American Bread Co.

National Labor Relations Board - Board Decisions

Mar 7, 1968

170 N.L.R.B. 85 (N.L.R.B. 1968)

AMERICAN BREAD COMPANY
American Bread Company and Teamsters , Chauf-
feurs, Helpers and Taxicab Drivers, Local Union
327, affiliated with International Brotherhood of
Teamsters , Chauffeurs , Warehousemen and Help-
ers of America and American Bakery and
Confectionery Workers' International . Union,
AFL-CIO. Case 26-CA-2386
March 7, 1968
DECISION AND ORDER
BY MEMBERS FANNING, BROWN, JENKINS, AND
ZAGORIA
On November 21, 1966, Trial Examiner Thomas
F. Maher issued his Decision in the above-entitled
proceeding, finding that the Respondent had en-
gaged in and was engaging in certain unfair labor
practices within the meaning of the National Labor
Relations Act, as amended, and recommending that
it cease and `desist therefrom and take certain affir-
mative action, as set forth in the attached Trial Ex-
aminer's Decision. Thereafter, the Respondent and
the Intervenor filed exceptions to the Trial Ex-
aminer's Decision and supporting briefs.
The Board has reviewed the rulings of the Trial
Examiner made at the hearing and finds that no
prejudicial error was committed. The rulings are
hereby affirmed. The Board has considered the
Tri al Examiner's Decision, the exceptions and
briefs, and the entire record in the case, and hereby
adopts the findings,' conclusions, and recommenda-
tions of the Trial Examiner.2
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the Recom-
mended Order of the Trial Examiner and hereby
' We agree with the Trial Examiner that the Respondent violated Section
8(a)(1) and (2) of-the Act by recognizing and bargaining with the Inter-
venor during the pendency of a real question concerning representation
Midwest Piping & Supply Co., Inc, 63 NLRB 1060 The record clearly
shows that the Respondent had full knowledge of Local 327's active and
continuing organizational campaign when it recognized the Intervenor;
that Local 327s claim was not n bare claim , but was supported by signed
authorization cards, that the Respondent engaged in disparate treatment of
the two unions involved herein , and, that Local 327 was continuing to pur-
sue before the Board its claim that the expedited election was invalid
because of the Regional Director 's unit determination , a matter which was
litigated in the proceedings involving Cases 26-CC-94 and 26-CP-19 On
this basis , we find that a substantial question concerning representation ex-
isted notwithstanding Local 327's strength of I authorization card out of a
unit of 92 when Local 327 demanded recognition and a total of 8 cards
when the Respondent recognized the Intervenor
I In view of our unit determination this day in Cases '26-CC-94 and
26-CP-19, 170 N LR B 91, we do not find it necessary to adopt either of
the alternate bargaining units found appropriate by the Trial Examiner
85
orders that the Respondent, American Bread Com-
pany, Nashville, Tennessee, its officers, agents, suc-
cessors, and assigns, shall take the action set forth
in the Trial Examiner's Recommended Order.3
' Delete from paragraph 2(a) of the Trial Examiner's Recommended
Order that part thereof which reads "to be furnished" and substitute
therefor "on forms provided ." Also delete from paragraph I(a) and the
relevant part of the Notice, the phrase "or any other labor organization."
TRIAL EXAMINER'S DECISION
STATEMENT OF THE CASE
THOMAS F. MAHER, Trial Examiner: Upon a
charge and an amendment thereto filed on April 18
and May 31, 1966, respectively, by Teamsters,
Chauffeurs, Helpers and Taxi Cab Drivers, Local
Union 327, affiliated with International Brother-
hood of Teamsters, Chauffeurs, Warehousemen
and Helpers of America, herein called the Team-
sters, the Regional Director for Region 26 of the
National Labor Relations Board, herein called the
Board, issued a complaint on behalf of the General
Counsel of the Board on June 2, 1966, against
American Bread Company, Respondent herein, al-
leging violations of Section 8(a)(1) and (2) of the
National Labor Relations Act, as amended (29
U.S.C. Sec. 151, et seq.), herein called the Act. In
its duly filed answer Respondent, while admitting
certain allegations of the complaint, denied the
commission of any unfair labor practice.
