UNITED STATES OF AMERICA
FEDERAL LABOR RELATIONS AUTHORITY
Office of Administrative Law Judges
WASHINGTON, D.C. 20424-0001
MEMORANDUM
DATE:
September 22, 2005
TO:
The Federal Labor Relations Authority
FROM:
PAUL B. LANG
Administrative Law Judge
SUBJECT:
U.S. DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION
SERVICE, FIELD OPERATIONS,
(CLAXTON, GEORGIA)
Respondent
and
Case No. AT-CA-04-0461
AMERICAN FEDERATION OF GOVERNMENT
EMPLOYEES, LOCAL 3152, AFL-CIO
Charging Party
Pursuant to Section 2423.34(b) of the Rules and Regulations
5 C.F.R. §2423.34(b), I am hereby transferring the above case to
the Authority. Enclosed are copies of my Decision, the service
sheet, and the transmittal form sent to the parties. Also enclosed
are the transcript, exhibits, and any briefs filed by the parties.
Enclosures
UNITED STATES OF AMERICA
FEDERAL LABOR RELATIONS AUTHORITY
Office of Administrative Law Judges
WASHINGTON, D.C.
20424-0001
U.S. DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION
SERVICE, FIELD OPERATIONS,
(CLAXTON, GEORGIA)
Respondent
and
Case No. AT-CA-04-0461
AMERICAN FEDERATION OF GOVERNMENT
EMPLOYEES, LOCAL 3152, AFL-CIO
Charging Party
NOTICE OF TRANSMITTAL OF DECISION
The above-entitled case having been heard before the
undersigned Administrative Law Judge pursuant to the Statute and
the Rules and Regulations of the Authority, the under-signed herein
serves his Decision, a copy of which is attached hereto, on all
parties to the proceeding on this date and this case is hereby
transferred to the Federal Labor Relations Authority pursuant to
5 C.F.R. §2423.34(b).
PLEASE BE ADVISED that the filing of exceptions to the attached
Decision is governed by 5 C.F.R. §§2423.40-2423.41, 2429.12,
2429.21-2429.22, 2429.24-2429.25, and 2429.27.
Any such exceptions must be filed on or before
OCTOBER 24, 2005, and addressed to:
Office of Case Control
Federal Labor Relations Authority
1400 K Street, NW, 2nd Floor
Washington, DC 20005
_______________________________
PAUL B. LANG
Administrative Law Judge
Dated:
September 22, 2005
Washington, DC
OALJ 05-48
UNITED STATES OF AMERICA
FEDERAL LABOR RELATIONS AUTHORITY
Office of Administrative Law Judges
WASHINGTON, D.C.
20424-0001
U.S. DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION
SERVICE, FIELD OPERATIONS,
(CLAXTON, GEORGIA)
Respondent
and
Case No. AT-CA-04-0461
AMERICAN FEDERATION OF GOVERNMENT
EMPLOYEES, LOCAL 3152, AFL-CIO
Charging Party
Brad A. Stuhler
For the General Counsel
Sandra J. Fortson
For the Respondent
Stan Painter
For the Charging Party
Before:
PAUL B. LANG
Administrative Law Judge
DECISION
Statement of the Case
On June 28, 2004, the American Federation of Government
Employees, Local 3152, AFL-CIO (Union) filed an unfair labor
practice charge against the U.S. Department of Agriculture, Food
Safety and Inspection Service, Field Operations, Washington, DC
(Claxton, Georgia) (Respondent). On
November 19, 2004, the Regional Director of the Atlanta Region
of the Federal Labor Relations Authority (Authority) issued a
Complaint and Notice of Hearing in which it was alleged that the
Respondent committed an unfair labor practice in violation of
§7116(a)(1) and (5) of the Federal Service Labor-Management
Relations Statute (Statute) by implementing a change in the number
of employees who are allowed to be on prescheduled annual leave
for each shift for certain of its employees who are members of
the collective bargaining unit represented by the National Joint
−3−
Council of Food Inspection Locals, American Federation of
Government Employees, AFL-CIO (AFGE). In a timely Answer to the
Complaint the Respondent denied that it had committed the alleged
violation of the Statute.
A hearing was held in Savannah, Georgia on April 20, 2005.
