On December 14, 2017, the National Labor Relations Board published a Request for Information in the Federal Register, seeking public comment regarding the December 2014 overhaul of its representation election procedures. The Board twice extended the deadline for submission of feedback. Before the window closed last night, there were almost 7,000 submissions. This number is obviously exaggerated by the number of form submissions sent in at the behest of organized interests. A quick glance at the Board’s catalog page shows consecutive submission of files with the same document name (e.g., “do_not_rescind_the_2014_rules_997.pdf,” “do_not_rescind_the_2014_rules_998.pdf,” “do_not_rescind_the_2014_rules_999.pdf,” etc.).
Regardless, there has been a significant amount of comment, and we will now need to watch whether the Board uses this feedback as the basis for further internal analysis and activity, or issuance of a formal Notice of Proposed Rulemaking.
- Chamber of Commerce of the United States of America
- Coalition for a Democratic Workplace
- National Federation of Independent Business
- Society for Human Resource Management
- 1199SEIU United Healthcare Workers East
- Republican Labor Committee Chairpersons
- United Association of Journeymen and Apprentices of the Plumbing & Pipe Fitting Industry
- Professors Martin H. Malin, Jon M. Werner