Pursuant to notice a hearing was held before me
in Nashville, Tennessee, where the parties were
represented by counsel and afforded full opportuni-
ty to be heard to present oral argument, and to file
briefs. Briefs were filed by all parties on August 10,
1966.
Upon consideration of the entire record, includ-
ing the briefs, and upon my observation of wit-
nesses appearing before me, I make the following:
FINDINGS OF FACT AND CONCLUSIONS OF LAW
1. THE BUSINESS OF THE RESPONDENT
American Bread Company, Respondent herein, is
a Tennessee corporation with its principal office
and place of business in Nashville, Tennessee,
where it is engaged in the baking, sale, and distribu-
tion of bread and other bakery products. During
the 12-month period immediately preceding the is-
suance of the complaint herein American Bread
Company, in the operation of its business, received
goods and materials from points directly outside the
State of Tennessee valued in excess of $50,000, and
during the same period of time shipped goods
valued in excess of $50,000 from its Nashville, Ten-
nessee , plant, directly to points located outside the
State of Tennessee. Upon the foregoing I conclude
and find that Respondent is an employer engaged in
commerce and in operations affecting commerce
170 NLRB No. 20
86 DECISIONS OF NATIONAL
within the meaning of Section 2(6) and (7) of the
Act.
If. THE LABOR ORGANIZATIONS INVOLVED
Teamsters, Chauffeurs, Helpers and Taxi Cab
Drivers, Local Union 327, affiliated with Interna-
tional Brootherhood of Teamsters, Chauffeurs,
Warehousemen and Helpers of America and Amer-
ican Bakery and Confectionery Workers' Interna-
tional Union, AFL-CIO, herein called the Bakery
Workers, are now and have been at all times
material herein labor organizations within the
meaning of Section 2(5) of the Act.
III. THE ISSUE
The effect of the Teamsters demand for recogni-
tion upon the subsequent recognition of the Bakery
Workers and the execution of a collective agree-
ment with it.
IV. THE UNFAIR LABOR PRACTICE
A. Background
The parties in this proceeding are not strangers
to the Board's processes. In April 1965 the Team-
sters demanded recognition as majority representa-
tive of a unit of Respondent's production, main-
tenance, and sales driver employees. Upon Respon-
dent's refusal to grant recognition to the Teamsters
its employees, on April 19, went on strike in
protest. Whereupon, on April 23, 1965, Respon-
dent filed with the Board its petition in Case
26-RM-182 for an expedited election among the
employees affected, namely "all route salesmen,
transport drivers, production and maintenance em-
ployees employed by American Bread Company"
at its Nashville plant, with the customary exclusion
of clerical, supervisory, and guard personnel.' The
election was conducted thereafter on May 28. Of
the 284 eligible voters 244 actually voted, of whom
131, a majority, voted against the participating
union, the Teamsters. These results were eventually
certified by the Regional Director on July 30, 1965,
after the resolution of a number of challenges and
objections. Notwithstanding its rejection by the
employees in the unit in which it sought to
represent them the Teamsters continued its strike
for recognition against Respondent until August 5,
1965. Respondent meanwhile filed charges in Cases
26-CC-94 and 26-CP-19 against the Teamsters al-
leging violation of Sections 8(b)(4)(A) and (B)
and 8(b)(7)(B) of the Act. A complaint was
' I am administratively advised that this unit found appropriate by the
Regional Director in Case 26-RM-182 is presently the subject of review by
the Board pursuant to an order of remand in Cases 26-CC-94 and
26-CP-19 involving the Teamsters and Respondent herein The complaint
in the instant case , however, alleges as an appropriate unit all of Respon-
dent 's Nashville production and maintenance employees, driver-salesmen,
LABOR RELATIONS BOARD
thereafter issued. On December 7, 1965, a hearing
in the matter was held before Trial Examiner
Arthur E. Reyman, and on February 26, 1966, he
issued his Decision in which he found that the
Teamsters picketing constituted a violation of the
Act, as alleged, and recommended that a cease-
and-desist order be issued directed to the Team-
sters misconduct (but see fn. 1, supra). Meanwhile
there appears to have been a series of charges filed
with the Regional Director by both the Company
and the Teamsters, each directed at the alleged
misconduct of the other. These were Cases
26-CA-2092 and 26-CP-18. These appear to have
been administratively disposed of and all that
remains are the charges, complaints, and findings
directed against the Teamsters in the outstanding
Cases 26-CC-94 and 26-CP-19, and the issues
raised by the charge of the Teamsters against the
Company herein.
