Wright Aeronautical Corp.

National Labor Relations Board - Board Decisions

Dec 3, 1942

45 N.L.R.B. 977 (N.L.R.B. 1942)

In the . Matter of WRIGHT AERONAUTICAL CORPORATION and INTERNA-
TIONAL UNION , UNITED AUTOMOBILE , AIRCRAFT AND AGRICULTURAL.
IMPLEMENT WORKERS OF AMERICA , AFFILIATED WITH THE C. I. O.
In the Matter of WRIGHT AERONAUTICAL CORPORATION and INTERNA-
TIONAL ASSOCIATION OF MACHINISTS (AFFILIATED WITH THE A . F. OF L._
Cases Has. 0-2j68 and C-2369, respectively .Decided December
3)194 ,
Jurisdiction : aircraft manufacturing industry.
Unfair labor practices
Company-Dominated Union: employee representation plan assisted by company'
support and modeled after similar plan at other plants of employer, found by
Board in prior proceeding to be company-dominated.
Remedial Orders : employer ordered to disestablish dominated organization;
contract with dominated organization abrogated.
Mr. Paul J. Kuelthau, for the Board.
Messrs. Frost d Jacobs, by Mr. Cornelius J. Petzhold, of Cincinnati,
Ohio, and Messrs. Spe4we, Windels, Walser, Hotchkiss cQ Angell, by
Mr. Andre Maximov, of New York City, for the respondent.
Messrs. Maurice Sugar and N. L. Smokier, by M11r. N. L. Smokier, of
Detroit; Mich., for the UAW-CIO.
Mr. Herman A. Gerig, of Cincinnati, Ohio, for the A. F. of L.
Mr. John G. Witte, of Washington, D. C., and Mr. L. O. Thomas, of
Battle Creek, Mich., for the I. A. M.
Mr. Joseph A. Roach, of Cincinnati, Ohio, for the Association.
Mr. Eugene R. Thorrens, of counsel to the Board.
DECISION
AND
ORDER
STATEMENT OF THE CASE
Upon separate charges duly filed by International Union, United
Automobile, Aircraft and Agricultural Implement Workers of Amer-
ica, affiliated with the C. I. 0., herein called the UAW-CIO, and by
International Association of Machinists (affiliated with the A. F. of
45 N. L. R. B., No. 143.
493508-43-vol 45-62 977
978 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
L.), herein called the I. A. M., the National Labor Relations Board,
herein called the Board, by the Regional Director for the Ninth Region
(Cincinnati, Ohio), issued its complaint dated September 21, 1942,
against Wright Aeronautical Corporation, Lockland, Ohio, herein
called the respondent, alleging that the respondent had engaged in and
was engaging in unfair labor practices affecting commerce, within the
meaning•of Section 8 (1) and (2) and Section 2 (6) and (7) of the
National Labor Relations Act, 49 Stat. 449, herein called the Act.'
Copies of the complaint, accompanied' by notice of hearing thereon,
were duly served upon the respondent, the UAW-CIO, the I. A. M.,
and Aeronautical Employees Association, Inc., he,ejn,called the Asso-
ciation, a labor organization alleged in the complaint to be dominated
by the respondent.
%
With respect to the unfair labor practices, the complaint alleged in
substance (1) that in February 1941, and thereafter, the respondent
dominated and interfered with the formation and administration of
the Association and contributed support thereto; (2) that during the
period from January 1941, to the date of the complaint, the respondent
(a) urged, persuaded, and warned its employees to refrain from join-
ing or retaining membership in the UAW-CIO or the I. A. M.; (b)
made disparaging remarks about the UAW-CIO and the I. A. M.; and
,(c) threatened its employees with discharge if they joined or assisted
the UAW-CIO or the I. A. M., or if they refrained from joining or
assisting the Association; and (3) that, by the foregoing acts, the
respondent interfered with, restrained, and coerced its employees in
the exercise of the rights guaranteed in Section 7 of the Act.
In its answer, filed about October 1, 1942, the respondent admitted,
among other things, the allegations of the complaint with respect to
the nature of its business and denied the commission of the unfair
labor practices.
