Titan Box Corp.

National Labor Relations Board - Board Decisions

Jan 29, 1974

208 N.L.R.B. 787 (N.L.R.B. 1974)

TITAN BOX CORP.
Titan Box Corporation and Local Union No. 2393-S
of the United Brotherhood of Carpenters & Joiners
of America, AFL-CIO. Case 3-CA-5308
January 29, 1974
DECISION AND ORDER
BY MEMBERS FANNING, KENNEDY, AND
PENELLO
On October 16, 1973, Administrative Law Judge
Thomas A. Ricci issued the attached Decision in this
proceeding. Thereafter, the Respondent filed excep-
tions and a supporting brief.
Pursuant to the provisions of Section 3(b) of the
National. Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
authority in thisproceeding to a three-member panel.
The Board has considered the record and the
attached Decision in light of the exceptions and brief
and has decided to affirm the rulings, findings, and
conclusions of the Administrative'Law Judge and to
adopt his recommended Order as modified herein.'
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge, as
modified herein, and )hereby orders that the Respon-
dent, Titan Box Corporation, Liverpool, New York,
its officers, agents, successors, and assigns, shall take
the action set forth in the said recommended Order,
as modified below:
Delete paragraph 2(c) of the Administrative Law
Judge's recommended Order and reletter the remain-
ing paragraphs accordingly.
1 The Respondent excepts , inter alia, to the Administrative Law Judge's
recommended Order . We conclude that his extension of the certification
year for 12 months from the date the Respondent begins to bargain was not
warranted and shall modify the recommended Order accordingly.
DECISION
STATEMENT OF THE CASE
THoMAS A. Ricci, Administrative Law Judge: A hearing
in this proceeding was held at Syracuse, New York, on
August 16, 1973, on complaint of the General Counsel
against Titan Box Corporation, herein called the Respon-
dent or the Company. The charge was filed on May 25,
1973, and the complaint issued on July 12, 1973. The issue
of the case is whether the Respondent refused to bargain in
good faith with the Union in violation of Section 8(aX5) of
the statute. Briefs were filed by the General Counsel and
the Respondent.
Upon the entire record and from my observation of the
witness , I make the following:
FINDINGS OF FAcr
787
1. THE BUSINESS OF THE RESPONDENT
Titan Box Corporation, a New York State corporation,
is engaged in the manufacture , sale, and distribution of
boxes , crates, pallets, and related products, and maintains
its principal office and place of business in the city of
Liverpool, New York. During the past year the Respon-
dent purchased , transferred , and had delivered to its New
York plant wood and other goods and materials valued in
excess of $50,000, of which an amount valued in excess of
$50,000 was transported to that location directly from out-
of-state sources. I find that the Respondent is engaged in
commerce within the meaning of the Act.
II. THE LABOR ORGANIZATION INVOLVED
In its answer to the complaint the Respondent denies
any knowledge,as to whether the Union is in fact a labor
organization. A Board-conducted election (Case
3-RC-5494), which resulted in the Union's certification,
was predicated upon a stipulation of the parties , and which
formed the basis for the Regional Director's finding that
the Union is a labor organization within the meaning of the
Act. The certification which followed, of course, inherently
reaffirmed that finding, and the subsequent collective-
bargaining sessions were full implementation of the
Union's statutory function as bargaining agent for the
employees involved. I find that the Union is a labor
organization within the meaning of Section 2(5) of the Act.
M. THE UNFAIR LABOR PRACTICES
A Picture of the Case
This is a refusal-to-bargain case. While admitting that an
election was held among . its employees, that a majority
voted in favor of the Union, that a regular certification of
exclusive representative status was issued to the Union,
and that it discussed conditions of employment with the
Union on that basis thereafter, the Respondent does not
concede the appropriateness of the bargaining unit as
alleged in the complaint, purely a restatement of the unit in
which the election was held . It is a unit which conforms
precisely with the first one deemed appropriate in the
statute. Accordingly, on the entire record , I find that all
production and maintenance employees of the Respon-
dent, including shipping and receiving employees, but
excluding all office clerical employees, professional .em-
ployees, guards, and supervisors as defined in the Act,
constitute a unit appropriate for the purpose of collective
bargaining within the meaning of Section 9(b) of the Act.
