General Motors Corp., Inland Division

National Labor Relations Board - Board Decisions

Aug 17, 1981

257 N.L.R.B. 820 (N.L.R.B. 1981)

DECISIONS OF NATIONAL LABOR RELATIONS BOARD
General Motors Corporation, Inland Division and
Local Union No. 87, United Rubber, Cork, Li-
noleum and Plastic Workers of America, AFL-
CIO-CLC. Case 9-CA-15273
August 17, 1981
DECISION AND ORDER
BY CHAIRMAN FANNING AND MEMBERS
JENKINS AND ZIMMERMAN
On May 1, 1981, Administrative Law Judge Mi-
chael O. Miller issued the attached Decision in this
proceeding. Thereafter, the General Counsel filed
exceptions and a supporting brief and Respondent
filed cross-exceptions and a brief in opposition to
the General Counsel's exceptions and in support of
Respondent's cross-exceptions.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the Na-
tional Labor Relations Board has delegated its au-
thority in this proceeding to a three-member panel.
The Board has considered the record and the at-
tached Decision in light of the exceptions and
briefs and has decided to affirm the rulings, find-
ings,' and conclusions 2 of the Administrative Law
Judge and to adopt his recommended Order.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor Re-
lations Board adopts as its Order the recommended
Order of the Administrative Law Judge and
hereby orders that the complaint be, and it hereby
is, dismissed in its entirety.
t The Administrative Law Judge inadvertently stated that in George
Webel d/b/a Webel F'eed Mills & Pike Transit Company, 217 NLRB 815
(1975), the Board found no significant detriment to unit employees from
the subcontracting of certain work. We note that the Board at fn. I did
not pass on that issue since no exceptions were filed with regard thereto.
2 In adopting the Administrative Law Judge's Decision, Member Jen-
kins adheres to the view set forth in his separate concurring opinions in
Westinghouse Electric Corporation (Mansfield Plant), 150 NLRB 1574
(1965), and General Electric Company, 240 NLRB 703 (1979).
DECISION
STATEMENT OF THE CASE
MICHAEl O. MILLER, Administrative Law Judge: This
case was heard in Dayton, Ohio, on February 2 and 3,
1981, upon a charge filed by Local Union No. 87, United
Rubber, Cork, Linoleum and Plastic Workers of Amer-
ica, AFL-CIO-CLC, herein called the Union, on May 1,
1980, and a complaint issued on behalf of the National
Labor Relations Board, herein called the Board, by the
Regional Director for Region 9 on June 19, 1980. The
complaint alleges that General Motors Corporation,
Inland Division, herein called Respondent or Inland, vio-
lated Section 8(a)(l) and (5) of the National Labor Rela-
257 NLRB No. 112
tions Act, as amended, herein called the Act, by unilater-
ally subcontracting unit work without notice to, or bar-
gaining with, the Union. Inland's timely filed answer and
amended answer deny the commission of any unfair
labor practices.
All parties were afforded full opportunity to appear, to
examine and cross-examine witnesses, and to argue
orally. The General Counsel and Respondent have filed
briefs which have been carefully considered.
Based upon the entire record, including my observa-
tion of the witnesses and their demeanor, I make the fol-
lowing:
FINDINGS OF FACT
1. RESPONDENT'S BUSINESS AND THE UNION'S L.ABOR
ORGANIZATION STATUS; PRELIMINARY CONCLUSIONS
OF LAW
Respondent is a Delaware corporation engaged in the
manufacture of automotive parts at its facilities in
Dayton and Vandalia, Ohio. Jurisdiction is not in dis-
pute. The complaint alleges, Respondent admits, and I
find and conclude that Respondent is an employer en-
gaged in commerce within the meaning of Section 2(2),
(6), and (7) of the Act.
Respondent's production and maintenance employees'
are represented for collective-bargaining purposes by the
Union. The complaint alleges, Respondent admits, and I
find and conclude that the Union is a labor organization
within the meaning of Section 2(5) of the Act.
II. THE AI..EGED UNFAIR LABOR PRACTICE
A. The Subcontracting
Inland manufactures parts for General Motors' auto-
mobiles. As of September 1979, it had approximately
6,900 employees on the job of whom perhaps 300 were
engaged in the manufacture of various kinds of ball
joints. Of those, two or three spent a portion of their
time manufacturing ball joints for the Corvette auto-
mobile and for certain replacement or service installa-
tions, the ball joint manufacture involved herein. By
May 1980, due to layoffs, Respondent's work force was
reduced to about 5,000, of whom approximately 200 pro-
duced ball joints.
