
STATEMENT OF THE CASE
HUBERT E . LOTT, Administrative Law Judge. This
case was heard at , Gettysburg, Pennsylvania , on Febru-
ary 14 and 15 , 1984, on an' unfair labor practice charge
filed October 19, 1983 ,11 by United Food and Commer-
cial Workers International Union, Local 295, AFL-CIO,
CLC (the. Union) against Round Hill Foods , Inc. (Re-
spondent) and on a .complaint issued on December 1.
The issue in this case is ' whether or not Respondent
violated Section 8(a)(1) and (5 ) of.the Act by refusing to
sign a collective -bargaining agreement where the parties
had reached full agreement on the terms.'
. The parties were afforded an opportunity to be heard,
to call , to examine and cross -examine witnesses, and to
introduce relevant evidence . -Since the close of hearing,
briefs have been received from the parties in this case.
The parties were afforded an opportunity to be heard,
to call , to examine and cross-examine witnesses, and to
introduce relevant evidence . Since the close of hearing,
briefs have been received from the parties in this case.
On the entire record and based on my observation of
the witnesses and in consideration of the briefs submit-
ted, I make the following
FINDINGS OF FACT
1. JURISDICTION
Respondent is a Pennsylvania corporation engaged in
the business of producing and processing turkeys at its
New Oxford, Pennsylvania plant. During 1983, Respond-
All dates refer to 1983 unless otherwise indicated
ent sold and shipped products valued in excess of
$50,000 directly from its New Oxford plant to points
outside the Commonwealth of Pennsylvania . Respondent
admits, and I find , that the Company is an employer en-
gaged in commerce within the meaning of Section 2(2),
(6), and (7) of the Act. It further admits, and I find, that
United Food and Commercial Workers International
Union , Local 295, AFL-CIO, CLC is a labor organiza-
tion within the meaning of Section 2(5) of the Act.
H. THE ALLEGED UNFAIR LABOR PRACTICES
A. Background
On August 2, 1980, the Union was certified as the col-
lective-bargaining representative in a unit consisting of:
All production and maintenance employees, em-
ployed at employer's New Oxford, Pennsylvania
plant, but excluding the over-the-road truck drivers,
the live haul crew and all other employees, guards
and supervisors as defined in the Act.
The results of the election were: 64 for, 56 against, 4
challenged ballots, and 1 void ballot. The Union engaged
in a strike at Respondent's plant from April 30 1981, to
July 29, 1981, at which time it made an unconditional
offer to return to work on behalf of all striking employ-
ees. Respondent returned striking employees to work as
needed until all were returned at the end of 3 months. In
the meantime unfair labor practice charges were filed by
the Union against Respondent in July and August 1981
alleging violations. of Section 8(a)(1), (3), and (5) of the
Act. Complaints and amended complaints issued in Case
4-CA-12247 in August 1981, September 1982, and Janu-
ary. This case was heard by me on April 11. After 7
days of trial when the General Counsel rested her case,
the parties executed a settlement agreement which was
approved by me on April 19. Adjustments in backpay
figures required the execution of a new settlement agree-
ment which was approved by me on July 6. Basically the
settlement agreement called for the settlement of all out-
standing unfair labor practice allegations, payment by
Respondent of approximately $41,000 in backpay, rein-
statement of two discharged employees, and the reassign-
ment of two others. The agreement also contained a non-
admission clause and a recognition clause whereby certi-
fication was extended to October 15. Respondent also
agreed to withdraw 4-RM-1050 and the supporting peti-
tion. Notice was posted in Respondent's plant on April
19 and all provisions of this agreement were complied
with; except the single allegation contained in the instant
complaint.
