[ v27 p785 ]
27:0785(85)CA
The decision of the Authority follows:
27 FLRA No. 85
DEPARTMENT OF THE NAVY
NAVAL SUBMARINE BASE,
NEW LONDON (NEW LONDON,
CONNECTICUT)
Respondent
and
NATIONAL ASSOCIATION OF GOVERNMENT
EMPLOYEES, LOCAL R1-100
Charging Party
Case No. 1-CA-60304
DECISION AND ORDER
The Administrative Law Judge issued the attached Decision in the
above-entitled proceeding finding that the Respondent had engaged in the
unfair labor practices alleged in the complaint and recommending that it
be ordered to cease and desist from the unfair labor practices and take
appropriate remedial action. Thereafter, the Respondent and the General
Counsel each filed exceptions to the Judge's Decision and Order, and the
General Counsel filed a statement in response to the Respondent's
exceptions.
Pursuant to section 2423.29 of the Authority's Rules and Section 7118
of the Federal Service Labor-Management Relations Statute (the Statute),
we have reviewed the findings and conclusions of the Judge and find that
no prejudicial error was committed. The findings are hereby affirmed.
Upon consideration of the Judge's Decision, the exceptions, and the
entire record, we adopt the Judge's findings, conclusions and
recommended Order. /*/
ORDER
Pursuant to section 2423.29 of the Authority's Rules and Regulations,
and section 7118 of the Federal Service Labor-Management Relations
Statute, the Department of the Navy, Naval Submarine Base New London,
New London, Connecticut, shall:
1. Cease and desist from:
(a) Refusing to furnish, upon request by the National
Association of Government Employees, Local R1-100, the exclusive
representative of its employees, the names and the home addresses
of all employees in the bargaining unit it represents.
(b) In any like or related manner interfering with,
restraining, or coercing its employees in the exercise of the
rights assured them by the Statute.
2. Take the following affirmative action in order to effectuate the
purposes and policies of the Statute:
(a) Upon request by the National Association of Government
Employees, Local R1-100, the exclusive representative of its
employees, furnish it with the names and home addresses of
employees in the bargaining unit it represents.
(b) Post at its facilities at the Naval Submarine Base New
London, copies of the attached Notice on forms to be furnished by
the Federal Labor Relations Authority. Upon receipt of such
forms, they shall be signed by the Commanding Officer and shall be
posted and maintained for 60 consecutive days thereafter, in
conspicuous places, including all bulletin boards and other places
where notices to employees are customarily posted. Reasonable
steps shall be taken to ensure that such Notices are not altered,
defaced, or covered by any other material.
(c) Pursuant to section 2423.30 of the Authority's Rules and
Regulations, notify the Regional Director, Region I, Federal Labor
Relations Authority, Boston, Massachusetts, in writing, within 30
days from the date of this Order, as to what steps have been taken
to comply herewith.
Issued, Washington, D.C., June 26, 1987.
Jerry L. Calhoun, Chairman
Henry B. Frazier III, Member
Jean McKee, Member
FEDERAL LABOR RELATIONS AUTHORITY
NOTICE TO ALL EMPLOYEES AS ORDERED BY THE FEDERAL LABOR
RELATIONS
AUTHORITY AND TO EFFECTUATE THE POLICIES OF THE FEDERAL SERVICE
LABOR-MANAGEMENT RELATIONS STATUTE
WE NOTIFY OUR EMPLOYEES THAT:
WE WILL NOT refuse to furnish, upon request by the National
Association of Government Employees, Local R1-100, the exclusive
representative of our employees, the names and home addresses of all
employees in the bargaining unit it represents.
WE WILL NOT in any like or related manner interfere with, restrain or
coerce our employees in the exercise of the rights assured them by the
Statute.
WE WILL, upon request by the National Association of Government
Employees, Local R1-100, the exclusive representative of our employees,
furnish it with the names and home addresses of employees in the
bargaining unit it represents.
. . . (Activity)
Dated: . . . By: . . . (Signature) (Title)
This Notice must remain posted for 60 consecutive days from the date
of posting, and must not be altered, defaced, or covered by any other
material.
If employees have any questions concerning this Notice or compliance
with its provisions, they may communicate directly with the Regional
Director, Region I, Federal Labor Relations Authority, whose address is:
10 Causeway Street, Room 1017, Boston, MA 02222-1046 and whose
telephone number is: (617) 565-7280.
