[ v21 p339 ]
21:0339(45)CO
The decision of the Authority follows:
21 FLRA No. 45
AMERICAN FEDERATION OF GOVERNMENT
EMPLOYEES, LOCAL 2782, AFL-CIO
Respondent
and
DEPARTMENT OF COMMERCE
BUREAU OF THE CENSUS
Charging Party
Case No. 3-CO-50002
DECISION AND ORDER
The Administrative Law Judge issued the attached Decision 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
therefrom and take certain affirmative action. The Respondent filed
exceptions to the Judge's Decision.
Pursuant to section 2423.29 of the Authority's Rules and Regulations
and section 7118 of the Federal Service Labor-Management Relations
Statute, the Authority has reviewed the rulings of the Judge made at the
hearing and finds that no prejudicial error was committed. The rulings
are hereby affirmed. Upon consideration of the Judge's Decision and the
entire record, the Authority hereby adopts 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, it is hereby ordered that the American Federation of Government
Employees, Local 2782, AFL-CIO, shall:
1. Cease and desist from:
(a) Unilaterally refusing or failing to proceed to arbitration
regarding three grievances filed by the Department of Commerce, Bureau
of the Census, on March 8, 1984, contrary to the requirements of section
7121 of the Federal Service Labor-Management Relations Statute, after
receiving timely notice of the Department of Commerce, Bureau of the
Census' desire to invoke arbitration.
(b) In any like or related manner interfering with, restraining, or
coercing unit employees in the exercise of their rights assured by the
Federal Service Labor-Management Relations Statute.
2. Take the following affirmative action in order to effectuate the
purposes and policies of the Statute:
(a) Upon request, proceed to arbitration regarding the three
grievances filed by the Department of Commerce, Bureau of the Census, on
March 8, 1984.
(b) Post at its business offices and its normal meeting places,
including all places where notices to members and employees of the
Department of Commerce, Bureau of the Census, are customarily posted,
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 President of the American Federation of Government
Employees, Local 2782, AFL-CIO, or a designee, and shall be posted and
maintained for 60 consecutive days thereafter, in conspicuous places,
including all bulletin boards and other places where notices to members
and other 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) Submit appropriate signed copies of such Notices to the Director,
Bureau of the Census, for posting in conspicuous places where the unit
employees are located, where they shall be maintained for a period of 60
consecutive days from the date of posting.
(d) Pursuant to section 2423.30 of the Authority's Rules and
Regulations, notify the Regional Director, Region III, Federal Labor
Relations Authority, 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., April 18, 1986.
/s/ Jerry L. Calhoun, Chairman
/s/ Henry B. Frazier III, Member
FEDERAL LABOR RELATIONS AUTHORITY
NOTICE TO ALL MEMBERS AND OTHER 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
WE HEREBY NOTIFY OUR MEMBERS AND OTHER EMPLOYEES THAT:
WE WILL NOT unilaterally refuse or fail to proceed to arbitration
regarding the three grievances filed by the Department of Commerce,
Bureau of the Census, on March 8, 1984, contrary to the requirements of
section 7121 of the Federal Service Labor-Management Relations Statute,
after receiving timely notice of the Department of Commerce, Bureau of
the Census desire to invoke arbitration.
WE WILL NOT in any like or related manner interfere with, restrain,
or coerce unit employees in the exercise of their rights assured by the
Statute.
WE WILL, upon request, proceed to arbitration regarding the three
grievances filed by the Department of Commerce, Bureau of the Census, on
March 8, 1984.
(Labor Organization)
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, Federal Labor Relations Authority, Region III, whose address
is: P.O. Box 33758, Washington, D.C. 20033-0758 and whose telephone
number is: (202) 653-8500.