About September 1979, Respondent began to examine
its plant facilities to find prime manufacturing floor
space, i.e., space with a solid base and a high bay or ceil-
ing, in which to place new machinery to be used in the
manufacture of parts for GM's line of "J" cars about to
be introduced. It determined that the space it desired to
use was the space then occupied by the machinery for
the manufacture of the Corvette and service ball joints.
According to Respondent's superintendent of production
engineering, that space was not being used efficiently
and its acquisition for the J car work required the re-
moval of only a few machines. The decision to move out
Respondent admits that its production and maintenance employees.
more extensively described in the complaint and in the parties' collective-
bargaining agreement, constitute a unit appropriate for purposes (of col-
lective bargaining within the meaning of Sec. 9(b) of the Act.
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GENERAL MOTORS CORP., INLAND DIVISION
the Corvette and service ball joint operation was made in
September 1979.
On March 18, 1980, the machines involved in the man-
ufacture of the subject ball joints were removed from the
Inland plant and delivered to GWF Industries, Inc., on
consignment, expressly for the purpose of manufacturing
these ball joints. In mid-April 1980, GWF submitted
samples to Respondent's purchasing department and, on
April 24, 1980, executed a contract to fulfill all of Re-
spondent's needs for these particular ball joints for an ex-
tended period. GWF bought the raw forgings from
Inland, trucked them to its own plant about 25 miles
away from Respondent's plant, and machined them on
the equipment consigned to it by Inland. It began to sell
and ship the completed ball joints to Inland on May 2,
1980. Since then, it has produced and shipped approxi-
mately 10,000 to 11,000 pieces per month.
Respondent's total daily production of ball joints as-
semblies is approximately 130,000. The production sub-
contracted to GWF accounted for less than 600 per day.
GWF is a corporation formed in October 1979 by
George W. Francis who retired as Inland's plant man-
ager in November 1977. Among Francis' initial employ-
ees was Frank Brigitzer, a retired employee who, prior
to his retirement, had worked on the subject ball joints.
Respondent did not notify the Union of, or bargain
with the Union about, the subcontracting of this work.
The Union learned about it from employees after the ma-
chinery had been removed and first questioned it in a
meeting with Respondent's director of labor relations,
Charles Wallis, on March 28, 1980. That was also the
first that Wallis had heard of it.
In Respondent's plant the subject ball joint work had
been performed on an as-needed basis; no employees
worked consistently at that task. Charles Henry, foreman
of the department where the work had been performed,
estimated that it required the time of two or three em-
ployees for approximately I week out of each month.
Respondent's witnesses estimated, based on timestudies,
that an entire year's production of these parts required
approximately 40 to 50 percent of an employee work
year (2,080 hours). 2 From the time that GWF acquired
the contract for these ball joints until about the end of
January 1981, its employees worked approximately 1,072
hours.3 Initially, GWF returned its tools to Inland for
sharpening. Thereafter, it sent the tools out to a contrac-
tor for sharpening and paid for approximately 178 hours
of such work. It also paid for 8 to 10 hours of machine
maintenance.
None of the Inland employees who had previously
worked on the subject ball joints was laid off as a direct
result of the subcontract. One, Brigitzer, had retired
prior to the subcontract. He was not replaced. Another,
Mayabb, was transferred from the first to the second
shift where, because of his familiarity with certain clutch
and spring work which was being increased, he was
Additionally, there would be time spent by those in indirect labor.
including tool grinders. According to Henry, a full day's production of
the subject ball joints might require a couple of hours of a tool grinder's
time to sharpen the tools used.
I This figure includes some time spent on nonproductive duties and
does not include Francis' time.
needed. Henry testified that Mayabb's shift change
would likely have occurred even without the loss of the
subject ball joint work. A third employee who had
sometimes worked on these ball joints, Hisel, was as-
signed to a clutch job on April 21, 1980, and his rate of
pay was reduced from $9.60 per hour to $9.46 (until Sep-
tember 15, 1980). Additionally, one of the department's
group leaders, Leistner, went on sick leave on April 10,
1980, and subsequently retired; there was no need to re-
place him.