-------------------- ALJ$ DECISION FOLLOWS --------------------
Case No. 1-CA-60304
DEPARTMENT OF THE NAVY, NAVAL SUBMARINE BASE
NEW LONDON (NEW LONDON, CONNECTICUT) /1/
Respondent
and
NATIONAL ASSOCIATION OF GOVERNMENT EMPLOYEES,
LOCAL R1-100
Charging Party
Richard H. Greenberg, Esquire
For the Respondent
Danny R. Veilleaux, Esquire
For the Charging Party
Marilyn H. Zuckerman, Esquire
For the General Counsel
Before: WILLIAM B. DEVANEY
Administrative Law Judge
DECISION
Statement of the Case
This proceeding, under the Federal Service Labor-Management Relations
Statute, Chapter 71 of Title 5 of the United States Code, 5 U.S.C.
Section 7101, et seq., /2/ and the Final Rules and Regulations issued
thereunder, 5 C.F.R. Section 2423.1, et seq., concerns a request for the
names and home addresses of bargaining unit employees. It was initiated
by a charge, filed on June 23, 1986 (G.C. Exh. 1 A), which alleged
violations of Sections 16(a)(1) and (5) of the Statute; and a first
Amended charge, filed on July 9, 1986 (G.C. Exh. 1 C), which alleged
violations of Sections 16(a)(1), (5) and (8) of the Statute. The
Complaint and Notice of Hearing issued on August 22, 1986 (G.C. Exh. 1
E), alleged violations of Sections 16(a)(1), (5) and (8) and set the
hearing for October 10, 1986, at a place to be designated later; and by
Notice dated September 26, 1986 (G.C. Exh. 1 G), the place of hearing
was designated, pursuant to which a hearing was duly held on October 10,
1986, in New London, Connecticut, before the undersigned.
All parties were represented at the hearing, were afforded full
opportunity to be heard, to introduce evidence bearing on the issues
presented, to examine and cross-examine witnesses, and were afforded the
opportunity to present oral argument. At the conclusion of the hearing,
November 10, 1986, was fixed as the date for mailing post-hearing
briefs. General Counsel by timely motion, joined in by counsel for the
Charging Party and to which counsel for Respondent did not object, for
good cause shown, requested an extension of time to December 12, 1986,
within which to mail briefs. By Order dated November 4, 1986, General
Counsel's motion was granted, in part; attention of all parties was
directed to: Farmers Home Administration Finance Office, St. Louis,
Missouri and American Federation of Government Employees, AFL-CIO, Local
3354, 23 FLRA No. 101, which had been decided by the Authority on
October 31, 1986; and the time for filing post-hearing briefs was
extended to December 1, 1986. Respondent and General Counsel each
timely mailed a brief, received on, or before, December 2, 1986, which
have been carefully considered. Upon the basis of the entire record, I
make the following findings and conclusions:
Findings
1. At all times material, National Association of Government
Employees, Local R1-100 (hereinafter referred to as the "Union") has
been the exclusive representative of all employees at Naval Submarine
Base New London, the Branch Commissary Store, New London, Naval
Submarine School, Personnel Support Activity New London and Naval
Submarine Support Facility New London, with certain exceptions more
fully set forth in Paragraph 5 of the Complaint (G.C. Exh. 1 E) and in
Article I of the Agreement of the parties (G.C. Exh. 2, Art. I, p. 2).
2. By letter dated April 24, 1986 (G.C. Exh. 3), Mr. Kevin J.
McGill, President of the Union, pursuant to "AFGE Local 1760 v. FLRA
USCA 2nd, No. 85-4144" formally requested the names and home addresses,
"of all bargaining unit employees" (G.C. Exh. 3, Tr. 13-15). There are
approximately 550 employees in the bargaining unit, of whom about 150
are members of the Union (Tr. 13).
3. By letter dated April 30, 1986 (G.C. Exh. 4), Respondent
requested information as to the Union's purpose in seeking the names and
addresses. Although Respondent stated it was "advised to refrain from
furnishing such information . . . ," Respondent further stated,
" . . . you should also be aware that the addresses maintained
in our computer are probably out of date and/or incomplete as
employees are not required to furnish and/or provide updated
information to this office." (G.C. Exh. 4).
Respondent never offered the home addresses it had available (Tr.
69), nor was the Union interested in obtaining any but current home
addresses.