-------------------- ALJ$ DECISION FOLLOWS --------------------
Case No.: 3-CO-50002
AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, LOCAL 2782,
AFL-CIO
Respondent
and
DEPARTMENT OF COMMERCE BUREAU OF THE CENSUS
Charging Party/Agency
Erica F. Cooper, Esquire
Bruce D. Rosenstein, Esquire
For the General Counsel
Ruth A. Sanders
Russ Davis
For the Respondent
Paul A. Bath
For the Charging Party
Before: BURTON S. STERNBURG
Administrative Law Judge
DECISION
Statement of the Case
This is a proceeding under the Federal Service Labor-Management
Relations Statute, Chapter 71 of Title 5 of the U.S. Code, 5 U.S.C.
Section 7101, et seq., and the Rules and Regulations issued thereunder.
Pursuant to an amended charge first filed on October 3, 1984, by the
Department of Commerce, Bureau of Census, (hereinafter called the
Charging Party or Bureau), a Complaint and Notice of Hearing was issued
on December 31, 1984, by the Regional Director for Region III, Federal
Labor Relations Authority, Washington, D.C. The Complaint, which was
amended at the hearing, alleges in substance that the American
Federation of Government Employees, Local 2782, AFL-CIO, (hereinafter
called the Union) violated Sections 7116(b)(1) and (8) of the Federal
Service Labor-Management Relations Statute, (hereinafter called the
Statute), by virtue of its actions in failing and refusing to proceed to
arbitration on three grievances filed by the Bureau.
A hearing was held in Washington, D.C. on February 20, 1985. All
parties were afforded the full opportunity to be heard, to examine and
cross-examine witnesses, and to introduce evidence bearing on the issues
involved herein. The General Counsel submitted a post hearing brief on
March 20, 1985, which has been duly considered. /1/
Upon the basis of the entire record, including my observation of the
witnesses and their demeanor, I make the following findings of fact,
conclusions, and recommendations.
Findings of Fact
The Union is and has been the exclusive collective bargaining
representative of two units of the Bureau's employees stationed in the
Washington, D.C. Metropolitan Area. On June 23, 1977, the Union and the
Bureau executed a collective bargaining agreement covering the above
mentioned employees. The agreement was to be effective for a period of
three years and from year to year thereafter absent appropriate notice
by either party to the contrary. /2/ Article 7 of the collective
bargaining agreement sets forth a grievance procedure, the last step of
which is binding arbitration. If the parties can not mutually agree on
the selection of an arbitrator, then, in accordance with the grievance
procedure, a list of seven arbitrators is to be secured from Federal
Mediation and Conciliation Service (FMCS). Upon the receipt of the list
from FMCS, the parties will alternately take turns striking single names
from the list until only one arbitrator's name remains on the list. The
grievance procedure further provides that either party to the collective
bargaining agreement may "as the final step in the grievance procedure"
invoke arbitration following the receipt of the opposing parties
decision pursuant to Section 7.10 of the grievance procedure which is
entitled "Formal Grievance".
On or about October 28, 1983, after approximately six months of
bargaining by Mr. David Warner on behalf of the Bureau and Mr. Edward
Hanlon, then Chief Steward and Chief Negotiator for the Union, Mr.
Hanlon and Mr. Warner initialed off on a new collective bargaining
contract. /3/ The collective bargaining contract was subject to
ratification by the Union membership, and a 30 day period thereafter for
final approval by higher representatives of the Bureau.
Also on October 28, 1983, Mr. Hanlon and Mr. Warner entered into a
Memorandum of Understanding (MOU) wherein the Union agreed to withdraw
"all unfair labor practices which have been filed and are currently
pending, including those being investigated and those already scheduled
for hearings". The Union also agreed to abide by Article 30 of the
"proposed new agreement" pending ratification of the Agreement. Article
30 of the new Agreement provides, among other things, that the Union
will give the Bureau 30 days notice prior to filing any unfair labor
practice charge.
According to the credited testimony of Mr. Warner, the Union ratified
the new October 28, 1983 collective bargaining agreement between the
parties on or about November 9 or 10, 1983. On or about December 10,
1983, approximately 30 days following ratification, the Bureau began to
implement the contract. Thus, the Bureau established an alternate work
schedule, provided Union access to the mails, prepared a survey
concerning employee interest in a day care center, effected changes in
employees' work space, etc.
