UNITED STATES OF AMERICA

BEFORE THE NATIONAL LABOR RELATIONS BOARD

DIVISION OF JUDGES

 

 

QUICKWAY TRANSPORTATION, INC.

 

and                                                                                          5-CA-33111

                        5-CA-33257

                        5-CA-33446

                        5-CA-33497

 

DRIVERS, CHAUFFEURS & WAREHOUSEMEN TEAMSTERS

LOCAL UNION NO. 639 a/w INTERNATIONAL BROTHERHOOD

OF TEAMSTERS

 

James C. Panousos, esq., and

Daniel Heltzer, esq., counsel for the

   General Counsel

Philip Giles, of Washington D.C.

   for the charging party,

James H. Hanson, esq., and

A. Jack Finklea, esq.,

   of Indianapolis, Indiana for the

    Respondent

 

DECISION

 

Statement of the Case

 

            Eric M. Fine, Administrative Law Judge. This case was tried in Washington, D.C., on October 3 to 5, November 26 to 30, and December 3 to 5, 2007.  The initial charge was filed on March 13, 2006, and the last charge was filed on March 8, 2007.[1]  All charges were filed by filed by the Drivers, Chauffeurs & Warehousemen Teamsters Local Union 639 a/w International Brotherhood of Teamsters (the Union or Local 639) against Quickway Transportation, Inc. (Respondent).  The issues in this case include Section 8(a)(1) allegations of surveillance, the creation of the impression of surveillance, interrogation; Section 8(a)(3) allegations of unlawful: discharge, refusal to accept the unconditional offer to return to work of unfair labor practice strikers, the lockout of unfair labor practice strikers; and Section 8(a)(5) allegations of direct dealing and diversion of bargaining unit work without bargaining in good faith.[2]

 

            On the entire record, including my observation of the demeanor of the witnesses, and after considering the briefs[3] filed by the General Counsel and the Respondent, I make the following[4]

 

Findings of Fact

 

I. Jurisdiction

 

            Respondent, a corporation, with its main office in Nashville, Tennessee, has been engaged in transporting dairy products from warehouses and dairies to grocery stores in various portions of the country, including from the Marva Maid Dairy (MMD) in Landover, Maryland to Giant Food stores in the greater Washington, D.C. metropolitan area.  Since around April 2006, when it commenced its operations for MMD, Respondent has derived gross revenues in excess of $50,000 on an annual basis from the transportation of freight from Maryland directly to points located outside of Maryland.  Respondent admits and I find it is an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act and the Union is a labor organization within the meaning of Section 2(5) of the Act.

 

II. Alleged Unfair Labor Practices

 

Respondent is a transportation company primarily transporting dairy products and groceries for food chains.  Respondent’s corporate office is in Nashville, Tennessee.  Respondent uses about 675 to 700 drivers throughout its 17 terminals nationwide.  About 500 of those drivers are company drivers.  Out of the 17 locations, five are organized by various Teamsters affiliates, they are: Landover, Detroit, Indianapolis, Shelbyville and Lynchburg.  Respondent has contracts with the Teamsters at all but the Landover facility.

 

William Prevost has been the president of Respondent since February 2004, when he began working at the company.  Prevost testified Respondent completed a handshake agreement as of the week prior to his testimony on a five-year contract extension for the bargaining unit at the Shelbyville terminal.  Cannon has been employed by Respondent since July 19, 2004.  Cannon was a terminal manager from July 2004 until July 2006.  In July 2006, he became the Atlantic regional vice-president until August 2007, when he became the northern regional vice-president. 

 

Cannon became involved with Respondent’s start up of the Landover terminal in January 2006 when he began visiting the terminal to gather information concerning area wages and deliveries.  At that time, Giant owned the dairy, and deliveries to the Giant stores were being made by drivers employed by Giant Transportation.  In January 2006, negotiations were ongoing between MMD and Giant for MMD’s purchase of the dairy, and MMD had already selected Respondent to be its primary carrier from Landover.  Cannon testified that Mike Miller, Respondent’s director of pricing and business analysis, had created a pre-opening model as to how it would operate the Landover terminal.  The model was based on 21 drivers, 21 trucks, 46 trailers, one yard jockey truck, with two yard drivers.  Under the model, drivers were supposed to run two loads a day.  Respondent signed a contract on March 3 with MMD for the delivery of the dairy products out of Landover, with a March 27 startup for the deliveries.  Respondent selected Michael Ortt as the terminal manager for the Landover operation.  In March, Cannon was terminal manager for Newark, Ohio, but he continued to assist with the Landover start up.  David Taylor, the then Atlantic regional vice president also assisted in the startup. 

 

Cannon testified Respondent began advertising for company drivers in mid January and they began to hire drivers before the operation started.  The hiring process including running a motor vehicle report on the driver’s application for no more than two moving violations in the past three years, the driver having two years of current tractor trailer experience, an interview, no past convictions or DUI’s, a drug screen and a physical.  Cannon testified it took 6 to 7 business days from the time a driver first called until he was hired.  At time of the sale of the dairy to MMD, Giant laid off about 75 drivers and Respondent had former Giant drivers apply for employment.  Cannon knew that Giant drivers were union members.  Cannon testified that prior to operations starting on March 27, Respondent committed to hiring about three former Giant drivers, including Angelo Jackson and Kenneth Tucker.  Cannon testified that over a two to three month period they hired about seven or eight former Giant drivers.  Cannon testified that more applied than were hired.  Cannon testified the company drivers based in Landover were guaranteed $1000 a week at the start up of the operations for a six week period, while Respondent’s dispatchers became acclimated to the routes out of the Landover terminal.  When the guarantee ended the company drivers were paid $.45 a mile and $15 a stop.  For detention at a stop after an hour, the driver also received $20 an hour paid in 15 minute increments.[5] 

 

Cannon testified Respondent also received a list from MMD, which MMD had received from Giant, of area agencies for the supply of temporary drivers.  Cannon testified Respondent started using temp agencies from day one of the Landover operation, and was using them six days a week.  Cannon testified that from the end of March 2006 until the strike in January 2007, Respondent probably used temporary drivers almost every day.  He testified that on the slowest days, Tuesday, Wednesday and Thursday, there may have been a few days that they did not require temporary drivers.  Cannon testified if Respondent hired enough permanent drivers to handle the peak days which are Saturday and Monday, there would not have been enough work Tuesday through Friday to keep all of the drivers active.  Cannon testified all Respondent’s company drivers were full time. 

 

  1. The Union campaign

 

Kenneth Tucker applied to Respondent through a friend Angelo Jackson in early March for a job as a truck driver.  Tucker’s job application is dated March 8.  Tucker and Jackson had previously worked for Giant as drivers.  Tucker began driving loads for Respondent at the Landover facility on March 27.  Tucker’s initial assignment with Respondent was helping to train other drivers, including drivers Respondent hired and drivers Respondent had brought in from other terminals to help start the Landover terminal.  Tucker performed the training before the operation started.  Tucker showed the drivers how the procedures were handled at the stores, with the loading and unloading of the milk and dollies.  Jackson also conducted training for these individuals.[6] 

 

Tucker testified that on March 20, Tucker and Jackson met with Cannon and Ortt at the Landover facility.  Tucker provided trip tickets from his prior work week at Giant Food to show Cannon and Ortt the wages he would have earned with the miles and stops pay Respondent was offering.  In response, Cannon said he would drop the mileage and stops pay rate for four weeks, and would pay $1,000 per week, until they figured something out with the pay.  Tucker testified he presented the paper work because of a concern, “That you wouldn't be able to make half the money that they say you would be able to make running on those terms.”  Jackson had a concern over the same issue.  Tucker testified that Cannon later said the $1000 guarantee was extended to six weeks.  The drivers at Giant had been paid by the hour, not by miles and stops.[7]

 

Tucker testified to the following: Jackson called Tucker in May 2006, and Jackson said that he wanted to seek union representation for Respondent’s employees.  Jackson said he was going to contact Phil Giles of the Union.  Later on that evening or the next day, Jackson called Tucker and stated Jackson had spoken with Giles.  Jackson said he wanted to meet with Giles on May 7 and that all who wanted to attend were welcome.  Tucker attended the May 7, meeting at the Teamsters hall in Washington, D.C.  Present were Giles and Respondent employees Tucker, Jackson, Mark Duncan, and Mike Wilkins.  During the meeting, Giles discussed the need to distribute authorization cards to the employees, and having those cards signed and returned to Giles.[8]  Giles gave cards out to each of the men in attendance.  Tucker was designated as the go between to collect signed cards from the men who attended the meeting and return them to Giles.  All of the employee attendees at the meeting subsequently obtained signed cards and returned them to Tucker to return to Giles.  Jackson had four to five cards signed.  Former Respondent driver Roger Branch identified a card Branch signed on May 9.  The Union filed a petition for election with Region 5 for Respondent’s employees on May 17.

 

            Tucker testified that during the union campaign Respondent campaigned against the Union by showing videos, paycheck distributions, and bulletin board postings.  Respondent distributed a memo dated June 1, under the signature of Ortt to company drivers and hostlers informing them that there had been recent organizing activity at Respondent, and that a secret ballot election was scheduled for June 22.  The employees were reminded of their right to vote no.  It was stated, “If you give me a chance to show you what you and Quickway can accomplish without the interference of the union, I am confident you will come to the same conclusion that several other Quickway terminals (and 92% of America’s workers) have reached- the union is not in anyone’s best interest.”  Tucker identified other anti union distributions he received from Respondent.  Respondent also stipulated at the hearing that it ran a campaign opposing the Union.

 

  1. The surveillance, Jackson’s discharge,

                                    and the creation of impression of surveillance

 

1. Creation of impression of surveillance

 

            Tucker credibly testified at follows: Tucker attended a meeting with Jackson, Taylor and Cannon on May 25, at around 3 or 4 p.m.  Tucker had just turned in his paper work upon the completion of his shift when Taylor asked Tucker to attend the meeting.  After the door was closed, Taylor told Jackson he was being terminated.  Taylor read from a letter providing Jackson the reasons for his discharge.  Tucker testified that, “They had read the letter and told him that was it, you know, and didn't give him a chance to respond.”  Tucker testified that Jackson attempted to respond.  Tucker testified that, “he wanted to try to explain the issue that they were talking about, but they didn't let him.”  Tucker testified the issue was “Something about him being followed and videotaped at a store and taking too much time and falsifying a document.”[9]  Tucker testified that, during the meeting, Taylor read from another memo explaining to Jackson the reasons he was discharged.  Taylor provided Jackson with a copy of this memo upon Jackson’s request. 

 

            Tucker credibly testified Jackson left and Tucker was about to leave, when Cannon asked Tucker to have a seat.  Cannon pulled his chair within inches of Tucker’s chair.  Tucker testified Cannon said, “he knew that I was a leader and a professional and that he heard that I was involved in starting the union up.”  Tucker responded that he was not part of it.  Tucker testified that Cannon then stated, “that the guys who‑‑ that were opposing the union had told him that I was one of the guys helping to start the union up.”  Tucker again denied it.  Tucker testified that during the exchange, Cannon said, “that they did not need a union.  They thought that their open door policy was good enough.  They did not need a third party and that, you know, all unions do is milk companies and employees out of money.”  Cannon stated the drivers were saying that Tucker was in the middle between the drivers and the company, and that Cannon stated Tucker should not be in the middle.  Tucker denied being in the middle.[10] 

 

            Tucker credibly testified that, during the May 25 meeting, after Jackson left, Taylor stated Respondent would be issuing a letter the next morning to the drivers.  Taylor showed Tucker a typewritten document under Taylor’s signature addressed to all drivers.  The letter stated that, “As many of you may already know a Quickway Driver was terminated today for being dishonest when filling out his route sheet.”  The document went on to caution drivers about the importance of filling out their route sheets.  Tucker testified that Taylor said that about 10 drivers were followed that week and that on that particular day, Jackson and Tucker were followed and Tucker conducted himself like a professional.

 

a. Respondent’s witnesses

 

Cannon testified he received training on what a supervisor could and could not do during the union campaign.  Cannon identified a campaign instruction sheet that Prevost gave Cannon, Taylor and Ortt entitled, “Remember These Tips.” (Tips sheet).  Cannon testified he participated in a conference call with Taylor and Prevost in which Prevost reviewed the Tips sheet.

 

Cannon testified he arrived at the Landover terminal on May 25, having flown in from Columbus, Ohio.  Cannon was changing positions with Taylor at the terminal on a weekly basis, and it was Cannon’s turn to be there and Taylor’s to go home.  When Cannon arrived, Taylor invited Cannon into the office to meet with Jackson and Tucker.  Cannon testified Jackson’s termination took place and then Jackson left, and Tucker remained in the office with Cannon and Taylor.  Cannon testified Taylor and Tucker then had a conversation, but Cannon could not recall what they discussed.  Cannon testified that, at one point in time, Cannon took over the conversation.

 

Cannon testified, in explanation, that around a week before the May 25 meeting, Tucker had pulled Cannon aside seeking help in that Tucker told Cannon that the other drivers were coming to Tucker with complaints.  Cannon could not recall what type of complaints they were.  Cannon testified Tucker did not want to play the middleman between the drivers and management.  Cannon testified he told Tucker that he needed to take himself out of that position of being the go-to or fix-it person.  Cannon testified that on May 25, Cannon wanted to revisit that conversation and that Cannon initiated the discussion.  Cannon testified, “That's when I took over the conversation with David Taylor and Kenny Tucker.  So I just wanted to revisit with that and somewhat reiterate that, Kenny, you don't have to be in this position to be the sounding board for the drivers.  We've got office personnel that‑‑ that has that responsibility and has that duty to take care of any type of problems that the driver may have.  I conveyed to him that his response to the drivers, if they did have any complaints, would be, you need to go see management about that.”  Cannon testified that Tucker, “did bring up that another complaint, that everybody was pointing their finger at him, as far as starting the union.  And me and David Taylor both stopped him right there and said, Kenny, let's make it very well known that no one is pointing the finger at you, as far as starting the union.”

 

            Cannon testified that during the May 25, meeting, Cannon brought up the possibility of Tucker becoming as dispatcher as they had noticed leadership qualities in Tucker, particularly during his training of office personnel.  Cannon testified Tucker liked the compliments they were giving him stating he was interested.  Cannon testified that during the May 25, meeting, Taylor told Tucker that Tucker had also been followed but that Tucker did “a fantastic job.”[11] 

 

Cannon denied telling Tucker that Cannon had received reports from other drivers that Tucker was involved in union organizing.  Cannon testified he did not know Tucker was involved in union organizing at that point in time, although he learned later on that Tucker was involved.  When asked when he learned, Cannon testified, “I can't recall.  Just with, you know, the‑‑ they talked back and forth from driver to office personnel.  It eventually did come out, but putting to a calendar and what date, I can't recall.”  However, Cannon testified he was sure he did not know at the time of the May 25 meeting.  Cannon testified that as of the time of the May 25 meeting, he knew it was illegal to engage in surveillance of union activities.  He denied stating anything that would give drivers the impression that he was engaging in surveillance of their union activities.  He denied asking Tucker whether he was involved in union activities because Cannon knew it was illegal to do so based on the training he had received from Prevost.

 

Cannon could not recall if the Union’s petition for election had been filed at the time of the May 25, conversation.  However, Cannon testified he knew about the union activity at the facility as of May 25, stating that, “I picked up a few rumors, that's about it.”  Cannon testified the first indication was from Walt Aumen, the general manager of the dairy plant.  Cannon testified he could not recall the date, but Aumen came into the dairy one morning and a group of drivers were standing in front of the dairy.  Cannon testified when Aumen passed by “he caught a few key words pertaining to union.”  Cannon testified the other rumors were from other drivers to Ortt or Cannon stating “Just union talk.”  Cannon explained, “Nothing in particular or any detailed subject matter.  It was just, they're talking about union, from what we hear.”