4. Mr. McGill met with Mr. Robert S. Knowles, then Head,
Labor/Employee Relations, subsequently acting Civilian Personnel Officer
(Tr. 46), and discussed the Union's request. Although Mr. McGill
asserted that Mr. Knowles told him that the Base Comptroller had the
home addresses (Tr. 23, 43) which Mr. Knowles denied (Tr. 56), it is
unnecessary to resolve the conflict, if there were a conflict, since Mr.
Knowles, in his subsequent letter of May 7, 1986, specifically informed
Mr. McGill,
"2. You are further advised that the base Comptroller does not
maintain a listing of addresses. All such information is
maintained by the servicing disbursing center." (G.C. Exh. 6).
As Mr. Knowles testified, Respondent does have in its personnel data
system computer the addresses of employees as of January, 1985, and
addresses of new employees at date of hire (Tr. 56) but does not
maintain current home addresses (Tr. 55). Current home addresses are
maintained only by the Fleet Accounting Office in Norfolk, Virginia, for
payroll purposes, for all employees except the commissary store.
Commissary store employees are paid out of the Navy Finance Office in
Great Lakes, Illinois, which maintains home addresses, for payroll
purposes, for commissary store employees (Tr. 56-57).
5. By letter dated May 1, 1986 (G.C. Exh. 5), the Union set forth
its purpose in seeking the names and home addresses and Respondent, by
letter dated May 7, 1986 (G.C. Exh. 6), refused to provide the requested
names and home addresses, asserting that the employee's right to privacy
of their home addresses outweighed the Union's right to have the
information and further stated that the names and home addresses were
not maintained locally. /3/
6. Respondent did provide the Union with a list of bargaining unit
employees by work address and by organization (Tr. 35-36) and the record
shows, as General Counsel states, " . . . detailed testimony at trial as
to alternative access . . . ," including use of the internal mail
system.
Conclusions
After the hearing in this case, the Authority, on October 31, 1986,
issued its decision in Farmers Home Administration Finance Office, St.
Louis, Missouri, 23 FLRA No. 101, 23 FLRA 788 (1986) (hereinafter
referred to as "Farmers Home Administration"), to which the parties were
specifically directed by the Order granting an extension of time within
which to file post-hearing briefs. Farmers Home Administration, supra,
and numerous subsequent like decisions, including: Philadelphia Naval
Shipyard, 24 FLRA No. 4, 24 FLRA 37 (1986); Defense Mapping Agency
Aerospace Center, St. Louis, Missouri, 24 FLRA No. 5, 24 FLRA 43 (1986);
Social Security Administration, Northeastern Program Service Center, 24
FLRA No. 13, 24 FLRA 108 (1986); Department of the Air Force, Scott Air
Force Base, Illinois, 24 FLRA No. FLRA 226 (1986); Department of Health
and Human Services, Social Security Administration, 24 FLRA No. 60, 24
FLRA 543 (1986); Department of Health and Human Services, Social
Security Administration and Social Security Administration Field
Operations, New York Region, 24 FLRA No. 62, 24 FLRA 583 (1986), are
controlling and are dispositive of all issues raised by Respondent.
First, Respondent asserts, "The information requested by the Union is
not relevant and necessary as contemplated by 5 U.S.C. 7116(b)(4)"
(Respondent's Brief; pages are not numbered, but, excluding the cover
sheet, this is the third page) and that, "It is Respondent's position
that the General Counsel has failed to sustain its burden of proving
that the data was necessary to a legitimate collective bargaining need
of the Union." (Respondent's Brief, sixth page). Although it is quite
true that the Union in its letter of May 1, 1986, stated that its, " . .
. interest in acquiring the home address of bargaining Unit Employees
will be confined to mailed information concerning the local and the
National Unions activities and for the solicitation of new members"
(G.C. Exh. 5), Respondent made no inquiry as to what Mr. McGill meant by
"local and the National Union activities" which, as Mr. McGill
testified, directly related to collective bargaining and specifically to
a survey form which Mr. McGill had prepared (Tr. 30-31). But, in any
event, the Authority in Farmers Home Administration, supra, stated in
this regard,
" . . . we find that the statutory requirement concerning
sufficiency of a request under section 7114(b)(4) is satisfied . .