However, despite the fact that the Bureau had been implementing the
terms of the new collective bargaining agreement, the Union, due to a
controversy surrounding Article 19.2 of the new collective bargaining
agreement which pertained to alternate work schedules for unit employees
in the Bureau's Computer Services Division, refused to formally sign the
new collective bargaining agreement.
By separate Memorandums date March 8, 1984, the Bureau filed three
separate "Formal" grievances against the Union. Two of the grievances
concerned alleged violations of the October 28, 1983 MOU and the third
grievance concerned an alleged "intentionally false, inflammatory
letter" from the Union to unit employees in connection with a pending
representation matter before the Federal Labor Relations Authority. /4/
When the Union failed to respond to the grievances, the Bureau by three
separate letters dated April 14, 1984, consistent with applicable
provisions of both the 1977 and 1983 collective bargaining contracts,
invoked arbitration on each of the grievances. Attached to each of the
three April 14, letters invoking arbitration was a copy of the original
grievance, a proposed settlement and a Form R-43 which was utilized
under the 1977 contract to obtain a list of arbitrators from the FMC.
Neither the March 8, 1984 grievances nor the April 13, 1984, letters
invoking arbitration specifically mentioned which contract the Bureau
was proceeding under.
On April 23, 1984, the Union responded to the Bureau's request for
arbitration taking the position that the November, 1983 collective
bargaining contract was "void, null, and without any legal meaning
whatsoever" due to pending litigation thereon before the Federal Labor
Relations Authority, and that in such circumstances the matters raised
in the grievances were "not grievable or arbitrable at this time". The
Union closed its letter stating as follows:
However, if the Agency wishes to seek enforcement of any
provision of the 1977 agreement currently in legal effect, it may
do so pursuant to the negotiated grievance procedure of that
contract. The Union will, of course process any management
grievance pursuant to the 1977 contract.
By memorandum dated May 4, 1984, the Bureau notified Mr. Hanlon, then
president of the Union, that it was unaware of any authority for the
Union's position that it could make a unilateral determination
concerning the arbitrability and/or grievability of any matter. The
memorandum further advised the Union that the Bureau intended to proceed
"independently to arbitration" and give serious thought to filing an
unfair labor practice predicated upon the Union's refusal to process
grievances. Four days later, on May 8, 1984, the Bureau filed a
completed FMCS Form R-43, entitled "Request For Arbitration Panel". On
May 14, 1984, the FMCS forwarded a panel of arbitrators to both the
Union and the Bureau.
On July 19, 1984, the Bureau and the Union entered into a Memorandum
of Agreement covering the disputed language appearing in Article 19.2 of
the new collective bargaining agreement which pertained to alternative
work schedules for unit employees in the Bureau's Computer Division.
Paragraphs (a), (b) and (c) dealt solely with Article 19.2. Paragraphs
(d), (e) and (f) read as follows:
(d) Immediately sign the current (November 9, 1983) contract
without the article 19.2.
(e) The contract is effective as of the date of signature of
this memorandum. However, any agency actions taken under the
November 9 contract must be considered as if the contract had
taken effect when implemented by the agency. The agency will not
raise the defense of timeliness with respect to grievances
concerning the issues of physical relocation, or the impact of
reorganization under article 23 and 24, respectively, occurring
between December 10, 1983 and July 19, 1984.
(f) The Agency will withdraw the unfair labor practice charge
filed in Case No. 3-CO-40019 now pending.
On July 23, the Bureau sent a memorandum to the Union wherein it
requested the Union's position on the Bureau's March 8, 1984 grievances.
By Memorandum dated August 13, 1984, the Union requested that the
parties take immediate steps to form a five member arbitration panel
pursuant to Sections 9.3 and 10.3 of the new contract. The Union
proposed September 10, 1984, as the date the parties would each submit a
list of 10 arbitrators. /5/
By Memorandum dated August 14, 1984, the Bureau reiterated its
request for the Union's position on the Bureau's three pending
grievances and asked for a response by August 17, 1984.