The parties were present with counsel and were afforded the
opportunity to present evidence and to cross-examine witnesses.1/
This Decision is based upon consideration of the evidence,
including the demeanor of witnesses, and of the post-hearing briefs
submitted by the parties.
Positions of the Parties
The General Counsel maintains that in February of 2004 the
Respondent unilaterally changed a past practice with regard to
prescheduled annual leave1/ for bargaining unit food inspectors
who were assigned to the HIMP plant1/ in Claxton, Georgia.1/ The
Claxton HIMP plant had been in existence since January of 2000
and, according to the General Counsel, had consistently followed
a procedure whereby two employees in each of the two shifts were
allowed to preschedule leave at the same time. The General Counsel
further maintains that the procedure for prescheduled leave was
a binding past practice inasmuch as it had been administered with
the knowledge of two of the Respondent's senior management
representatives.
The General Counsel also argues that the change in the
procedure for prescheduled leave had a greater than de minimis
effect on bargaining unit employees because certain employees had
been denied leave because of the change. It was reasonably
foreseeable that such denial of leave would have a disruptive
1/ The Respondent did not cross-examine either of the General
Counsel's witnesses.
2/ The term "leave" will henceforth be used to refer to annual
leave.
3/ HIMP (HACCP Inspection Model Project) refers to a food
processing plant at which the Respondent was operating a pilot
system whereby the plant itself was allowed to develop its own
inspection system which was monitored by the Respondent's
employees. HACCP stands for Hazard Analysis Critical Control
Inspection.
4/ The General Counsel acknowledges that the Respondent's
prescheduled leave policy involves the exercise of a management
right within the meaning of §7106(a)(2)(A) of the Statute.
−4−
effect on the personal lives of these employees because of the
necessity of rescheduling family vacations and other personal
events.
Finally, the General Counsel argues that the Respondent has
failed to carry its burden of establishing the affirmative defense
that the issue of prescheduled leave was covered by the collective
bargaining agreement (CBA) between the parties.
The General Counsel proposes a status quo ante (SQA) remedy
whereby the Respondent would be ordered to reinstate the procedure
for allowing two employees per shift to preschedule leave for the
same time period and to maintain that procedure until the
completion of impact and implementation bargaining with the Union.
The Respondent maintains that it was not required to provide
the Union with notice and an opportunity to bargain over
prescheduled leave because the issue of leave is covered by the
national CBA. The prior practice at the Claxton plant was not
a binding past practice because it was contrary to the CBA.
According to the Respondent, the alleged change in the number of
employees allowed to be on prescheduled leave was no more than
an action to bring the procedure at the Claxton plant in line with
the policy set forth in the CBA.
The Respondent further maintains that the General Counsel
has failed to establish the alleged unfair labor practice by a
preponderance of the evidence inasmuch as the General Counsel did
not rebut the Respondent's affirmative defense that prescheduled
leave was covered by the CBA.
Findings of Fact
The Respondent is an agency within the meaning of
§7103(a)(3) of the Statute. The National Joint Council of Food
Inspection Locals, American Federation of Government Employees,
AFL-CIO (AFGE) is a labor organization as defined in §7104(a)(4)
of the Statute and is the exclusive representative of a unit which
includes the Respondent's employees and which is appropriate for
collective bargaining. The Union is an agent of AFGE for the
purpose of representing bargaining unit members who are employed
by the Respondent.
The Change in Procedure for Prescheduled Leave
On or about February 15, 2004,1/ Douglas M. Fulgham, the
president of the Union, was informed by John Anderson, who was
5/ All subsequently cited dates are in 2004 unless otherwise
indicated.
−5−
then the Union representative at Claxton, that the Respondent had
changed the past procedure of allowing four employees, or two per
shift, to preschedule leave (Tr. 11, 12). Fulgham thereupon
contacted Dr. Aguirre, the immediate supervisor of the bargaining
unit employees at Claxton. Dr. Aguirre informed him that
Dr. William Moore, the circuit supervisor, had directed her to
make the change. Fulgham then contacted Dr. Moore who informed
him that he had been instructed to make the change while at a meeting
in Atlanta, Georgia; according to Fulgham, Dr. Moore did not state
the source of the instructions (Tr. 13). On or about February 25
Fulgham spoke with Dr. Larry Smith, the District Manager, and asked
if he had initiated the change in the prescheduling procedure.
