Dakota Sand & Gravel Co.

National Labor Relations Board - Board Decisions

Jun 25, 1974

211 N.L.R.B. 1026 (N.L.R.B. 1974)

1026 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Dakota Sand & Gravel Co. and Teamsters Local
# 123, affiliated with International Brotherhood of
Teamsters, Chauffeurs, Warehousemen and Help-
ers of America . Case 18-CA-3972-2
June 25, 1974
DECISION AND ORDER
BY MEMBERS FANNING, KENNEDY, AND
PENELLO
On March 18, 1974, Administrative Law Judge
Ivar H . Peterson issued the attached Decision in this
proceeding . Thereafter , Respondent filed exceptions
and a supporting brief, and the General Counsel filed
cross -exceptions and a supporting brief.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations Act, as amended, the
National Labor Relations Board has delegated its
authority in this proceeding to a three -member panel.
The Board has considered the record and the
attached Decision in light of the exceptions , cross-
exceptions , and briefs , and has decided to affirm the
rulings, findings, and conclusions of the Administra-
tive Law Judge only to the extent consistent
herewith.'
We find in agreement with the Administrative Law
Judge that Duane Kruckenburg is not a supervisor
within the meaning of the Act, and that his
interrogation by Plant Manager Richter and Assist-
ant Plant Manager Reuer constituted a violation of
Section 8(a)(1) of the Act.
We further find that Richter's offer to striking
employees to arrange a meeting with Respondent's
owner (which offer was first communicated to
striking employees on the picket line by Reuer), for
the purpose of obtaining increased pay and benefits,
but only after the strikers' withdrawal from the
Union, was an offer of an implied promise of benefit
for the withdrawal of these employees from the
Union, and as such was a violation of Section 8(a)(1).
We additionally find that Respondent's prepara-
tion and sponsorship of an employee petition to
assist them in withdrawing from the union is a
further violation of Section 8(a)(1) of the Act.
However , contrary to the conclusions and findings
of the Administrative Law Judge, we do not find that
Respondent 's granting of an across-the-board wage
i The Administrative Law Judge inadvertently found that 20 employees
signed the withdrawal petition made available by the Employer , when in
fact there are I I signatures.
We find in agreement with the Administrative Law Judge that the
following unit included in the appendix to his Decision entitled "Notice to
Employees" is an appropriate unit for purposes of collective bargaining:
All full time and regular part time employees of Dakota Sand & Gravel
Company at its ready mix and wash plant operations located on South
12th Street in Bismarck, North Dakota , including ready-nux drivers,
increase to all ready-mix drivers during the pendency
of the representation petition was a "final payoff" for
abandonment of the Union. Respondent Attorney
Bucklin offered unrefuted testimony at the hearing
that a general company policy had been established
for some time to attempt to keep competitive in the
payment of wages with rival Atlas, Inc. Additionally,
Plant Manager Richter testified as to a business
necessity in raising wages to attract and keep
qualified workers, even if this meant raising wages of
those employees in the unit petitioned for who were
previously out on strike. In September laborers were
given a general increase of 25 cents per hour when it
became apparent after a conversation with the state
unemployment office that Dakota' s wages were too
low and that needed workers were seeking employ-
ment with competitors. On October 1 the truckdri-
vers, including the strikers, were granted an increase
of 50 cents per hour. Unrefuted testimony was
offered that this wage was competitive but no more
than wages paid employees of Atlas, Inc.
As the violations of Section 8(a)(1) which we find
in agreement with the Administrative Law Judge are
not, in our view, sufficiently pervasive to undermine
the union 's majority status and impede the election
process within the meaning of Gissel Packing Co.,2
we shall not issue a bargaining order in this case.3
ORDER
Pursuant to Section 10(c) of the National Labor
Relations Act, as amended, the National Labor
Relations Board adopts as its Order the recommend-
ed Order of the Administrative Law Judge as
modified below:
1. Substitute the following paragraph 1(b) for
present paragraph 1(b); and insert the following
paragraph 1(c), renumbering present paragraph 1(c)
as (d).
"(b) Offering implied promises of benefit in an
attempt to seek employee withdrawal from the
Union.
"(c) Assisting employees to withdraw from the
Union by the preparation or circulation of a
petition."