On August 17, 1984, the Union replied to the Bureau's July 3, 1984
memorandum stating in pertinent part as follows:
Obviously, the confusion over which contract was in effect from
December 10, 1983, to July 19, 1984, made the processing of any
grievance very difficult -- Union, Agency, or employee. That
confusion has now, hopefully, been cleared up.
I have not made a final determination of arbitrability or
grievability on your grievance. However, to provide an answer to
your July, 1984, letter and consider your grievances, I require
reasonable official time. Article 5 did not contemplate the right
of management to file a grievance. No such management right is
required by law.
I am willing to consider a final response to your March, April,
and July correspondence and forward it to you within 10 workdays
if in return you recognize that the Union president or designees
are entitled to reasonable amounts of official time over and above
that contained in Article 5 to process management grievances.
By Memorandum dated August 15, 1984, the Bureau replied to the
Union's August 13, 1984, letter concerning its request that the parties
take immediate steps to form a permanent arbitration panel by September
1, 1984. The Bureau, pointing out that there would not be sufficient
time to review the qualifications of the arbitrators, suggested October
31, 1984, as the date to select a panel of arbitrators. On August 17,
1984, the Union answered the Bureau's August 15, 1984, memorandum. The
Union accused the Bureau of stalling on the matter and suggested
September 17, 1984 as an alternate date for exchanging lists of
arbitrators.
On August 20, 1984, the Union again wrote the Bureau concerning its
pending grievances. Thus, the Union agreed to process the pending
grievances filed by the Bureau through Articles 8, 9 and 10 of the new
1983 contract provided it was allowed additional official time to
perform such activities. Articles 8, 9 and 10 of the new contract are
the grievances and arbitration provisions of the new contract.
On September 7, 1984, the Bureau sent a memorandum to the Union
wherein it set forth its position on the official time provisions of the
contract. By a separate memorandum, also dated September 7, 1984, the
Bureau informed the Union that while it expected to have its list of
arbitrators ready for exchange by the end of October, it was of the
opinion that the establishment of a panel should not prevent the parties
from proceeding immediately to arbitration on the unresolved grievances.
On October 26, 1984, the Bureau notified the Union that it was
prepared to meet for purposes of establishing the arbitration panel
called for in the new contract.
As of the date of the hearing, the Union had not agreed to proceed to
arbitration on the Bureau's three grievances.
Discussion and Conclusions
The General Counsel takes the position that the record supports a
conclusion that the Union failed and/or refused to participate in the
submission of the Bureau's three grievances to arbitration and thereby
violated Sections 7116(b)(1) and (8) of the Statute. In support of this
position the General Counsel points out that none of the three
grievances were predicated solely upon provisions of the 1983 contract
and as such were actionable under the grievances and arbitration
provisions of either the 1979 or 1983 contract. In such circumstances
according to the General Counsel, even if it be concluded as contended
by the Union that the 1983 contract was not in effect at the time of the
initial request for arbitration of the three grievances, then the Union
was under an obligation to process the grievances under the 1979
contract, which by its terms remained in effect until superseded by a
new collective bargaining contract. In this latter context the General
Counsel points out, and I so find, that both the form and procedures
utilized in the processing of such grievances comported in all respects
with the grievance and arbitration provisions of the 1979 collective
bargaining contract.
The Union's sole defense to the instant complaint appears to be that
due to various disagreements concerning the wording of various
provisions of the 1983 contract, including the provisions dealing with
grievances and arbitration, the 1983 contract was not in effect at the
time the Bureau requested arbitration of its grievances. In such
circumstances, since the Bureau was in fact requesting arbitration under
the provisions of the 1983 contract, it, the Union, was under no
obligation to process the grievances. According to the Union it was
always willing to process the grievances under the 1979 collective
bargaining agreement.