Pursuant to notice, a hearing was held at Cincinnati, Ohio, on Oc-
tober 8 and 9, 1942, before Samuel Edes, the Trial Examiner duly
designated by the Chief Trial Examiner. At the opening of the hear-
ing the Association moved to intervene in the proceeding. The Trial
Examiner granted, without objection, the Association's petition.:for
intervention to the extent of its interest in the proceeding and per-
mitted the Association to file an answer. In its answer, filed at the
hearing, the Association, in substance, denied the allegations of the
complaint with respect to the unfair labor practices. The Board, the
respondent, the UAW-CIO, the I. A. M., and the Association were
represented by counsel or other representative and participated in the.
1By older dated September 1, 1942,• pursuant to Article IT, Section 36 (b) of National
Labor Relations Board Rules and Regulations-Series 2, as amended, the Board had con-
solidated the cases arising from the respective charges filed by the UAW-CIO and the
I. A. M.
i WRIGHT. AERONAUTICAL CORPORATION 979
Bearing.. All parties were afforded full opportunity to be-heard, to
examine and cross-examine witnesses, and to introduce evidence bear-
ing on the issues.
At the hearing counsel for the UAW-CIO moved to strike the name
of the I. A: M. as a party to the proceeding. The Trial Examiner
denied the motion. At the conclusion of the hearing the Association
moved to dismiss the complaint on the ground that the evidence failed
to sustain its allegations. The Trial Examiner denied the motion.
Counsel for the Board moved to conform the pleadings to the proof.
There was no t objection. and the Trial Examiner granted the motion.
During the course of the hearing the Trial, Examiner ruled on other
motions and on objections to the, admission of evidence. The, Board
has reviewed the rulings of the Trial Examiner made at the hearing
and finds that no prejudicial errors were committed. The rulings are
hereby affirmed. At the close of the hearing the respondent, the
UAW-CIO, and the Association agreed to waive the issuance of an
Intermediate Report by the Trial Examiner, the making of proposed
findings of fact and proposed conclusions of law, and the privilege of
filing briefs and presenting oral -argument, and stipulated, in effect,,
that the'cises maybe transferred to the Board for disposition upon
the record as made at the hearing.2
On October 14, 1942, the Board, acting pursuant to Article II, Sec-
tion 36 (a) of National Labor Relations Board Rules and Regula-
tions-Series 2, as amended, transferred the cases to itself and ordered,
among other things, that no Intermediate Report be issued by the
Trial Examiner.
Upon the entire record in the case, the Board makes the following:
FINDINGS OF FACT
1. THE BUSINESS OF THE RESPONDENT
The respondent, a subsidiary of Curtiss-Wright Corporation, ,is a
New York,corjoration with, its principal place of business,,in New
York City.' The respondent' operates a plant'at Lockland,'Ohio, and'
five plants in the area of Paterson, New Jersey. Only the Lockland
plant is involved in this proceeding. At the Lockland plant, where
the respondent is engaged in the manufacture of aircraft engines, the
principal raw materials used are fabricated parts, castings, and steel
in bar form. The respondent obtains more than 50 percent of the prin-
cipal raw materials used at the Lockland plant from outside the
State of Ohio, and it ships more than 75 percent of its products fin-
ished at the L•ockland plant to points outside the State of Ohio. The
3 By letter dated November 13, 1942, the I. A. H. also consented to expedite the pro-
ceeding in the manner hereinabove set forth.
980 DECISIONS OF NATI'OI\TAL LABOR RELATIONS BOARD
respondent admits that it is engaged in commerce within the meaning
of the Act.
II. THE LABOR ORGANIZATIONS INVOLVED
, -International Union, United Automobile, Aircraft and Agricultural
Implement Workers of America, affiliated with the Congress of In-
dustrial ' Organizations , is a labor organization admitting to member-
ship employees of the respondent.
International Association of Machinists, affiliated with the Amer-
ican Federation of Labor, is a labor organization admitting to member-
ship employees of the respondent.
. • Aeronautical Employees Association, Inc., is an unaffiliated organ=
ization' admitting to membership employees of the respondent.