2. Delete paragraph 2(a) and renumber the
remaining paragraphs accordingly.
sand and gravel drivers, loader operator and wash plant operator,
excluding office clerical employees , construction crew employees,
guards and supervisors as defined in the Act.
2 395 U.S. 575 ( 1969).
3 Member Fanning would find the October wage raise an additional
violation of Sec . 8(axl), as did the Administrative Law Judge, and in view
of the Respondent's interrogation, implied promise of benefit for withdraw-
al from the Union, and assistance to employees by making a withdrawal
petition available, would affirm the recommended Gissef bargaining order.
211 NLRB No. 147
DAKOTA SAND & GRAVEL CO.
3. Substitute the attached notice for that of the
Administrative Law Judge.
APPENDIX
NOTICE To EMPLOYEES
POSTED BY ORDER OF THE
NATIONAL LABOR RELATIONS BOARD
An Agency of the United States Government
WE WILL NOT discourage membership in or
activities on behalf of Teamsters Local # 123,
affiliated with International Brotherhood of
Teamsters, Chauffeurs, Warehousemen and Help-
ers of America by questioning our employees
about their union membership, activities, or
sympathies, or those of their fellow employees.
WE WILL NOT offer implied promises of benefit
to employees in an attempt to seek their with-
drawal from Teamsters Local # 123, affiliated
with International Brotherhood of Teamsters,
Chauffeurs, Warehousemen and Helpers of
America.
WE WILL NOT assist our employees to withdraw
from Teamsters Local # 123, affiliated with
International Brotherhood of Teamsters, Chauf-
feurs, Warehousemen and Helpers of America by
preparing or circulating a petition to that effect.
WE WILL NOT in any like or related manner
interfere with, restrain, or coerce employees in the
exercise of their rights guaranteed by Section 7 of
the Act.
DAKOTA SAND &
GRAVEL CO.
(Employer)
Dated By
(Representative) (Title)
This is an official' notice and must not be defaced
by anyone.
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.
Any questions concerning this notice or compli-
ance with its provisions may be directed to the
Board's Office, 316 Federal Building, 110 South
Fourth Street, Minneapolis, Minnesota 55401, Tele-
phone 612-725-2611.
DECISION
STATEMENT OF THE CASE
IVAR H. PETERSON, Administrative Law Judge: I heard
1027
this case in Bismarck, North Dakota, on January 22 and
23, 1974, upon the complaint issued by the Regional
Director for Region 18, on December 5, 1973, based upon
charges filed on September 6, 1973, by Teamsters Local
# 123, affiliated with International Brotherhood of Team-
sters, Chauffeurs, Warehousemen and Helpers of America,
herein called the Union. Briefly stated, the complaint
alleged that Dakota Ready Mix (Dakota Sand & Gravel
Co.) violated Section 8(a)(1) and (5) of the Act. In its
answer, the Respondent admitted certain jurisdictional
allegations of the complaint and that Larry Richter was a
supervisor.' In effect, the Respondent denied the remain-
ing allegations of the complaint. In substance, the issues
raised by the complaint are (a) whether the Respondent
unlawfully questioned an employee, Duane Kruckenburg,
about his activities on behalf of the Union; (b) whether
Richter and Reuer impliedly promised employees in-
creased benefits if they would resign from the Union and
return to work; (c) whether Reuer caused a petition to be
formulated and circulated among the employees which
provided for their withdrawal of membership in the Union;
(d) whether on or about October 1 it granted a wage
increase to its employees during a period that a question
concerning representation was pending in order to discour-
age activities on behalf of the Union; (e) whether a unit of
"all full-time and regular part-time employees of the
Respondent at its ready-mix and wash plant operations
... in Bismarck, North Dakota, including ready-mix
drivers, sand and gravel drivers, loader operator and wash
plant operator, excluding office clerical employees, con-
struction crew employees, guards and supervisors as
defined in the Act, constitute an appropriate unit for
purposes of collective bargaining within the meaning of
Section 9(b) of the Act"; and (f) whether the Respondent
should be required to recognize and bargain with the
Union, which represented a majority of the Respondent's
employees in the foregoing unit at all times after June 25
until on or about August 28 or 29, because its unfair labor
practices destroyed the opportunity for a free and fair
election.