. when a general written request for the information is made. A
precise explication of the reasons for the request involved here
is not necessary . . . In our view, an exclusive representative's
need for the names and home addresses of the bargaining unit
employees it is required to represent is so apparent and
essentially related to the nature of exclusive representation
itself, that unlike requests for certain types of other
information, an agency's duty to supply names and home addresses
information does not depend upon any separate explanation by the
union of its reasons for seeking the information." (23 FLRA at
795).
Second, Respondent asserts that, "The Union has other adequate means
of communicating with employees" (Respondent's Brief, eighth page).
With regard to this contention, the Authority has stated,
"We will not review the adequacy of alternative methods of
communication on a case-by-case base. Consistent with the view of
the Court of Appeals for the Second Circuit . . . we find that the
mere existence of alternative means of communication is
insufficient to justify a refusal to release the information.
Further, we find that it is not necessary for us to examine the
adequacy of alternative means in cases involving requests for
names and home addresses because the communication between unit
employees and their exclusive representative which would be
facilitated by release of names and home address information is
fundamentally different from other communication through
alternative means which are controlled in whole or in part by the
agency . . . we find that the names and home addresses of unit
employees are necessary and should be provided whether or not
alternative means of communication are available." (23 FLRA at
796-797).
Third, Respondent asserts that it, " . . . is prohibited by law from
releasing the information requested by the Union" (Respondent's Brief,
tenth page). With regard to this contention, the Authority has stated,
"On balance, we find that the public interest to be furthered
by providing the Union with an efficient method to communicate
with unit employees it must represent far outweighs the privacy
interests of individual employees in their names and home
addresses. Disclosure of the requested information would not
constitute a clearly unwarranted invasion of personal privacy and
does not fall within the (b)(6) exemption to FOIA. Since the
information does not fall within the exemption, its disclosure is
required under the FOIA and, under exception (b)(2) to the Privacy
Act, its release is not prohibited by law."
* * * *
" . . . we conclude that the disclosure of the names and home
addresses of bargaining unit employees to the Union is necessary
within the meaning of section 7114(b)(4) of the Statute for the
Union to discharge its statutory obligations. Consistent with
that conclusion, we find that disclosure of the information sought
here falls within the routine use established by OPM, and its
disclosure is therefore a routine use under exception (b)(3) of
the Privacy Act. Therefore, even if the disclosure was not
authorized under exception (b)(2) of the Privacy Act, relating to
the FOIA, it is authorized under exception (b)(3).
"Release of the requested information is therefore not
prohibited by law. It may be released pursuant to exceptions
(b)(2) and (3) of the Privacy Act." (23 FLRA at 793-794).
Fourth, Respondent asserts that, " . . . the information is not
'reasonably available' either at the local activity or elsewhere. A new
computer program would have to be written in order to extract only the
names and addresses of bargaining unit employees. This is different
from the facts in FHA (Farmers Home Administration), supra, where the
names and addresses were readily available." (Respondent's Brief,
seventh page).
Section 14(b)(4) imposes on an agency the duty to furnish data to the
exclusive representative,
"(B) which is reasonably available and necessary . . . ."
(Emphasis supplied).
Even though such data is "normally maintained" in the regular
Respondent does maintain home addresses in the regular course of
business for payroll purposes, and even though such data is necessary
within the meaning of Section 14(b)(4)(B), nevertheless, such data must
also be "reasonably available." While the evidence and testimony at the
hearing suggested a question as to whether the Union's request for
current names and home addresses constituted data" which is reasonably
available," pursuant to Section 14(b)(4)(B), Respondent largely skirted
the issue at the hearing, /4/ and the only testimony or evidence offered
was: a) everyone's home address is maintained regardless of the method
of payment (Tr. 61-62); b) that to furnish current home addresses the
computer programs would have to be re-programmed (Tr. 57, 61); and c)
that there is a two to three month backlog on programming (Tr. 57).
Although Mr. Knowles stated, " . . . the office that does their
programming for them was behind and they had a significant problem with
the payroll as a result" (Tr. 57-58), the only conclusion, or inference,
that can be drawn is that a significant problem resulted because
programming had not been done -- not because of re-programming. Indeed,
Mr. Knowles perceived no problem in providing names and home addresses,
but only that "It would require a program and to write a program to
specifically extract that information." (Tr. 61).
