The company's appeal can be reduced to one issue: whether the arbitration awards draw their essence from the collective bargaining agreement between Jasper and the union. The limited scope of judicial review of arbitration awards is well-settled. See, e.g., National Wrecking Co. v. Int'l Brotherhood of Teamsters, Local 731, 990 F.2d 957, 960 (7th Cir. 1993); Polk Bros., Inc. v. Chicago Truck Drivers Union, 973 F.2d 593, 596 (7th Cir. 1992); Chicago Typographical Union No. 16 v. Chicago Sun-Times, Inc., 935 F.2d 1501, 1505 (7th Cir. 1991); United Steelworkers of America v. Enterprise Wheel Car Corp., 363 U.S. 593, 596, 80 S.Ct. 1358, 1360, 4 L. Ed. 2d 1424 (1960). As we stated recently in Sullivan v. Lemoncello, 36 F.3d 676, 682-83 (7th Cir. 1994), the Supreme Court has reiterated this longstanding principle:

Judicial review of arbitration awards is limited. See, e.g., Nat'l Wrecking, 990 F.2d at 960; Polk Bros. v. Chicago Truck Drivers Union, 973 F.2d 593, 596 (7th Cir. 1992); Chicago Typographical Union v. Chicago Sun-Times, 935 F.2d 1501, 1505 (7th Cir. 1991). We will uphold "an arbitrator's award based upon a misreading of the contract so long as the arbitrator's interpretation is derived from the language of the contract."

Ethyl Corp. v. United Steelworkers of America, 768 F.2d 180, 184 (7th Cir. 1985), cert. denied, 475 U.S. 1010 (1986). Given this limitation on our authority, and the principle that we resolve any reasonable doubts in favor of enforcing the arbitration award, Polk Bros. v. Chicago Truck Drivers Union, 973 F.2d 593, 597 (7th Cir. 1992), "[i]t is only when the arbitrator must have based his award on some body of thought, or feeling, or policy, or law that is outside the contract . . . that the award can be said not to `draw its essence from the collective bargaining agreement.'" Ethyl Corp., 768 F.2d at 184-85 (emphasis added).

[11] Judicial review of arbitration awards is extremely limited. Polk Bros. v. Chicago Truck Drivers Union, 973 F.2d 593, 596 (7th Cir. 1992); Ethyl Corp. v. United Steelworkers of America, 768 F.2d 180, 183 (7th Cir. 1985), cert. denied, 475 U.S. 1010, 106 S.Ct. 1184, 89 L.Ed.2d 300 (1986); see United Steelworkers of America v. Enterprise Wheel Car Corp., 363 U.S. 593, 596, 80 S.Ct. 1358, 1360, 4 L.Ed.2d 1424 (1960). As long as the arbitrator's award is based on his interpretation of the contract, a court cannot disturb it. See, e.g., Enterprise Wheel, 363 U.S. at 599, 80 S.Ct. at 1362; Ethyl Corp., 768 F.2d at 184.

As for its argument that the arbitrator overstepped his authority more broadly, Billerud cites four cases in which the Seventh Circuit criticized an arbitrator's attempt to add non-bargained for requirements to a CBA under the guise of contract interpretation. See Anheuser-Busch, 280 F.3d at 1138, 1142 (Arbitrator cannot shield himself from judicial correction by merely ‘making noises of contract interpretation'.”); Polk Bros., Inc. v. Chicago Truck Drivers, Helpers & Warehouse Union, 973 F.2d 593, 597-99 (7th Cir. 1992) (arbitrator went “well beyond his authority”); Tootsie Roll Indus., Inc. v. Local Union No. 1, 832 F.2d 81, 83-85 (7th Cir. 1987) (same); Young Radiator Co. v. Int'l Union, UAW, 734 F.2d 321, 325 (7th Cir. 1984) (Arbitrator “failed to confine himself to the terms of the collective bargaining agreement.”). These cases are easily distinguished as a matter of law, since all address awards where arbitrators ignored express, unambiguous contractual language or clearly relied on policies or law outside the agreement, none of which the arbitrator did in this case.

To the extent that there is any ambiguity as to whether an arbitration award derives its essence from a contract, a court should "resolve any reasonable doubt about whether an award draws its essence from the collective bargaining agreement in favor of enforcing the award." Polk Bros., Inc. v. Chicago Truck Drivers, Helpers and Warehouse Workers Union (Independent), 973 F.2d 593, 597 (7th Cir. 1992); see also Sullivan v. Lemoncello, 36 F.3d 676, 682-83 (7th Cir. 1994)(stating that "as long as the arbitrator is even arguably construing or applying the contract and acting within the scope of his authority a court cannot overturn an arbitration award"). A. Conduct that Occurred Prior to Effective Date of CBA

The key question is whether the award "draws its essence" from the contract, and in determining whether that is the case courts resolve any reasonable doubts in favor of enforcing the award. Polk Bros., Inc. v. Chicago Truck Drivers Union, 973 F.2d 593, 597 (7th Cir. 1992). A. The Violation

By contrast, in the two primary cases cited by defendants, the Seventh Circuit reversed an arbitrator's decision, where his interpretation plainly contradicted the express terms of the collective bargaining agreement. Anheuser-Busch, Inc. v. Beer Soft Drink Union, 280 F.3d 1133, 1145 (7th Cir. 2002); Polk Bros. v. Chi. Truck Drivers, Helpers Warehouse Workers Union, 973 F.2d 593, 598-99 (7th Cir. 1992). In Anheuser-Busch, a collective bargaining agreement provided two different commission rates: one for delivery drivers working alone and another for delivery drivers working with a helper.

Accordingly, an arbitrator's decision fails to draw its essence from the collective bargaining agreement and will be vacated only when it is based on "some body of thought, or feeling, or policy, or law that is outside the contract," Lee Lumber, 2 F.2d at 797, or when the decision is "without foundation in reason or fact, or wholly baseless and without reason."Anderson v. Nat'l R.R. Passenger Corp., 754 F.2d 202, 203 (7th Cir. 1984); see Polk Brothers Inc. v. Chicago Truck Drivers, Helpers and Warehouse Workers Union, 973 F.2d 593, 597 (7th Cir. 1992); Chicago Typographical Union, 935 F.2d at 1505. Moreover, any reasonable doubt as to whether the arbitrator interpreted the contract on some private notion of equity should be resolved in favor of enforcing the decision.

In Polk Brothers, Inc. v. Chicago Truck Drivers, we rejected the union's argument that when a CBA limited an arbitrator's jurisdiction, it did not also limit the arbitrator's authority to remedy a violation that was within its jurisdiction. 973 F.2d 593, 597 (7th Cir. 1992) (upholding the district court's decision to vacate the part of the arbitrator's award that reinstated employees past the expiration of the applicable agreement). Enterprise Wheel is distinguishable from the present case because there was no subsequent CBA that cut off the arbitrator's jurisdiction.