After complaint in the present case issued on Decem-
ber 1, the General Counsel issued a motion dated De-
cember 22, withdrawing approval of the settlement
agreement and consolidating the cases for hearing. I
granted the motion on December 29. Respondent filed a
motion for reconsideration on January 6, 1984, and the
General Counsel filed an opposition motion on January
20, 1984. Extensive arguments by both sides were heard
on the record, after which I ruled in favor of Respond-
ent, i.e., not to set aside the settlement agreement and
ROUND HILL FOODS -
consolidate the cases for reasons stated on the record
which in summary were that since , the General Counsel
alleges only the failure to sign an agreement ,, it could be
tried on its,own merits and should she prevail , she would
have a remedy in conjunction with the remedy in the
settlement , agreement which would effectuate the policies
of the Act . I also , pointed out that • a large amount of
backpay had been distributed to several employees and
in' case the General Counsel lost any portion or all of the
8(a)(3) allegations, it would create needless problems.
The General Counsel reserved the right to file a special
appeal on my ruling , which was not taken and the in-
stant case was heard as scheduled.
B. Facts Surrounding this Case
After the signing of the settlement agreement , the par-
ties met on May 26 . The Union was represented by
International Representative George Nestler and four
employees who were on the Union 's negotiating commit-
tee. Negotiating sessions were held on August 16. and
September 7 and Nestler and two employees attended
each session. Nestler was the only person representing
the Union at the September 21 and 28 meetings. Re-
spondent 's complete proposal was presented at this latter
meeting ; however, the parties were not in full agreement
on the proposal.
On October 4, after notices were sent to all employees,
a union meeting was scheduled to discuss the contract.
Only five employees attended . On October 5, Nestler
called -Respondent 's counsel John Tryon and told him
that the Company 's proposed agreement was over-
whelmingly rejected because there were no union shop'
or checkoff provisions. Nestler suggested another negoti-
ating meeting which was scheduled for October 11.
At the October 11 meeting Nestler and one employee
attended for the Union. Respondent presented its com-
plete proposal of 'September 28 and offered language
changes on departmental transfers , no-strike , no-lockout
clause , and the wage schedule . Nestler stated that -he
would present the whole package at a ratification meet-
ing schedules for Sunday , October 16 , but that he would
not recommend that the membership accept it. '
The Union mailed notices to all employees informing
them of a ratification meeting to be held on Sunday, Oc-
tober 16 . On October 13 Nestler called Tryon and stated
that he did not like the management-rights clause and the
duration of the contract and would like to have a union-
security clause and checkoff clause in the agreement. He
proposed that if Respondent accepted the checkoff pro-
vision,, he would recommend that the employees accept
the contract . Tryon replied that he would check with his
client and get back to Nestler . On October 14, Tryon in-
formed Nestler that his client had not changed his posi-
tion and would not agree to a checkoff clause.
A union ratification meeting was held on October 16
at the union hall. Sixteen employees attended the meet-
ing and Nestler read the Company's final offer after
which the employees voted 13 to 3 to accept the con-
tract. -
Thomas Bross III, who is Respondent's vice president,
and general manager, testified that on the morning of
October 17 , when he learned from his . plant manager
1089
William Schiflet that only 13 employees either attended
the union meeting or voted for ratification, he called a
management meeting: He discussed the low turnout with
his father- and brother and it was decided not to sign the
agreement because the Union represented a very small
percentage of the employees . It was decided at this meet-
ing, according to Bross, that their attorney was to be in-
striicted not to sign the contract because only 13 em-
ployees attended the ratification meeting and some em-
ployees had made comments 'that they did not want the
Union. He further stated that from April to October 11,
1982, Schiflet and other supervisors told him on many
occasions that the employees did not want the Union.