III. THE UNFAIR LABOR PRACTICES 3
A. Domination and support of the Association
As- indicated above, the respondent operates five plants in the area
of Paterson , New Jersey, and one at Lockland, Ohio, and this proceed-
ing involves only the Lockland plant. On October 9, 1942, the Board
issued its Decision and Order 4 against the respondent with respect to
its Paterson plants, in which, among other things, we directed. the
disestablishment of the Wright Aeronautical Employees' Association,
herein called the Paterson Association. In that case, upon the basis
of•a written stipulation of facts entered into between counsel for the
Board and the respondent with respect to the formation and adminis-
tration of the Paterson Association, we found that the Paterson
Association, formed in 1935, had grown out of a group insurance plan
sponsored by the respondent, and that the respondent had contributed
to the Paterson Association substantial financial and other support.,
8 The record includes a written stipulation of facts entered into between counsel for the
Board and the respondent with respect to the formation and administration of the Asso-
ciation. In the stipulation , among other things, the respondent agreed that , in the event
tile Board petitioned ' a court for the enforcement of an order based upon facts and conclu-
sions of law embodied in the stipulation , the respondent would not contest the Board's
findings of fact, conclusions of law, and order . The respondent did not offer any evi-
dence at the hearing In addition , counsel for the Board offered no evidence with respect
to the allegations , aside trom those relating to the Association , that the respondent had
engaged in, and was engaging in, unfair labor practices within the meaning of Section
8 (1) of the Act. We therefore do not find that the respondent has engaged in unfair labor
practices within the meaning of Section 8 ( 1), except as the unfair labor practices herein-
after found relate to the Association.'
' Matter of Wright Aeronautical Corporation and International Union, United Automo-
bile, Au craft and Agricultural Inipleient Workers of America, C. I. 0., 44 N. L R . B. 959-
Such support included: (a) permitting circulation of Paterson Association by-laws,
membership application cards, notices, and other literature on company time and property ;
(b) permitting Paterson Association elections to be held on company time , and property;
(c) furnishing the Paterson Association , free of charge , an office on company piemises,
clerical assistance , stationery , furniture , equipment , and the use of mimeographing facilities;.
WRIGHT AERONAUTICAL CORPORATION 9S1
In'the present cases, there was introduced in evidence the written stip-
ulation of facts upon which we based our decision and order in the
case relating to; the Paterson Association. In addition, counsel for
the Board• and the respondent entered into a written stipulation of
fact's; mentioned above, with respect to the Association, upon the basis
,of which we find the following:
On or about January 1, 1941, the respondent opened in Norwood,
Ohio, an instruction center for the training of employees to engage in
machine-shop work at Lockland, a new plant.° Such employees, after
completing 3 months' schooling at Norwood, together with employees
hired for other work at Lockland were sent by the respondent to its
Paterson plants for a period of from 2 to 6 weeks' training or until
the Lockland plant could absorb them? While in Paterson, such
employees mingled with Paterson employees, including representatives
of the Paterson Association and of other labor organizations. Three
trainees -from the Cincinnati area, while in Paterson, signed articles
of incorporation, dated-March 4, 1941, for the formation of the'Asso='
ciation and, in March 1941, while in Paterson, sent the articles to the
Secretary of State of the State of Ohio for filing. Subsequently, a
"Code of Regulations or By-laws" patterned on the "By-laws" or gov-
erning regulations of the Paterson Association were drafted.8 While
in Paterson, representatives of the Association who were employees
in training for the Lockland plant engaged in solicitation for Associa-
tion membership on company time and premises among employees
being trained for the Lockland plant, without the knowledge of "senior
management" but with the knowledge and aid of supervisors, includ-
ing foremen, subforemen, leadmen, and other minor supervisors, all
of whom directed and supervised the work of groups of men varying in
number. In the training groups' at Norwood, "company representa-
tives" permitted solicitation for membership in the Association to be
made of employees in training by Association representatives on
company time and property.' After the trainees returned from Pater-
son, solicitation for Association membership continued at the,Lock-
land plant and signatures to Association application cards were solic-
ited on company time and property, sometimes with the knowledge
(d) paying Paterson, Association representatives for time spent on Paterson Association
business ; ( e) contributing substantial sums of money to help defray expenses of Paterson
Association social events ; and ( f) permitting installation and operation of candy-vending
machines , profits of which accrued to the Paterson Association.
eNornnood and Lockland are located in the metiopolitan area of Cincinnati.
From January 1 to June 30, 1941,, the respondent sent to Paterson for training- 380
employees who returned to Cincinnati . During this period , 11 of said employees obtained
supervisory positions in the Lockland plant.
I In general the Paterson Association "By-laws" provided for the establishment of an
employee-representation, plan with employee representatives elected by employees in
electoral districts of the plant . The Association 's golerning rules diffeied from those
of the Paterson Association in verbiage and in matters of organizational structure. of
minor importance.