 

Prevost testified that he ordered the driver surveillance because of performance issues at the Landover facility.  Prevost claimed he only became aware there was union organizing drive at Landover, after Respondent received notice that the men had submitted cards to have an election.  Prevost testified this was probably the last week of May 2006.  Prevost testified as soon as he learned there was a pending election, he requested his labor counsel to prepare the Tips sheet instructions in terms of what management could and could not say in communicating with employees during an organizing campaign.  Prevost testified he issued the sheet to Taylor, Cannon, John Hoover and the other people in the organization that had contact with the Landover terminal.  Prevost testified as soon as he received the sheet he emailed it to Cannon and Taylor, and he had a training session with them over the phone.  Prevost testified that during the training session they discussed the TIPS memo that they would not threaten, interrogate, make false promises to employees to try to get them to vote against the union, and Respondent would not spy on employees during the organizing campaign.  Prevost testified that during the union campaign, Respondent presented information to the employees as to why they did not need a union at Landover.  He testified that, “our preference would've been to have run without it, but we were fine with it.”  Prevost testified that Respondent started distributing materials about the Union around early June.

 

            Prevost initially testified that he did not have any knowledge of reports of the number of employees for or against the union during the campaign.  He testified that “most of the employees we hired had been laid off from a union company, so I was not surprised when the petition came across and I was not surprised when the vote was in favor of the election.”  He then testified that he received reports from the facility that, “They thought the majority was for the union.  There was six or seven guys that did not want it, but the bulk of them had worked in union organizations before and wanted it.”  Prevost denied receiving reports as to who the union leaders or contacts were.

 

            I do not credit Prevost’s claim that he was unaware of union activity at Landover until after the Union filed its petition for election.  Similarly, I do not credit Cannon’s claim that he was unaware that Tucker was one of the union leaders at the time of the May 25 meeting.  Respondent’s counsel stated the following as part of his opening statement, “After about a month of operating, we began to hear that there were rumors of union organizing going on.  We were aware of it.  We opposed it.  We engaged in a campaign, once the petition was filed, to try and defeat that organizing attempt and it was unsuccessful.”  Since Respondent started operating on March 27, counsel’s remarks place Respondent’s knowledge of the union campaign at the end of April or early May.[12] 

 

            Along these lines, Cannon testified that he knew about the union activity at the time of the May 25, meeting stating that, “I picked up a few rumors, that's about it.”  Cannon testified the first indication was from the general manager of the dairy plant who heard employees were talking about the Union and who passed that knowledge on to Respondent’s officials.  Cannon testified that other rumors of the union activity came directly from the drivers to Ortt and Cannon.  Cannon testified that on May 25, he had just returned to the terminal after a week’s absence, yet he admitted knowing about the Union campaign prior to the May 25, meeting.  Clearly, as Respondent’s counsel admitted, Respondent’s officials gained knowledge of the campaign early on, and I have concluded this information was quickly passed to Prevost, despite his claims to the contrary.

 

While Cannon admitted knowing about union activity prior to the May 25, meeting, he disingenuously claimed that he did know Tucker was involved in union organizing as of May 25.  He admitted to obtaining knowledge of Tucker’s pro-union stance from the drivers later on, but could not recall a date.  He could only state it was after May 25.  Cannon testified that as of the time of the May 25 conversation, he knew it was illegal to engage in any type of surveillance of union activities, to give drivers the impression he was engaging in surveillance of their union activities, or to question Tucker about his union activities, because he received training from Prevost on the Tips sheet prior to the May 25. 

 

Prevost incredibly claimed he only became aware there was union organizing drive at Landover, when he received notice of the Union’s filing of its May 17, petition for election.  Prevost estimated this was probably the last week of May 2006.  Prevost testified that when he became aware of the campaign, he had his counsel prepare the Tips sheet, which he emailed and discussed by phone with Cannon and Taylor.  Cannon’s testimony as to the timing of the Tips trainings reveals that Prevost was aware of the union activity some time prior to Jackson’s May 25, discharge.  Like his denial of knowledge of the union campaign prior to ordering the surveillance, Prevost initially testified that he did not have any knowledge of reports of the number of employees for or against the union during the campaign.  He then testified that he received reports from the facility that, “They thought the majority was for the union.  There was six or seven guys that did not want it, but the bulk of them had worked in union organizations before and wanted it.”  Despite receiving these reports, Prevost denied receiving reports as to who the union leaders or contacts were, although Cannon admitted to receiving those types of reports at least pertaining to Tucker. 

 

In view of the admission by Respondent’s counsel that Respondent was aware of the Union campaign around a month after the operation started, as well as Cannon’s testimony that he received reports about union activity from both dairy personnel and from drivers, I do not credit Prevost’s claim that he did not learn of the union campaign until after the petition was filed.  Cannon’s claim that he did not recall whether the petition was filed at the time of the May 25 meeting is also clearly disingenuous.  He claimed that he received training as to what he could say to employees prior to the May 25, meeting as part of his defense to allegations made by Tucker.  Yet, Prevost testified the training was only initiated due to the filing of the petition.  Therefore, if either are to be credited then Prevost learned of the petition prior to the May 25 meeting, consulted with counsel, had Respondent’s Tips memo distributed to Cannon and Taylor and had a conference call with them prior to the May 25, termination meeting.  If all of this occurred as their testimony indicates, I find it highly unlikely that Cannon would not have been told by Prevost that a petition for election had been filed which Prevost claimed was the basis for the training.  I also find it highly unlikely, that Cannon, who impressed me as an intelligent individual would not have recalled he was aware of such information at the time he participated in the meeting where Jackson was terminated.

 

I have concluded based on the credible testimony, admissions, and the record as a whole that four of Respondent’s employees met with Giles on Sunday, May 7, due to a meeting initiated by Jackson.  They thereafter began distributing cards to the remainder of the unit of about 27 employees for signature beginning the week of May 8.  I have concluded, as admitted by counsel and based on Cannon’s testimony, that Respondent’s officials received reports of this activity shortly after it began from the dairy officials and from drivers themselves.  I also have concluded that this information was quickly relayed to Prevost who was a hands on manager and who was opposed to the facility being organized.  Thus, I discredit his claim that he only first became aware of the union activity after petition was filed on May 17.  I also discredit Cannon’s claim that he did not know Tucker was one of the Union leaders at the time of the May 25 meeting.  Rather, I find they both became aware of the union activity shortly after it began at Landover, and they quickly learned from reports from the drivers that Jackson and Tucker were leaders of that activity.  Any doubt as to this conclusion is confirmed by Tucker’s credible testimony that Cannon accused him of helping to start the union campaign on May 25, and that Cannon had been informed of it by drivers opposing the union. 

 

Clearly, Respondent was receiving information from the drivers and dairy officials and monitoring the status of the Union’s support at the facility.  Both Jackson and Tucker had worked for Giant, which had been organized by the Union, and they concertedly met with Cannon and Ortt on March 20, to protest Respondent’s system of pay, and their protest resulted in a short term change of the system in that their meeting resulted in their receiving wage guarantees during the start up of the operation.  Both Ortt and dispatcher Horner testified Respondent’s method of pay was a source of complaints among employees.  I have concluded that Respondent’s officials knew early on from reports they received from drivers, and from their own surmise were aware that Jackson and Tucker were leaders in the union campaign, and that it was no accident that Tucker was asked to attend Jackson’s discharge meeting or that Cannon had a heart to heart talk with Tucker immediately following Jackson’s discharge.

 

            Concerning the conversation that took place during the May 25, meeting, I have credited Tucker’s version of events over that of Cannon’s.  Tucker, considering his demeanor, testified in a calm and straight forward fashion about the conversation with good recall.  On the other hand, Cannon’s story was somewhat convoluted and did not make sense considering the record as a whole.  Tucker’s and Giles testimony revealed that Jackson contacted the union, and during the union meeting on May 7, it was agreed that Tucker would serve as the intermediary between the other drivers and Giles in terms of the solicitation of union cards.  Tucker, along with Jackson, had prior to the union campaign met with Cannon and Ortt to protest Respondent’s pay policy.  Following the selection of the Union, Tucker continued his course of conduct by serving on the Union’s negotiating committee and attended all the meetings with Respondent’s officials.  The notes of the meetings reveal that Tucker was not afraid to speak and let his feelings be known during the negotiation sessions.  Thus, I do not credit Cannon’s claim that about a week before the May 25, meeting, that Tucker approached Cannon for help, that Tucker told Cannon that the other drivers were coming to Tucker with complaints and that Tucker did not want to play middleman between Respondent and the drivers.  I do not find this claim, which was denied by Tucker to be credible.  Tucker concertedly complained to Respondent about wages with Jackson, voluntarily placed himself as intermediary between the drivers and Giles in terms of card solicitation, and he served on the Union’s negotiating committee.  He voluntarily placed himself in the middle, and I do not find it believable, considering the demeanor of the two witnesses that he elected to complain about his role to Cannon during the middle of the union drive.[13]

 

b. Analysis

 

            Cannon testified he initiated a conversation with Tucker on May 25, in that Cannon wanted to “reiterate that, Kenny, you don't have to be in this position to be the sounding board for the drivers.  We've got office personnel that‑‑ that has that responsibility and has that duty to take care of any type of problems that the driver may have.  I conveyed to him that his response to the drivers, if they did have any complaints, would be, you need to go see management about that.” Thus, Cannon instructed Tucker not to engage in concerted activity by telling him to tell drivers if they had any complaints rather than speak to Tucker they should go see management.  This is akin to instructing Tucker not to discuss work related problems with other drivers, and I find the remark to be violative of Section 8(a)(1) of the Act. See, Jeanette Corp., 217 NLRB 650, 656-657 (1975), enfd. 532 F.2d 916 (3d Cir. 1976); and K Mart Corp., 297 NLRB 80, fn. 2 (1989).

 

            In Bridgestone Firestone South Carolina, 350 NLRB No. 52, slip op. at 2 (2007), the Board stated:

 

     In determining whether an employer's statement has created an unlawful impression of surveillance, the test is “whether the employees would reasonably assume from the statement that their union activities had been placed under surveillance.” Flexsteel Industries, 311 NLRB 257, 257 (1993); United Charter Service, 306 NLRB 150 (1992) The standard is an objective one, based on the perspective of a reasonable employee. Flexsteel, supra. The General Counsel has the burden of establishing, by a preponderance of the evidence, that the employer unlawfully created the impression of surveillance.  Grouse Mountain Lodge, 333 NLRB 1322, 1323 (2001).
     Not all employer statements about employees' union activities are unlawful. An employer does not create an unlawful impression of surveillance where it merely reports information that employees have voluntarily provided. See, e.g. Rock-Tenn Co., 315 NLRB 670, 682 fn. 19 (1994), enfd. 69 F.3d 803 (7th Cir, 1995), and overruled on another point by Chelsea Industries, 331 NLRB 1648 (2000), enfd. 285 F. 3d 1073 (D.C. Cir. 2002). As we recently reaffirmed in North Hills Office Services, “The gravamen of an impression of surveillance violation is that employees are led to believe that their union activities have been placed under surveillance by the employer.” 346 NLRB No. 96, slip op. at 6 (2006) (emphasis in original). Thus, merely informing employees that their coworkers have volunteered information about ongoing union activities does not create an impression of surveillance, particularly in the absence of evidence that management solicited that information. Id.

 

In Bridgestone Firestone, supra, the plant manager issued a letter to employees in which he thanked employees for informing him that a union was attempting to organize the facility.  In concluding the respondent did not create the impression of surveillance by the letter the Board explained the respondent relayed to employees only that certain coworkers had had voluntarily provided information about the existence of the union campaign.  It was stated reasonable employees would not discern from the letter the respondent learned of their activities through a program of unlawful surveillance. Bridgestone Firestone South Carolina, supra., slip op. at 3,

In North Hills Office Services, 346 NLRB 1099, 1101 (2006), the complaint alleged two instances of the creation of the impression of surveillance.  On one occasion, a supervisor told an employee that two of her coworkers reported that the employee drove them to a union meeting.  The supervisor did not deny making the statement but testified he never asked any employee to provide him with information.  In the other instance, an employee testified that during a meeting in which she was given a discriminatory warning for distributing union literature on company time the operations manager told her two of her coworkers informed him that she was distributing union literature during working hours.  The operations manager did not deny making the statement.  In dismissing the Section 8(a)(1) allegations, the Board majority held that volunteering information concerning an employee’s union activities by other employees, in the absence of evidence that management solicited that information does not create an impression of surveillance. 

 

            However, in Flexsteel Industries, 311 NLRB 257 (1993), the Board majority stated:

 

   The judge found that the Respondent created the impression of surveillance when its personnel manager, Don McFarland, on two occasions, informed employee Leroy Clark that he had heard rumors about Clark's union activity. Specifically, in early December 1991, McFarland told Clark he had heard a rumor that Clark had instigated the union campaign. Thereafter, in late December 1991 or early January 1992, McFarland told Clark that he heard a rumor Clark was passing out authorization cards. The judge found that McFarland's disclosures would tend to coerce and restrain Clark from continuing this kind of protected activity. We agree.

* *

It was stated in Flexsteel that “an employer creates an impression of surveillance by indicating that it is closely monitoring the degree of an employee's union involvement. See Emerson Electric Co., 287 NLRB 1065 (1988).” Id at 257.  In Flexsteel it was noted that in two separate occasions in statements coupled with interrogations and implicit threats, McFarland related his knowledge of ‘rumors’ to Clark, thereby informing him clearly that management was aware not only that Clark may have been a union supporter, but was also taking note of the reported manifestations of that support by asserting that Clark may have instigated the union campaign and that Clark had been passing out authorization cards.  It was stated that McFarland's statements, on their face, reasonably suggested to Clark that the Respondent was closely monitoring the degree and extent of his organizing activities, and that these types of statements would reasonably lead Clark to believe that his protected activity was under surveillance, and this would tend to discourage this protected activity. Flexsteel Industries, supra. at 258.

 

            Similarly, in his partial dissent in Flexsteel Industries, member Oviatt stated in agreement with the majority that the respondent there did unlawfully create the impression of surveillance pertaining to another employee when a supervisor told that employee that he knew the employee was getting people to sign authorization cards because people had told the supervisor that he was doing so. Flexsteel Industries, supra. at 260.  In Emerson Electric Co., supra at 1085, the Board, in finding that a plant manager unlawful created the impression of surveillance during a one on one meeting with an employee, stated:

 

Gilbert stated not only that he knew that Alsup had attended union meetings, but also indicated that he knew the extent of this involvement. As set forth above, Gilbert said that he knew that Alsup had “expressed an interest in the union,” but that Gilbert did not consider Alsup to be a “pusher” for or against the union effort. These statements would reasonably suggest to Alsup that the Respondent was closely monitoring the degree of his union involvement. For these reasons we find that the Respondent created the impression of surveillance in violation of Section 8(a)(1) of the Act.

 

The Board reached a similar result in finding a violation in United Charter Service, 306 NLRB 150, 151 (1992), wherein it was stated, “even if it were common knowledge that the employees were attempting to organize, Vieira's comments went beyond permissible limits. Not only did he tell the employees that he knew of their organizing efforts, he also went into detail about the extent of the activities and the specific topics they discussed at the meetings.”  It was found, Vieira's statements reasonably suggested to the employees that the respondent “was closely monitoring the degree and extent of their organizing efforts and activities.”

 

            I find Respondent unlawfully created the creation of the impression of surveillance by Cannon’s remarks to Tucker during the May 25 meeting.  Tucker and Jackson, the two leading union adherents were instructed to attend the meeting.  At the outset of the meeting, Jackson was told he was being terminated and had the allegations for his termination read to him by Taylor, which related to Jackson being followed, videotaped at a store, taking too much time, and falsifying a document.  Jackson was not permitted to defend himself against the allegations.  Jackson then left, and Tucker was alone with Cannon and Taylor.  Cannon pulled his chair within inches of Tucker’s chair.  Cannon told Tucker he knew Tucker was a leader and a professional and that he heard Tucker was involved in starting the union start up.  Tucker responded he was not part of it.[14]  Cannon stated that the guys who were opposing the Union had told him that Tucker was one of the guys helping to start the union up.  Tucker again denied it.  Cannon said, “they did not need a union.  They thought that their open door policy was good enough.”  Cannon stated they did not need a third party and that all unions do is milk companies and employees out of money.  Cannon stated the drivers were saying Tucker was in the middle between the drivers and Quickway.  Cannon stated Tucker should not be in the middle.  Tucker responded he was not in the middle.  Cannon, in fact, admitted his remarks went further testifying he told Tucker, “you don't have to be in this position to be the sounding board for the drivers.  We've got office personnel that‑‑ that has that responsibility and has that duty to take care of any type of problems that the driver may have.  I conveyed to him that his response to the drivers, if they did have any complaints, would be, you need to go see management about that.”  During the meeting, Taylor told Tucker that 10 drivers were followed including Tucker.  Cannon’s comments to Tucker, in the context of this meeting, conveyed to him that Respondent was closing monitoring the extent and nature of his union activities thereby creating the impression of surveillance in violation of Section 8(a)(1) of the Act. See, Flexsteel Industries, 311 NLRB 257 (1993); Emerson Electric Co., 287 NLRB 1065 (1988), and United Charter Service, 306 NLRB 150, 151 (1992).