There is no evidence or testimony as to the cost of the necessary
re-programming and no evidence or testimony of any problem or difficulty
in furnishing the names and addresses for bargaining unit employees,
beyond having to " . . . write a program to specifically extract that
information." As Counsel for General Counsel stated in her closing
remarks, " . . . He (Mr. Knowles) said that they could, if they wished,
that they could distinguish bargaining unit from non-bargaining unit . .
. So that it is maintained and it is reasonably available. Now, how
much time it would take and exactly what it would require, there is no
testimony and they didn't go so far as to find out." (Tr. 94). It is
true that in Farmers Home Administration, supra, that home addresses " .
. . retained by the Respondent in official personnel files, in a card
index system, and in a computer file" (19 FLRA No. 21, 19 FLRA 195, 202
n. 2; 23 FLRA at 795, were found in the Authority's decision on remand
to be "reasonably available . . . ." (23 FLRA at 795); but it is not
true, as Respondent asserts, that the facts in Farmers Home
Administration were essentially different. In Farmers Home
Administration, as here, it was necessary to extract the data from
records maintained by the agency -- there, from official personnel files
(OPFs), a card index, or a computer -- and here from a computer file.
Although preparation of the data requested was not explored in Farmers
Home Administration, it has been specifically considered in Defense
Mapping Agency Aerospace Center, St. Louis, Missouri (hereinafter
referred to as "Defense Mapping," supra; and in Social Security
Administration, Northeastern Program Service Center, hereinafter
referred to as "Northeastern Program"), supra. In Defense Mapping,
supra, the cost of preparing names and addresses, "taking into
consideration labor costs and the time of the computer and the
keypunching" was estimated to be $736 and the cost of each run
thereafter was estimated to be $21, for 1500 employees. (19 FLRA No.
85, 19 FLRA 675, 688-689). In its decision on remand, in response to
the agency's assertion that to retreive the information from either its
personnel records or its computerized payroll system would be
unnecessarily costly and time consuming (24 FLRA at 44), the Authority
held,
" . . . Based on our decision on remand in the FHAFO case, we
find that the Respondent in this case was required to furnish the
Union with the names and home addresses of the employees in the
bargaining unit. Further in that regard, we find that the names
and home addresses of the unit employees are reasonably available
to the Respondent and that it would not place an undue burden on
the Respondent to provide the Union with the information
requested." (24 FLRA at 46) (Emphasis supplied).
In Northeastern Program, supra, the cost was less explicitly
estimated but it was asserted, inter alia, " . . . the addresses must be
extracted manually from each personnel locator card, and it would take
about 40 man hours to accomplish . . . Since the Personnel Branch was
short staffed, the burden so thrust upon Respondent . . . would be
onerous." (19 FLRA No. 108, 19 FLRA 913, 925). In its decision on
remand, in response to the agency's assertion, inter alia, that the
information was not readily available because it would require the
compilation of addresses from many sources (24 FLRA at 109), the
Authority, again, held that,
" . . . we find that the home addresses of the unit employees
are reasonably available to the Respondent and that it would not
place an undue burden on the Respondent to provide the Union with
the information requested." (24 FLRA at 112).
Here, employees names and addresses, maintained in computerized
payroll systems, are reasonably available to Respondent by writing a
program to extract the names and addresses of bargaining unit employees
and, as Respondent has offered no evidence or testimony whatever that
re-programming would be unnecessarily costly, time consuming, or
difficult, I conclude that it would not place an undue burden on
Respondent to provide the Union with the information requested.
Respondent's refusal to furnish the requested information in this case
constituted a violation of Sections 16(a)(1), (5) and (8) of the
Statute. Accordingly, it is recommended that the Authority adopt the
following:
ORDER
Pursuant to Section 2423.29 of the Authority's Rules and Regulations,
5 C.F.R. Section 2423.29, and Section 18 of the Statute, 5 U.S.C.
Section 7118, the Authority hereby orders that the Department of the
Navy, Naval Submarine Base New London, New London, Connecticut, shall:
1. Cease and desist from:
(a) Refusing to furnish, upon request by the National
Association of Government Employees, Local R1-100, the exclusive
representative of its employees, the home addresses of all
employees in the bargaining unit it represents.
(b) In any like or related manner interfering with,
restraining, or coercing its employees in the exercise of the
rights assured them by the Statute.
2. Take the following affirmative active in order to effectuate the
purposes and policies of the Statute:
(a) Upon request by the National Association of Government
Employees, Local R1-100, the exclusive representative of its
employees, furnish it with the home addresses of employees in the
bargaining unit it represents.