B. The Teamsters Latest Demand
After all of the foregoing had transpired the
Teamsters renewed its efforts to represent Respon-
dent's employees. Whereas it sought in April 1965
to represent "route salesmen and production, main-
tenance, shipping and receiving [all inside em-
ployees]," with the customary exclusions, its de-
mands ; a year later, in March 1966, were more
modest. Thus under date of March 23, 1966, Don
Vestal, local president of the Teamsters, demanded
recognition of his organization as representative of
Respondent's sales drivers. He further indicated
that the Teamsters were then organizing another
segment of Respondent's employees and when a
majority of them had designated it as their bargain-
ing representative he would notify Respondent ac-
cordingly.
C. Respondent's Refusal To Recognize
By letter of March 28, 1966, Respondent, by its
attorney, replied to the Teamsters demand for
recognition by rejecting it, stating:
The American Bread Company does not be-
lieve that you, in fact, represent a majority of
its driver-salesmen and, therefore, declines to
recognize Teamsters Local Union No. 327 as
bargaining agent for these employees.
If and when Teamsters Local Union No. 327 is
certified by the National Labor Relations
Board as bargaining agent for the driver-
salesmen of the American Bread Company, the
appropriate officials of the American Bread
garage and maintenance employees, and all other employees, with the
customary exclusions, and Respondent's answer admits this appropriate-
ness In the context of the issues presented herein I am not disposed to
await the outcome of a final determination of what the most appropriate
bargaining unit should be
AMERICAN BREAD COMPANY 87
Company together with myself will meet with
you for the purpose of collective bargaining.
Parenthetically , of the total of 92 driver-salesmen
stipulated to be included in the group for whom
Vestal demanded recognition , among the 289 total
employees on Respondent 's March 23 payroll (the
one nearest the date of Vestal 's demand ), only one,
employee Wiltshire , was shown to have signed a
Teamsters authorization card prior to the demand
for recognition . Seven more drivers signed cards
between March 31 and April 11, 1966.
the Teamsters never represented more than 8 of the
92 drivers for whom it sought recognition during
the period within which it was making its demand,
such a demand was specious and fraudulent. Ac-
cordingly , Respondent urges , the nature of the
Teamsters claim was not such as would create a
real question concerning representation , a basic
requirement in the assessment of Respondent's sub-
sequent allegedly unneutral conduct.
F. Conclusions
D. The Bakery Workers Appear
During March and early April 1966, as cor-
respondence between Respondent and the Team-
sters was in progress , the Bakery Workers procured
signed authorization cards from 170 of Respon-
dent's employees. On April 5, 1966, the Bakery
Workers, through its attorney, Kenneth Harwell,
notified Respondent that it represented a majority
of all the production and maintenance employees,
truckdrivers, relay drivers, route salesmen, relay
salesmen , garage employees , relay station em-
ployees , sanitation employees, receiving stock em-
ployees, thrift store sales employees , and shipping
employees. It advised Respondent that it was
authorized to bargain with it on behalf of these em-
ployees and that it accordingly requested recogni-
tion in behalf of them. In support of its claim to
majority status the Bakery Workers volunteered to
submit its authorization cards to an impartial third
party for a card check. Reverend John Sessons of
Nashville was -agreed upon and after comparing the
signed employee authorization cards with payroll
signatures provided by Respondent he certified that
a majority of Respondent's employees had signed
Bakery Workers authorization cards. A tally of
these cards in evidence discloses that 170 cards
were received of a total of 295 employees previ-
ously stipulated to be included in the group, as of
April 2, 1966, the payroll date nearest the date of
Respondent's recognition, of the Bakery Workers.
On or about April 15, 1966, Respondent posted
on its bulletin board a notice to the effect that it
was negotiating a contract with the Bakery Work-
ers."- As a result of these negotiations a collective-
bargaining agreement was executed by the parties
on May 8, 1966.3
E. The Contentions of the Parties
It is General Counsel 's contention that by violat-
ing the neutrality conditions required of an em-
ployer when faced with competing claims for recog-
nition Respondent thereby violated Section 8(a)(2)
of the Act. Respondent, on the other hand, insists
that because it has been shown in the record that
' The credited testimony of employee Wiltshire
' The credited testimony of Respondent's president , Bernard Evers, Jr
'Midwest Piping & Supply Co ., Inc , 63 NLRB 1060, William Penn Broad-
casting Company , 93 NLRB 1 104
1. The appropriate unit
It has been agreed upon by the parties and I ac-
cordingly conclude and find the following, in the al-
ternative , to be units appropriate for the purposes
of collective bargaining.