 

2. The surveillance and discharge of Angelo Jackson

 

            In Benjamin Franklin Plumbing, 352 NLRB No. 71 (2008), in finding that the discharge of two employees violated Section 8(a)(1) of the Act, the Board approved the use of a Wright Line analysis for Section 8(a)(1) allegations that turn on motive. See also, General Motors Corp., 347 NLRB No. 67 fn. 3 (2006) (“Wright Line applies to all 8(a)(3) and 8(a)(1) allegations that turn… on employer motivation”).  In Wright Line, 251 NLRB 1083 (1980), enfd. 662 F.2d 899 (1st Cir. 1981), cert. denied 455 U.S. 989 (1982). Approved in NLRB v. Transportation Management Corp., 462 U.S. 393, 395 (1983), the Board established a framework for deciding cases turning on employer motivation.  To prove that an employer action is discriminatorily motivated and violative of the Act, the General Counsel must first persuade, by a preponderance of the evidence, that an employee's protected conduct was a motivating factor in the employer's decision.  The elements commonly required to support such a showing are union activity by the employee, employer knowledge of that activity, and antiunion animus on the part of the employer. Wal-Mart Stores, 340 NLRB 220, 221 (2003).  If the General Counsel is able to make such a showing, the burden of persuasion shifts “to the employer to demonstrate that the same action would have taken place even in the absence of the protected conduct.” Wright Line, supra, at 1089.

 

            In the instant case, on March 20, Tucker and Jackson met with Cannon and Ortt to protest Respondent’s wage policy, resulting Cannon contacting Prevost and Respondent temporarily instituting a guaranteed wage rate for the drivers at the Landover facility.  Jackson contacted the Union towards the end of April, and he arranged a meeting attended with Tucker, Giles and two other drivers on May 7, at the Union hall.  During the May 7, meeting, Jackson, Tucker and the two other drivers were given union authorization cards for distribution amongst the bargaining unit members.  At the May 7, meeting, Tucker agreed to serve as the intermediary between the drivers and Giles in terms of the collection of union cards.  Thereafter, union cards were distributed amongst Respondent’s drivers by Jackson, Tucker and the two other drivers.  On May 17, the Union filed a petition for election.  On May 22, Respondent had Jackson followed.  On May 25, Respondent discharged Jackson in Tucker’s presence without allowing Jackson to defend himself against the allegations against him.  Tucker was also told he had been followed.  After Jackson left, Cannon told Tucker he knew Tucker was a leader and that he had been informed by other drivers that Tucker had help start the Union.  Tucker denied the allegation, but Cannon persisted and stated the guys who were opposing the Union had told Cannon that Tucker was one of the guys helping to start the Union.  Tucker again denied it.  Cannon told him they did not need a union, their open door policy was good enough, they did not need a third party, and that all unions do is milk companies and employees out of money.  Cannon told Tucker that the drivers said that Tucker was in the middle between the drivers and management, and he stated that Tucker should not be in the middle.  Tucker he responded that he was not in the middle.  Cannon testified that, he initiated the conversation with Tucker and that, “I conveyed to him that his response to the drivers, if they did have any complaints, would be, you need to go see management about that.”  I have concluded that Respondent received reports and concluded from its own surmise that Jackson and Tucker were the leading union adherents.  I have concluded that Cannon unlawfully created the impression of surveillance, and that he unlawfully instructed Tucker not to engage as a middleman between Respondent and the employees thereby instructing him not to engage in protected concerted activities.  There is evidence of knowledge, timing and anti-union animus with respect to Respondent’s surveillance of its drivers.  Under the Board’s Wright Line analysis the burden shifts to Respondent to establish that they would have engaged in the driver surveillance absent the union activity.  This they have failed to do. 

 

Prevost testified Respondent’s operational model for Landover was initially was set with 21 trucks and 21 drivers with a six day a week operation using a first and second shift deliveries.  Prevost testified during the first couple of months the start up at Landover was not making money, and the actual business application was not matching the model.  Prevost testified they were not getting the projected utility out of the men or the equipment they had anticipated going into the business.  Prevost testified that to service the customer, Respondent had to rent extra equipment and extra drivers, and they were not able to hire enough local drivers.  Prevost testified that after a month or six weeks, they made a decision to do driver observations to determine where they had a modeling problem.  Prevost testified he directed Taylor, Cannon, Lyman Helms, then Safety Director John Hoover, and Hoover’s assistant Anna Thomas to be involved in the Landover driver observation.  Prevost testified Respondent would have received the financial reports around the second week of May, so the conversation would have been around May 10 to May 15.  Prevost testified the primary conversation was with Taylor, but he also spoke with Hoover, and they spoke to the others who were involved.  However, the referenced financial reports were not submitted into evidence, thus the decision and timing to commit the surveillance were based solely on Prevost’s testimony, part of which I have already discredited in terms of his claim of lack of knowledge of the employees’ union activities. 

 

            Concerning the actual observations, Prevost testified that he thought six drivers followed.  Prevost testified the observers were given the most efficient route from the dispatch in terms of selecting which drivers were to be observed.  Prevost testified he received several verbal reports about the study.  Prevost testified it was concluded based on the observations that the drivers, due to traffic congestion, could not do double loads as Respondent originally anticipated in its model.  Prevost testified Respondent adjusted the model to go from 21 to 26 drivers, due to traffic.  Prevost testified he only received a negative report about one of the six drivers and the rest were performing as they were instructed.  Prevost testified there were no other changes made to the model.

 

            I find Prevost’s explanation as to the timing and the cause of the observation not be supported by record evidence.  Respondent’s payroll records as summarized in R.A. Exh. 34 reveal that by week ending April 22, Respondent already had hired 24 company drivers, and by week ending May 13, it was up to 25 drivers.  Thus, the model of 21 drivers was adjusted upward before Respondent conducted the surveillance.  Moreover, Cannon testified the company drivers started with a four week guarantee of $1000 a week, which was extended to six weeks.  However, Respondent’s records reveal that the drivers were being paid uniform rates per day, as opposed to Respondent’s mileage and stops formula until May 20. (R. A. Exh. 34, p. 6).  Since the drivers were given a uniform rate per day, then it is unlikely that a driver spending extra time at a store, impacted on his pay, or that he had a reason to do so. 

 

            On May 22, when the pay guarantee ended, Respondent followed Jackson, and shortly thereafter Tucker, the two leading union adherents.  While Jackson apparently did not fill out his log sheet as accurately as Respondent would have liked, Cannon testified that at as of May 22, recording the reason for the delay probably was not required because it was still a new operation.  Thus, Cannon acknowledged as Respondent’s records confirm that Respondent was in a transition period with respect to its operation and pay system, so the drivers, except for the two leading union adherents were not being monitored very closely as to how they filled in the pay forms.  Yet, Jackson was followed on May 22, and fired on May 25, without being allowed to explain the accusations against him.[15]  Respondent’s claims become all the more untenable in that while there were two discrepancies on Jackson’s May 22 trip sheet, only one of two of those misfilings cost Respondent or its customer money.  Cannon testified it amounted to a 20 minute overage, which rounded down cost to Respondent and or its customer $5 in extra pay for Jackson.  Thus, although Prevost testified Respondent was having a hard time retaining drivers, it discharged Jackson who had helped train its other drivers with no warning, or chance for an explanation, for what was in essence a $5 overage.  Respondent’s extreme reaction of discharge by failing to at least give Jackson a warning against future conduct, in the circumstances here, signals that Respondent was motivated by something other than the inaccurate filling out the form and a $5 overage.  That Respondent’s discharge of Jackson was premeditated and in furtherance of Respondent’s anti union cause is further substantiated by Tucker’s testimony that during the same meeting in which Jackson was discharged Taylor showed Tucker a pre-drafted memo to all drivers announcing Jackson’s termination.  Thus, as Tucker credibly testified whatever ever Jackson had to say did not matter as Respondent was intent on firing him.  More than that Respondent was intent on making sure that the employee who had initiated the union campaign had been summarily discharged and that the discharge served as a warning to other employees.

 

The circumstances, behind the actual surveillance also smack of pretext.  Despite Respondent’s contention that it was just a random list of drivers to be followed, Hoover, who along with Thomas did the actual surveillance, testified that the day when he and Thomas arrived at the hotel in Landover from the airport, Ortt came to their hotel, and said, “here's the guy I want you to follow,” in reference to Jackson.  Hoover testified Thomas was present for the conversation.  Hoover testified Ortt only gave them one driver to follow the first day of their observation and that was Jackson.  Hoover testified that Ortt gave him other drivers the next day.  Hoover testified that they only followed three or four different drivers, and he could only recall the names of two of them, Jackson and Tucker.[16]  Hoover testified he could recall these two drivers because Jackson’s performance did not make sense, in that Jackson would sit in the parking lot both before and after making deliveries.  Hoover testified Jackson would sit for no reason and read the paper although Jackson had an empty dock.  Hoover testified when they followed Tucker, he was “Mr. Perfect,” in that he did everything by the book.  As a result of Tucker’s good work, Hoover testified they followed him twice, just in case the first time was not accurate.[17]

 

            Thomas’ testimony varied from Hoover’s.  She said nothing about Ortt meeting them at the hotel the first day they were there, or Ortt’s only naming Jackson as the driver they were to follow the first day.  Contrary to Hoover, Thomas testified she was not involved in any meetings the day of her arrival at Landover “other than we all decided that we would meet at a certain time the next morning, and then all went to our separate rooms.”  Thomas testified the people who were going to carry out the observation met early the next morning and that someone had a list of the drivers.  She testified they divvied the list up among two teams of surveillors.  She testified they each took a couple of driver’s names, and left.  Thomas then changed her testimony stating it was not really a list, but a packet, and when she opened the packet she saw there were three drivers in her packet.  Thomas testified the other team was also handed a packet, but she did not see the driver names in that packet.  Thomas testified both packets were about the same size.  When asked how many drivers were on the list, Thomas testified, “I couldn't tell you that.  I believe we got a list of three or four, and I'm sure that's probably what the other team got.  I don't know for sure.”  Thus, Thomas testimony changed from the amount of drivers she observed from a couple, to three, then to three or four.  Thomas testified the first day Arthur and Hoover were on her team and they went out together.  She testified Lyman and Fred Long were on the other team.  Thus, Thomas did not mention anything about their just following Jackson the first day as Hoover testified; and Hoover did not testify about there being two teams of observers as Thomas claimed. 

 

            Moreover, Respondent did not provide a consistent story to either Tucker or in the testimony its witnesses as to the number of drivers that were actually followed.  Tucker credibly testified that on May 25, Taylor told him ten drivers were followed.  However, Prevost testified it was only about six drivers who were followed.  Ortt gave a differing opinion stating that he provided the list of drivers to be followed and there were only four or five drivers that were followed.  Hoover testified they only followed three or four drivers, and did not mention a second team of observers.  Thomas testified there were two teams of observers, and then varied her testimony stating that from two to four drivers as being the number that her team observed.

 

            Respondent could also provide only limited documentary evidence as to the driver observations.  Aside from evidence pertaining to Jackson, only one other written report was provided relating to driver Andrew Garner.[18]  Cannon stated he received Garner’s report from Taylor, there is no explanation as to why if other reports existed that Taylor did not provide Cannon with all of the reports.  Cannon testified that Jackson was fired for, “Falsification of legal document,” referring to Jackson’s, Monday May 22, trip sheet.[19]  Cannon testified that on the May 22, trip sheet Jackson reported he arrived at store 342 at 12 noon and left at 1:20 p.m.  Cannon testified Jackson would have received $5 detention pay for the 20 minutes over the hour, since the pay is rounded down.  Cannon testified upon reviewing a written report from Taylor, the times Jackson arrived and departed from store 342 were false on Jackson’s trip sheet.[20]  Cannon testified this was a legal document, the falsification of which was cause for termination.  Cannon testified this was the only reason Jackson was terminated.  Cannon testified he is not aware of Respondent terminating any other driver for falsification of legal documents.  Thus, despite its operation of 17 terminals, Respondent put forth no evidence of any other driver being discharged or even disciplined for misstating information on their route sheet.

 

A report written by Taylor to Jackson, dated May 25, states he was observed arriving at his first stop on May 22 at 6:30 a.m. and that he backed into the dock to unload at 7:40 a.m.  He was then observed pulling out of the dock and parking in the store lot at 7:50 a.m. and sitting in his tractor and reading the paper until 8:15 a.m.  It is stated that on his dispatch route sheet Jackson he wrote down that he arrived at the store at 7 a.m. and departed at 8 a.m.  It is stated therein that on his last stop of his four stop route, he was observed arriving at the store at 11:50 a.m. and backing directly into the dock to make his delivery, and that he pulled away from the dock and parked his vehicle in the parking lot at 11:59 a.m., with his delivery completed.  He was then observed of sitting in his tractor until 12:50 p.m. and leaving the area.  On his dispatch route sheet he wrote that he arrived at 12 noon and departed at 1:20 p.m.  It stated on the report that his actions were two acts of dishonesty and constituted falsification of company records as reflected on page 38 of Respondent’s handbook which subjected Jackson to immediate termination.  Taylor stated Jackson’s actions at the last stop required Respondent to pay him 20 minutes for delay time at the last store.  Taylor also wrote that Jackson’s actions were constituted unauthorized absence from duty during regularly scheduled work hours citing page 39 of the handbook which is the subject of immediate termination.  It is stated because of his actions Jackson was terminated immediately.  However, despite the two reasons, listed in Taylor’s letter, Jackson’s typed termination report reflects that he was terminated on May 25, as approved by Ortt on June 2, with only the only stated reason on the report being for “Falsifying Company Documents.” 

 

            Respondent produced in response to the General Counsel’s subpoena request a handwritten memo dated May 25, with Gardner written at the top, which Cannon testified looked to be a report on an observation of driver Andrew Garner.  Cannon became aware of the report through Taylor.  Cannon testified after Taylor resigned from the company, Cannon took over his position; and Taylor gave Cannon all of his files.  Garner recorded on his May 25 trip sheet that he arrived at the third store 108 at 7:45 and departed at 8:50.  He placed at the bottom of the sheet that for store 108, “Docks blocked for 1 hour.”  However, the observation report for Garner states “arrived at 7:36 and immediately docked then talked to another guy (Giant driver) for 15 minutes, then went inside, pulled out 8:45.  The last paragraph on the Garner observation report states, “we left at 11.18 to last store arrived at 11:33 –we proceeded to conduct a grid search to no avail.  At 11:54 a.m. a telephone contact attempt was made.  We were informed driver had not made his delivery yet.  We call Elcott store and they said he was there between 11:00 & 11:30--- At 12:03 he still had not made his delivery.  Waited until 1:15 no show called terminal and they said he called in empties at quarter till 1:00.  The arrival and departure time Garner reported on his trip sheet for the last store was 12:01 to 12:40.  Cannon testified he never confronted Garner for falsification of documents.  He testified he was not aware if Ortt did.