Upon the entire record in the case and from my
observation of the witnesses as they testified, and consider-
ation of the briefs filed herein, on or about February 13, I
make the following:
FINDINGS OF FACT
1. THE BUSINESS OF THE RESPONDENT
The Respondent, a North Dakota corporation, with its
principal office and place of business in Bismarck, is
engaged in a variety of distinct operations. It is involved in
sand and gravel production for sale and for use in its own
operations, and the production of ready-mix for sale and
for use in its own ready-mix construction, owns a shopping
center, and holds controlling interest in Earth Builders,
Inc., a highway construction firm. During the construction
season, from spring to fall, it employs from 60 to 70
persons in all its operations; in the winter season, it
employs between 5 and 15 persons. I find that the
1 At the hearing , the Respondent also stipulated that Timothy Reuer was
a supervisor.
1028 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
Respondent is an employer engagqd in commerce within
the meaning of Section 2(6) and (7) of the Act, and that the
Union is a labor organization within the meaning of
Section 2(5) of the Act.
II. THE ALLEGED UNFAIR LABOR PRACTICES
A. Interrogation
In the latter part of June , Kruckenburg, a ready-mix
truckdriver , following conversations with other employees,
went to the Union to obtain information about joining. As
a result of this meeting, Kruckenburg began to distribute
union authorization cards to his fellow workers . Shortly
thereafter, virtually all of Respondent 's ready-mix drivers
attended an organizational meeting held at the union hall.
On or about July 2, Richter , the manager of Respondent,
called Kruckenburg into his office. Reuer, who is manager
of the ready-mix plant , was also present . Richter indicated
that he had heard that "some of the guys" had been at the
union hall on the previous Tuesday and wanted to know
how many and whether they had signed up. Kruckenburg
replied that all the dump truck , gravel truck , and cement
truckdrivers had attended and signed up. In answer to a
question as to why they had signed union cards , Krucken-
burg said that it was "to try and get better wages and
vacation ...: . Both Reuer and Richter admitted that the
questioning of Kruckenburg had in fact occurred.
The Respondent appears to contend that Kruckenburg,
as assistant ready-mix plant manager , was a "supervisor"
within the meaning of the Act. On the other hand, counsel
for the General Counsel contends that Kruckenburg's
testimony "clearly establishes that he possessed none of the
customary indicia of supervisory authority. At best the
evidence shows that he merely implemented the routine
instructions of Ready-Mix Plant Manager Reuer in
Reuer's absence . This evidence is entirely inadequate to
show that Kruckenburg 's responsibilities in this regard
require the exercise of any independent judgment . Further,
Respondent 's self-serving statements that, in the absence
of Richter and Reuer from the plant , they looked to
Kruckenburg to run the operations is clearly specious
where, as here , the Respondent admits that "that eventuali-
ty has never occurred."
B. Alleged Unlawful Promises of Increased Benefits
On or about August 20 , the drivers of Respondent went
on strike . On August 28, while the strike was still in
progress, Reuer spoke with some of the strikers on the
picket line, including Richard Roller and Roger Eckroth.
Both of the latter credibly testified that during the
conversation Reuer stated that he could not see that the
Union had done anything for the employees and that they
probably could get just as much by meeting directly with
the owners of the Respondent , the Wachters . Reuer offered
to arrange such a meeting. It should be noted that Reuer's
offer to arrange a meeting with the owners was not in
response to any urging or request on the part of the
strikers.
On August 28, while the strike was still in progress,
Reuer spoke with a group of strikers on the picket line.
Richard Roller and Roger Eckroth were among that group
and both testified that during this conversation Reuer said
he could not see that the Union had done anything for the
employees and that they probably could get just as much
by meeting directly with the owners of the Respondent, the
Wachters . Reuer offered to arrange a meeting with the
Wachters . It should be noted that Reuer's offer to arrange
a meeting with the owners was not made at the urging of
the strikers.
On August 28 and 29 , Richter spoke with some of the
strikers . The first conversation occurred in the office at the
ready-mix plant shortly after the foregoing conversations
that Reuer had had with the strikers . During this
conversation , Richter stated that he could arrange a
meeting between the strikers and the owners for the
purpose of obtaining the increased wages and benefits the
employees were seeking. However , he added that the
Respondent could do no talking until the employees had
withdrawn from the Union. On the morning of August 29,
after the employees had abandoned the strike but before
they returned to work, Richter met with the employees in
the ready-mix plant lunchroom . During this conversation
he again stated that a meeting could be arranged with the
owners for the purpose of obtaining better wages and
benefits . There is no evidence that, before the foregoing
conversations between Richter and the employees, the
question of withdrawing from the Union had been
discussed by the employees . Accordingly, counsel for the
General Counsel states that it is "therefore evident that
Richter's offer to have Respondent meet and negotiate
directly with employees after they had withdrawn from the
Union was the sole reason striking employees attempted to
withdraw from the Union and ultimately abandoned the
strike."