I also find that on September 22, 1972, and at all times
thereafter, the Union has been and now is the exclusive
statutory collective-bargaining representative of all the
employees of the Respondent in the above-described unit.
In support of the complaint the General &unsel argued,
at the hearing, what appear to be (1) a primary and direct
violation of Section 8(aX5), and (2) a collateral, or
inferential unfair labor practice violation of the same
section, but based on the record as a whole. On June 4,
1973, less than 12 months before the end of the certifica-
208 NLRB No. 118
788 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
tion year (see Ray Brooks v. N.L.R.B., 348 U.S. 96), the
Respondent unilaterally, and completely without prior
bargaining with the Union, instituted a wage incentive
system, thereby changing the method and amount of
compensation payable to the employees for the work they
performed. Absent any justification for so clearly bypass-
ing and ignoring the statutory exclusive representative of
the employees, this was the clearest possible refusal to
bargain unfair labor practice in violation of the statute.
N.L.R. B. v. Benne Katz, d/b/a Williamsburg Steel Products
Co.; 369 U.S. 736 (1962).
Before this unilateral action the Respondent met with the
union representatives at approximately eight bargaining
sessions ; it sent two persons to do the negotiating on its
behalf-Mr. Buchanan, the plant manager, and Mr.
Robert McMillan, a labor relations specialist and consult-
ant. Mr. John Chapman, owner and president of the
Company who engaged McMillan for this purpose,
instructed him in the bargaining and discussed with him,
between the meetings, what progress was made. Through-
out, from first to last, he told McMillan, who carried the
primary burden of talking, that in no event was he to give
any consideration to any demands the Union might make
on two major subjects; the first was economics, however
the question might arise-wages, more holidays, more
vacations, etc. The second was anything that related to
union security-whether in the form of union shop or
checkoff. McMillan explained at the hearing that the
reason for these basic attitudes was that the Respondent
could not afford any economic concession at all and that
Chapman, as a matter of philosophical conviction, was
opposed to any pressure on employees to join unions or to
an employer acting as collection agent for a labor
organization.
Defense against the first argument is twofold. The
Company asserts that in the course of the bargaining it did
make an economic offer to the Union, a proposal, it
contends, that would have increased the earnings of the
employees. It says this took the form of a profit-sharing
scheme, which the Union rejected. The argument then goes
that the wage incentive system later instituted unilaterally
brought the employees less-in money-than the profit-
sharing proposal would have produced, and that therefore,
just as an employer is privileged to grant wage increases
after they have been rejected by a union and after there has
been an absolute impasse in the bargaining on that very
point, it is also privileged to grant wage increases
unilaterally so long as the money benefits total less than
that rejected by the bargaining agent in some other form. A
further defense, still against this first complaint allegation,
is based on the fact that Respondent advised the Union, 10
days in advance, of its decision and intention to make the
unilateral change in method of pay. It now asks: inasmuch
as the Union did not raise any hue and cry over the
proposal, did not request that the Company bargain before
r From the transcript
JUDGr Ricci Would this be a correct statement The Company
talked to you on this, "Do some bargaining with us, you're experienced,
you're a labor relations man. You . Buchanan will come in with
you, he'll keep the notes He'll help you." Then they also told you that
this corporate client had asked for your services, but where economics
acting as though the Union did not exist, what does it have
to complain about?
As to the second argument of misconduct advanced by
the General Counsel-essentially a theory of pervasive bad
faith-the Respondent insists it did bargain on everything,
that it made many concessions to union demands, and that
it never literally refused to meet on request; all this,
according to the Respondent, reflected no more than hard
bargaining, which was its right.
Unilateral Action
Both McMillan and Ruggiano testified about the
bargaining sessions that started after the September
certification of the Union. Their combined stones indicate
there were seven or eight meetings, beginning in November
and ending on March 13, 1973. At an early stage the Union
presented a printed copy of its standard contract, and there
was much discussion of many of the provisions it
contained. Speaking very candidly, McMillan made quite
clear in his testimony that no union proposal which might
cost the Company any money-what he placed in the
category of "economic" matters-was given any considera-
tion whatever. In December Ruggiano proposed a 20 cents
per hour wage increase and some form of union security.