William Schiflet testified that when he learned the re-
sults of the vote at the ratification meeting on the morn-
ing of October 17, he told Thomas Bross III. When,
Bross heard the 'results, he said he would not sign the
agreement. According to Schiflet a management meeting
was called at which the attendance at both union meet-
ings was the only topic discussed prior to deciding not to
sign the agreement . Schiflet testified that the April 1982
employee petition was not . discussed . ' He also testified
that when he heard the results of the ratification meet-
ing, the Company realized that , it had an agreement but
management did not want 13 employees deciding the fate
of all employees and the Company.2
John Tryon , Respondent's counsel, testified that on the
morning of October 17, he' received a telephone call
from Schiflet and Bross . He was told about the poor at-
tendance at the union meetings held on October 16 and
4, and the low vote count and was asked ' whether or not
the Company had to sign the agreement . He was not
sure whether the April 1982 employee petition was ever
mentioned . Later that morning Tryon returned Nestler's
telephone call. Nestler informed Tryon that the Union
would sign the agreement whereupon , Tryon told Nes-
tler that the Company would not sign because it had a
good-faith doubt of the Union 's majority status. Tryon
mentioned as reasons-for the Company's position the em-
ployee petition signed in April 1982, the decline in the
number of employees bn the Union's negotiating commit-'
tee, lack of attendance at'union meetings , and lack of
support in the plant for the Union.
C. Respondent 's Defense
As part , of its defense Respondent offered an employee
petition into evidence .- This petition states in substance
that the employees of Round Hill Foods do not want to
be represented by a Union . It is signed and dated by 81
employees . The dates range over March and April 1982.
This employee petition was used to support Respondent's
good-faith doubt when . it filed Case 4-RM-1050 in April
1982.
In addition to the above , Respondent presented evi-
dence of employee disaffection for the, Union. Mary
Smith , a supervisor at Respondent 's plant , stated that in
June ,. 17 named ' employees told her they did not want
the Union and 2 named employees told her they did not
2 The seniority list and addition show that as of October 16, the Com-
pany employed 227 employees .
1090 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
want to pay union dues. Three other unnamed employees
also stated in June that they did not want a union. She
periodically related employee's lack of support for the
Union to Schiflet but never gave him any employee
names.
Roger Gardner, ..a leadman for- Respondent, testified
that during the summer up to October, six named em-
ployees told him they did not want to be represented by
the Union. He relayed these conversations to Supervisor
Terry Kennedy in September or October. -
Terry Kennedy, a supervisor at Respondent's plant,
testified that in early 1983, probably February, five
named employees told him they did not want a union.
He also testified that employee Linda Reed in February
told him about seven named employees that did not want
a union. He in turn reported these conversations to Schi-
flet and Plant, Superintendent Jesse Snyder during that
same time period.
Respondent also relies on the decline in employee at-
tendance at the negotiating sessions held from May to
October and the poor attendance at the October.4 and 16
union meetings and the very low vote count at this last
union meeting held to ratify the agreement.
Analysis and Conclusions
As I understand Respondent's case, there is no serious
contention that the parties did not reach agreement over
a contract. William Schiflet admitted there was agree-
ment and other Respondent witnesses made no effort to
refute this fact. In effect this issue was not part of Re-
spondent's defense and was not litigated. In brief Re-
spondent's counsel attempted to argue that Respondent
withdrew its offer prior to receiving notice of accept-
ance'_on-October 17. However, counsel's own testimony
refutes this argument.
The major thrust- of Respondent's defense is that after
October 15, it enjoyed a rebuttable presumption of the
Union's majority status since the settlement agreement
extended the certification to that date. On October 17,
the date Respondent was informed that the Union would
sign the collective-bargaining agreement, Respondent
was free to register a good-faith doubt as"to the Union's
majority status and it did just that.
The basis given for Respondent's doubt consisted of an
antiunion petition signed and dated by 81 employees in
March and April 1982 and employee expressions of repu-
diation made to supervisors, which in -Respondent's
view, would support Respondent's good-faith doubt of
the Union's majority status. I, will not consider these fac-
tors in assessing Respondent's' good-faith doubt because
they are in derogation of the settlement agreement ap-
proved by me on April 19. Respondent's counsel filed- a
motion for reconsideration prior to hearing and argued
strenuously on the record against setting aside the settle-
ment agreement and consolidating Case 4-CA-12247
which alleged violations over the period of time covered
by the antiunion petition and some employee statements
of repudiation. Furthermore, as part of the settlement
agreement, Respondent's counsel agreed to'• withdraw
this antiunion petition which supported his - good-faith
doubt in Case 4-RM-1050. Now Respondent wants to
go behind the settlement agreement and pick.and choose
whatever might support a good-faith doubt while at the
same time opposing any litigation of unfair labor prac-
tices that occurred prior to the settlement agreement.