On August 29, an antiunion or withdrawal petition was
made available to the employees at the office of the ready-
mix plant . This petition was on Reuer's desk and the
employees read it and signed it as they came into the office
to pick up delivery tickets. One employee testified that he
was called to the office by Reuer and asked to read the
petition . This petition, addressed to the Union, read as
follows:
Each of us signing below withdraw and resign from the
Union. We are giving a copy of this to our employer so
that they will know that after today they can talk
directly to us about our jobs, and we want to talk to our
employer directly.
It bore the signatures of 20 employees . There is no dispute
that the discussions regarding the petition and the actual
signing of it occurred during substantial periods of working
time . The petition was prepared by the Respondent's
attorney, Leonard Bucklin , who was first contacted about
this matter by Reuer. There is no evidence that the petition
was prepared at the request of any of the employees, and
there is evidence that the employees had never discussed
such a petition among themselves and that no employee
requested that the Respondent prepare such a petition or
any similar document for them to present to the Union.
Moreover , while the envelope in which the petition was
mailed to the Union bore the return address of Roger
DAKOTA SAND & GRAVEL CO. 1029
Eckroth, the latter testified that his address was used at the
request of Richter and Reuer, apparently for the reason
that the Respondent feared that the petition would be
destroyed by Nelson of the Union if he saw the
Respondent's address on it.
C. The Alleged Unlawful Pay Increase
On or about October 1 , the Respondent gave an across-
the-board pay increase of 50 cents per hour to the ready-
mix drivers which was in addition to an increase of 25
cents per hour given them during the spring of 1973. The
record shows that on August 30 the Union filed a petition
for certification of representatives with the Regional Office
which covered a unit of truckdrivers including pickup
truckdrivers . This petition was being processed at the time
of the October 1 wage increase and the record shows that
counsel for the Respondent was fully aware that a question
concerning representation existed . In its answer and
testimony the Respondent characterized the October 1
increase as a "normal wage increase " and that it was
necessary to grant it in order to make the Respondent's
wage scale "competitive." It should be noted that the
Respondent did not come forward with any of its books
and records to support its contention that this was a
normal increase . Counsel for the General Counsel con-
tends that this failure "further supports the obvious
inference that the 50 -cent per hour increase was the final
payoff for the employees ' abandonment of the strike and
the Union ." Moreover , counsel for the General Counsel
asserts that none of the witnesses for the Respondent could
recall "any prior instances when an across-the -board wage
increase had been granted in the Fall of the year," and that
it is also significant that none of the across-the-board wage
increases granted in previous years "ever exceeded 25 cents
per hour."
D. The Alleged Refusal To Bargain
k
As set forth above, the complaint alleged that the
appropriate unit consisted of all "full-time and regular
part-time employees of Respondent at its ready-mix and
wash plant operations located . . . in Bismarck, North
Dakota, including ready-mix drivers, sand and gravel
drivers, loader operator and wash plant operator, excluding
office clerical employees, construction crew employees,
guards and supervisors as defined in the Act." In its
answer, the Respondent asserted that the Union "delayed
the raising of any question concerning representation until
such time as constituted an attempt to block normal wage
increases to the employees" and that if the Respondent had
withheld and refused the 1973 wage increase "it would
have constituted a penalty to the employees and a violation
of the rights of the employees granted under the Act."
Furthermore, the Respondent asserted that there had been
a long delay in any complaint or processing of unfair labor
practice charges and that "in this seasonal construction
business, there normally would be a substantial change in
identity of the employees by the time any election is held."