In April 1980, there was a reduction in force among
Respondent's toolroom and machine repair employees.
At least one employee was laid off.
It is obvious that, had Respondent retained the subject
ball joint work, there would have been some greater
amount of work available for unit employees in both
direct and indirect labor positions. I cannot conclude
from this record, however, that such retention would
have obviated the need for any layoffs, required that any
laid-off employees be recalled, prevented any transfers,
or maintained the need for any group leaders.
By the time of the hearing herein, placement of the
new machinery related to the J car had created 16 jobs.
Respondent estimated that, when fully installed, the new
machinery would provide about 21 positions.
B. Relevant Contractual Provisions
Respondent and the Union have had a succession of
collective-bargaining agreements. The current agreement
is effective from November 5, 1979, through September
14, 1982. It provides, inter alia, the following:
(6) The right to hire; promote . . . and to maintain
discipline and efficiency of employees, is expressly
recognized as the sole responsibility of the Compa-
ny except that Union members shall not be discrimi-
nated against as such. In addition, the products to
be manufactured, the location of plants, the sched-
ules of production, the methods, processes and
means of manufacturing are solely exclusively the
responsibility of the Company.
The contract contains no other provisions directly re-
lated to the subcontracting of production work. By com-
parison, however, in regard to the skilled trades, the con-
tract provides the following:
(62y) (1) Employes of an outside contractor will not
be utilized in a plant covered by this Agreement to
replace seniority employes on production assembly
or manufacturing work, or fabrication of tools, dies,
jigs, and fixtures, normally and historically per-
formed by them when performance of such work
involves the use of Company-owned machines,
tools, or equipment maintained by Company em-
ployees.
(4) In all cases, except where time and circum-
stances prevent it, Management will hold advance
discussion with and provide advance, written notice
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DECISIONS OF NATIONAL LABOR RELATIONS BOARD
to a specified member of the Local Union's Skilled
Trades and Apprentice Committee or the District
Committeeman representing Maintenance Depart-
ment employes who work in the plant located near-
est the Company's Main Purchasing Office, and the
Chairman of the Shop Committee, prior to letting a
contract for the performance of maintenance and
construction work.
(5) In no event shall any seniority employee who
customarily performs the work in question be laid
off as a direct and immediate result of work being
performed by an outside contractor on the plant
premises.
The contract also includes, as appendixes, letters setting
forth the Company's position that it has the right to
decide whether or not to perform maintenance and
skilled trades work itself or through outside contractors,
with assurances that Respondent "expects to continue its
general operating policy of placing primary reliance on
its own skilled trades employes to perform maintenance
to the extent consistent with sound business practice, as
in the past."
According to Wallis, the subcontracting of production
work has been the subject of collective-bargaining nego-
tiations in each round of contract talks since at least 1967
when he became Respondent's chief negotiator. In those
negotiations, he said, Inland has consistently taken the
position that the subcontracting of production work was
a management right protected under paragraph 6 of the
agreement, quoted above, encompassed within the lan-
guage providing that "the products to be manufactured
. . .are solely exclusively the responsibility of the Com-
pany."
In 1979, during negotiations for the current agreement,
the Union made the following demands relative to sub-
contracting:
96. Establish plant closure clause. Employes laid off
due to full or partial plant closure, or sending
work historically done by Inland employes out to
be manufactured by other concerns will be paid a
lump severance award of $1,000.00 per year cred-
ited service, plus full retirement benefits for life
with no restriction on additional earnings after re-
tirement.
106. Stop all use of outside contractors and update
machinery and equipment to permit our people to
do work. Stop contracting out production work.
Note: Want all jobs protected against outside con-
tractors. Company failure to stop using contrac-
tors is strikeable issue!
* * *
114. Return all jobs presently in outside job shops
back to the plant ...
155. All work previously done by Department 54
employes that is now being done by outside con-
cerns must be returned to Department 54 Tractor
Trailer Operators (Truck driver's classification).
Despite the language contained in the quoted demands,
particularly items 106 and 114, Union President William
H. Hutchins maintained that all these demands related
only to subcontracting of skilled trades and trucking
work or to rumors of the establishment of a new plant
by Respondent in Mexico.