McMillan brushed off the raise demand and "I told him
very specifically that the authority to grant the Union shop
was out." McMillan's reaction to Ruggiano was consistent
with Chapman's directions to him, which Chapman
recalled as follows: "In respect to wages, maintenance of
membership, dues checkoff, any economic situation was in
the discussion of inability of this company to absorb more
liability."
Q. (By Company Counsel) Is it a fair summation
that, in your opinion, you felt that on non-economic
matters you were on your own?
A. Yes.
Q. (By the General Counsel) Mr. McMillan, during
the course of the negotiating sessions up to your last
meeting of March 13th, did the company make any
concessions with respect to wages, pay fringes, any
economic item?
A. No.'
Ruggiano last met with McMillan on March 13, when,
frustrated in his repeated attempts at meaningful discus-
sion about two of his major concerns, he demanded to
speak with owner Chapman personally. Chapman did meet
with him several times in April and May, sometimes with a
state conciliator in attendance. One of these meetings is
very revealing; Chapman, who testified after Ruggiano,
said the union agent reported it correctly as a witness.
Ruggiano asked him three plain questions: "Are you going
to move on Union security? . . . How about a checkoff of
dues? . . . How about an increase in wages?" To each
question Chapman answered a simple no. At another
meeting Chapman told Ruggiano he thought it "immoral
are concerned, anything about raises, fringe benefits , more overtime or
Union security, and those, say. "no. you 're not authorized to make any
counteroffers on Union security or money matters." say , "no." Is that
what they told you?
Tut Wrrt.iss Right.
TITAN BOX CORP.
to force a man to become a member of a union against his
will," and "shat they couldn't afford to give any increases."
At one point Ruggiano asked for a 5.5-percent raise, but
again Chapman said he could not afford it.
Chapman and Ruggiano last met on May 22 . This was
the meeting where Ruggiano put his last three questions
and received a refrain of nos . By letter dated May 23
Chapman wrote to the Union as follows:
We wrote you May 8th regarding our plans for
reinstating an incentive plan at Titan Box . The plan is
now ready and we will put it into effect Monday, June
4th. Enclosed please find a memorandum describing
the plan in detail.
Attached to this letter was a copy, of a five-page
statement, the first sheet headed: "Memorandum: To all
hourly rated employees-subject : Wage Incentive." The
statement explained in precise detail the mechanics of the
new system and announced it would become operative on
June 4 . Although the total document is not ,easily
understood by an outsider, it does set out what appear to
be standard production requirements for a great number of
itemized parts, time schedules for production, and a
statement indicating ' that, depending upon the production
capacity and personal diligence of individual employees,
they could earn 10 percent more than otherwise under the
new system.
As promised , the wage incentive system was in fact made
effective on June 4 . After the unfair labor practice . charge
was filed on May 25 , Ruggiano and Chapman met..again
with a state conciliator, at. the Union's request, apparently
its last attempt to avoid litigation . Ruggiano asked the
same old three questions-would the Company change its.
position on union security, checkoff, or economic matters?
This time Chapman said no, the matter would have to be
decided in court . See Equitable Life Insurance Company,
133 NLRB 1675.
Chapman had also written a letter to Ruggiano on May
8, as follows:
Some months ago Titan Box Company abandoned a
method of incentive pay because of its inequities and
because it was impossible to administer. We are
currently working on a new incentive plan and hope to
put it in effect within the next several weeks.
Ruggiano received this letter on May 15, and his
testimony is that no mention of the subject was made at all
by anyone in the later meetings.
A wage incentive plan is but one of many methods for
paying employees more money than they might earn under
some other system . The increase in the employee 's wages
might be dependent upon his personal effort , but the in-
crease nevertheless, is in no way dependent upon the
company's profit or loss statement. As such ,'of course, the
method of payment, like any other, is a mandatory subject
of collective . bargaining, and may not be fixed or , altered
unilaterally by an employer while it is under statutory duty
to bargain with the employees ' representative . The cases on
789
the subject are too well established to justify much
citation.2
I find that by putting in effect the wage incentive system
on June 4, 1973, the Respondent illegally refused to
bargain with the Union and thereby violated Section
8(aX5) and ( t) of the Act. As the Supreme Court -,said in
Katz, supra:
A refusal to negotiate in fact as to any subject which is
within f 8(d), and about which the union seeks to
negotiate, violates § 8(5) though the employer has
every desire to reach agreement with the union upon an
over-all collective agreement and earnestly and in all
good faith bargains to that end. We hold that an
employer's unilateral change in conditions of`eniploy-
ment under negotiation is similarly a violation of f
8(a)(5), for it is a circumvention of the'duty to negotiate
which frustrates the objectives of § 8(aX5) much as
does a flat refusal.