982 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
of foremen or other immediate supervisors, including subforemen.and
other minor supervisors."
On July 30, 1941, after a request by the Association for exclusive
recognition1? and after a check by, a certified public accountant of, As-,
sociation membership application cards and•company pay-roll records,
the respondent recognized the Association as the exclusive bargaining
representative of its Lockland employees." In. July 1941, however,
the respondent contemplated "an expansion of its working forces dur-
ing the ensuing months." On December 1, 1941, at a time when its
working force at the Lockland plant had more than doubled,12 the
respondent entered into a 1-year contract with the Association, effec-
tive October 1, 1941, without any check of Association membership
in the interim 13 The contract, patterned in general after a contract
then in force between the respondent and the Paterson Association,
dated December 9, 1940, contains provisions with respect to seniority,
lay-offs, hours, wage increases, vacations, strikes, and a grievance
procedure. However, the contract restricts the employees' choice of
representatives,, as does the Association's governing regulations,, to
employees.
Oral testimony introduced by the Association indicates that the
Association is financed, so far as appears, by annual membership dues,
of $4. In May 1942, in addition, the Association obtained a loan of
$1,000, secured by the personal note of officers of the Association,
from a bank. Association witnesses- testified that they expected the
e The wording in the membership application cards -used by the Association followed
verbatim , except as to the name of the organization , the language in the Paterson Asso-
ciation 's membership application, car ds
to The date of the request does not appear.
n The cai ds checked included those signed at Paterson as -li ell as those signed in Ohio.
Of 2,764 employees , excluding executives , supervisors, and guards , as of July 19, 1941,
the Association had 1,950 cards
12 The total number of all employees at the end of each of the following months was
appioximately as follows
Total
Executives,
supervisors,
and guards
Employees
in unit
June 1941 ------- --------------------------------------- 2, 800 620 2,180
July 1941 ----------------------------------------------- 3,500 660 2,840
Aug 1941 -------- -------------------------------------- 4, 200 690 3, 510
Sept 1941 ------------------------------------------ 5, 900 740 5,160
Oct 1941 ----------------------------------------- 7, 100 780 6,320
..Nov 1941 -------------------------------------------- 8,000 835 7, 165
Dec 1941---------------------------------------- 8,800 870 7, 930
Since December 1941, "a substantial number of additonal employees have been hired"
At the hearing , Association witnesses asserted that the Association had approximately
12,000 current , dues-paying members.
i3The contract excludes from its coverage, among others , "foremen, assistant foremen,
sub-foremen , . . or any employee working in superiisoiy capacity or with the right to hire
or discharge or whose duties it is to recommend hiring or discharging . . Pursuant to its
terms, the contract was still in force at the time of the hearing, since negotiations were
pending between the respondent and the Association for a new agreement
WRIGHT AERONAUTICAL CORPORATION 983
Association to pay the loan., So far as appears, elections and meet-
ings of the Association have been held off company premises.
B, . Conclusions
On the basis of the evidence hereinabove reviewed, we are of the
opinion that the Association has a congenital weakness and that the
respondent has given it, support vital to its formation and develop-
ment. We have found that the Paterson Association- was a company-
dominated labor organization. Lockland employees at the Paterson
plant for training, as well as Paterson employees generally, were sub-
ject.to the coercive influences of the respondent existent at the Pater-
son plants which precluded a- free choice of representatives 14 The
Association was formed at Paterson and modeled after the Pater-
son Association in its essential structure and features. Moreover,
the respondent aided in the formation of the Association since com-
pany representatives permitted solicitation for Association member-
ship on company time and property at Paterson, Norwood, and
Lockland. Thus the Association came into being as an extension or
offshoot of the Paterson Association and impressed the Lockland
emplyees in training at Paterson as such an organization. Further-
more, inasmuch as the company pay roll at the Lockland plant had
more than doubled since the respondent's last investigation of Associa-
tion membership, the respondent entered into the exclusive bargaining
contract with the Association without making an adequate check of
the extent of the Association's authority to represent the employees
at the time of its execution. Thus the respondent gave potent support
to the Association. It is also significant that the respondent's contract
with the Association follows generally the form of the respondent's
1940 contract with the Paterson Association. Finally, the Associa-
tion's governing rules 15 and its contract with the respondent, in effect,
as did the contract between the respondent and the Paterson Associa-
tion and its governing rules, forbid outside affiliation by restricting
the choice of Association representatives to employees. A labor or-
ganization formed and operating under the circumstances disclosed
here could not function independently of the respondent, and is
incapable of acting as a bona fide bargaining agency for the employees.