According to Fulgham, Dr. Smith stated that he was unaware of
any change. Fulgham told Dr. Smith that the leave schedules for
2003 and 2004 (GC Ex. 2) supported the Union's position that there
had been a change. He faxed the documents to Dr. Smith at his
request (Tr. 14). Dr. Smith told Fulgham that he would get back
to him after he had reviewed the situation (Tr. 15).
On or about March 11, after having verified that the
Respondent had not rescinded the recent change, Fulgham again
contacted Dr. Smith. Dr. Smith informed Fulgham that, based upon
discussions with management personnel in Washington and with labor
relations personnel, he would not revoke the decision to limit
prescheduled leave to two employees at a time, which is to say
one per shift (Tr. 15, 16).
Dr. Smith testified that, as of the time of the hearing, he
had been employed by the Respondent for twenty-six years. He
became the Deputy District Manager in 2000 and the District Manager
in 2003. Dr. Smith further testified that he changed the number
of employees in Claxton who could simultaneously take prescheduled
leave so as to bring the practice in Claxton in line with what
he understood to be agency policy. He took this action after
discovering that the agency policy was not being followed (Tr. 28,
29). According to Dr. Smith, he first learned that the agency
policy was not being followed in Claxton when the Deputy District
Manager, Dr. Nassir, informed him that he (Dr. Nassir) had learned
about the situation from a super-visor who was assigned to Claxton.
Dr. Smith also testified that he was told by his subordinates
at the district level that they had no prior knowledge that the
agency policy was not being followed in Claxton (Tr. 34, 35).
The Leave Scheduling Procedure Prior to the Change
It is undisputed that, until February of 2004, the number
of employees allowed to preschedule simultaneous leave was not
limited to one per shift.1/ According to Fulgham, at or around
6/
The following language appears at the end of the leave schedule
−6−
the time when the Claxton facility became a HIMP plant he met with
Dr. Beckman, who was the Inspector in Charge at Claxton, John
Anderson, the Union representative at the plant, and Dr. Tom
Watson, the Circuit Manager. At that time they agreed that two
employees could be on leave at the same time on each shift. The
functions of employees on leave would be performed by the relief
inspector and by the team leader. Dr. Beckman kept district
management personnel informed of the agreement by telephone; this
arrangement prevailed until 2004 (Tr. 18-20).
The Respondent's Policy
for 2003:
Please note: A maximum of two people can have scheduled
A/L per shift. All requests have been listed but, where
there are more than two, you work it out and notify
your supervisor who will be off. (GC Ex. 2, p. 6).
That language does not appear on the leave schedule for 2004
which immediately follows.
−7−
It is significant to note that, although the Respondent
purported to rely on a pre-existing policy or contractual provision
regarding the prescheduling of leave, it did not introduce either
the collective bargaining agreement (CBA) or a written policy
(assuming that there was one) into evidence.1/ However, Dennis
E. Greening, the District Manager for the Des Moines, Iowa District
and the Respondent's chief negotiator for the most recent CBA,
testified that the parties agreed to:
. . . allow the practices that were in place [for]
scheduling annual leave to remain unless there were a
problem identified, and then we would deal through those
procedures through Article VI of the Agreement, which
talks about negotiations (Tr. 51).
There is no evidence that further negotiations occurred with regard
to the Claxton HIMP plant.
Greening also testified that:
Section 4, item 2, or A-2, says, The district manager
designee will determine how many employees can be off
on annual leave simultaneously within a lead roster.
Available relief will be considered in determining the
number to be off simultaneously (Tr. 46).1/
Greening stated that he did not know whether the manager of an
individual HIMP plant could determine how many employees could
be on leave at the same time (Tr. 47).
Upon redirect examination Greening stated that:
. . . different locations had different ways of
scheduling leave that the individuals liked doing a
certain way. We still - we as management, or the Agency,
maintained control of leave approval, and the numbers
of people that could be off within that system. The
systems are what we said we will maintain, not the
7/ In its case in chief the Respondent attempted to introduce
its "last best offer" on annual leave into evidence. I sustained
the General Counsel's objection because the document had not been
included in the Respondent's prehearing disclosure and because
there was an insufficient basis for an exception to the
requirements of §2423.23 of the Rules and Regulations of the
Authority (Tr. 42-44).