Moreover, Respondent wants to resurrect a stale antiun-
ion petition which it agreed to withdraw as part of the
settlement of all outstanding allegations. The parties la-
bored long and hard to hammer out the settlement agree-
ment, each side giving up something in return for not'
having to undergo expensive litigation. It is my opinion
that both sides have to live with that agreement.
Another reason for rejecting the antiunion petition and
much of the employee repudiations of the Union is that
these indicia form no part of Respondent's good-faith
doubt at the time it decided not to -sign the collective-
bargaining agreement. It was stated several times by Re-
spondent's witnesses that either the petition played no
part in the management decision on October '17 or that
the employee-attendance at the union meetings and espe-
cially the low ratification vote was the deciding factor in
not recognizing the Union any further. Therefore, I will
not consider the petition as a basis for Respondent's
doubt of majority status. _
I have already discussed to some extent above employ-
ee antiunion expressions made to supervisors. After cull-
ing the evidence, I find that 17 named employees stated
their antiunion sentiments in June 1983. In that same
month, two named 'employees stated that they did not
want to pay union dues and three unnamed employees
stated that they did not want the Union. Further evi-
dence indicates that from the summer up to October, six
named employees - stated that they did not want the
Union. Finally, in February, five named employees indi-
cated their rejection of the Union. I have rejected hear-
say testimony as to other employee feelings, eliminated
some duplicated names, and rejected presettlement state-
ments and testimony about three unnamed employees. I
also rejected the two named employees -who did not
want to pay union dues because that is not sufficient
reason to support a good-faith doubt. This "leaves Re-
spondent with approximately 23 employees who rejected
the Union out of a total employee complement of 227.
This in my opinion does not come close to a sufficient
basis for doubting the Union's majority status.
Respondent raises as another basis for its doubt of ma-
jority status, the decline in employee attendance at nego-
tiating sessions from May to October. The number of
employees attending union negotiating sessions does not-
in my opinion indicate lack of union support. Physicians
Surgeons Community Hospital, 231 NLRB 512 (1977). -
The only real basis Respondent advanced for its good-
faith doubt rests on the attendance at two union meetings
and the very-low ratification vote registered at the Octo-
ber 16 meeting. Admittedly, the attendance at these two
union meetings was very low and the ratification vote
was probably an embarrassment to the Union since all
employees were notified of the meeting and there were
227 employees who were directly affected by the out-
come of that meeting. However, these were intraunion
matters which should not be relied on by the Company
to support a good-faith doubt. Attendance at union meet-
ings has never been considered as a basis for•rebutting a
-ROUND HILL -FOODS 1091
presumption of majority status. Although the low turn-
out in this case might be extreme, deciding just how
many employees should attend a union meeting and what
a representative voter should be is not my province.
.• Respondent's counsel offers as further evidence of the
Union's lack of majority support the employee abandon-
ment of the strike in July 1981 citing, Stoner Rubber Co.,
123 NLRB 1440 (1959), and Celanese Corp. of America,
95 NLRB 664 (1951). The evidence does not support this
contention. The parties agreed on the record that on
July 29, 1981, the Union made an unconditional offer to
return to work on behalf of all strikers. There was no
.evidence that strikers crossed the picket line to work or
that striker replacements were hired, thus diminishing
the Union's support. Moreover the strike abandonment
,was presettlement and not considered by Respondent
when it decided not to sign the collective-bargaining
agreement.
CONCLUSIONS OF LAW
1. Respondent is an employer engaged in commerce
within the meaning of Section 2(2), (6), and (7) of the
-Act.
.• 2.-The Union is a labor organization within the mean-
ing of Section 2(5) of the Act.