There is no evidence to support the assertion , obliquely
suggested at the hearing, that the Company tried to sell this
incentive plan to the Union but failed to convince it. As a
witness Chapman stated that as early as April 12, "I do
seem to remember that I suggested to Mr . Wersing [the
state conciliator ) fairly casually that we were working on
an incentive plan." In its brief the Respondent relies upon
this single phrase out of Chapman 's mouth to support a
contention that as of April 12 there had been comprehen-
sive bargaining to impasse on the very incentive plan put in
effect on June 4. The truth of the matter is Chapman then
had no idea what the plan would be about at all. "Mr.
Novak : . . . You used the words . . . you explained
incentive in a . relative casual manner. What do you mean
by `relative' and 'casual'? The Witness : When I say
'relative,' and 'casual,' I mean I didn 't have any detailed
program as to what it was going to be.... because we
were just considering it at that time. Later we gave them
more detailed explanation." In fact , still according to
Chapman 's own testimony, he had nothing he - could
discuss with Ruggiano even .after the May 8 letter . "Judge
Ricci: Would this be correct , that you wrote the letter of
May 23rd ; . before that date, you didn't have the wage
incentive plan worked out in detail ? The Witness: Yes, sir.
Judge Ricci : It was shortly before the ' 23rd that the
Company finally had it completed in its implementation,
how much it would be? The Witness : Yes. It takes time to
do these things."
Chapman 's testimony not only belies any notion, that the
plan was bargained out to impasse before June 4, but it
also effectively disposes of the. concomitant and completely
inconsistent argument that , if there was no bargaining,
about the incentive - plan, it was Ruggiano's fault, because
he did not bring , the subject up and insist that it be
discussed before the Company went ahead with its
announced . intentions . If the unilateral action must be
excused because the Union failed to talk about„ it in
advance, there was no bargaining. If Chapman himself,
and, of course, the Company did not even know what the
s N.L.R.B. v. Dothan Eagle, Inc. a subsidiary of Thompson Newspapers,
434 F .2d 93 (C.A. 5, 1970). ,
790 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
plan would be, if in fact there did not yet exist a plan that
could be evaluated and discussed by anyone, how could
the union agent demand any talking at all? And besides all
this, the defense ignores the basic principle of the entire
statute,' the very essence of this complaint , which is that
whenever an employer wishes to alter conditions of
employment in these circumstances-particularly during
the certification year-the law prohibits it from doing so
before consulting and bargaining with the exclusive
representative. It is hardly a defense to an unfair labor
practice by any respondent that the other party to the
collective-bargaining relationship failed to take steps
necessary to prevent its commission.
I also find no merit in the contention that the Union's
earlier refusal to agree to a profit -sharing proposal justified
the Company's later conduct . Apart from the-fact that both
concepts-profit sharing and incentive wage system-sug-
gest that employees would receive something more in cash
if they worked harder or more productively, this reality
alone does not warrant a finding that the two proposals
were the same , or even substantially parallel . There are too
many intangibles and generalities in a profit-sharing plan
to compare it to any precise time-study system of
individual production standards . Moreover ; this is exactly
what collective bargaining iss all about . If one proposal to
resolve a dispute-economic or otherwise-fails of a
meeting of the minds , you try another . But the critical
element is that you talk about it, you do not change the
condition of employment as though the union did not exist.
It was the Respondent's failure to propose this exact
incentive plan to the Union , and, to discuss it fairly and
openly that constitutes the heart of the unfair labor
practice found.