8/ It is unclear whether this language is alleged to be a direct
quote from the CBA or merely a summary of its provisions.
−8−
numbers that could be off because that's determined by
the work load and that varies from year to year (Tr. 57).
The Effect of the Change in Leave Scheduling Procedure1/
John Anderson testified that he has been denied leave in 2004
because of the change in the scheduling procedure. According to
Anderson, he was denied leave during the week of May 16-22 because
Tom wanted time off on May 20 and 21 and Linda wanted time off
on May 21; he also was denied leave on July 20 and on a number
of other occasions. This caused a conflict with a planned family
vacation (Tr. 24-26).
Anderson's testimony is corroborated by the leave schedules
that Fulgham submitted to Dr. Smith (GC Ex. 2). At the end of
each of the schedules is an explanation of various symbols; the
meaning of the asterisk is "Exceeds number of relief personnel.
Don't anticipate leave being granted." Asterisks appear after
"John" for both May 20 and 21. An asterisk also appears after
"Tom" for May 21, apparently because Linda also wanted that date.
There is also an asterisk after Anderson's name for July 20,
apparently because Linda wanted to take leave for the entire week.
Similar notations appear at various other dates after the names
of other employees.1/
9/ Although the Respondent has not pursued the de minimis defense
which was included in its prehearing disclosure, the effect of
the change in procedure is relevant to the availability of the
SQA remedy requested by the General Counsel.
10/ The asterisk was given the same meaning in the schedule for
2003. However, the symbol does not appear in the body of the
schedule.
−9−
There is no evidence as to whether Anderson or any other
employee was eventually allowed to take leave that was initially
denied.1/ However, it is more likely than not that a significant
number of those employees were not able to take leave on the
preferred dates. Furthermore, it is likely that many of the
employees who were initially denied leave had to change personal
plans because of uncertainty as to whether their leave requests
would be granted.
Upon consideration of the evidence, I find as a fact that,
from January of 2000 to February of 2004, the Claxton HIMP plant
followed a procedure whereby two employees per shift were allowed
to preschedule leave on the same dates. I further find that the
leave procedure was changed by the Respondent in February of 2004
and that, after the change, only one employee per shift was allowed
to preschedule leave on a given day. The Respondent made that
change without affording the Union advance notice or an opportunity
to bargain.
With regard to the Respondent's policy regarding the
prescheduling of leave at HIMP plants, I find that the CBA did
not set a limit on the number of employees who could preschedule
leave on the same date, but, on the contrary, allowed for the
continuation of past procedures in the absence of negotiated
changes. This is not to say that local managers were required
to allow for prescheduled leave regardless of their relief
capability, but only that a specific limit was not set for all
HIMP plants. Therefore, the procedure which had been followed
at Claxton prior to February of 2004 was not inconsistent with
the CBA.
Discussion and Analysis
The Procedure for Prescheduling Leave is a Condition of Employment
In determining whether a matter involves a condition of
employment the Authority will consider (a) whether it pertains
to bargaining unit employees, and (b) whether there is a direct
connection between the matter and the work situation of bargaining
unit employees, Antilles Consolidated Education Association and
Antilles Consolidated School System, 22 FLRA 235, 237 (1986).
The procedure for prescheduled leave meets both of those criteria.
11/ Dr. Smith testified that more than one person on each shift
would be permitted to take prescheduled leave when the relief
capability allowed for a relaxation of the general rule; this
would occur "fairly often" (Tr. 31). However, there is no
evidence as to how much advance notice was given to employees
whose leave requests were eventually granted.
− 10 −
It is undisputed that the procedure affects bargaining unit
employees at the Claxton HIMP plant and there can be no valid doubt
that the issue of leave affects the work situation of those
employees. Such a conclusion has been endorsed by the Authority
in 56th Combat Support Group, MacDill Air Force Base, Florida,
43 FLRA 1565 (1992). Therefore, I conclude that the procedure
for prescheduling leave at the Claxton HIMP plant is a condition
of employment.