Finally, the Respondent contends that the Union peti-
tioned for an election for a different unit than either "(a)
the unit for which the Union previously demanded
recognition or (b) the unit sought by the NLRB." The
Respondent contends that the appropriate bargaining unit
is not the one defined in the complaint nor the one for
which the Union demanded recognition, nor the one for
which the Union petitioned for an election . The Respon-
dent asserts that the appropriate unit is "all full-time and
regular part-time employees of Respondent turning time-
cards in to, and supervised out of," the Bismarck office,
excluding office clerical employees, guards and supervisors
as defined in the Act. In his brief, counsel for the General
Counsel points out that it is a well-settled principle that the
bargaining unit a labor organization seeks to represent
need not be the most appropriate unit. He therefore
contends that the unit set forth in the complaint "clearly
constitutes an appropriate unit."
Reuer testified that, as ready-mix plant manager, he
directly supervised the 10 ready-mix truckdrivers and the 3
gravel truckdrivers and that he also supervised the
individual who operated the loader and that this person
also served as the wash plant operator. In addition, he
testified that, although the Respondent had other employ-
ees, such as heavy equipment operators and the ready-mix
construction crews, these employees worked under his
supervision only for limited periods in the winter. Moreo-
ver, on these limited occasions, the persons who substituted
for the drivers sought herein were supervisory personnel,
and generally were foremen on the construction crews. The
record shows that during the winter months the Respon-
dent employed from 5 to 15 men and that at least
approximately one-third of these are foremen. During the
summer months, which is a peak construction season, it is
primarily in cases of illness or absences that a substitute
truckdriver is used. Furthermore, Reuer testified that in
these instances the person substituted is a laborer who has
been designated as a "stand-by truckdriver." Finally, the
evidence clearly shows that the ready-mix operation is
physically separate and distinct and that none of the other
supervisors ever supervised the ready-mix operations. The
Respondent presented no evidence to show that the
truckdrivers ever operate heavy equipment, work on
construction crews, or participate in any other of the
Respondent's operations. Richter testified that during the
peak operational period the only employees who would
actually be performing their jobs on the Respondent's
premises were the ready-mix and dump truck drivers and
the operator of the loader and wash plant. He further
related that there is no overall wage scale in effect, that
wages vary from employee to employee, that only some of
the employees receive health and life insurance, that some
receive paid vacations but that none received paid
holidays, and that none received sick leave or pension
benefits. There is no timeclock for employees, with the
result that all ready-mix plant employees turn in their
timecards to the "batch man," whereas all other employees
turn in their time directly to the office. In view of these
factors, counsel for the General Counsel submits that the
unit set forth in the complaint "is a separately supervised,
homogeneous group of employees at a separate location
who do not perform work in the multitude of other
operations engaged in by this Respondent " He argues that
the "mere fact that on limited occasions employees from
1030 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
other operations perform truck driving work in the ready-
mix operation is not sufficient to show that all the
employees in the Respondent's other operations share a
community of interest with the employees sought herein
especially, as here, the substitutes are primarily foremen
from the Respondent's construction operation whom the
Respondent employs year around." He concludes, there-
fore, that the unit set forth in the complaint is "an
appropriate unit" and with "a minor and insignificant
exception, the unit alleged in the Complaint is the same
unit in which the Union sought recognition by its letter of
July 2."
The Respondent does not dispute that the Union
represented a majority of the employees in the appropriate
unit . The evidence, both by way of direct testimony and by
the authenticated authorization cards introduced into
evidence, clearly establishes that at all times between June
25 and August 28 the Union represented a very substantial
majority of the employees in this unit. There is nothing in
the record to show that the Respondent denies that the
Union made a sufficient request for recognition and
bargaining when it sent the Respondent the July 2 letter.
Indeed, to the contrary, the Respondent through its
attorney suggested a meeting to discuss the matter and a
meeting was held between the parties on July 10. There is
no indication that the Respondent doubted the Union's
majority status at that time inasmuch as it refused the
Union's offer to examine the authorization cards.
I conclude and find that the Respondent attempted to
bribe the employees to abandon the Union in exchange for
a substantial increase in pay. Moreover, the Respondent
questioned an employee in an effort to find out the
employees were seeking union representation and, thereaft-
er, declined to recognize the majority representative and
attempted to get them to abandon their strike in the Union
in return for an increase in pay and benefits. Finally, the
Respondent assisted the employees in withdrawing from
the Union and then, a month later, granted them the
largest hourly increase they had ever received.