All salesmen-drivers at Respondent's Nashville,
Tennessee , plant, excluding all other em-
ployees, office clerical employees, guards and
supervisors as defined in the Act constitute an
appropriate unit of Respondent 's employees
for the purpose of collective bargaining within
the meaning of Section 9(b) of the Act.
All production and maintenance employees,
driver-salesmen , garage and maintenance em-
ployees and all other employees at Respon-
dent's Nashville, Tennessee , plant , excluding
office clerical employees, professional and
technical employees, watchmen , guards and
supervisors as defined in the Act, constitute an
appropriate unit of Respondent 's employees
for the purpose of collective bargaining within
the meaning of Section 9(b)of the Act.
2. The effect of Respondent's recognition of the
Bakery Workers
Nothing is so firmly established in the law of
labor relations as the obligation of an employer to
maintain a position of strick neutrality when faced
with the conflicting claims of two or more rival
unions which give rise to a real question concerning
representation in a unit appropriate for collective
bargaining.` Implicit in this concept of neutrality is
the existence of a real representation question. And
in this respect it is understood, of course, that the
filing of a representation petition by a rival or-
ganization , a condition not present here, is not the
sine qua non.5 What is significant is the character of
the rival claim. Thus Respondent invites my atten-
tion to the Board's most recent pronouncement on
the subject wherein it holds that "an employer does
not violate the Act by extending recognition to one
of the competing unions where the rival 'union's
claim is clearly unsupportable or specious, or other-
wise not a colorable claim."
' Novak Logging company, 119 NLRB 1573, 1574, and cases cited in fn
4
6 The Boy 's Markets , Inc , et al , 156 NLRB 105, 107.
88 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
In the instant situation certain things are clear:
The rivals exist , the claim was made, and by
Respondent 's recognition of the Bakery Workers
and execution of a contract , after the making of the
claim, the neutrality was breached . What remains
to be determined then is whether , by established
standards , the claim of the Teamsters failed to
create a real question concerning representation. I
find no such deficiency.
The Teamsters demand on March 23, 1966,
should not have come as a complete suprise, and
indeed there is testimony in the record that Pres-
ident Evers had heard that the Teamsters were
"making some effort to organize the employees."
Moreover , it is worthy of note that in the litigious
atmosphere in which Respondent and the Team-
sters were operating over the past year the Team-
sters demand for recognition could well have been
viewed as one more phase of a continuing engage-
ment . Nor could it possibly have been viewed as a
baseless claim , for when last the Teamsters had an
opportunity to display its strength among Respon-
dent's employees , in the election the year before, it
received 125 votes in an overall unit . It certainly
cannot be said , therefore , that the demand, as
Respondent received it, was either specious or un-
supportable . For, while the claim in The Boy's Mar-
kets, supra , was held by the Board to be "clearly un-
supportable" (emphasis supplied), here , in con-
trast , it is not clear at all that the Teamsters claim
lacked support.
Nor is it of consequence, as Respondent and the
Bakery Workers claim , that the Teamsters may
have previously comported itself in a manner not
entirely in keeping with the requirements of the
Act, referring to the recent findings in Cases
26-CC-94 and 26-CP-19. I know of no authority
for the proposition that the only labor organizations
eligible for the representation of employees are
those of established legal and moral virtue.7
Nor is it of consequence that General Counsel
has failed to establish the substantiality of the
Teamsters representation . Findings based upon
evidence adduced at the hearing disclose that but
one of the 92 in the unit had authorized the Team-
sters to represent him at the time the claim was
made; and only seven more joined him in the week
that followed , prior to Respondent's refusal. This
information, the number of employees signing
authorization cards, should be of no concern to an
employer when a claim is made , for indeed the
cases are; legion where the inquires of an employer
as to precisely such a fact, the number who signed,
have been found to be violations of the Act.