The Authority has also held that, regardless of whether agency
action is an exercise of a management right, the agency is not
absolved of the duty to notify the appropriate labor organization
prior to implementing a change in working conditions and to bargain
to the extent required by law, United States Department of the
Air Force, 913th Air Wing, Willow Grove Air Reserve Station, Willow
Grove, Pennsylvania, 57 FLRA 852, 855 (2002). Accordingly, the
Respondent was not entitled to unilaterally change the procedure
for prescheduling leave.
The Procedure Which Existed Prior to February of 2004 Was a
Binding Past Practice
The Authority has long held that conditions of employment
may arise out of a past practice, Department of the Treasury,
Internal Revenue Service, (Washington, DC), et al., 27 FLRA 322,
324 (1987). In order to find the existence of a past practice,
there must be a showing that the practice has been consistently
exercised over a significant period of time and followed by both
parties, or followed by one party and not challenged by the other,
U.S. Patent and Trademark Office, 57 FLRA 185, 191 (2001). The
General Counsel has made such a showing.
It is undisputed that the Respondent allowed simultaneous
prescheduled leave for two employees per shift from the time of
the establishment of the Claxton HIMP plant in January of 2000
until February of 2004 when the procedure was terminated by order
of Dr. Smith. Thus, the Respondent followed the procedure in
establishing annual leave schedules for the years 2000, 2001, 2002
and 2003; furthermore, the Respondent allowed employees to take
their prescheduled leave throughout each of those years. Thus,
the procedure was followed consistently over a significant period
of time.
The Respondent did not challenge Fulgham's testimony that
supervisory personnel at Claxton kept the district office informed
of the progress of negotiations over the leave policy. Fulgham's
testimony was not effectively rebutted by Dr. Smith's assertion
that neither he nor his subordinates at the district level were
aware of the procedure at Claxton. Furthermore, the provision
of the CBA to allow local procedures to remain in effect put the
Respondent on constructive notice that facilities such as the
− 11 −
Claxton HIMP plant might not have been following a uniform
procedure with regard to the prescheduling of leave. Therefore,
the procedure at Claxton was followed by both parties or, at the
very least, followed by the Union and not challenged by the
Respondent in spite of the Respondent's actual or constructive
knowledge of its existence.
The Remedy
Since, as acknowledged by the General Counsel, the change
in conditions of employment involved the exercise of a management
right, a SQA remedy may only be applied under the criteria set
forth in Federal Correctional Institution, 8 FLRA 604, 606 (1982)
(FCI). Those criteria will be set forth below and applied to the
circumstances of this case.
Whether, and when, notice was given to the Union by the
Respondent. It is undisputed that the Respondent provided the
Union with no advance notice before changing the procedure for
granting prescheduled leave.
Whether, and when, the Union requested bargaining over the
change in procedure. This criterion is not applicable since the
Union did not receive advance notice of the change. Nevertheless,
Fulgham promptly and persistently inquired as to the Respondent's
intentions and demonstrated the existence of a past practice to
Dr. Smith.
The willfulness of the Respondent's actions in failing to
discharge its bargaining obligations under the Statute. Although
the Respondent might have believed that it was under no duty to
bargain because of a contrary policy or contractual provision,
the evidence indicates that the belief was unfounded because no
such policy or provision existed. In any event, the Respondent's
belief that it had no duty to bargain does not detract from the
willful nature of its failure to do so, U.S. Department of Energy,
Western Area Power Administration, Golden, Colorado, 56 FLRA 9,
13 (2000).
The nature and extent of the impact experienced by adversely
affected employees. Both Anderson's testimony and a comparison
of the leave schedules for 2003 and 2004 demonstrate that the impact
of the denial of leave in 2004 was significant and that bargaining
unit employees had not experienced such denial prior to 2004.
Whether, and to what degree, a status quo ante remedy would
disrupt or impair the efficiency and effectiveness of the
Respondent's operations. The Respondent has not addressed the
appropriateness of a SQA remedy. Even if this were not so, there
is no evidence that the maintenance of the past practice caused
− 12 −
any disruption or loss of efficiency prior to February of 2004
or that there was any change in conditions after that time such
as would support a conclusion that future disruptions are likely
to occur.
In summary, the General Counsel has satisfied four of the
five criteria set forth in FCI thereby justifying the imposition
of a SQA remedy.