We find that the respondent dominated and interfered with the
formation and administration of the Association and contributed
support thereto, and thereby interfered with, restrained, and coerced
"Although the respondent prior to '1941 had discontinued giving the Paterson Associa-
tion the tangible forms of support mentioned in footnote 5, supra , such discontinuance,
as we have found in the case relating to the Paterson Association , did not free the em-
ployees from the effect of the respondent 's prior domination and support
15
We do not decide that the existence of a rule of this chaiacter in itself ' renders the
Association company -dominnted.
:984 DECISIONS OF 'NATIONAL LABOR RELATIONS BOARD
its employees in the exercise of the rights guaranteed in Section 7 of
the Act;- We further find that the contract entered into between
the respondent and the Association and the contractual relationship
'existing thereunder have been and are a means of utilizing an
,employer-dominated organization to frustrate the exercise by the
respondent's employees of the rights guaranteed in Section 7 of the
Act.
1V. THE EFFECT OF THE UNFAIR LABOR PRACTICES UPON COMMERCE
The activities of the'respondent set forth in Section III above,
occurring in connection with the operations of the respondent de-
scribed in Section I 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 and obstructing commerce
and the free flow of commerce.
V. THE REMEDY
Having found that the respondent has engaged in unfair labor
practices, we shall order it to cease and desist therefrom and to take
certain affirmative action designed to effectuate the policies of the
Act.
We have found that the respondent has dominated and interfered
with the formation and administration of the Association and has
contributed support thereto. The effects and consequences of the
respondent's domination, interference with, and support of the As-
sociation, as well as the continued recognition of the Association as
the bargaining representative for its employees; constitute a continu-
ing obstacle to the free exercise by its employees of their right to
self-organization and to bargain collectively through representatives
.of their own choosing. Because of 'the respondent's illegal conduct
with regard to the Association, it is incapable of serving the respond-
ent's employees'as a genuine collective bargaining agency. Moreover,
the continued recognition of the Association would be obstructive of
the free exercise by the employees of the rights guaranteed to them
by the Act. Accordingly we shall order that the respondent dises-
tablish and withdraw all recognition from the Association as repre-
sentative of any of its emplo}-ees for the purposes of dealing with it
16 See, for example, N. L R. B. v. Newport News Shipbuilding & Dry Dock Co, 308
U. S 241, reversing 101 F. (2d) 841 (CCA 4), enf as mod. 8 N L R B. 866; N. L R. B.
Y. Link-Belt Co., 311 U. S' 584, reversing 110 F. (2d) 506 (CCA 7), enf. as mod 12
N L. R. B 854; Westinghouse Electric & Mfg. Co v N. L. R B, 312 U S. 660, aff'g,
per curiam, 1]2 F. (2d) 657 (CCA 2), enf. as mod 18 N. L. R B 100; Swift & Co. v
N. L. R. B., 106 F (2d) 87 (CCA 10) enf. as mod. 7 N. L. R B. 26(); Continental Oil Co.
v. N. L. R B, 113 F. (2d) 473 (CCA 10), enf. as mod 12 N L R B. 789; The Texas
'Company v N. L R B., 119 F (2d) 23 (CCA 7), enf 26 N. L R B. 1059.
WRIGHT AERONAUTICAL CORPORATION 985,
concerning grievances, labor disputes, wages, rates of pay, hours of
employment, or other conditions of employment.17 We have also found
that the contract entered into between the respondent and the As- l
sociation and the contractual relationship existing thereunder have
been the means whereby the respondent has utilized an employer-
dominated labor organization to frustrate self-organization and de-
feat genuine collective bargaining by its employees. Under these-
circumstances, any continuation, renewal, or modification of the exist-
ing contract would perpetuate the conditions which have deprived
employees of the rights guaranteed to them by the Act and would
render ineffectual the other portions of our remedial order. We shall
therefore order the respondent to cease giving effect to any contract,
between it and the Association, or to any modification or extension.
thereof. Nothing in this decision or in our order should be taken,
however, to require the respondent to vary those wage, hour, and other
substantive features of its relations with the employees themselves,
if any, which the respondent established in performance of the con-
tract as extended, renewed, modified, supplemented, or superseded.1'
Upon the basis of the foregoing findings of fact and upon the
entire record in the proceeding, the Board makes the following:
CONCLUSIONS OF LAW
1. International Union, United Automobile, Aircraft and Agricul-
tural, Implement Workers of America, affiliated with the Congress of
Industrial 'Organizations, International Association of -Machinists,
affiliated with the American Federation,of Labor, and Aeronautical
Employees Association, Inc., are labor organizations, within the mean-
ing of Section 2 (5) of the Act.