Furthermore, as it is clear that it is the practice of
the Board to require but one authorization card of
a union seeking to intervene in an election," less
' Cf. N.L.R B v . Fulton Bag & Cotton Mills, 180 F.2d 68 (C.A 10)
" Cf. 0 D. Jennings and Company, 68 NLRB 516
° William Penn Broadcasting Co., supra.
10 The Boy's Markets, Inc , supra
rigid standards cannot be set to permit an employer
to free himself of his obligation of neutrality. Con-
sequently , any argument suggesting a showing of
substantiality has no place in the situation
presented by the Teamsters demand for recogni-
tion.
In their briefs to me the parties appear to have
confused the requirements for the establishment of
a claim that would create a question concerning
representation with the substantiality that is
required for the filing of a representation petition.
It is true , of course , that the filing of a petition
establishes such a real question ;9 and it is equally
true that the Board 's rules require a showing of in-
terest in the form of authorization cards signed by
at least 30 percent of the employees in the unit.
This is not to say , however, that a 30-percent show-
ing required for the filing of a petition which is to
be used as evidence of the existence of a real
question concerning representation automatically
and independently becomes the requirement for a
demand for recognition where , as here, no petition
is involved. I accordingly reject any suggestion that
substantiality is an element of a union 's claim for
majority status in circumstances where a rival situa-
tion is created by a union 's demand, as distinct
from its filing of a petition . To the extent , there-
fore, that the complaint herein alleges a violation
based upon the Teamsters being designated by a
"substantial number" of employees (par. 8), 1 would
conclude and find that General Counsel has failed
in its proof. But as substantiality is of no moment in
the circumstances presented here I would further
conclude that , having made its claim, which for
reasons previously considered must necessarily be
considered colorable,10 the Teamsters thereby
created a real question concerning representation.
Upon the foregoing , therefore, it is clear that dur-
ing the pendency of a real - question concerning
representation Respondent breached the neutrality
required of it by recognizing and bargaining with
the Bakery Workers . As such conduct has con-
sistently been held to be interference , restraint, and
coercion of employees in the exercise of their statu-
tory rights and unlawful assistance to a labor or-
ganization , I conclude and find that Respondent has
thereby violated Section 8(a)(1) and (2) of the
Act.' 1
V. THE EFFECT OF THE UNFAIR LABOR PRACTICES
UPON COMMERCE
The activities of the Respondent set forth in sec-
tion IV , above, occurring in connection with its
business operations described in section 1, above,
have a close , intimate , and substantial relation to
trade , traffic, and commerce among the several
" The Boy's Markets, Inc., 156 NLRB 105, 107, Scherrer and Davisson
Logging Company, 119 NLRB 1587, William Penn Broadcasting Company,
93 NLRB 1104, Midwest Piping & Supply Co , Inc , 63 NLRB 1060
AMERICAN BREAD COMPANY
States, and tend to lead to labor disputes burdening
and obstructing commerce and the free flow of
commerce.
VI. THE REMEDY
Having found and concluded that Respondent
rendered unlawful assistance and support to the
Bakery Workers thereby interfering with, restrain-
ing, and coercing its employees in the exercise of
rights guaranteed them by Section 7 of the Act, I
shall recommend that it cease and desist therefrom.
Affirmatively I shall recommend that Respondent
withdraw and withhold any recognition it has
granted the aforesaid Bakery Workers or any other
labor organization unless and until the National
Labor Relations Board has certified it, or such
other labor organization as may qualify, as majority
representative of Respondent's employees following
a Board-conducted election in either of the units
which I have found to be appropriate for the pur-
poses of collective bargaining. I shall further
recommend that nothing in the Board's Order be
construed as varying or abandoning wages, hours,
seniority, or other substantial benefits contained in
any outstanding agreement between the Respon-
dent and the Bakery Workers.Y2 I shall further
recommend that Respondent post the customary
notices.
RECOMMENDED ORDER
Upon the entire record in this case, and pursuant
to Section 10(c) of the National Labor Relations
Act, as amended, I recommend13 that American
Bread Company, its officers, agents, successors,
and assigns, shall:
1. Cease and desist from:
(a) Rendering aid, assistance, or support to
American Bakery and Confectionery Workers' In-
ternational Union, AFL-CIO, or any other labor or-
ganization, by recognizing it or bargaining with it as
a representative of Respondent's employees unless
and until it is certified by the National Labor Rela-
tions Board as such representative in an ap-
propriate bargaining unit.