 

            In sum, the credited testimony reveals that on May 22, just five days after the petition for election was filed, Respondent began conducting a surveillance of its drivers.  Included in the surveillance were leading union adherents Jackson and Tucker.  Hoover’s testimony, reveals Respondent’s officials were so anxious to have Jackson watched that Ortt came to their hotel room on the day of their Landover arrival, a Sunday when the terminal was closed, and gave them Jackson’s name stating “here's the guy I want you to follow.”  On May 25, Jackson and Tucker were called into a meeting, and Jackson was summarily discharged without being given a chance to defend himself.  During the same meeting, Tucker was told Respondent had received reports that he had helped start up the Union, and that he was serving as a middle man between drivers and management.  Tucker was told Respondent was opposed to the Union, and that he was to stop serving as a middle man, and to instruct the drivers to take their complaints directly to management.  In response to the evidence of timing, animus, and knowledge, the testimony of Respondent’s officials differed as to the number and names of drivers watched other than Tucker, Jackson, and Garner, and records were only produced for Garner and Jackson with a claim that records for other drivers could not be located since Taylor was no longer employed there.  Yet, Garner, who appeared to have as many deviations in his report as Jackson was not disciplined over the incident.  Respondent officials Hoover and Thomas also gave inconsistent descriptions as to how the surveillance was conducted.  I have also discredited Prevost’s testimony as to his knowledge of union activity at the facility at the time he ordered the surveillance and his reasons for ordering the surveillance were not supported by the documentary evidence as Respondent submitted no records in support of Prevost’s testimony concerning the financial status of Landover, and Respondent had already hired more drivers than the original model called for prior to initiating the surveillance.  The discharge of Jackson was further undercut by the fact that Respondent had only recently changed its system of payment for the drivers, and Cannon’s admission that the drivers were not being scrutinized for their accuracy in filling out the trip sheets at the time because Respondent was in a transition period.  Accordingly, Respondent has not established that it would have engaged in the surveillance of its drivers absent their union activity and I find that surveillance to be violative of Section 8(a)(1) of the Act.

 

      Jackson’s May 25, discharge was a direct result of the surveillance which I have found to be unlawful.  Jackson was terminated shortly after Respondent ended its guaranteed pay system, at a time when Cannon testified the driver’s accuracy in filling out their trip sheet was not being strictly enforced.  Jackson was discharged by Taylor, the regional vice president, although Cannon testified it would normally be the terminal manager’s job to make such a decision to discharge the employee.  Jackson’s overage was only $5 and he was given no warning or chance to defend himself at time when Prevost testified Respondent was having difficulty in securing drivers.  Hoover testified the first day he was there he was giving specific instructions by Ortt that Jackson was the one Ortt wanted Hoover to watch.  The Board has long held that when an employer adopts discriminatory rules as a result of a union campaign, the discipline or discharge of employees pursuant to those rules is unlawful. See, Tuscaloosa Quality Foods, Inc., 318 NLRB 405, 411 (1995); Hyatt Regency Memphis, 296 NLRB 259 (1989); and Baptist Memorial Hospital, 229 NLRB 45 (1977), affd. 568 F.2d 1 (6th Cir. 1977).  I find counsel for the General Counsel’s motion to withdraw the complaint allegation over Jackson’s discharge at the end of his case in chief does not preclude an unfair labor practice finding here since the surveillance allegation remained part of the complaint and was found to be unlawful.  I find that in these circumstances, Jackson’s May 25, 2006, discharge was fully litigated, in that it came about as a result of the unlawful surveillance, and the discharge was violative of Section 8(a)(1) and (3) of the Act. See, Sheet Metal Workers Local 162 (Dwight Lang’s Enterprises), 314 NLRB 923, fn. 2 (1994), holding the General Counsel does not have unlimited discretion to withdraw complaint allegations after presenting evidence.  This concept is especially applicable here because the circumstances concerning Jackson’s discharge were fully litigated as part of the lawfulness of the surveillance involving Jackson and Tucker.

 

C. The interrogations

 

General Counsel witness Kevin Cook worked for Respondent as a company driver out of Landover from March to January 2007.[21]  Cook testified he had one conversation with Cannon and one with Taylor on how he was going to vote in the union election.  He testified the conversation with Taylor occurred first.  It was about two or three weeks prior to the June 22, election.  Cook testified, after he completed his run that day, Ortt asked Cook if he needed a ride home.  Cook stated he was waiting for Tucker to come back because they were riding together.  Ortt said Tucker was gone, and Taylor offered Cook a ride.  Taylor took Cook home in Taylor’s car.  Cook testified that during the drive, “We both was talking and then he started on about the‑‑ about the union election is coming up and he said that he knew he had lost all the Giant drivers and he was hoping that he had my support and vote a no with the union‑‑ and I told him that he had my support.”  Cook later stated when he told Taylor that Taylor had Cook’s support that Taylor said, “good guy or something.”  Cook testified Taylor patted Cook on the knee and then started talking about Taylor’s father.  Cook testified he did not tell Taylor the truth when he told him he had his support with a no vote.  Cook testified he did not tell Taylor the truth, “Because then he'd want them to terminate me or something.”  He testified he was afraid Taylor would terminate him, “Because he was the vice president of the company.”  Cook was aware the company was against the Union.

 

Cook testified he had a conversation with Cannon around a week before the election outside the office in the Landover plant.  The conversation took place when Cook returned from one of his runs.  Just Cannon and Cook were present.  Cook testified he came in from his run, turned in his paperwork and made his copies.  Cannon asked if he could speak to Cook and Cook agreed.  Cook testified, “He walked out of the office and asked how I was doing, and I said I'm doing okay.  He said that he hoped that he had my support with the election, and I said yeah, you got my support, because I was against the union.  And he said, good guy, and he patted me on my shoulder and that was it.”

           

In determining whether a supervisor's questions to an employee constitutes an unlawful interrogation, the Board examines whether under all the circumstances, the questioning tends to interfere with, restrain, or coerce employees in the exercise of Section 7 rights. Rossmore House, 269 NLRB 1176 (1984), affd. 760 F.2d 1006 (9th Cir. 1985).  In making this assessment, the Board reviews various factors, including whether the employee is an open union supporter, the employer's background (whether there is a history of employer hostility and discrimination), the nature of the information sought (whether the interrogator appeared to be seeking information on which to base action against individual employees), the identity of the questioner in terms of how high they are in the company hierarchy, the place and method of the interrogation, and the truthfulness of the reply.  The Board will determine whether under all the circumstances the questioning at issue would reasonably tend to coerce the employee at whom it is directed so that he or she would feel restrained from exercising rights protected by Section 7 of the Act. Carroll & Carroll, 340 NLRB 1328, 1332 (2003).  The Board will also find statements that are not phrased as questions to constitute unlawful interrogations when they are designed to elicit responses from employees about their union sentiments. Medcare Associates, Inc., 330 NLRB 935, 941 fn. 21, citing NLRB v. McCullough Environmental Services., Inc., 5 F.3d 923, 929 (5th Cir. 1993).

 

            Respondent argues that I should not credit Cook because he stated that Taylor patted him on the knee showing approval for his anti-union stance during the first conversation, and he stated that Cannon patted him on the shoulder during the second conversation.  Respondent contends Cooks’ testimony that both Taylor and Cannon had similar reactions to Cook’s anti union response undermines Cook’s credibility.  Respondent also argues that Cook’s testimony as to his remarks about the use of owner operators during the October 15 meeting when the strike vote was taken undermines Cook’s overall credibility. 

 

            Having considered Respondent’s arguments, I am nevertheless persuaded that Cook should be credited concerning his encounters with Taylor and Cannon.[22]  Respondent called both Ortt and Cannon as witnesses.  Ortt did not deny Cook’s assertion that around three weeks before the election, Ortt helped arrange a ride home for Cook with Taylor.  Moreover, Cannon did not deny having the conversation with Cook in the manner Cook testified.  Finally, Prevost admitted that he received reports from the facility that the majority of the employees were for the union in that most of the employees had worked in union organizations before and wanted it.  In a clear reference to Giant, Prevost testified that most of the employees Respondent hired were laid off from a union company.  Thus, Prevost’s testimony serves to corroborate Cook’s testimony that Respondent’s officials, including Taylor, were keenly aware that the ex-Giant drivers supported the Union.  Cook also testified in a credible and consistent fashion about his conversations with Taylor and Cannon, and his testimony is undenied on the record by Respondent’s witnesses who did appear at the hearing.

 

            I find that both Taylor and Cannon violated Section 8(a)(1) of the Act by interrogating Cook.  The union filed a petition for election on May 17.  On May 22, Respondent for the first time at this facility began to follow drivers, including leading union adherents Jackson and Tucker.  On May 25, Respondent discharged Jackson, and during the same meeting told Jackson and Tucker that they had been followed.  Tucker was informed by Cannon in Taylor’s presence that Respondent was a aware Tucker helped start the union, Tucker was serving as a middle man between the drivers and the Respondent, and Tucker should cease acting in that capacity.  On May 26, Taylor issued a memo dated May 25, in all capital letters notifying the drivers of Jackson’s discharge.  While Jackson’s name was not specifically mentioned in the memo, Taylor acknowledged news traveled fast amongst the drivers by starting the memo out, “AS MANY OF YOU ALREADY KNOW A QUICKWAY DRIVER WAS TERMINTATED TODAY…”.  In early June Respondent began to distribute campaign literature against the union.

 

            Viewed against this backdrop, I do not find Taylor’s conversation with Cook to constitute a mere permissible campaign statement by one of Respondent’s officials.  There is no contention that prior to the conversation, Cook had broadcast his sentiments about the union to Respondent’s officials.  Taylor, a regional vice president, was a high level official with Respondent.  Terminal manager Ortt had helped arrange for Taylor to give Cook a ride home in Taylor’s car.  Thus, Cook was a captive audience for a one on one meeting with Taylor.  During the ride home, a conversation about the upcoming union election ensued, and Taylor told Cook that he had lost all the Giant drivers and he was hoping he had Cook’s support with a no vote for the union.  Cook responded that Taylor had his support.  I find Taylor’s remarks were coercive.  First they served to create the impression of surveillance in that Taylor related that Respondent was keeping track of employees’ union sentiments when he stated he knew he had lost the Giant drivers.  Second, his remark that he hoped he had Cook’s support, placed Cook in the Hobson’s choice of not responding thereby creating the inference that he supported the Union, or responding as he did by assuring Taylor that Taylor had Cook’s support.  Given the circumstances of the conversation, and its content, I find Taylor interrogated Cook in violation of Section 8(a)(1) of the Act.  Given Jackson’s recent discharge, which Respondent broadcast to the drivers by memo, it was reasonable for Cook to fear reprisal as he testified if he announced his pro union position to Taylor during the car ride.

 

Similarly, I find Cannon’s encounter with Cook to constitute a coercive interrogation violative of Section 8(a)(1) of the Act.  While Cannon was not a regional vice president at the time of the conversation, his testimony revealed that he had been alternating with Regional Vice President Taylor in supervising the Landover start up.  Cannon was also present, along with Taylor, for Jackson’s termination meeting.  Thus, just a week before the election, Cannon requested a one on one meeting with Cook, outside of Respondent’s office.  Respondent had conducted a campaign against the Union, and Cannon told Cook that he hoped he had Cook’s support with the election.  Cook responded that Cannon had his support and that he was against the Union.  Cook was again placed in a position where he had to respond to a high level official, in a one on one situation, about Cook’s union sentiments.  That Cook felt compelled to misinform Cannon that Cannon had Cook’s support because Cook was against the Union reveals that Cook felt coerced by Cannon’s inquiry.  I have concluded, given the circumstances, Cook’s feelings were reasonable.[23]

 

  1. The diversion of bargaining unit work

 

1. The use of temporary drivers

 

            Respondent began making deliveries out of Landover on March 27, to about 200 Giant stores and 10 Stop and Shop stores.  The Stop and Shop stores were in southern New Jersey.  These deliveries did not require the drivers to layover.  Respondent had 17 company drivers during the week of March 27.[24]  The parties stipulated Respondent also used temporary drivers on an on going basis from the outset of the Landover operation.  The number of temporary drivers Respondent used varied on a daily basis.  For example, during the week of June 1, Respondent used four temporary drivers on Monday, one each on Tuesday, Wednesday, and Thursday, three on Friday, and five on Saturday.  Respondent paid the temporary agencies by the hour, including overtime, for the use of the temporary drivers.  The temporary drivers were compensated by the temporary agencies for their pay and benefits.  The temporary drivers could change from day to day as referral of the drivers was based on the discretion of the temporary agency, subject to Respondent’s right to reject a particular driver.  Respondent generally used a greater number of temporary drivers on Mondays and Saturdays, with Saturdays being the highest usage.  The temporary drivers drove the 21 cabs Respondent originally rented from Ryder to begin its operation.  Respondent would also rent additional cabs as needed from Ryder on a daily basis for the heavier work days, Mondays and Saturdays, for the temporary drivers.  The temporary drivers pulled the same trailers as the company drivers.

 

            The NLRB election was held on June 22, and a certification of representative was issued for the Union on July 10, in the following unit:

 

All full-time and regular part-time company driver employees and hostlers employed by the Employer making deliveries from its domicile at 5 S. Club Drive, Landover, Maryland; but excluding all office clerical employees, professional employees, managerial employees, guards and supervisors as defined in the Act.

 

Following the election, Respondent continued to use the temporary drivers on a weekly basis.  For example, during the week of July 10, Respondent used four temporary drivers on Monday, four on Tuesday, four on Wednesday, four on Thursday, six on Friday, and eight on Saturday.  During the week of August 7, Respondent used four on Monday, three on Tuesday, four on Wednesday, four on Thursday, three on Friday, and six on Saturday.  During the week of September 18, Respondent used four temporary drivers on Monday, three on Tuesday, two on Wednesday, one on Friday, and three on Saturday.  During the week of October 9, Respondent used a temporary driver on Monday, and three on Saturday.  During the week of October 16, Respondent used one temporary driver on Monday, two on Wednesday, one on Thursday, three on Friday, and four on Saturday.[25]

 

2. Bargaining unit driver Branch is offered

to convert to be an owner operator

 

Roger Branch was hired by Respondent as a company driver around April 16.[26]  Branch interviewed for the job as company driver with Cannon and Ortt.  Branch credibly testified to the following: During the interview, Branch told Cannon that Branch owned a company with his own truck, and that he wanted to work for Respondent as an owner operator.  Cannon replied they could not do that at the time, but if Branch took a job as a company driver, Respondent could take him on as an owner operator later and Branch could then drive his own truck.  Branch testified, “I accepted.”  Branch testified Cannon did not give Branch a specific time as to when he could become an owner operator, nor did they discuss what the compensation would be for an owner operator at that time.[27] 

 

Branch was hired by Respondent on April 17 as a company driver at $.45 a mile, $15 a stop, and if there was delay time at the stores $20 an hour broken down into 15 minute increments.  Branch testified after he started working for Respondent, he continued to ask Ortt and Cannon about becoming an owner operator.  Branch testified he and Cannon had a conversation in June 2006, about rates if Branch were to convert to an owner operator.  The conversation took place in Respondent’s office and that he thought Ortt was also present.  Branch testified in response to a leading question that he was approached by management about the conversation.  Branch testified that, during the meeting, Cannon showed Branch three of Branch’s trip sheets dated June 5, 12, and 19, which contained Cannon’s handwriting.  Cannon had used Branch’s mileage and stops for each of those weeks to show Branch what he would have earned as an owner operator for Respondent rather than being a company driver.  Branch testified the numbers Cannon told him he would be paid as an owner operator were $1.13 a mile, $18 dollars a stop, and $.33 a mileage surcharge, which is a fluctuating number to offset the cost of fuel to the driver.  Branch testified Cannon’s calculations were already on the sheets prior to time the meeting started.  Branch testified the mileage for the week of June 19 presented by Cannon was based on Branch’s mileage totals ending on June 24.  Branch testified that since Cannon had Branch’s mileage figures as current as of June 24 at the meeting that the meeting with Cannon took place after the June 22 union election.[28] 

 

            Cannon initially testified that an announcement had been made at Landover that Respondent was to be receiving new northern New Jersey (NNJ) runs, and that Respondent was going to lease owner operators.[29]  Cannon testified that once the word got out that Respondent was going to be picking up the new freight and going to lease owner operators, Branch phoned Cannon at the Newark terminal and inquired whether it was time for them to talk about Branch being an owner operator.  Cannon testified Branch stated he heard Respondent was getting some business and that he was still interested in being an owner operator.  Cannon stated he would probably be out there in the near future and they could talk about it then. 