2. By dominating and interfering with the formation and adminis-
tration of, and contributing support to, Aeronautical Employees As-
sociation, Inc., the respondent has engaged in and is engaging in
unfair labor practices, within the meaning of Section 8 (2) of the Act.
3. By interfering with, restraining, and coercing employees in the
exercise of the rights guaranteed in Section 7 of the Act, the respond-
ent has engaged iii and is engaging in unfair labor practices, within
the meaning of Section 8 (1) of the Act.
4. The aforesaid unfair labor practices are unfair labor-practic's-
affecting commerce, within the meaning of. Section 2 (6) and (7) of
the^Act.
11 See, for example , N L. R. B. v. Linn,-Belt Co ., .supra; H. J. Heinz Co v. N. L R B
311 U S 314, aff'g 110 F. (2d) 843 (CCA 6) enf'g 10 N L R B 963: N. I, R B v
Newport News Shapbuildanp h Day Dock Co, supra: N . L. R. B. v The Falk Corporation..
.308 U. S 453, rev'g 106 F (2d) 454, mod. 102 F. (2d) 383 (CCA 7), enf'g 6 N. L. R B
654.
"National Licoi ice Co . V. N. L. R B , 309 U S 350, aff ' g as mod 104 P (2d) 655
(CCA 2 ), enf. as mod . 7 N L R. B 537; N L R B . v. J Greencbauni Tanning Co , 110 F. (2d)'
984 (CCA 7), enf. as mod 11 N. L . R B 300 , cert . denied 311 U. S 662.
986 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
ORDER
Upon the basis of the above findings of fact and conclusions of law,
and pursuant to Section 10 (c) of the National Labor Relations Act,
the National Labor Relations Board hereby orders that the respondent,
Wright Aeronautical Corporation, Lockland, Ohio, and its officera,
agents, successors, and assigns, shall:
1. Cease and desist from :
(a) Dominating or interfering with the formation and administra-
tion of, or contributing support to, Aeronautical Employees Associa-
tion, Inc., or any other labor organization of its employees;
(b) Recognizing Aeronautical Employees Association, Inc., as q
representative of any of its employees for the purpose of dealing with
the respondent concerning grievances, labor disputes, wages, rates of
pay, hours of employment, or other conditions of employment;
(c) Givnig effect to the "Contract" dated December 1, 1941, between
the respondent and Aeronautical Employees Association, Inc., or any
extension, renewal, or modification thereof, or any other contract ,or
agreement between the respondent and the said labor organization
which may now be in force;
(d) In any other manner interfering with, restraining, or coercing
employees in the exercise of the right to self-organization, to form,
join, or assist labor organizations, to bargain collectively with repre-
sentatives of their own choosing, and to engage in concerted activities
for the purposes of collective bargaining or other mutual aid or
protection.
2. Take the following affirmative action, which the Board finds will
effectuate the policies of the Act :
(a) Withdraw all recognition from, and completely disestablish,
Aeronautical Employees Association, Inc., as the representative of,
any of its employees for the purposes of dealing with the respondent
concerning grievances, labor disputes, wages, rates of pay, hours of
employment, or other conditions of employment;
(b) Post immediately, in conspicuous places at its plant in Lock-
land, Ohio," and maintain for a period of at least sixty (60) conse-
cutive days from the date of posting, notices to its employees stating:
(1) that the respondent will not engage in the conduct from which it
is ordered to cease and desist in paragraphs I (a), (b), (c), and (d) of
this Order, and (2) that the respondent will take the affirmative action
set forth in paragraph 2 (a) of this Order;
(c) Notify the Regional Director for the Ninth Region in writing
within ten (10) days from the date of this Order,'what steps ,the're-
spondent has taken to comply herewith.