- 3. All production and maintenance employees, em-
ployed at employer's New Oxford, Pennsylvania plant,
but excluding the over-the-road truck drivers, the live
haul crew and all other employees, guards and supervi-
sors as defined in the Act constitute a unit appropriate
for the purpose of collective bargaining within the mean-
ing of Section 9(b) of the Act. -
4. By refusing on October 17 to" execute and honor a
written agreement embodying the terms and conditions
of employment agreed to with the Union on October 16
and 17, Respondent violated Section 8(a)(1) and (5) of
the Act. -
-- 5. The foregoing unfair labor practices affect com-
merce within the meaning of Section 2(6) of the Act.
THE REMEDY
Having found that Respondent has engaged in the
unfair labor practices in violation 'of Section 8(a)(1) and
(5) of the Act, I shall recommend that it be ordered to
- cease and desist therefrom and that it take certain affirm-
ative ' action designed to effectuate - the policies of . the
Act-. • - .
Having found that Respondent on October 17, 1983,
repudiated and, about that date, has refused to execute
,!the contract which was agreed on by Respondent and
the Union-on October 16 and 17, 1983, I shall recom-
mend that Respondent be required to execute that agree-
='ment forthwith and to give effect to all terms and provi-
sions of 'that agreement retroactively to October 17,
1983: The loss of earnings and benefits, if any, under the
recommended Order herein shall be computed in the
manner set forth- in F. W. Woolworth Co., 90 NLRB 289
"•(1950); plus interest as set forth in Florida Steel Corp.,
231 NLRB 651 (1977).
---,Finally, I shall recommend that, on request, Respond-
ent bargain with the Union as the exclusive representa-
tive of the employees in the appropriate unit, and that
Respondent be required to post the customary notices.
On these findings of fact and conclusions of law and
on the entire record, I issue the following recommend-
ed3
ORDER
The Respondent, 'Round Hill Foods, Inc., New
Oxford, Pennsylvania, its officers, agents , successors, and
assigns, shall
1. Cease and desist from
(a) Failing to bargain in good faith by refusing to exe-
cute and honor collective-bargaining agreements con-
cluded by it with United Food and Commercial Workers
International Union, Local 295, AFL-CIO, CLC (the
Union) or any other labor organization.
- (b) In any like or related manner interfering with, re-
straining , or coercing employees in the exercise of the
rights guaranteed them by Section 7 of the Act.
2. Take the following action necessary to effectuate
the policies of the Act.
(a) Forthwith execute the collective-bargaining agree-
ment consummated by Respondent and the Union on Oc-
tober 17, 1983, with respect to the following bargaining
unit: - -
All production and maintenance employees, em-
ployed at employer's New Oxford, Pennsylvania
plant, but excluding the over-the-road truck drivers,
the live haul crew- and all other employees, guards
and supervisors as defined in the Act.
(b) Upon execution of the aforesaid agreement, give
retroactive" effect to the "provisions thereof and, in the
manner set forth in the section herein entitled "The
Remedy," make whole,the employees, with interest, for
any loss they may have suffered by reason of Respond-
ent's, failure to sign and effectuate all terms of the agree-
ment.
(c) 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.
(d) Post at its facilities in New Oxford, Pennsylvania,
copies of the attached notice marked "Appendix."4
Copies of the notice, on forms provided by the Regional
Director for Region 4, after being signed by the Re-
spondent's authorized representative, shall be posted by
the Respondent immediately upon receipt and maintained
for 60 consecutive days in conspicuous places including
3 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 -
4 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 Na-
tional Labor Relations Board" shall read "Posted Pursuant to a Judgment
of the United States Court of Appeals Enforcing an Order of the Nation-
al Labor Relations Board "
1092 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
all places where notices to employees are customarily (e) Notify the Regional Director in writing within 20
posted. Reasonable steps shall be taken by the Respond- days from the date of this Order what steps the Re-
ent to ensure that the notices are not altered, defaced, or spondent has taken to comply.
covered by any other material.