 

            Cannon testified that he went to Landover, met with Branch, and they went over the contract for owner operators.  Cannon testified they discussed rates Branch could make upon becoming an owner operator.  Cannon did not know the date he met with Branch, but estimated that it was a few weeks before the Union was certified.  Cannon testified they talked about pay regarding dollar per mile, stop pay, what insurance was available through the company, and what insurance was required by an owner operator.  He testified they discussed the other requirements in that the owner operator would have to maintain at least a $1,000 escrow account, and the possibilities of purchasing a license plate for the truck through Respondent.  Cannon testified he took what Branch had made in the past days or even weeks on his mileage and stops when he was running around Washington and Baltimore and applied it to the owner operators pay scale.  Cannon identified his handwriting on the trip tickets he presented to Branch during the meeting testifying he wrote the calculations on the sheet regarding Branch’s pay.  Cannon testified he told Branch they were going to start the NNJ runs at the end of August or beginning of September.  However, the start date of the NNJ runs was pushed back several times until the actual date of October 16.  Cannon testified Branch signed the owner operator agreement on October 13, because he told Cannon he did not want to become an owner operator until Respondent started the NNJ runs.[30]

 

Giles identified a document entitled, “Independent Contractor Agreement,” with Respondent listed as the carrier.  Giles testified Branch gave Giles the document at the union hall on July 16, following a union meeting on that date.[31]  Giles testified Branch told Giles that Respondent had talked to Branch about being an owner operator.  Branch asked Giles what he thought of it, and Giles said not much.  Giles asked Branch what the rates were and Giles told him that he did not think much of the rates.  Guiles testified that, “He told me he had talked to Mr. Cannon about this in the prior week I believe.”

 

On July 17, Giles sent by fax and first class mail a letter to Taylor.  Giles sent the letter because of the information Branch had provided Giles.  In the letter, Giles stated:

 

              As you also may know, the National Labor Relations act (NLRA) prohibits an employer from diverting bargaining unit work from employees in the certified bargaining unit to other employees, or from otherwise converting bargaining unit work to non-bargaining unit work.  Furthermore, the NLRA prevents an employer from unilaterally changing wages, hours and other terms and conditions of employment without bargaining over such proposed changes with the Union.

   It has come to our attention that Quickway intends to offer or already has offered bargaining unit work to drivers and hostlers on an independent contractor, or owner-operator basis.  Such improper diversion of bargaining unit work would violate federal labor law and demonstrate bad faith on the part of Quickway in refusing to bargain with its certified collective bargaining representative.

*.*.*

The Union also demands that Quickway immediately engage in good faith collective bargaining over any proposed change in Quickway’s operations, as well as to commence the forming of a collective bargaining agreement between Quickway and the Union.

 

Cannon responded to Giles by letter dated July 28, in which Cannon stated:

 

   In your letter dated July 17, 2006, you requested information from Quickway Transportation, Inc., with respect to contracting with independent contractors at its Landover terminal because of concerns that Quickway (h)as diverted bargaining unit work to those independent contractors in violation of federal law.  The underlying premise of your letter and your request for information is incorrect.

   Quickway currently has equipment for and needs 26-27 company route drivers to do the work presently being performed at the Landover terminal.  Unfortunately, we only have 22 route drivers and have been supplementing the workforce with the use of temporary employees from a local temp agency.  Because of the cost involved in using temporary employees, Quickway would like to reduce the use of temporary employees and is actively trying to hire additional route drivers to fill the company trucks.

   Quickway has also begun advertising to attract independent contractors to work out of the Landover facility.  We anticipate beginning some additional runs that will require layovers.  Notwithstanding the fact that Quickway does not have enough route drivers to perform its current work, Quickway does not have any sleeper cab equipment at its Landover terminal to perform those runs.  Using company route drivers is therefore not an option, and Quickway will have to supplement its workforce with independent contractors who have sleeper cab equipment.  Those independent contactors may also supplement any work that cannot be performed by route drivers with company equipment.  Suffice it to say, however, despite Quickway Transportation’s plans to use independent contractors, no work is being diverted or taken from bargaining unit employees.[32]

3. The contracting with owner operators

 

Respondent contracted with Thomas Purnell as its first owner operator out of Landover on August 8.  Purnell began running routes for Respondent on August 10, which was a Thursday, and he worked three days that week.  Purnell’s records show beginning August 14, he worked five days a week for Respondent through and including the week of September 18.  Purnell worked four days during the week of September 25, and thereafter resumed his five day a week schedule through the week of October 9.  Purnell was running all local runs during this period, which theretofore had been performed by the company drivers or temporary employees.[33]  Dion Lane was the second owner operator hired by Respondent with a contract date of September 5.  Lane ran five days the week of September 18, three the week of September 25, five the week of October 2, and four the week of October 9.  Terringus Walker entered a contract with Respondent on September 19.  Walker ran three days the week of September 25, four the week of October 2, and six the week of October 9.  Respondent contracted with additional owner operators on October 5, October 10, and on October 13.  Respondent’s records reveal that it had contracted with six owner operators by October 16 the day the NNJ runs began.  Respondent subsequently contracted with additional owner operators on November 14; November 29; December 11, and on December 21.  Cannon testified Respondent had has many as 13 owner operators during the strike beginning on January 12. 2007.

 

            Branch credibly testified to the following:  On October 13, Branch signed Respondent’s agreement entitled “Independent Contractor Agreement.”  Ortt approached Branch and gave him the agreement on October 13.  Branch had previously received a call from Ortt stating that on October 16, Respondent was going to start the new NNJ runs.  On October 16, he began running routes as an owner operator for Respondent. 

 

            As an owner operator Branch used Respondent’s DOT number.[34]  Branch testified that upon signing the contract his runs also changed from local to NNJ runs.  When Branch became an owner operator his compensation was $1.13 for mileage, $18 a stop, and whatever the fuel surcharge was for the week.  Respondent paid for tolls when Branch was a company driver.  As an owner operator, Branch was also reimbursed by Respondent for tolls for about $100 to $150 on a weekly basis.  When Branch was a company driver, Respondent was responsible for his taxes, and when he became an owner operator he was responsible for his taxes.  When Branch became an owner operator he purchased insurance for his truck through Respondent.  He did not insure Respondent’s truck when he drove it as a company driver.  He testified that under the terms of the independent contractor agreement with Respondent, he could only work for Respondent.  He testified this was because he could not use Respondent’s DOT authority without their permission, and he was purchasing his insurance through Respondent.[35]  As an owner operator, Branch had to put a sign on his truck that said Quickway and he had to display Respondent’s DOT number.  The sign was a peel and stick sign.  Branch testified the owner operators were not represented by the Union.  Branch testified, “The operators didn't say that they were.  I assumed myself, once I went on this contract, all my union stuff that I was being represented by, was no longer.”  He testified no one told him this was the case.

 

4. Contract Negotiations August 8 to October 4

 

During contract negotiations, the parties worked from a typed template combining proposals from both the Union and Respondent.  The parties stipulated there were bargaining sessions on August 8, 9, 30, 31, September 1, October 2, 3, 4, November 7, 8, 9, December 6, 7, and 8, 2006, and on January 15 and 17, 2007.  Giles testified in preparing for negotiations with Respondent he contacted the International Union's research department and was sent four contracts that Respondent had with other Teamsters local unions.  Giles testified that all four contracts included owner operators as being covered by the collective bargaining agreement.[36]

 

In attendance for the Union during negotiations sessions were Giles and unit members Tucker and Mark Duncan, and for Respondent were Cannon and Respondent’s attorney James Hanson, with Ortt attending one or two sessions.  During the August 8, session, the parties exchanged proposals.  Giles testified that during the session he informed Respondent that while they may reach tentative agreements on specific proposals nothing was agreed to until they reached an agreement on everything.  Giles testified the Union’s initial proposal on subcontracting was “that bargaining unit work could be subcontracted only if equipment and manpower were exhausted.”  Giles testified Respondent’s initial proposal on subcontracting was included in a proposed management rights article, and it provided for unlimited subcontracting of bargaining unit work.

 

Cannon testified, relying on Hanson’s notes, that during the August 8, session, there was a notation in the notes at page 4, stating, “extra work‑‑offered to available employees already working.”  Cannon testified that there was a discussion on August 8, that extra work would be offered to company drivers that are currently working or scheduled to work.  He testified any company drivers not scheduled to work would be offered to possibly come in on their off day.  Cannon testified that any work beyond that would be offered to subcontractors.  Cannon testified that on August 8, if Respondent needed an extra driver it was offering the work to company drivers first.

 

In addition to the regular attendees, Ortt attended the August 9, session.  During that session, the Union agreed to Respondent’s proposed Article 3 management rights article, with the exception of the last sentence which would have allowed for unlimited subcontracting.  Giles testified that it was reflected in his notes for this session that Hanson stated that when and if Respondent obtained some additional work that involved layovers, they would come to the Union and compare having company drivers do the work versus using owner operators.  Giles responded he wanted it be perfectly clear that Hanson said they would come to the Union when the Company wants to use owner operators on layover runs and Hanson replied, yes, and that they were looking at owner operators to supplement the workforce now in place instead of using temps on some local runs.  Giles testified it is reflected in his notes that he told Respondent again, during the August 9, session that nothing was agreed to until everything was agreed to.

 

            Cannon testified concerning the August 9 session referring to page 15 of Hanson’s notes testified Giles stated on August 9, that the key issues in negotiations were wages, health and welfare, vacation, sick leave, personal days and holidays.[37]  However, as reflected at page 16 of Hanson’s notes, following Giles remarks about the big picture or key issues, a discussion ensued about the use of owner operators.  Hanson’s notes read:

 

JHH: Using o/o’s-replace rent-a-driver-may use in place of—our workforce exhausted.

MO: To cover the temp

CC: O/o’s cant get into some stores- a handful

KT: Will take away from us –my runs[38]

JHH: Not trying to take away from our drivers

PG: Only cannot be run by co. drivers?

CC: Calculation by miles, stops –is issue 75-80% of loads require layover.

PG: How about using cartage agreement?

CC: Not going to do it that way-too expensive.

 

Cannon testified there was a discussion that Respondent was going to replace the temporary agency drivers that Respondent was using to supplement their company driver fleet, and Respondent was going to start using owner operators instead of the temps.[39] 

 

As set forth above, the first owner operator agreement was signed with Respondent for Landover on August 8, for Purnell, who began running routes on a full time basis on August 10.  Giles, referencing his notes, testified he had a phone call with Hanson on August 15.[40]  Giles testified that during the call Hanson told Giles that on August 10, Respondent sent out one owner operator on a regular route.  Hanson stated the driver was off sick and the company offered the work to company drivers including Tucker and it was turned down.  Hanson also stated Respondent had no interest in returning Jackson to work or paying him any money.  Giles asked Hanson to send Giles the video tape they had of Jackson.  Giles testified Hanson did not send him the tape.

 

The next session was August 30.  Giles testified that during the August 30, session, the parties tentatively agreed to a recognition clause that mirrored the NLRB certification.  Giles testified that Respondent’s proposal on Article 3 management’s rights was again discussed at this meeting.  Giles again insisted that Respondent delete the last sentence providing for unrestricted subcontracting from the article.  Hanson replied they would have to put the article on hold.  Giles testified he did believe subcontracting was discussed at the next two sessions held on August 31 and September 1.

 

On September 27, the Union filed an unfair labor practice charge in Case 5-CA-33257, alleging Respondent had diverted and/or subcontracted bargaining unit work by using independent owner operators without bargaining in good faith with the Union.  The charge also alleged Respondent had engaged in direct dealing with employees.

 

            The parties met on October 2.  Giles testified that during the meeting he told Hanson the Union considered anything delivered from the dairy to be unit work, and Hanson had said on August 9, regarding the use of owner operators that when and if they got any work that required a layover, they would talk to the Union and negotiate the use of owner operators versus having Company drivers do it.  Giles testified he considered the work being performed by owner operators to be union work, “Because we were certified as all full and part-time drivers at that location.  There were no owner operators at the time that the operation was started.  It would be new work.  Anything that, you know, was new to the unit, you know, was still covered by the unit.  It was still unit work.”  Giles testified that at the beginning of the meeting, Hanson responded to Giles concern about Respondent’s using owner operators, by stating that Respondent had been subcontracting since they started the Landover operation by using temporary drivers.  Hanson stated if someone feels cheated about this tell us.[41]  It is reflected in Giles notes of October 2, that Giles stated stops were being removed from existing runs and put on new trailers to create additional runs.  Hanson stated the customer tells how and when to deliver the milk.  Tucker asked what about a driver that has a regular run and now he gets something else and an owner operator gets his run.  Cannon stated we never had set loads, and Tucker replied we have had them for the last three months.  Hanson stated we have to check the facts and the parties had a caucus.

 

Giles testified that during the caucus, Giles called MMD and talked to then Dairy Manager Aumen, who has since retired.  After the caucus, Giles made the assertion that he thought the owner operators were being used to do bargaining unit work.  Giles testified he asserted that loads were being manufactured by taking stops off existing runs and combining them to make an additional trailer load of milk.  He testified Hanson’s response is reflected at the top of page two of Giles October 2, notes.  Giles testified Hanson responded that the dairy determines the number of stops and how many dollies are on a trailer.  Giles testified, “We went back and forth” and that Ortt said he was not pulling stops off of the trucks to make additional loads.[42]  Giles testified Tucker said that was not true.  Tucker said, he had seven stops on a specific run, and there was one stop off, so there was only had six stops.  Giles testified the impact of the loss of a stop was  Tucker would have lost mileage and stop pay.

 

Owner operators were discussed later on during the October 2, session as reflected at page 5 of Giles notes.  At that time, Giles stated owner operators were being used to do bargaining unit work.  Giles testified Respondent was not performing any layover runs out of Landover at that time.  Hanson responded Respondent was going to use owner operators on runs that require a layover.  Giles responded that any delivery made from that dairy was bargaining unit work, and that giving it to an owner operator without bargaining with the Union is a diversion of bargaining unit work.  Hanson responded owner operators were not company employees, and were not part of the bargaining unit.  Giles testified, “I responded by saying, look, when this bargaining unit was stipulated to, there were no owner operators but this was new work that should be bargained over.  I asked him specifically have you changed your position on what you told me in August, that the Company would bargain with the Union on the use of owner operators.  He responded, no, not on the new work.  I asked him to explain.”  Giles testified that Hanson said “that to the extent that they use owner operators, as they have used the temps, we will continue our past practice.  He then stated on the new work, we will come to the Union, and if able or not to run without a layover, we'll bargain over the new work and the cost, et cetera.”  Giles testified he responded that when the Union stipulated the bargaining unit, they were unaware of any temps or owner operators.  Hanson responded that it was not the company’s fault that the Union did not know about temps.  Giles stated there were owner operators that were included in the bargaining unit at other Quickway locations and they were covered by the contract.  Giles asked Hanson if he intended intend to bargain with the Union over the use of owner operators.  Giles testified, Hanson “responded by saying, no.”  Hanson went on to state that he had never seen anything like the other Quickway locations where the owner operators pay Union dues but do not receive any benefits under the contract.  Giles testified he ended the session at that time.

 

            Cannon testified that, according to Hanson’s notes, Giles opened up the October 2 session talking about owner operators stating he was going to go to the NLRB for a Section 10(j) injunction.  Cannon testified as he interpreted the notes that during the discussion Hanson responded Respondent had been subcontracting since the start up by using temp drivers, and now Respondent was going to use owner operators doing the same type of work.  Cannon testified the Union made a claim that Respondent was taking stops off current loads to make up additional loads just to give owner operators, and the Union mentioned company driver William Walker was losing loads.  Cannon testified, in reviewing page 43 of Hanson’s notes, that during a caucus Hanson and Cannon placed a call to Ortt, Respondent took the last three weeks of pay of Walker and averaged it out.  Cannon testified the notes show that the average came to in gross wages to $1,215, and the current week was $1,181.  Cannon testified the notes reference a claim from Giles one load went from nine to six stops, which he testified is not a possibility.  Cannon testified Ortt told Hanson and Cannon there were no nine stop loads, that the majority were five to six stops.  Ortt indicated he had only seen one eight stop load.  Cannon testified a driver’s pay fluctuates weekly based on the stores orders.  Cannon testified that following the caucus at 2:03 p.m., they returned to negotiations and Respondent discussed with the Union the information they received from Ortt about Walker’s pay.  Cannon testified Hanson’s notes at page 47, reveals that later on there was a general discussion about subcontracting.  Hanson’s notes read as follows:

 

(general discussion re subk. & NJ runs)

-Co has subc BU work since start of operation

-Co uses o/os everwhere else

-Co will discuss new work with union to see if drivers want that work

-Co will decide when to add driver and equipment

-Co will cost new work by o/os vs. co. driver[43]

 

For the October 3 session, it is reflected at the third page of Giles notes that Hanson referenced Article 15.09 and stated, “15.09 We’re OK.”  Article 15.09 reads:

 

Section 15.09. Bargaining Unit Work/Subcontracting. Supervisory employees or non-bargaining unit personnel may perform the work covered by this agreement or the Employer may subcontract the work covered by this Agreement when all of its employees are working, scheduled to work or are unavailable to work.