Respondent's answer to all of the above-quoted de-
mands was the same; it recommended that the Union
withdraw them from the table. However, according to
the memorandum of understanding issued in regard to
the most current contract, it did agree to use its Depart-
ment 54 employees for the transportation of "in process
material" being moved from, or returned to, the Inland
Division in the Dayton area as well as for the transporta-
tion of Inland production material between Inland in-
plant locations. It further agreed that noncommon carrier
air freight would normally be transported by Depart-
ment 54 employees if drivers and equipment were availa-
ble and there were no emergencies precluding such utili-
zation. To the extent that the Union's demands sought
restrictions on the subcontracting of other than skilled
trades or trucking work, no agreements were reached.
C. Past Practices
According to Wallis, Inland has been subcontracting
production work since at least 1965. For at least the last
5 years, the Union has been filing grievances over such
subcontracting. Thus, for example, in April 1975 two
grievances were filed protesting the subcontracting of
floor care work to an outside janitorial firm. Respondent
denied them on the basis of its past practices and the ab-
sence of any adverse impact on unit employees. In Feb-
ruary 1977, the Union protested the subcontracting of
cleaning work in Department 310. Inland responded,
denying the grievance on the basis of the unavailability
of required special equipment and the absence of any ad-
verse impact. The Union withdrew this grievance with
prejudice. However, according to the Union's witnesses,
unit employees are again doing this work. Grievances
were filed in December 1977 and May 1978 by shipping
department employees protesting the use of outside con-
tractors to store and ship service parts. Inland's answer
denied the grievances on the basis of its past practices, its
economic justification for the action taken, and the ab-
sence of any impact upon unit employees. Union Presi-
dent Hutchins testified that this work was ultimately
brought back when Inland opened new warehouse facili-
ties. In January 1978, the Union protested the subcon-
tracting of packaging work. In denying the grievance
Inland relied on paragraph 6 of its collective-bargaining
agreement and the absence of adverse impact. According
to Wallis, this particular subcontract was entered into be-
822
GENERAL MOTORS CORP., INLAND DIVISION
cause the packaging work involved an inefficient use of
floor space and was only a part-time operation. Darrell
Collins, chairman of the Union's shop committee, testi-
fied that this particular grievance and others on the same
subject were settled in the 1979 negotiations with back-
pay or makeup work for the employees. In October
1979, the Union grieved the subcontracting of certain
rubber-making work in Department 310. Once again, Re-
spondent cited paragraph 6 of its collective-bargaining
agreement to justify its actions. Of particular significance
is a grievance filed on October 27, 1978, protesting re-
moval of machinery and equipment to manufacture dust
cells and the subcontracting of that work. In rejecting
the Union's grievance, the foreman stated:
It is true that we have removed some equipment
from Dept. 248-249 that produced and finished dust
cells. This is necessary so that the Dept. can free up
adequate floor space to take on new business....
The supervisor added that the removal was necessary
"to make room for new business . . . [that] will more
than make up for the people that were displaced in the
change" This grievance was ultimately withdrawn with-
out prejudice. Hutchins claimed that there was no impact
upon unit employees at that time because the Company
was in a hiring situation. Wallis disputed that assertion.
No objective evidence was offered to support or contra-
vene either position.
Hutchins further testified that the Union would not
know of Respondent's subcontracting unless something
specifically brought it to the Union's attention. When
asked why the Union would not be aware of subcon-
tracting, he testified that it was "because the Company
had never contacted us in the past [about subcontracting]
. ."; Inland "had never made [the Union] aware in ad-
vance of anything going out."
D. Analysis and Conclusions
In Westinghouse Electric Corporation (Mansfield Plant),
150 NLRB 1574 (1965), the Board, in amplifying upon
Fibreboard Paper Products Corp. v. N.L.R.B., 379 U.S.
203 (1964), made clear that Fibreboard did not lay down
"a hard and fast rule to be mechanically applied." It set
forth, at 1577, five criteria to be considered in determin-
ing whether unilateral subcontracting violated Section
8(a)(5) of the Act: Whether the subcontracting "was mo-
tivated solely by economic considerations"; whether it
"comported with the traditional methods by which the
Respondent conducted its business operations"; whether
the subcontracting in question varied "significantly in
kind or degree from what had been customary under
past established practice"; whether "the Union had the
opportunity to bargain about changes in existing subcon-
tracting practices at general negotiating meetings"; and,
whether the subcontracting had any "demonstrable ad-
verse impact on employees in the unit." These criteria,
the Board has held, are to be weighed and considered
cumulatively. See General Electric Company, 240 NLRB
703 (1979); Rochester Telephone Corporation, 190 NLRB
161 (1971); and Union Carbide Corporation. Carbon Prod-
ucts Division, Clarksburg Works, 178 NLRB 504 (1969).