(b) Post at its facilities at the Naval Submarine Base New
London copies of the attached Notice on forms to be furnished by
the Federal Labor Relations Authority. Upon receipt of such
forms, they shall be signed by the Commanding Office and shall be
posted and maintained for 60 consecutive days thereafter, in
conspicuous places, including all bulletin boards and other places
where notices to employees are customarily posted. Reasonable
steps shall be taken to insure that such Notices are not altered,
defaced, or covered by any other material.
(c) Pursuant to Section 2423.30 of the Authority's Rules and
Regulations, 5 C.F.R., Section 2423.30, notify the Regional
Director, Region I, Federal Labor Relations Authority, Room 1017,
10 Causeway Street, Boston, Massachusetts, 02222-1046, in writing,
within 30 days from the date of this Order, as to what steps have
been taken to comply herewith.
WILLIAM B. DEVANEY
Administrative Law Judge
Dated: March 30, 1987
Washington, D.C.
--------------- FOOTNOTES$ ---------------
(*) The Judge's reference in his recommended Order and Notice to home
addresses is amended to read "names and home addresses."
(1) Although designated "Naval Submarine Base New London", the
address, presumably, should be Groton, Conneticut (see, G.C. Exhs. 4, 6;
Caption, Respondent's Brief); however the address as shown on the
complaint and the formal documents, including Respondent's Answer (G.C.
Exh. 1 F), is New London and that address, in the absence of a request
by any party to change it, has been retained.
(2) For convenience of reference, sections of the Statute hereinafter
are, also, referred to without inclusion of the initial "71" of the
statutory reference, e.g., Section 7116(a)(5) will be referred to,
simply, as "Section 16(a)(5)."
(3) It is undisputed that to furnish current home addresses, the
Norfolk Fleet Accounting Office and Great Lakes Finance Office computer
programs would have to be re-programmed (Tr. 57). It is also not
disputed that there is a two to three month backlog on programming (Tr.
57). Beyond showing that production of current home addresses would
require re-programming, on which there was a backlog, Respondent offered
no evidence or testimony as to the cost of re-programming.
(4) In its Answer to Paragraph 7(a) of the Complaint which, inter
alia, alleged that "The data . . . is reasonably available . . . . "
(G.C. Exh. 1 E), Respondent, after denying Paragraph 7(a), stated, in
material part, "Respondent is without knowledge as to whether it
possesses the names and current home addresses of all employees employed
in the bargaining unit described in paragraph 5 of the Complaint . . .
." (G.C. Exh. 1 F). In his opening statement, Counsel for Respondent
stated, in relevant part, ". . . General Counsel has not supported his
burden of proof in even showing and proving that respondent maintains
such a list as per the union request." (Tr. 45). See Counsel for
Respondent's essentially identical statement in his closing statement
(Tr. 74).
APPENDIX
NOTICE TO ALL EMPLOYEES PURSUANT TO A DECISION AND ORDER OF
THE FEDERAL
LABOR RELATIONS AUTHORITY AND IN ORDER TO EFFECTUATE THE
POLICIES OF
CHAPTER 71 OF TITLE 5 OF THE UNITED STATES CODE FEDERAL SERVICE
LABOR-MANAGEMENT RELATIONS STATUTE
WE HEREBY NOTIFY OUR EMPLOYEES THAT:
WE WILL NOT refuse to furnish, upon request by the National
Association of Government Employees, Local R1-100, the exclusive
representative of our employees, the home addresses of all employees in
the bargaining unit it represents.
WE WILL NOT in any like or related manner interfere with, restrain,
or coerce our employees in the exercise of the rights assured them by
the Federal Service Labor-Management Relations Statute.
WE WILL, upon request by the National Association of Government
Employees, Local R1-100, the exclusive representative of our employees,
furnish it with the home addresses of all employees in the bargaining
unit it represents.
. . . (Agency or Activity)
Dated: . . . By: . . . (Signature)
This Notice must remain posted for 60 consecutive days from the date
of posting and must not be alatered, defaced or covered by any other
material.
If employees have any questions concerning this Notice or compliance
with any of its provisions, they may communicate directly with the
regional Director of the Federal Labor Relations Authority, Region I,
whose address is: Room 1017, 10 Causeway Street, Boston, MA 02222-1046,
and whose telephone number is: (617) 565-7280.