 

Giles’s notes reflect that he told Hanson concerning Article 15.09 that the Union maintains the Employer should have enough employees to do the work of the bargaining unit.  Hanson responded that he did not know what Giles meant as it was cheaper to use company drivers than temporaries.  Hanson stated Respondent was not going to have its manpower needs dictated by the Union, and Respondent will decide when it hires and who it hires.  Giles asked Hanson how much temps cost the company and Hanson stated he did not know.  Giles stated bargaining unit work should be covered by union members, and Respondent should maintain enough drivers to do the work of the unit.  Hanson said, as reflected in Giles notes, that if we do not have enough drivers to get the work done, then we will subcontract it.  Giles stated, as reflected in his notes, if the normal work of the union requires 25 people, the company should have 25 drivers, not 10 and then say they can subcontract the rest.  Giles stated as to overtime, drivers who are off work should be offered over time before the company calls in a temporary or anyone else.  If the overtime is refused by the bargaining unit then a temporary would be allowed.  Hanson stated the Union was not going to tell them whether they have 18, 20, or 24 drivers that they were going to staff as they saw fit.  Giles stated if you are subcontracting every day you should be trying to hire someone.

 

During the conversation, Hanson stated he anticipated they were going to start getting some Jersey work in about two weeks, which is referenced by the parties as northern New Jersey work.[44]  Giles testified Hanson stated that some of the routes were up to 500 plus miles, might have 6 stops on them, that on average they would be around 475 miles a trip with 5 stops.  He estimated that it would take 12 to 16 hours to run these trips.  Hanson stated that 65 percent of the routes would take over 14 hours to run.  Giles notes reflect Hanson stated they had done some costing for the routes using owner operators versus company drivers with per diem and hotel, and that it would be 3.5 to 9.5 cents a mile less to use owner operators.  Giles asked what would the costs be without per diem and a hotel, and Hanson said he would have to figure that out.  In response to Giles’ inquiry, Hanson told Giles that Respondent calculated $25 per day per diem and $75 a day hotel costs if they had to layover someone without a sleeper cab.  Giles responded $75 a night for a hotel could buy a lot of sleeper cabs.  Giles asked what Respondent was proposing to the owner operators and Cannon responded the stop pay was $1.33 a mile, and he said that was based on $1.13 a mile and $18 per stop.  Hanson said the tolls were the owner operator's expense.  Giles notes reflect Hanson stated they were proposing to use owner operators for the New Jersey stores for all of the obvious reasons.  Giles asked if that included the New Jersey stores that were currently being serviced, and Hanson said no the new stores.  Giles asked if they were talking about the 54 new Stop & Shop Stores throughout New Jersey that are presently not being handled by Marva Maid, and Cannon replied yes.  Giles stated some of the runs could be handled by the bargaining unit.  Tucker stated they were currently servicing two New Jersey runs that were 400 plus miles and five stops.  Giles stated the Atlantic City run is 433 miles and five stops, and the Rio Grande run is 479 miles and five stops.  Giles testified both were existing runs being serviced by the bargaining unit.

 

Giles testified that they again discussed Article 15.09 later on during the October 3 session.  Giles raised it, and his notes reflect that during the discussion Hanson stated the Union was not going to tell them when to spend money on equipment.  Hanson stated if they get more business they might give it to another carrier.  A discussion ensued about making money, and Hanson said they could make money with owner operators.  Giles stated they must be making more money with company drivers, or they would only have all owner operators.  Giles stated that Article 15.09 and the last sentence of Article 3, the management rights article was a major problem.  Giles stated the company was going to have to do something about it or this was all just a big waste of time.  Giles stated, if you think I'm going to negotiate a contract that allows unlimited subcontracting, then “I'm pissing in the wind.”  Hanson stated it is not that bad, that Respondent had owner operators in other parts of the country, and that some operations are better served by using owner operators.  Hanson stated we now have 24 company drivers, the work we started with, Respondent figured they would need 27 drivers and that was what they want to have.  Giles stated as new work is added, the Union wanted their membership to grow also, and if the work was doable with company drivers, the Union wanted to do it.  Giles stated he was going to have a problem with the subcontracting language as written.  Hanson stated they were trying to do the Landover work with company drivers but the New Jersey runs make more sense with owner operators.  Giles stated they needed to agree on some language because the Union could not agree to open subcontracting language.  Hanson stated they would work on it tonight, and the Union should suggest some language also.[45] 

 

            Cannon testified that on October 3, the parties discussed proposal 15.09 relating to subcontracting.  Cannon referred to page 53 of Hanson’s notes.  Cannon testified Giles stated they were going to hold on Section 15.09, Cannon testified “I guess there was a little bit of disagreement from the union and company, and Phil Giles was still making the plea that the company should hire enough drivers to do all the work.”  Cannon testified there was a discussion if Respondent did not have enough drivers they were going to subcontract out to temporary drivers or even owner operators.  Cannon testified the New Jersey runs were probably referenced during this discussion.  Cannon testified the pay amounts to the owner operators of $1.13 per mile and $18 a stop, were referenced in Hanson’s notes referring to pay 54 of Hanson’s notes.  Cannon testified the fuel surcharge being paid to the owner operators was not included in the calculations presented to the Union.  Hanson’s notes reveal that Giles stated during the meeting, “Average, 45 miles an hour, with stops of 30 minutes each.  If it can be done without a layover, the bargaining unit does it or do it.”  Cannon testified Hanson’s notes again reflect a discussion of subcontracting at pages 58 and 59.  Cannon testified they were still discussing Article 15.09, and Giles had made a statement if Respondent was using subcontractors every day, he insisted that Respondent hire more drivers, or even casual temps or part timers.[46] 

 

The October 4 session was also attended by Ortt.  Giles testified, and his notes reflect, that when they opened the session, Giles made a verbal proposal pertaining to subcontracting of unit work.  Giles testified he proposed the Employer agree the work of the bargaining unit shall include but not be limited to the delivery of dairy products from the Marva Maid Dairy in Landover, Maryland, to retail or wholesale facilities owned or operated by (the name of the operation was left blank in the proposal), that are 500 miles or less in total mileage and can be run without a layover.  The Employer agrees that the deliveries now being made in New Jersey shall remain bargaining unit work.  Giles testified he arrived at the 500 mile limit as a compromise based on his experience that a run of that distance or less could be done without a layover.  Hanson responded he would look at the proposal during a break.

 

            Giles testified that, after the break, Hanson stated as to subcontracting Respondent should have a full complement of drivers by next week.  Giles testified Hanson had previously said that would be 27 drivers.  Hanson stated if they had the full complement of drivers, it was their intent to run the work they originally bid on with company drivers and he hoped everyone would feel better.  Giles responded the Union’s proposal was made to protect the work the unit was handling when the Union filed the petition.  Giles stated his proposal gave definition to the work and there was work that will be new that could also be run with the company drivers.  At the end of the meeting, Giles notes reflect he stated this will not continue much longer, that the Union would be prepared to settle in the next round, and that they would present a total solution to the company.

 

5. The October 15 strike vote

 

Giles testified that on October 15, he held a meeting with members of the bargaining unit.  Giles called the meeting because he was receiving phone calls from members of the union that people were very angry, “that they‑‑ they were anxious to get a contract completed.”  Giles testified Tucker and Duncan served as conduits between bargaining unit members and Giles.  Giles testified Tucker, Duncan, and other drivers called him.  Giles testified, “they were very upset about the pay structure.  They were very upset about their benefits, the fact that there was no contract in place.  So they were just, you know, upset about the whole situation really.”[47]  Giles identified a sign in sheet for bargaining unit employees containing 21 signatures for the October 15 meeting beginning at 9 a.m., and lasting until 10:55 a.m.  Giles identified a two page handwritten agenda that he testified he prepared prior to the start of the meeting.  Giles testified the agenda was not all inclusive of what was discussed at the meeting.

 

Giles testified Tucker opened the October 15, meeting with a prayer, then Giles updated the membership on negotiations stating he felt they were very close on agreement on a lot of the language in the contract.  Giles stated they must be willing to maintain area standards regarding pay and benefits.  Giles stated they would either get an agreement or they would have to do something else.  He stated if they had to do something else they would have to act at a time which would have maximum impact.  Giles stated he had filed strike paperwork weeks ago but the constitution required them to take a vote on whether to strike.  Giles explained this gave the committee the big stick that sometimes got things moving at the bargaining table. 

 

Giles testified he told the members there was an issue that was probably being overlooked that they needed to understand, that Respondent was subcontracting the bargaining unit work, that the Union had filed unfair labor practice charges over this problem, and the outcome of the negotiations did not mean a thing if Respondent continued to outsource their work.  Giles explained the situation in more detail, and then he threw the meeting open to questions.  Giles testified there was a lot of discussion and people were asking for more details on what he told them.  Giles could not specifically recall who spoke at that time.  He testified the discussion, lasting about 30 minutes, was a general discussion with a question and answer period.  Giles testified he explained to the membership about the unfair labor practice charges, that they were important because it was always important to follow the law but even more than that if the Company continued to divert the work we might have to take action to stop the diversion.  Giles testified he discussed the complaint that issued over the termination of Angelo Jackson, and that charges had been filed on the surveillance and the impression of surveillance. 

 

Giles testified that following the discussion they took a strike vote which was unanimous to strike.  Giles stated if it became necessary to strike they would see a picket line when they showed up for work and that they should join the picket line.  Giles testified  he told the employees they were waiting to strike because they were still in negotiations, that it was possible they could resolve the charges, and it was Giles’ hope Respondent would stop diverting work.  Giles testified the diversion of work was the main issue to him.

 

Giles’ written agenda for the meeting reflects a motion was made by Tucker and Duncan to have the negotiating committee continue negotiations until a tentative agreement is reached or in the judgment of the negotiating committee with the approval of the Union’s executive board a strike should be called.  Giles testified the motion was made at the meeting.  Giles testified he knew they were going to make the motion before the meeting started because he had discussed it with them and he filled in their names on the agenda before the meeting started.  Giles testified he did not make any notes on the agenda outline during the meeting, except to add the time the meeting ended.[48]

 

            Tucker testified that, during the meeting, Giles spoke about Respondent’s engaging in unfair labor practices, specifically the firing of Jackson, the videotape and following of Tucker and Jackson, and the diverting of bargaining unit work to owner operators.[49]  Tucker testified they then had a strike vote by secret ballot.  Tucker testified before the strike vote, Giles stated contract negotiations were still going on.  Tucker testified the vote was unanimous to strike.  Tucker testified there was no strike date given at the meeting.  Tucker testified that as far as he could remember there was no discussion about the negotiations, it was all about the unfair labor practices and going on strike for the unfair labor practices.  Tucker testified he gave the opening the prayer and that was all he recalled he talked about at the meeting.  Tucker did not recall making a motion at the meeting to authorize the strike, but he would not deny that he did so.[50]

 

            Kevin Cook testified that, during the meeting, Giles distributed a contract that Respondent had given out, and Giles wanted to go over the whole contract.  Cook testified they took a vote to see if anyone wanted to accept the contract, and everyone turned the contract down.  Giles then explained what an unfair labor practice was, and he stated all the work that came out of MMD was their work as company drivers and no one could come in and take it from them.  Giles then passed out the ballots to take a strike vote and asked if anyone had any questions or any concerns.  Cook testified he did not recall what everyone said, but he stood up and said he was hurting “from losing out on going to northern New Jersey because of the owner operators.”  Cook later testified he said at the meeting “that I was hurting because of the owner operators, that I wasn't making enough money because they were taking most of the work going to North Jersey.”  When confronted that the NNJ runs did not start until October 16, which was after the October 15 meeting, Cook testified, “Well, they was taking the long distance runs, not just the North Jersey.  They were taking the local runs that was long distance.”  Cook testified the owner operators were hurting him.  He testified, “They was also taking the long distance runs going further, Virginia, Delaware.  Cook testified they took a strike vote by secret ballot and it was unanimous.  Cook testified that Giles explained the difference between an unfair labor practice and economic strike.  Cook testified Giles said all the work that comes out of MMD is the company drivers’ work, and it's an unfair labor practice to give it to temp drivers or owner operators.”[51]

 

            Phillip Langhorn testified the meeting started with Tucker leading a prayer and then Tucker spoke for a minute stating they were not getting anywhere at the bargaining table.  Then Giles spoke and said the meetings with Respondent were not going very well, “they weren't getting anywhere, and so we had a strike, a vote to strike.”  Langhorn testified, Giles told them what Respondent had offered and it was not acceptable.  When asked if he recalled Giles saying anything about unfair labor practices, Langhorn testified, “The unfair labor practice was with the owner operators running during our work.”[52]  He testified the unfair labor practice was what they were going on strike about.  When asked what else was discussed with regard to unfair labor practices, Langhorn replied, “we considered unfair was getting paid by the mileage.”  Langhorn testified the drivers said they wanted to be paid by the hour. 

 

            Langhorn testified he thought they discussed Jackson’s being fired for stealing time and that it came up that drivers were being followed.  He testified Tucker raised it, “that they was being I guess targeted, I guess they figured they was and they was being followed by Quickway.”  Langhorn testified that it was not just Tucker who said it.  He testified, “They said they was being watched, and Angelo was being followed.”  Langhorn testified that Giles said, “The unfair labor practice was them taking our work. The owner operators. The vote was conducted on a secret ballot. Strike, a strike vote.”  Langhorn testified it was his understanding that they were going out on strike for the unfair labor practices of the owner operators doing the company drivers’ work.  Langhorn testified Giles gave that reason, and the drivers were complaining about the owner operators taking their work.  He testified a few of the drivers complained about it including Tucker.  Langhorn testified Tucker was speaking for all of the drivers.  Langhorn testified there may have been a discussion about upholding area standards, which is hourly pay.  He testified most of the drivers, including Langhorn, wanted to be paid by the hour.  He testified that was one of the complaints.  He testified, the strike was about the unfair practice with the outside drivers doing our work, as well as the drivers’ desire to be paid by the hour.  Langhorn testified the drivers felt it was unfair to get paid my miles and stops.

 

Jameel Keys testified during the meeting Giles explained they would be going on strike because the work was being given away to temporary drivers and owner operators.  Keys testified the drivers took a vote and agreed if it came to it, they would be prepared to strike.  Keys did not know whether the NNJ runs had started at the time the Union took the strike vote.  Keys testified a lot of times, the company drivers would be back for second runs but there was no run because the owner operators or temp drivers had them.

 

a. Credibility

 

            Giles credibly testified he did not take notes during the October 15 meeting, but created the agenda outline prior to the time of the meeting, except noting the ending time on the outline.  In this regard, the agenda outline was only two pages for close to a two hour meeting and was nowhere near the detail of the contemporaneous notes Giles maintained during the collective bargaining negotiations.[53]  The second page of the agenda outline was mostly left blank except for a description of the pre-planned motion by Tucker at the end of the meeting.  I have also credited Giles and the testimony of the bargaining unit employees that Giles discussed the unfair labor practices at the meeting including the diversion of bargaining unit work.  The negotiations leading up to the strike vote did not focus on economics, rather the parties were dealing with language issues including subcontracting.  In fact, subcontracting was discussed during the August 8, 9, and 30 sessions, and the use of owner operators was specifically discussed on August 9. 