The Authority has held that an agency has a right under the Statute
to process grievances through the negotiated grievance and arbitration
procedures. Laborer's International Union of North America,
AFL-CIO-CLC, Local 1267, and Defense Logistics Agency, Defense Depot
Tracy, Tracy, California, 14 FLRA 686. The Authority has further held
that once arbitration is invoked by one party to a collective bargaining
agreement, the other party is obligated to proceed to, and participate
in, the requested arbitration proceedings. A failure of a party to so
participate, is violative of Section 7121 of the Statute and constitutes
an unfair labor practice. Department of Labor, Employment Standards
Administration/Wage and Hour Division, Washington, D.C. and AFGE, Local
12, AFL-CIO, 10 FLRA 316. The obligation to participate in arbitration
also applies to threshold questions concerning grievability and
arbitrability, Department of Labor, Employment Standards, et al, supra.
In view of the foregoing state of the law, it is obvious that
resolution of the instant complaint turns on whether or not the Union
did, as alleged in the complaint, refuse to proceed to arbitration on
the Bureau's three grievances.
A thorough review of the record, particularly the Union's responses
to the Bureau's request for arbitration, makes it clear that the Union
had no intention of cooperating in the requested arbitration
proceedings. Thus, the Union in its first response dated April 23,
1984, took the position that the grievances were not arbitrable since
they concerned issues covered by the November 1983 collective bargaining
agreement, which, according to the Union, was "null and void, and
without any legal meaning whatsoever". In line with such position, the
Union made it clear that it would only honor grievances predicated on
the 1979 collective bargaining agreement and then only under the
grievance and arbitration provisions of such agreement. Thereafter,
when the Bureau subsequently, in accordance with the past practice under
the grievance and arbitration provisions of the 1979 agreement,
requested and received a list of arbitrators from the Federal Mediation
and Conciliation Service, the Union, which had been furnished a copy of
the list of arbitrators supplied by the Federal Mediation and
Conciliation Service, made no effort whatsoever to participate in the
selection of an arbitrator.
Even after July 19, 1984, when all the problems with the 1983
collective bargaining agreement had apparently been worked out by the
parties, the Union while still contesting the grievability and
arbitrability of the Bureau's grievances, refused to pursue the matter
any further unless the Bureau recognized that the Union was entitled to
a "reasonable amount of official time over and above that contained in
Article 5 to process management's grievances".
While it is true that in the interim, the Union did propose that
steps be taken to establish the permanent panel of arbitrators called
for in the 1983 collective bargaining agreement, at no time did it
indicate any willingness to participate in the submission of the
Bureau's grievances to arbitration under either of the two collective
bargaining contracts.
Based upon the foregoing, I find that the Union has failed and/or
refused to participate in any arbitration proceedings concerning the
Bureau's grievances. Rather, the Union has usurped the powers of an
arbitrator and unilaterally determined that the grievances are not
arbitrable.
There is no doubt that as of April 14, 1984, the date the Bureau
invoked arbitration, one of the two collective bargaining contracts was
in effect. If the Union's position that the 1983 contract was "null and
void" is accepted, then the 1979 collective bargaining contract by its
terms remained in effect. In such circumstances the Union was obligated
to proceed to arbitration pursuant to the grievance and arbitration
provisions of such collective bargaining contract. However, despite the
fact that the Bureau followed the existing past practice and
successfully secured a list of arbitrators from the FMCS, the Union,
which was also furnished with a copy of the list of arbitrators, made no
attempt to meet with the Bureau for purposes of perfecting the Bureau's
request for arbitration. In fact, the Union as late as August 17, 1984,
some two months later, admittedly had made no attempt to even
investigate the merits of the grievances. /6/
Accordingly, I find that the record supports the conclusion that the
Union has failed to comply with Section 7121 of the Statute and by such
act has violated Sections 7116(b)(1) and (8) of the Statute.
Having found that Respondent violated Sections 7116(b)(1) and (8) of
the Statute, I recommend that the Authority issue the following:
ORDER
Pursuant to Section 2423.29 of the Authority's Rules and Regulations
and Section 7118 of the Statute, the Authority hereby orders that the
American Federation of Government Employees, Local 2782, AFL-CIO, shall:
1. Cease and desist from:
(a) Unilaterally refusing or failing to proceed to arbitration
regarding three grievances filed by the Department of Commerce,
Bureau of the Census on March 8, 1984, contrary to the
requirements of Section 7121 of the Statute, after receiving
timely notice of the Department of Commerce, Bureau of the Census'
desire to invoke arbitration.