The Remedy: Further Allegation
The remedial order now required to undo the effects of
the refusal to bargain as found includes a number of
elements . The Respondent must eliminate the present
incentive wage systems from its operations, it must bargain
with the Union in good faith, and the 1 -year period of
validity ordinarily accorded the Union's certification must
be restored , to start anew when the Respondent begins to
bargain as the statute dictates . And bargaining in good
faith means bargaining on all subjects relating to condi-
tions of employment , including this one or any other wage
incentive system the Company may propose, as well as any
other economic or union-security matter , such as union
shop or checkoff of dues. The order requiring good-faith
bargaining is as broad as the entire spectrum of the statute.
The further complaint allegation-that the Respondent
also violated Section 8(aX5) in another sense--adds
nothing of substance to this particular case . The evidence
does indicate that owner Chapman limited his representa-
tives' bargaining authority as to some very important
matters , anything involving money or union security. In
calling this proof of bad faith , and therefore a refusal to
bargain in good faith , what the General Counsel is really
saying is the Respondent did not accord the Union the
representative status to which it was entitled by virtue of its
certification. So phrased, this allegation has already been
found true, for unilateral action changing the method of
pay and the amount of employee compensation is also
rejection of the collective-bargaining obligation , refusal to
concede to the Union its statutory right to speak for the
employees . Whether the unfair labor practice already
found be called bad faith, or refusal to accord recognition,
or not authorizing Buchanan and McMillan to speak on
the Company's behalf, is only a matter of wording, and of
little moment. It is substance that counts. In this case,
regardless of whether the Respondent 's conduct as a whole
be described one way or another , in no event would the
remedial order, either in words or import, be changed.
At best, questions of the kind raised by the secondary
allegation here are tenuous and difficult to decide. As
stated, the testimony of McMillan himself, who rejected
out of hand each and every proposal relating to money or
union security, strongly points to a fixed position by the
Respondent to refuse even to consider anything the Union
might suggest on these very important mandatory subjects
of collective bargaining. Fairness demands , however, that
broad allegations of pervasive bad faith be appraised on
the basis of every jot and tittle of evidence in the record.
The Respondent did yield on a considerable number of
contract proposals advanced by the Union, in a number of
instances abandoning its past policy . Indeed, the General
Counsel conceded on the record that a certain amount of
bargaining-substantial bargaining-did take place with
respect to a number of items . And the company spokesman
did say, on a number of occasions , that rejection of
economic or plain money demands resulted from the
Respondent's asserted poor economic conditions. The
Respondent even offered to permit a proper representative
of the Union to examine its books to establish the truth of
that final assertion. Assuming, but not deciding, that this
record supported the General Counsel's second allegation
of wrongdoing, no useful purpose would be served by any
such additional finding, which conceivably could then still
further delay the day of good-faith bargaining, and further
prejudice the rights of the employees.
IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES
UPON COMMERCE
The conduct of the Respondent set forth in section III,
above, occurring in connection with the operations of the
Respondent described in section 1, above , have a close,
intimate, and substantial relation to trade, traffic, and
commerce among the several states and tend to lead to
labor disputes burdening commerce and obstructing
commerce and the free flow of commerce.
CONCLUSIONS OF LAW
1. All production and maintenance employees, includ-
ing shipping and receiving employees, at the Respondent's
Liverpool,. New York, location , excluding all office clerical
employees, professional employees, guards, and supervi-
sors as defined in the Act, constitute a unit appropriate for
the purposes of collective bargaining within the meaning of
Section 9(b) of the Act.
2. At all times since September 1972, the Union has
been and now is the exclusive representative of the
TITAN BOX CORP.
employees in said unit for the purposes of collective
bargaining within the meaning of Section 9(a) of the Act.
3. By unilaterally instituting a wage incentive system on
June 4, 1973, the Respondent has engaged in and is
engaging in unfair labor practices within the meaning of
Section 8(aX5) and (1) of the Act.
4. The aforesaid unfair labor practices are unfair labor
practices affecting commerce within the meaning of
Section 2(6) and (7) of the Act.
Upon the foregoing findings of fact, conclusions of law,
and the entire record, and pursuant to Section 10(c) of the
Act, I make the following recommended:
ORDERS
The Respondent, Titan Box Corporation, Liverpool,
New York, its officers, agents , successors , and assigns,
shall:
1. Cease and desist from:
(a) Unilaterally instituting any incentive system of pay,
or unilaterally making any changes in existing conditions
of employment , without first bargaining in good faith with
any exclusive collective-bargaining agent of its employees.
