As we reported last month, the DOL was considering what to do with the enjoined persuader rules, new regulations that would have drastically changed the interpretation of the advice exemption to the LMRDA reporting requirements. In sum, the new rules effectively narrowed the advice exemption to require reporting of a
persuader
Government Tightens Squeeze On Contractors, Publishes Final Persuader Rule For DoD, NASA and GSA Contracts
Contracting with the Department of Defense (“DoD”), National Aeronautics and Space Administration (“NASA”) and General Services Administration (“GSA”) will become more burdensome after December 2, 2011, according to final regulations published today. The regulations, which were proposed on April 14, 2010, and were adopted without any changes (no surprise…
Killing the Message and the Messenger – Can the NLRB Pull the Trigger?
The period for filing comments has now expired both for the NLRB’s proposed election regulations (killing the message by drastically shortening the time frame within which an employer may communicate with its employees between a union election petition and the secret ballot election), and the Department of Labor’s amendments to…
Comments Filed With Department Of Labor Over Proposed Persuader Rules
Another milestone in the government’s quest to upend labor relations in the United States passed last week. The deadline for filing comments with the Department of Labor (“DoL”) about its proposal to narrow the “advice” exemption under the Labor Management Reporting and Disclosure Act (“LMRDA”) expired September 21, 2011. Several interested parties filed comments…
Regulatory Two-Step – DOL and NLRB Announce Proposed Rules Limiting Employer Communications with Employees Regarding Union Representation
This week federal labor agencies have launched two proposed rulemakings of significance. Both may have a substantial impact on the substance and process of employer communications with employees on the issue of union representation.
First, the U.S. Department of Labor, Office of Labor-Management Services, announced a notice of proposed rule…