(b) In any like or related manner interfering with,
restraining, or coercing employees in the exercise of their rights
assured by the Statute.
2. Take the following affirmative action in order to effectuate the
purposes and policies of the Statute:
(a) Upon request, proceed to arbitration regarding the three
grievances filed by the Department of Commerce, Bureau of the
Census on March 8, 1984.
(b) Post at its business offices and its normal meeting places,
including all places where notices to members and employees of the
Department of Commerce, Bureau of the Census are customarily
posted, 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 President of the American Federation
of Government Employees, Local 2782, AFL-CIO, and shall be posted
and maintained for 60 consecutive days thereafter, in conspicuous
places, including all places where notices to members and to other
employees are customarily posted. The President of the American
Federation of Government Employees, Local 2782, AFL-CIO, shall
take reasonable steps to insure that such Notices are not altered,
defaced, or covered by any other material.
(c) Notify the Regional Director of Region III, Federal Labor
Relations Authority, in writing, within 30 days from the date of
this Order, as to what steps have been taken to comply herewith.
/s/ BURTON S. STERNBURG
Administrative Law Judge
Dated: April 19, 1985
Washington, D.C.
-------------- FOOTNOTES$ ---------------
(1) In the absence of any objection, the General Counsel's Motion to
Correct Transcript is hereby granted.
(2) The 1977 contract was amended in 1979 to conform to the
provisions of the Civil Service Reform Act.
(3) The new contract contained a grievance procedure similar to the
one contained in the old contract. However, rather than using such
terms as informal grievance, formal grievance, etc., the new contract
set forth the progression of the grievances by steps. Thus, step 5 of
the new grievance procedure was equivalent to the "formal grievance" in
the old contract and like the "formal grievance" was the last chance for
discussion between the parties prior to submission of the matter to
arbitration. With respect to arbitration, the new contract called for
the establishment of a permanent panel of arbitrators which would handle
cases on a rotating basis. The procedure for establishing the panel of
arbitrators was set forth in the contract. Finally, like the old
contract, either party was given access to arbitration.
(4) As authority for the grievance, the Bureau cited Article 1.1
which provides in both the 1977 and 1983 contracts that the basic
purpose of the collective bargaining agreements is " . . . to provide
for constructive and cooperative labor-management relations between the
parties".
(5) On August 15, the Bureau sent a reply memorandum wherein it
suggested October 31, 1984, as the date for exchanging lists of
arbitrators.
(6) To the extent that it is the Union's position that the October
28, 1983, MOU, on which two of the Bureau's grievances are predicated,
is part and parcel of the 1983 collective bargaining agreement and like
the 1983 agreement is null and void, I find that this is a threshold
determination to be made by an arbitrator, and not the Union.
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 MEMBERS AND OTHER EMPLOYEES
THAT:
WE WILL NOT refuse to proceed to arbitration regarding the three
grievances filed by the Department of Commerce, Bureau of the Census, on
March 8, 1984, contrary to the requirements of Section 7121 of the
Federal Service Labor-Management Relations Statute, after receiving
timely notice of the Department of Commerce, Bureau of the Census'
desire to invoke arbitration.
WE WILL NOT in any like or related manner interfere with, restrain,
or coerce unit employees in the exercise of their rights assured by the
Statute.
WE WILL, upon request, proceed to arbitration regarding the three
grievances filed by the Department of Commerce, Bureau of the Census, on
March 8, 1984.
(Labor Organization)
Dated: . . . By: (Signature)
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 any of its provisions, they may communicate directly with the
Regional Director of the Federal Labor Relations Authority, Region III,
whose address is: 1111 -- 18th Street, N.W., Suite 700, Washington,
D.C. 20036 and whose telephone number is: (202) 653-8452.