(b) In any like or related manner ' interfering with,
restraining , or coercing employees in the exercise of their
right to self-organization , to form organizations, to join or
assist Local Union #2393-S of the United Brotherhood of
Carpenters and Joiners of America, AFL-CIO, or any
other labor organization , to bargain collectively through
representatives of their own choosing , and to engage in
other concerted activities for the purposes of collective
bargaining or other mutual aid or protection , or to refrain
from any or all such activities , except to the extent that
such right may be affected by an agreement requiring
membership in a labor organization as a condition of
employment , as authorized in Section 8(aX3) of the Act.
2. Take the following affirmative actions necessary to
effectuate the policies of the Act:
(a) Discontinue its present incentive wage system of
payment.
(b) Upon request bargain in good faith with the Union as
the exclusive representative of all the employees in the
appropriate unit.
(c) Honor the Union's representative status pursuant to
its Board certification for it 12-month period starting with
the date when the Respondent begins to bargain as herein
required.
(d) Post at its place of business in Liverpool, New York,
copies of the attached notice marked "Appendix." 4 Copies
of said notice, on forms provided by the Regional Director
for Region 3, after being duly signed by the Respondent's
representative , shall be posted by the Respondent immedi-
ately upon receipt thereof, and be maintained for 60
consecutive days thereafter , in conspicuous :places , includ-
ing all places where notices to employees are customarily
posted. Reasonable steps shall be taken by the Respondent
to insure that said notices are not altered , defaced, or
covered by any other material.
(e) Notify the Regional Director for Region 3, in writing,
within 20 days from the receipt of this Decision, what steps
the Respondent has taken to comply herewith.
791
3 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 findings.
conclusions, recommendations, and recommended Order herein shall, as
provided in Sec. 102A8 of the Rules and Regulations , be adopted by the
Board and become its findings, conclusions, and order, and all objections
thereto shall be deemed waived for all purposes.
' In the event that the Board's Order is enforced by a judgment of the
United States Court of Appeals, the words in the notice reading "Posted by
Order of the National 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 EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
The National Labor Relations Board having found, after a
trial that we violated the Federal law by refusing to bargain
in good faith with Local Union # 2393-S of the United
Brotherhood of Carpenters and Joiners of America,
AFL-CIO:
WE WILL NOT refuse to recognize and bargain with
the Union as the exclusive representative of the
employees in the unit described below. The bargaining
unit is:
All production and maintenance employees,
including shipping and receiving employees, at
our Liverpool , New York , location, excluding all
office clerical employees , professional employees,
guards and supervisors within the meaning of the
Act.
WE WILL NOT unilaterally , or without bargaining first
with the Union, change any conditions of employment
for our employees.
WE WILL NOT in any like or related manner interfere
with, restrain or coerce employees in the exercise of
their rights to self-organization , to form labor organiza-
tions, to join or assist Local Union # 2393-S of the
United Brotherhood of Carpenters and Joiners of
America , AFL-CIO, or any other labor organization,
to bargain collectively through representatives of their
own choosing, or to engage in any other concerted
activities for the purposes of collective bargaining or
other mutual aid or protection, or to refrain from any
or all such activities except to the extent that such right
may be affected by an agreement requiring member-
ship in a labor organization as a condition of
employment, as authorized in Section 8(aX3) of the
Act.
WE HEREBY DISCONTINUE our existing wage incentive
system.
WE WILL bargain collectively , upon request, with the
above-named Union as the exclusive representative of
the employees in the above-described unit with respect
to rates of pay, wages, hours of employment , and other
conditions of employment and, if an understanding is
reached, embody such understanding in a signed
agreement.
TITAN BOX CORPORATION
(Employer)
792 DECISIONS OF NATIONAL . LABOR RELATIONS BOARD
Dated By or covered by any other material . Any questions. concern-
(Representative) (Title) ing this notice or compliance with its provision. may be
directed to the Board's Office, 9th Floor-Federal Build-
This is an official notice and must not be defaced by ing, 111 W. Huron Street, Buffalo, New York 14202,
anyone . Telephone 716-842-3100.
This notice must remain posted for 60 consecutive days
from the date of posting and must not be altered , defaced,