Appropriate units are:
All salesmen-drivers at Respondent's Nashville,
Tennessee, plant, excluding all other em-
ployees, office clerical employees, guards and
supervisors as defined in the Act, or
All production and maintenance employees,
driver-salesmen, garage and maintenance em-
ployees and all other employees at Respon-
dent's Nashville, Tennessee, plant, excluding
office clerical employees, professional and
'x The Bassack Company, Spring Valley Division, etc., 127 NLRB 1552
to In the event that this Recommended Order be adopted by the Board,
the word "Recommended " shall be deleted from its caption and wherever
else it thereafter appears , and for the words " I Recommend " there shall be
substituted "the National Labor Relations Board hereby orders."
89
technical employees, watchmen, guards and
supervisors as defined in the Act.
Nothing in this Decision and Recommended Order
shall require Respondent to vary or abandon any
wage, hour, seniority, or other substantive feature
on behalf of its employees which the' Respondent
has established while bargaining with the aforesaid
labor organization, or to prejudice the assertion by
its employees of any rights they may have derived
as a result of membership in or representation by
the said labor organization.
(b) In any like or related manner interfering
with, restraining, or coercing its employees in the
exercise of rights guaranteed them by Section 7 of
the National Labor Relations Act.
2. Take the following affirmative action which it
is found will effectuate the policies of the Act:
(a) Post at its Nashville, Tennessee, plant, copies
of the attached notice marked "Appendix." 14 Cop-
ies of said notice, to be furnished by the Re-
gional Director for Region 26, after being duly
signed by Respondent's representative, shall be
posted by Respondent immediately upon receipt
thereof, and be maintained by it for 60 consecutive
days thereafter, in conspicuous places, including all
places where notices to employees are customarily
posted. Reasonable steps shall be taken by Respon-
dent to insure that said notices are not altered,
defaced, or covered by any other material.
(b) Notify the Regional Director for Region 26,
in writing, within 20 days from the receipt of this
Decision, what steps have been taken to comply
herewith.l5
14 In the event that this Recommended Order is adopted by the Board,
the words "a Decision and Order " shall be substituted for the words "the
Recommended Order of a Trial Examiner" in the notice In the further
event that the Board 's Order is enforced by a decree of a United States
Court of Appeals , the words " a Decree of the United States Court of Ap-
peals Enforcing an Order " shall be substituted for the words " a Decision
and Order."
15 In the event that this Recommended Order is adopted by the Board,
this provision shall be modified to read. "Notify said Regional Director,
in writing, within 10 days from the date of this Order,-what steps the
Respondent has taken to comply herewith."
APPENDIX
NOTICE TO ALL EMPLOYEES
Pursuant to the Recommended Order of a Trial
Examiner of the National Labor Relations Board
and in order to effectuate the policies of the Na-
tional Labor Relations Act, as amended, we hereby
notify our employees that:
WE WILL NOT recognize American Bakery
and Confectionery Workers' International
Union, AFL-CIO, or any other labor organiza-
tion, as the representative of our employees for
the purposes of bargaining collectively con-
cerning conditions of employment, unless and
until said labor organization shall have been
certified by the Board as the exclusive
90 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
representative of such employees in a unit ap-
propriate for collective bargaining.
WE WILL NOT vary or abandon any wage,
hour, seniority, or other substantive feature
established in behalf of our employees while
bargaining with the American Bakery and Con-
fectionery Workers' International Union,
AFL-CIO, nor will we deny our employees any
right derived as a result of their membership in
or representation by said labor organization.
WE WILL NOT in any like or related manner
interfere with, restrain,' or coerce our em-
ployees in the exercise of rights guaranteed
them by Section 7 of the Act.
All our employees are free to form, join, or assist
any labor organization, or to refrain from doing so.
AMERICAN BREAD
COMPANY
(Employer)
Dated By
(Representative ) (Title)
This notice must remain posted for 60 consecu-
tive days from the date of posting and must not be
altered, defaced, or covered by any other material.
If employees have any question concerning this
notice or compliance with its provisions, they may
communicate directly with the Board's Regional
Office, 746 Federal Office Building , 167 North
Main Street , Memphis ,
Telephone 534-3161.
Tennessee 38103,