As stated in Shell Oil Company, 149 NLRB 305, 307
(1964), "the permissibility of unilateral subcontracting
will be determined by a consideration of the setting of
each case."
In the instant case, I am convinced that Respondent's
subcontracting clearly satisfies the first four tests enumer-
ated above. There is no contention that the subcontract-
ing of the subject ball joint manufacture was motivated
by other than economic considerations. The record also
establishes that Respondent has been subcontracting var-
ious kinds of work, including production work, for many
years. I take note, for example, of the grievances filed in
1978 and 1979 in regard to subcontracting of rubber
making, packaging, and the manufacture of dust cells. I
note further that like the subcontracting of the subject
ball joint manufacture, the subcontracting of the dust
cells involved the removal of machinery from Respond-
ent's plant, and the subcontracting of the packaging
work involved an inefficient use of space. Moreover, it
has been Respondent's practice to enter into these sub-
contracts unilaterally. Thus, even Union President
Hutchins acknowledged that Inland did not notify the
Union in advance about any work that was "going out."
Respondent, he said, never contacted the Union about
subcontracting. I must conclude, therefore, that the sub-
contracting involved here was at least not inconsistent
with Respondent's traditional methods of doing business
or with its past practices. I must reject as entirely too
narrow the General Counsel's contention that this partic-
ular subcontract varied from Respondent's past practices
because the record did not establish a specific history of
subcontracting the manufacture of these or other ball
joints.
Additionally, I find that the Union had, and exercised,
the opportunity to bargain about changes in Respond-
ent's existing subcontracting practices in the negotiations.
That question has been raised in every recent round of
negotiations. Proposals were made and there is no evi-
dence that Respondent refused to discuss them.4
These discussions failed to produce an agreement to
limit the subcontracting of production work; they have,
however, given rise to agreements limiting Respondent's
subcontracting of skilled trades work. In this regard, al-
though there exists a substantial difference in the number
of subcontracts involved, this case is not dissimilar from
Westinghouse, supra.5
The most difficult issue to be resolved here is whether
Respondent's subcontracting had "demonstrable adverse
impact upon" unit employees; i.e., whether it "resulted in
a significant impairment of job tenure, employment secu-
rity, or reasonably anticipated work opportunities for
' The General Counsel's contention that the Union's proposals in 1979
did not pertain to production work is contradicted by the plain meaning
of those proposals, particularly item 106.
s Respondent also contends that he Union had consciously wkaived its
right to restrict the subcontracting of production work. I cannot agree.
"The law is settled that the right to be consulted concerning changes ill
conditions and terms of emplosment is a right given by statute and
not necessarily one obtained by contracl To establish a sai'er of such a
right there must he a showing of clear relinquishment . ." .4ronca.
Inc., 253 NLRH 261, 261-264 (19O0) No such clear relinquishment has
been established here. See also Perkinm .Machine CornyUn. 141 NRB 98
(1963).
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DECISIONS OF NATIONAL LABOR RELATIONS BOARD
those in the bargaining unit." Union Carbide, supra at
508; Westinghouse, supra at 1576. Respondent's subcon-
tract resulted in the unit's loss of approximately one-half
of an employee's work year in production work and per-
haps one-quarter as much in such skilled trades work as
tool sharpening. No employee lost a job as a direct result
of the subcontract; however, by reducing the number of
hours of work available, that subcontract at least contrib-
uted to the factors requiring the transfer of one employ-
ee to another shift, the reassignment of a second to a job
at a slightly lower rate of pay, and the layoff of a third,
a toolroom employee. It also may have contributed to
the reduced demand for employees and leadership which
caused Respondent not to replace certain retired employ-
ees, including a group leader. On the positive side of the
ledger, by opening up space for new work, the subcon-
tract facilitated the ultimate increase in work available so
as to provide between 16 and 21 new jobs. 6
In Union Carbide, supra, the Board found that subcon-
tracting of production work while unit employees were
on layoff status did not cause a significant detriment in
unit work opportunities. There, like here, the facts did
not warrant a conclusion that any laid-off employees
were not recalled or were recalled late because of sub-
contracting. The work involved was not regularly as-
signed or scheduled and/or provided less than full-time
employment. See also Central Soya Company, Inc., 151
NLRB 1691 (1965), wherein it was held that subcontract-
ing while employees were on layoff status involved no
significant detriment inasmuch as the record failed to es-
tablish that the laid-off employees were qualified to do
the subcontracted work.'