In view of the foregoing factors, I have concluded that the
Respondent committed an unfair labor practice in violation of
§7116(a)(1) and (5) of the Statute by changing the procedure for
the allowance of prescheduled leave at the Claxton HIMP plant
without affording the Union advance notice and the opportunity
to negotiate. Accordingly, I recommend that the Authority adopt
the following Order:
ORDER
Pursuant to §2423.41(c) of the Rules and Regulations of the
Authority and §7118 of the Federal Service Labor-Management
Relations Statute (Statute), it is hereby ordered that the U.S.
Department of Agriculture, Food Safety and Inspection Service,
Field Operations, Washington, D.C. (Claxton, Georgia), shall:
1.
Cease and desist from:
(a) Implementing changes in procedures for the
prescheduling of annual leave by bargaining unit employees at the
Claxton HIMP plant without providing prior notice to the American
Federation of Government Employees, Local 3152, AFL-CIO (Union)
and affording the Union the opportunity to bargain over such
changes to the extent required by the Statute.
(b) In any like or related manner, interfering with,
restraining or coercing its 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) Restore the status quo ante at the Claxton HIMP plant
by permitting two employees per shift to preschedule annual leave
on the same day.
(b) Post at the Claxton HIMP plant copies of the attached
Notice on forms to be furnished by the Authority. Upon receipt
of such forms they shall be signed by the cognizant District Manager
and shall be posted and maintained for 60 consecutive days
thereafter in conspicuous places, including all bulletin boards
− 13 −
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 §2423.41(e) of the Rules and Regulations
of the Authority, notify the Regional Director of the Atlanta
Region of the Authority, in writing and within 30 days of the date
of this Order, as to what steps have been taken to comply.
Issued, Washington, DC, September 22, 2005
PAUL B. LANG
Administrative Law Judge
NOTICE TO ALL EMPLOYEES
POSTED BY ORDER OF
THE FEDERAL LABOR RELATIONS AUTHORITY
The Federal Labor Relations Authority has found that the U.S.
Department of Agriculture, Food Safety and Inspection Service,
Field Operations, Washington, DC (Claxton, Georgia) violated the
Federal Service Labor-Management Relations Statute and has ordered
us to post and abide by this Notice.
WE HEREBY NOTIFY OUR EMPLOYEES THAT:
WE WILL NOT implement changes in procedures for the prescheduling
of annual leave by bargaining unit employees at the Claxton HIMP
plant without providing prior notice to the American Federation
of Government Employees, Local 3152, AFL-CIO (Union) and affording
the Union the opportunity to bargain over such changes to the extent
required by the Statute.
WE WILL NOT, in any like or related manner, interfere with, restrain
or coerce our employees in the exercise of their rights assured
by the Federal Service Labor-Management Relations Statute.
WE WILL restore the status quo ante at the Claxton HIMP plant by
permitting two employees per shift to preschedule annual leave
on the same day.
______________________________
(Agency)
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, Atlanta Regional Office, whose address is:
Federal Labor Relations Authority, Suite 701, Marquis Two Tower,
285 Peachtree Center Avenue, Atlanta, GA 30303-1270, and whose
telephone number is: 404-331-5300.
CERTIFICATE OF SERVICE
I hereby certify that copies of this DECISION, issued
by PAUL B. LANG, Administrative Law Judge, in Case No.
AT-CA-04-0461, were sent to the following parties:
_______________________________
CERTIFIED MAIL AND RETURN RECEIPT
CERTIFIED NOS:
Brad A. Stuhler
Federal Labor Relations Authority
Suite 701, Marquis Two Tower
285 Peachtree Center Avenue
Atlanta, GA 30303-1270
7000 1670 0000 1175 0948
Sandra J. Fortson
Agency Representative
U.S. Department of Agriculture
Hearings & Appeals, LERD, FSIS
5601 Sunnyside Avenue
Beltsville, MD 20705
7000 1670 0000 1175 0955
Stan Painter
Vice President
AFGE Southern Council
4673 County Road 24
Crossville, AL 35962
7000 1670 0000 1175 0962
REGULAR MAIL:
President
AFGE
80 F Street, NW
Washington, DC 20001
Dated:
September 22, 2005
Washington, DC