 

            On August 8, Purnell, the first owner operator, signed a contract with Respondent and Purnell began to run routes for Respondent on a full time basis on August 10.  On September 11 and 23, respectively owner operators Lane and Walker began to run routes for Respondent.  On September 27, the Union filed an unfair labor practice charge over the diversion or subcontracting work to the owner operators without bargaining with the union.  On September 29, the Region issued complaint over Jackson’s termination and allegations pertaining to surveillance.  During the October 2, session, there was a discussion regarding the use of owner operators, where Giles and Tucker accused Respondent of pulling stops off company drivers’ routes and giving them to owner operators, and there was a dispute about owner operators doing bargaining unit work in general.  Giles opened up the October 2, meeting by stating the Union was seeking injunctive relief with the NLRB due to the use of owner operators.  During the October 3, meeting, the discussion about the use of owner operators continued, and Hanson informed Giles that Respondent intended to begin the NNJ runs in about two weeks.  On October 4, the last session before the strike vote the discussion about subcontracting continued. 

 

            Thus, during negotiations leading up to the strike vote the Union notified Respondent that subcontracting and the use of owner operators was of major concern to the Union to the extent that the Union had filed an unfair labor practice charge over the diversion of work, and the Union was seeking injunctive relief.  Both Tucker and Giles also accused Respondent of manipulating loads to the benefit of owner operators to the detriment of company drivers.

 

            I find, in these circumstances, that it likely, as Giles credibly testified, that during the October 15, meeting Giles told the members there was an issue that was probably being overlooked that they needed to understand, that Respondent was subcontracting bargaining unit work, that the Union had filed unfair labor practice charges over this problem, and that the outcome of the negotiations did not mean a thing if Respondent continued to outsource their work and to subcontract it.  Giles credibly testified he explained to the membership about the unfair labor practice charges, and if the Company continued to divert the work that they might have to take action to stop the diversion.  Giles credibly testified he discussed the complaint that issued over Jackson’s discharge, and that charges had been filed on the surveillance and the impression of surveillance.  Giles testified he explained in more detail along those lines, and then he threw the meeting open to questions.  Giles testified there was a lot of discussion and people were asking for more details on what he told them. 

 

            While their memories varied as to the specifics of the meeting, the drivers who testified supported Giles description of the meeting.  Tucker testified Giles spoke about Respondent’s engaging in unfair labor practices including the firing of Jackson, the videotaping and following of Tucker and Jackson, and the diversion of bargaining unit work to owner operators.  Cook testified that during the meeting Giles explained what an unfair labor practice was, and he stated that all the work that came out of MMD was their work as company drivers and that no one could come in and take it from them.  Cook testified he did not recall what everyone said, but that he stood up and said that he was hurting “from losing out on going to northern New Jersey because of the owner/operators.”[54]  Cook testified they took a strike vote by secret ballot and that he thought it was unanimous.  Similarly, Langhorn testified, “The unfair labor practice was with the owner operators running during our work.”  He testified the unfair labor practice was what they were going on strike about.  When asked what else was discussed with regard to unfair labor practices, Langhorn replied, “we considered unfair was getting paid by the mileage.”  Langhorn testified the drivers said they wanted to be paid by the hour.  Langhorn testified he thought they discussed Jackson’s being fired for stealing time and it came up that drivers were being followed.  Keys testified that during the meeting Giles explained what they would be going on strike for because the work was being given away to temporary drivers and owner operators.  Keys testified a lot of times, the company drivers would be back for second runs but there was no run because the owner operators or temp drivers had them.[55]  In sum, I have credited Giles and the drivers’ testimony that the unfair labor practices, including the diversion of work to owner operators was raised by Giles during the meeting, that the drivers whose pay was based on the number of miles and stops they ran were concerned about the diversion of bargaining unit work, and that the Union’s unfair labor practice claims played a significant role in the drivers vote to strike.

 

6. Contract negotiations November 7 to December 8

 

Giles testified that, during the November 7 session, subcontracting was discussed and they again discussed Article 3, Management Rights.  Giles told Hanson the Union was not agreeing to the last sentence in Article 3 pertaining to subcontracting.  Giles testified Hanson made a proposal stating hopefully this would resolve the subcontracting and management rights issues.  Hanson said Respondent would agree to delete the last sentence of Article 3 if the Union withdraws its proposal on subcontracting made on October 4, and accepts the Respondent’s proposal on Article 15.09.  Giles credibly testified, “I asked Mr. Hanson a question and I wrote this question verbatim in my notes.”  “Because I considered the question and its answer key.”  Giles testified he wrote in his notes, "Does the Company agree that the work presently being performed is bargaining unit work?"  Giles testified Hanson replied, “Yes.”  Giles testified Respondent acquired the NNJ stores on October 16, and that Giles had been informed by bargaining unit members that some of them had been doing some of the layover runs to NNJ.

 

Giles testified his notes reflect a caucus at 2:10 p.m. following Hanson’s proposal and Giles’ response.  Giles testified he took Tucker and Duncan to Giles’ office and explained to them that he had written verbatim the question and answer in his notes and that he felt that he had nailed down the work that Respondent had agreed to was the New Jersey work and that was the Union’s work.  Giles testified they were only out six minutes and returned following the caucus.  Giles testified when they returned they told Hanson the Union agreed with what he had just proposed and Respondent should withdraw Article 4.02, which was Respondent’s proposal on casual employees.  Respondent caucused and when they returned, there was a discussion about Article 4.02, which Respondent did not agree to withdraw during that session.  Giles testified, however, that during the November 7, session the parties tentatively agreed on the language of Section 15.09.  He testified this was reflected in his notes made on the printed working document, as opposed to his handwritten notes taken at the meeting.  It is stated in Giles handwriting next to 15.09 of the printed working document, “TA 11-7-/06 2:17 p.m.”  It was also stated in Giles actual notes of the meeting that the parties reconvened from a caucus at 2:16 p.m., at which point Giles stated “We agree.”  The latter comment was in obvious reference to Hanson’s proposal on subcontracting.  Giles testified Respondent later withdrew its proposal on Article 4.02 during the November 9, session.[56]

 

Cannon testified referencing page 97 of Hanson’s notes that during the November 9, session there was a discussion of the open issues and they were all related to economics, wages, health and welfare, pension, overtime, holiday pay, vacation pay, sick leave pay, a legal service plan, funeral pay, jury duty time and pay for drug tests.  Cannon testified there was an understanding between the parties that nothing was finally agreed to until the whole contract was agreed to.

 

Giles cited his bargaining notes from December 6, in testifying that at the outset of that session he stated that two complaints issued by the NLRB, and the Company should follow the law.[57]  Giles testified that following his introductory remarks about the NLRB complaints, the remainder of the session was a discussion on economics.  Giles testified that the four sessions following December 6, were also focused on economics, such as wages, benefits, and vacation.  He testified subcontracting issues were not discussed at those sessions.  Giles’ notes for the December 6 session reveal Respondent made its initial overall economic proposal, which included a proposal on wages which called for effective January 1, 2007, $45.5 per mile and $15 a stop.  It was a five year proposal calling for a $.5 per mile increase per year, and beginning the second year of the agreement a $.15 increase per stop a year.  Following Respondent’s presentation of the proposal, the Union caucused.  Tucker and Duncan did not return following the caucus.  Giles informed Respondent’s negotiators that Tucker and Duncan walked out and that they consider Respondent’s proposal insulting.  Giles notes reflect he told Respondent that, “If you wanted to be serious, I would have expected you to propose mileage in “steps.”  Hanson referred to it as a mileage matrix.[58]  The notes reveal Hanson said they would consider it but did not think it was feasible in this area.  Cannon stated, as reflected in the notes, “When I look at the lay of the land, i.e.: Balto and D.C.  It’s such a mess of traffic, it wouldn’t work.”  Giles responded, “My point exactly.  Mileages & stops don’t work.  You gotta pay by the hour in some way, even as a guarantee to back up miles & stops.”

 

            Cannon referencing page 116 of Hanson’s notes testified that on December 6, there was a discussion from Giles wanting Respondent to make a final offer.  Cannon testified it was not referenced in Hanson’s notes, “but as far as that I can recall, Mr. Giles made a comment of putting the company's best foot forward or indicating what you've got here, putting it all on the table.”  Cannon testified Respondent indicated they could put some more money on the table, and then Giles “actually used, as far as what I remember, requesting a best and last and final offer and also using a comment of putting the company's best foot forward, putting it on the table, which–“  I do not credit, Cannon’s testimony here.  Hanson’s notes at page 116, reveal that the following exchange occurred:

           

            JHH: We’ve got some room in the mileage & stops

            PG: Put it on the table-don’t hold back – cut (illegible) the fat to the bone.

 

There is no reference in Hanson’s notes to Giles using the term best, last final offer.  I am convinced if Giles had used such language Hanson, an experienced labor attorney, would have referenced it.

 

            Giles testified Tucker and Duncan returned to negotiations for the December 7, session.  Giles testified that over night he had looked at what Respondent had given him concerning pay records for drivers Tucker and Hughes.  He testified he tried to extrapolate hourly pay from those records and it was very low on an hourly basis.  He testified that on December 7, he told Respondent the records they had provided the Union were obviously not the norm.[59]  Giles notes reveal he stated, “I have some trip cards, hourly rate are very low.  Let’s not play with this.  What you showed me yesterday on Tucker and Hughes obviously is not the norm.  We need to agree on some other means of compensation, that means wages should be hourly.”

 

            Giles testified that, later on in that session, Respondent made a new economic proposal, the terms of which are reflected in Giles notes of the meeting.  Giles testified Respondent offered an increase in mileage rates and in hourly rates for the jockeys.  Giles testified that in response to the proposal that he stated that what Cannon had said the previous day is exactly what the problem is, and that the mileage pay would not work in the area.  Giles stated they did not feel the driver could make a fair wage on mileage pay and he asked if they would be willing to work on a pay system that, within a certain radius of Landover, would be hourly and beyond that would be a mileage-based pay system.  Giles notes reflect that he suggested that within a 75 mile radius of Landover the pay should be hourly pay.  He suggested in the alternative rather than a radius they could identify counties where there would be hourly pay.  Hanson stated they would have to talk about it before responding.  He testified Hanson responded, I do not know if we can get there.  Giles stated where there is a will there is a way.  Hanson stated we were not going to settle this contract based on the Giant contract.  Giles responded, “forget Giant.  We'll settle it with what we consider to be a fair settlement.”

 

            Hanson later stated they could try to develop a matrix, but it is not possible to do by tomorrow.  Hanson stated they had drivers that go into Chicago and Detroit, but do not face traffic jams like you do here.  He asked Giles if the Union had a proposal for a mileage rate, and Giles stated he did not as he did not think they could intelligently do a mileage rate.  Giles notes reflect that as discussion on pay continued, Giles repeated his proposal to have hourly pay within a certain area and mileage and stops beyond that area.  Hanson stated that is why they would come back with a mileage matrix.  He stated as reflected in Giles notes, we are hearing there is a lot of traffic in this area, we agree.  We are trying to address the concern.  Giles, according to the notes stated, we strongly feel that hourly pay is what is necessary to settle this contract.  Giles testified he also told them that we needed health and welfare, retirement, sick leave, and the other things that we proposed.  Giles notes reflect that at the end of the session, he stated more ULP complaints were coming.

 

            At the beginning of the December 8, meeting, Giles came forward with a proposal to Respondent.  Giles’ proposal as reflected in his notes was the drivers were to be paid $18 an hour, $.15 per mile, and $10 per stop.  Giles notes reflect he stated at the outset of the session, “You want incentive pay, we want hourly pay.  Let’s do both.”  Giles proposal included, as reflected in his notes, a daily and weekly guarantee as proposed, overtime as proposed, days off as proposed, sick leave as proposed, H & W as proposed, pension -2.25 all hours worked to Teamster National 401 (K) plan, holidays as proposed, vacation as proposed, funeral pay as proposed, jury duty as proposed.  It is stated in the notes that all leave should be based on hourly rates.  According to Giles notes, Hanson responded after a caucus, “We considered your proposal.  The numbers would annihilate us.  An increase of $800,000.  We’re not interested in that kind of cost.”  Towards the end of the meeting, Hanson told Giles that costs to the company were greater in the Union’s second proposal than in the Union’s first proposal.  Giles responded Hanson should then go with the Union’s first proposal.  Giles also told Hanson that he could not work with Respondent’s incentive pay as he did not have Respondent’s information.  Giles went on to state as reflected in his notes, “This needs to be concluded. One way or another.  I’m available, you tell me.”  Hanson responded they were going back to Nashville and see about a matrix, and that it might not be possible.  Giles later stated, “We’re not going to drag this out for months.  We need to wrap this up now.”  Giles asked for Respondent’s availability.  Giles stated, the “men and the union are really pissed over these ULP’s. The Company needs to stop breaking the law.”  A meeting was scheduled for January 15, 2007, based on the Respondent’s earliest availability.  Giles notes reflect that he stated, “No negotiations for 5 weeks.  Maybe you can get back sooner.”[60]  Cannon testified all the proposals were economic at the December 8 meeting, except for item 14 listed on the notes at page 165, which was the expiration date.

 

            On December 27, Region 5 issued a consolidated complaint against Respondent.  Included in the complaint for the first time was an allegation that Respondent since July 10, 2006, and at all times since then, has assigned work performed by the Union to other employees or independent contractors without prior notice to the Union and without giving the Union an opportunity to bargain in violation of Section 8(a)(1) and (5) of the Act.

 

7. Testimony of Respondent’s witnesses concerning the

need for and use of owner operators

 

Cannon testified there came a point when Respondent considered using owner operators and this related to the addition of 54 northern New Jersey stores (NNJ stores) to its Landover routes.  He testified MMD approached Respondent around June or July, regarding the addition of the NNJ stores.  MMD initially informed Respondent that MMD had about 35 stores in NNJ, however, by the October 16 start date for the NNJ runs the number increased to 54 stores.  Cannon testified Respondent was informed the NNJ stores were going to be 500 and 600 mile roundtrips, with five to possibly six stops on each run, and the routes would require a layover for the driver. 

 

Prevost testified that as part of the purchase of the dairy from Giant, MMD negotiated a minimum volume requirement, and if Giant did not meet that requirement, they were required to make a payment every month to MMD.  After a few months, Giant indicated to MMD that rather than make a cash payment, they would put the additional volume of 50 plus Stop & Shop locations located in New Jersey to be serviced by the Landover dairy.  Prevost testified based on the length of the NNJ runs and the overnights, “we determined it would be most efficiently operated with owner operators.”  Prevost testified the day cabs Respondent runs are purchased at a lower cost than sleeper cabs, and Respondent has a higher utility with the day cabs in that they can be used for up to three shifts.  Prevost testified MMD informed Respondent that since the NNJ work was supplementing the minimum volume requirement it was not permanent, and MMD insisted on a 90-day cancellation clause for the new work in its contract with Respondent.  Prevost testified Respondent was not going to buy expensive sleeper tractors that could be cancelled in 90 days.  Prevost testified Respondent purchased additional trailers for the NNJ runs under the condition that if the business went away, MMD would either buy the trailers from Respondent or reassign them and continue to make a monthly payment for them.  Prevost testified Respondent made the decision to use owner operators for the tractors because the MMD did not have use for the additional tractors.[61]

 

Prevost testified Miller, Respondent’s director of pricing and business analysis, modeled the new routes using company tractors and using owner operators and by far the most economically decision to MMD and to Respondent was to use owner operators.  Prevost testified Landover did not have enough tractors with the original 21 cabs to run the additional 54 northern NNJ stores.  He testified using owner operators was the most economical model for Respondent as it required no capital investment and it required a lower cost to the customer.  Prevost testified Respondent would have had a $900,000 to a million dollar in capital investment if it leased or rented the additional tractors for the new work.  He testified Respondent had done a leveraged buyout in June 2005, so they had certain bank covenants.  Prevost testified purchasing the tractors would have affected Respondent’s debt to equity ratio and it would affect Respondent’s fixed asset leverage ratio.  Prevost testified if the work went away, which it eventually did, Respondent was not stuck with the equipment with owner operators.[62]  Prevost testified the longer the lease for the tractors the lower the fixed asset cost because you are stretching the life of the asset over a longer period of time.  Prevost testified a month to month lease would have been very expensive because lessors do not want to lease month to month.