Further, in both Rochester Telephone Corporation, 190
NLRB 161 (1961), and American Oil Company, 171
NLRB 1180 (1968), the Board found no significant detri-
ment in subcontracting or other changes which resulted,
at most, in the loss of overtime opportunities. In Ameri-
can Oil, the unit employees lost the opportunity to work
approximately 5,700 hours of premium-rated work, about
9 percent of the total of that work for the period. By
comparison, the subcontracted ball joint work represent-
ed less than one percent of Respondent's ball joint pro-
' It is, of course, entirely possible that by engaging in collective bar-
gaining the parties could have found a way both to retain the subject
work and to create the new jobs.
' Gerald F Hinkle d/b/a Akron Novelty M1anufacturing Company, 224
NLRB 998 (1976), and Howmer Corporation. Austenal Microcast Division.
197 NLRB 471 (1972), cited by the General Counsel for the proposition
that subcontracting while unit employees are laid off is violative of Sec.
8(a)(5), are factually distinguishable. In both, the subcontracting occurred
in a context of other unfair labor practices, including discrimination and
bad-faith bargaining, and shortly after the unions had been certified
Moreover, the Board in Howmner specifically pointed out that the subcon-
tracting was different in kind and quantity from the employer's prior
practice. Thus, the employers therein had failed to meet several of the
Westinghouse criteria.
duction. Similarly, in George Webel d/b/a Webel Feed
Mills and Pike Transit Company, 217 NLRB 815 (1975),
no significant detriment was found in the subcontracting
of delivery work which affected no specific unit jobs but
deprived the unit as a whole (five employees) of 4 to 6
hours of work per day. 8
Viewing the instant case against the background of the
cited Board precedent, I am constrained to conclude that
the detriment to the unit employees caused by Respond-
ent's subcontracting of the subject ball joint manufacture
was not sufficiently significant as to mandate notice and
bargaining. Thus, Respondent has satisfied all five of the
Westinghouse criteria. Accordingly, and notwithstanding
that Respondent had ample time to notify and bargain
with the Union prior to the effectuation of the subcon-
tract, that such bargaining might have permitted Re-
spondent to achieve its objective of acquiring space for
the J car ball joint manufacture without the loss of unit
work or satisfied the Union that to do both was impossi-
ble, and notwithstanding that by frank and open notice
and discussion Respondent might have created a situa-
tion more conducive to increased productivity than to
grievance filing and litigation, I shall recommend that
the complaint be dismissed.
Upon the entire record, I make the following:
CONCLUSION OF LAW
Respondent has not violated the Act in the manner al-
leged in the complaint.
Upon the foregoing findings of fact, conclusions of
law, and the entire record, and pursuant to Section 10(c)
of the National Labor Relations Act, as amended, I
hereby issue the following recommended:
ORDER 'o
The complaint herein is dismissed in its entirety.
I Cf. Cities Service Oil Company, 158 NLRB 1204 (1966), where the
unit's loss of $3,000 (in 1964 dollars) of overtime earnings was held to
constitute a significant detriment to the unit employees. In that case,
however, unlike the instant case, the subcontract involved approximately
one-sixth of the unit's work, the employer had no practice of engaging in
"similar wholesale transfer[s] of accounts," and there was no contractual
underpinning for the employer's actions.
9 In other settings, General Motors has successfully improved both
productivity and product quality by involving its employees more deeply
in the production process. seeking out their ideas through "Quality of
Work Life" programs. See "The Reindustrialization of America," Busi-
ness Week, June 30, 1980, pp. 96-101. The principles involved there
would seem equally applicable here
'o In the event no exceptions are filed as provided by Sec. 102.46 of
the Rules and Regulations of the National Labor Relations Board, the
findings, conclusions, and recommended Order herein shall, as provided
in Sec. 102.48 of the Rules and Regulations, be adopted by the Board and
become its findings, conclusions, and Order, and all objections thereto
shall be deemed waived for all purposes.
824