The NLRB released 7 advisory memoranda in August 2020, including 2 relating specifically to COVID-19 and protected concerted activity. In Hornell Gardens the NLRB held that the discharge of an employee who complained about the use of shared PPE and refused to work a shift did not constitute protected concerted activity because the employee’s objection was not concerted, nor was it for the purpose of mutual aid or protection – it was an individual complaint and, thus, not subject to the NLRA’s protections. In Marek Brothers Drywall, the NLRB considered whether an employee had been retaliated against when an employee objected to the absence of hand wash and other COVID-19 safety precautions and, subsequently, was terminated. The NLRB rejected this claim, finding that there was insufficient evidence of retaliatory animus, and that the mere nexus in time between the complaint and termination was insufficient to support a claim.