IV. THE EFFECT OF THE UNFAIR LABOR PRACTICES
UPON COMMERCE
The activities of the Respondent set forth above, have a
close , intimate , and substantial relationship to trade,
traffic, and commerce among the several States, and tend
to lead to labor disputes burdening and obstructing
commerce and the free flow of commerce.
V. THE REMEDY
Having found that the Respondent has engaged in unfair
labor practices, it will be recommended that it cease and
desist therefrom and take certain affirmative action
designed to effectuate the policies of the Act.
Upon the basis of the foregoing findings of fact, and
upon the entire record in the case, I make the following:
CONCLUSIONS OF LAW
1. The Respondent , Dakota Sand & Gravel Co., is an
employer within the meaning of Section 2(6) and (7) of the
Act.
2. Teamsters Local # 123, affiliated with International
Brotherhood of Teamsters , Chauffeurs , Warehousemen
and Helpers , of America, is a labor organization within the
meaning of Section 2(5) of the Act.
3. By questioning employees concerning their union
and concerted activities , the Respondent violated Section
8(a)(1) of the Act.
4. By making promises of increased benefits to employ-
ees if they would withdraw from the Union , the Respon-
dent violated Section 8 (a)(1) of the Act.
5. By granting an across-the-board wage increase on
October 1 , 1973, thereby attempting to bribe the employees
to abandon the Union , the Respondent violated Section
8(a)(1) of the Act.
6. By refusing to bargain collectively with the Union,
which represented a majority of the employees in the
appropriate unit found above , the Respondent violated
Section 8(a)(5) and (1) of the Act.
7. The aforesaid unfair labor practices are unfair labor
practices affecting commerce within the meaning of
Section 2(6) and (7) of the Act.
RECOMMENDED ORDER2
Upon the basis of the above findings of fact and
conclusions of law, and upon the entire record in the case,
it is recommended that the Respondent, Dakota Sand &
Gravel Co., Bismarck, North Dakota, its agents, officers,
successors , and assigns , shall:
1. Cease and desist from:
(a) Discouraging membership in or activities on behalf of
Teamsters Local # 123, affiliated with International
Brotherhood of Teamsters, Chauffeurs, Warehousemen
and Helpers of America, or any other labor organization,
by unlawfully questioning any employee concerning his
union or protected concerted activities.
(b) Offering increases in pay or other benefits to
employees in return for their withdrawal from membership
or support of the Union.
(c) In any other manner interfering with, restraining, or
coercing its employees in the exercise of their right to self-
organization, to form labor organizations, to join or assist
the above-mentioned Union or any other labor organiza-
tion, to bargain collectively through representatives of their
own choosing, and to engage in other concerted activities
for the purpose of collective bargaining or other mutual aid
or protection, or to refrain from any and all such activities.
2. Take the following affirmative action which will
effectuate the policies of the Act:
(a) Upon request, bargain collectively with the above-
named union as the exclusive representative of the
employees in the unit described above concerning rates of
pay, wages, hours of employment, and other conditions of
2 In the event no exceptions are filed as provided by Sec. 102.46 of the ed in Sec. 102.48 of the Rules and Regulations, be adopted by the Board
Rules and Regulations of the National Labor Relations Board , the findings , and become its findings , conclusions , and Order , and all objections thereto
conclusions , recommendations, and recommended Order herein , as provid - shall be waived for all purposes.
DAKOTA SAND & GRAVEL CO.
employment and, if an understanding is reached, embody
such understanding in a signed agreement.
(b) Post at its place of business and plant in Bismarck,
North Dakota, copies of the notice attached hereto as an
Appendix.3 Copies of said notice, on forms to be provided
by the Regional Director for Region 18, shall, after being
duly signed by a representative of Respondent, be posted
immediately upon receipt thereof, and be maintained for a
3 In the event that the Board 's Order is enforced by a Judgment of a
United States Court of Appeals, the words in the notice reading "Posted by
Order of the National Labor Relations Board" shall read "Posted Pursuant
1031
period of 60 consecutive days thereafter, in conspicuous
places, including all places where notices to employees are
customarily posted. Reasonable steps shall be taken to
insure that said notices are not altered, defaced, or covered
by any other material.
(c) Notify the Regional Director for Region 18, in
writing, within 20 days from the date of this Order, what
steps the Respondent has taken to comply herewith.
to a Judgment of the United States Court of Appeals Enforcing an Order of
the National Labor Relations Board."