 

            Prevost testified Respondent was able to lease additional trucks on a daily basis for Mondays and Saturdays as part of its original deal with Ryder to lease the 21 trucks.  Prevost testified when Respondent leased a daily vehicle from Ryder it paid a fixed amount for the daily rental and a variable amount for the miles.  He testified Ryder has a pool of vehicles for daily rentals.  However, he testified they do not have a pool of vehicles for high-mileage short-term rentals.  He testified that would have depreciated Ryder’s asset so rapidly that it would have been cost prohibitive. 

 

Prevost testified there was nothing the Union could have done to convince Respondent to run the NNJ runs with additional company drivers and equipment.  He testified the return on capital analysis indicated it was much more advantageous to the company to use owner operators, especially when the business could have been cancelled on a 90-day notice.  Prevost testified owner operators were not hired or trained until Respondent knew the New Jersey business was coming on line.  He testified Respondent had some owner operators before the NNJ runs started, stating, “We brought them on to train them and we trained them on the existing business.”  Prevost testified there is a clause in Respondent’s contract with MMD that if there was a cancellation MMD had to pay for the trailers.  He testified there is such a provision for the tractors in the initial contract, but MMD would not agree to that for the tractors to be used for the NNJ stores.  Prevost testified it was about 4 cents a mile cheaper to use owner operators than company drivers from Landover for the layover runs.

 

Cannon attended negotiations between Respondent and MMD regarding rates for the NNJ runs.  He testified Respondent decided it would need an additional nine tractors to service the 54 NNJ stores.  It was decided Respondent would also need an additional 12 refrigerated trailers which Respondent purchased for this operation.  He testified Respondent did not receive any compensation from MMD for the purchase of the trailers.  Rather, Respondent was paid for the trailers by the rate MMD paid for the operation.  Cannon testified there was a contractual penalty to MMD if it cancelled the contract for the 54 stores prior to the end of the term in that MMD was obligated to purchase the extra trailers from Respondent.[63] 

 

Cannon testified Respondent’s decision to use owner operators rather than company drivers for the NNJ runs was a collective decision by Respondent’s officials.  Cannon testified the reasons were if Respondent used company drivers, they would have had to purchase additional equipment in the form of nine sleeper cabs.  He testified the decision to use owner operators because Respondent did not want to spend the capital for the nine sleeper cabs at a cost of $100,000’s each.  He testified the cost was the same whether Respondent purchased or leased the cabs.  Cannon testified there was nothing the Union could have offered to change Respondent’s decision not to make the additional capital expenditure.  Cannon testified the decision had nothing to do with actual drivers’ wages.  Cannon testified that in order to get the best utilization of the original 21 day cabs Respondent had acquired when it began the operation, it did not make sense to have those trucks used on runs that required layovers because then they would not be around the next morning.  Cannon testified Respondent was able to take on the 54 new stores without an extra equipment charge to MMD, “because we told them at the very beginning that we can do this with owner operators and we prefer to, because we did not want to invest the capital into a hundred thousand piece of equipment times nine.”  Cannon testified Respondent does not pay per diem or hotel costs when it uses owner operators, which it pays to company drivers who layover with company equipment.[64]  Cannon testified the start of the NNJ runs was expected by Respondent to be in the latter part of August, but it was pushed back several times by MMD until the start date of October 16. Cannon testified Respondent did a comparison and he recalled it being upwards of 17 to 19 cents more per mile to use company drivers for layover runs than owner operators. 

 

Miller testified he analyzed the use of owner operators for the 54 new stores.  He testified the cost of operating with owner operators versus the cost of operating company equipment was a little less expensive to run with owner operators so Respondent could use owner operators and not have to spend the capital to purchase tractors.  He testified the cost of the purchase of 10 sleeper cabs would have been about $900,000.  Miller testified Respondent would have been in the same position if they leased the tractors or purchased them.  Miller testified the leasing of cabs would be a capital investment because Respondent would have to make a five-year commitment for those tractors to a leasing company because a one year lease would be more costly.  Miller testified if they purchased or leased sleeper cabs on a five year lease, if Respondent lost the business, they would have to park the additional cabs or find some new business.

 

Miller testified Respondent started pricing the new business around July and finalized most of the details around the end of September 2006.  Miller testified, “We looked at it under both methods, under company and under owner operators, and we placed the bid based on the basis that we would try to use owner operators because we felt that was the best way to do that from a business sense.”  He testified once Respondent placed the bid the cost was fixed whether Respondent used owner operators or company drivers.  Miller testified the projected cost was about 4 1/2 cents per mile less to do the work with owner operators as opposed to company drivers.  Miller testified the 4 and ½ cent per mile cost differential included the cost of leasing or purchasing additional tractors.  Miller testified some of the company drivers actually made the NNJ layover runs on company equipment.  However, Miller claimed he did not compare the actual cost of those runs by the company drivers to what the owner operators were costing.  Miller testified that when he did the pricing for the 54 stores in July 2006, he did not have any knowledge that the Landover stores were unionized and the union status of Landover was not part of the pricing model.  Miller testified they came up with the cost of the owner operators by using what they thought the market would require to hire owner operators which was around $1.13 per miles plus $15 a stop.  He testified he did the analysis using those figures.[65]  Miller testified he concluded concerning it would be best to hire owner operators to run the NNJ runs without having to spend additional money on company equipment.  Miller testified he provided that conclusion to Prevost, who agreed.

 

Respondent’s records reveal that it had 24 company drivers working the week of October 16.  Respondent’s records reveal that it had contracted with six owner operators by October 16.  Cannon testified, “the purpose of the owner operators, once the northern New Jerseys came on, that they were going to run all of the northern New Jersey runs.”  Cannon testified, however, that after the NNJ runs started, some members of the bargaining unit did do NNJ runs.  Cannon testified that as far as he could recall none of the owner operators did local runs after the NNJ runs started on October 16.  However, Respondent’s payroll records as summarized by counsel for the General Counsel in appendices to his brief reveal that between October 16 and December 30, there were 16 days in which owner operators ran non New Jersey routes referred to as local runs which did not require a layover;[66] there were seven days in which owner operators ran SNJ routes which also did not require a layover and was pre-existing work;[67] and there were nine days in which owner operators ran mixed NNJ and SNJ.[68]  Respondent’s records also reveal that following October 16, company drivers also regularly ran NNJ runs.[69]

 

Cannon testified the maximum owner operators Respondent had was 13, which was during the course of the strike, and at the time of the hearing, Respondent was still using some owner operators, although Respondent lost both the NNJ and SNJ runs shortly after the start of the January 12, strike.  He testified they used owner operators through the strike from January 12 to March 2, 2007.  Cannon testified the owner operators used their own tractors but pulled the same trailers as company drivers and their product was loaded by MMD as it was for the company drivers.  The owner operators were listed on the assignment board as were the company drivers.  Cannon testified referring to the owner operators, temporary drivers and company drivers that “They all did the same work.”

 

Cannon testified that: During the time period of June 1, through October 16, the company drivers could not have handled all of Respondent’s loads because under Respondent’s model they expected the company drivers to run more loads than they were actually running.  Respondent was expecting a large percentage of drivers to run at least two loads a day, but they were not doing that.  As a result, Respondent had to use temp drivers and owner operators.  Company drivers would also call off from work.  Cannon testified it was less expensive for Respondent to use owner operators than temporary drivers, when Respondent was required to rent an extra tractor for the temporary driver.[70]  Cannon testified from the start of the operation to the time of the strike Respondent was trying to hire company drivers. 

 

            Prevost testified the initial projected model for Landover operations included 21 company drivers, and a six day a week operation with first and second shift deliveries.  Prevost testified they were able to hire up to 21 company drivers at some point, but still were not able to complete all of the loads.  He testified they realized they needed change the model to increase it to 26 company drivers to remedy the problem.   Prevost testified they used company drivers, temps, and “we brought in owner operators to train, once the New Jersey business was coming on line.”  Prevost testified, “The model for 26 was to be 26 company drivers, not owner operators.”  Prevost testified while the model called for 26 company drivers, Respondent actually made the increase in numbers by using temps and owner operators.  He testified Respondent had some owner operators before the New Jersey business started, stating, “We brought them on to train them and we trained them on the existing business.”  He testified when Respondent approached 26 drivers it included temporary drivers and owner operators.[71]

 

When asked why Respondent could not hire a full complement of company drivers, Prevost testified there was a high turnover at Landover during the March through December period.  He testified there was no longer high turnover among drivers at the time of the hearing.  He testified Respondent did not lower its hiring standards.  Prevost testified Respondent’s last offer to the Union has been implemented at the facility around a week after it was offered to the Union, which was in mid-January 2007.  He testified that this resulted in a wage increase.  Prevost testified Respondent no longer has a staffing problem at the facility since implementing the wage increase.  Prevost testified Respondent continues to use an owner operator or two at Landover, and continues to use temps there.  He testified when Respondent brought the owner operators on, Respondent never stopped using temporary drivers.

 

Ortt testified as follows: Respondent receives a daily fax from MMD in the afternoon showing the number of dollies each store was receiving the next day.  Ortt then broke the stores down into geographic areas, took the amount of dollies each store was receiving and planned the route for each trailer.  Upon Ortt’s completing the routes they were returned to MMD to load the trailers for the next day’s deliveries.  The dispatcher and terminal manager decided which routes a driver would be given.  The dispatcher, at the time of the hearing, was Arvester Horner.  Respondent tried to use company drivers by having them haul as many loads as possible to maximize their pay and fleet usage.  When Respondent ran out of company drivers they resorted to temporary drivers and at some point it was temps and owner operators.

 

Ortt testified that: Under DOT regulations a driver cannot drive more than 11 hours or work more than 14 hours in a day.  Respondent implemented a sign up sheet, at the Union’s suggestion, where the drivers could sign up for extra loads.  Respondent started using the sign up sheet in September or October 2006, and certain company drivers would regularly sign up.  When a company driver was out on a route they would be given first shot at an extra load.  If they did not want to do it then Respondent would contact any company driver who was off to see if they were interested.  Once Respondent exhausted its company drivers then they would call the temps and owner operators.  When a company driver delivered in the D.C. area they could not expect him to make two runs a day because it was too congested.  Ortt testified a driver could do two runs in the Baltimore area, and make the same amount of money as someone driving one run to Delaware.  Respondent was short company drivers from day one and it was a constant hiring battle.  Ortt testified they hired drivers who saw the work was too hard and left.  Respondent was short three or four company drivers at any given time.

 

            Ortt testified Respondent hired some of the owner operators prior to the start of the NNJ runs.  He initially claimed those owner operators were only used if Respondent was short of company drivers stating they would use the owner operators rather than calling temporary agencies to fill the gap.  He also initially testified that prior to October the owner operators were not scheduled every day, but were basically scheduled on an as needed basis if they did not have their full compliment of company drivers come in.  Ortt testified to offset the delay in the start of the NNJ runs Respondent put the owner operators on hold, and “only used them when we absolutely needed to, until the New Jersey did start up full time.”  Yet, Ortt then admitted that, despite his claim that owner operators were only being used as substitute drivers, the owner operators were being kept fully employed by Respondent.  Ortt testified under Respondent’s agreement with the owner operators they were not free to work for anyone else besides Respondent.  The owner operator was leased to Respondent because the tractor would be in possession of Respondent because Respondent’s DOT numbers were on the side of the tractor.  Ortt testified working with another carrier would have also caused problems with the insurance carrier.  In essence, in order to retain their services, pending the start of the NNJ runs on October 16, Respondent had to keep the owner operators hired prior to that date fully employed.

 

Ortt testified it cost Respondent at least $180 to $250 a day or more to use a temp driver than company drivers.  He testified if there was no vacant tractor for the temporary employee then Respondent had to rent an extra tractor.  Respondent paid the temporary agency by the hour for the temporary drivers, plus overtime rates.  He testified Respondent was paying the temporary agency $10 to $15 an hour per driver.

 

Horner had been employed by Respondent as a dispatcher since July 15 at the time of his testimony.  Horner testified as follows: Saturdays were the heaviest days and Horner could not meet deliveries with Respondents company trucks and drivers alone.  It was also fairly busy on Friday and Monday, with Monday being the second busiest day.  The set up was that no driver could be off on Saturday or Monday, although sometimes they called in sick.  On Mondays, Horner also had more loads than drivers and trucks.  Horner testified Respondent was renting three to five extra tractors from Ryder almost every Saturday since Horner started, and almost every Monday, they had to rent at least one tractor.[72]  When they had more loads on a day than they had scheduled drivers, he would first call company drivers who were already working and if they were not available he would call company drivers who were off that day.  Once he exhausted company driver availability, Horner would then resort to the temporary drivers.  Horner could call a temporary agency and get a driver with as little as two hours notice on many occasions. 

 

Horner testified that at some point Respondent started using owner operators.  Horner testified the owner operators were assigned loads “just like the regular drivers were assigned the loads.  If they called in sick or to take a day off, like I said, I'm going to call the Company drivers first, which I thought owner/operators, Company drivers, I went to them first.  If they was off, if they want to run that extra load.  If they don't want to run that extra load, then I go to the temp.”  When asked if he treated the owner operators the same as he treated the regular drivers, Horner responded, “They had a regular schedule? Yeah, they was assigned the New Jersey runs, yes, sir.  Some of the Jersey runs. So they were assigned on a regular basis? Yes, sir.”  He testified he asked the owner operators just as he did the company drivers if they were available to fill in for extra loads, and then Horner would go to the temporary agencies.  Horner testified he asked the company drivers to do extra loads before he asked the owner operators.  He testified that practice has not changed for the entire time he was there.[73]  Horner testified it was his decision to call drivers who were working first on a given day first to see if they wanted an extra load, and then to call the driver who was off from work.  Horner testified he learned to use this practice at the company he worked for before coming to Respondent.  Horner testified there was never a week where did not have to resort to using temporary drivers. 

 

            Horner testified Respondent receives a cube report from MMD detailing the milk to be delivered the next day to the stores.  The terminal manager then routes the stores with no more than 50 dollies per trailer.  Once everything is routed they send it back to MMD to load the trailers according to Respondent’s routing directions.  He testified it was possible for Respondent to have altered the number dollies in a trailer to give more work to one as opposed to another when they asked MMD to load the trailer.  Horner testified he did not set the routes.  Rather he received the routes and assigned the driver to the route.

 

                                            8. The January 12, 2007 strike.

 

Giles testified a decision was made to go on strike in the last week of December.  The decision was made by the Union’s officers and Giles in consultation with the Union’s legal representatives.  Giles testified it was decided the strike would begin on January 12, 2007, to allow the bargaining unit a couple of weeks of work to help pay for their Christmas holiday.  Giles testified that, “What triggered the decision in the last week of December was the National Labor Relations Board issued a complaint against the Company over the diversion of bargaining unit work.”

 

            Giles testified the parties reached tentative agreement on the subcontracting issue on November 7, and they bargained over economics and some other language issues after that date.  Giles testified he called the strike in January because Respondent’s actions were contrary to what they had agreed to concerning subcontracting.  Giles testified, “If you look at all my bargaining notes and you see the progression of events, that led up to that tentative agreement, you will see that the Company understood the Union's concern over the subcontracting and the Union's willingness to, to allow limited subcontracting to allow the Company to operate in the event that there was a sudden vacancy or absence for some reason.  During this time, the Company continued to hire additional owner operators, and also during this time, it was in mid December, it was after we had had our December session, the Company suddenly brought in, I don't know, 12, 15 drivers from other parts of the country and were using them to ride with the existing bargaining unit members and do all of that.[74]  So I mean I didn't know where any of this was going.  Like I said though, the actions of the company were contrary to what we had agreed to, in the spirit to which we agreed to it.  I'd say it again.  I wasn't trying to stop this Company from offering service to its customer, to have service failures, but we were certainly nailing down the scope of the work and the fact that bargaining unit work should be done by bargaining unit members.  And they continued to hire more owner operators and divert additional work.”

 

Giles testified as follows: The strike began at 9:30 p.m. on January 12, 2007.  Giles called Tucker at about 5 p.m. on January 12, and told him the strike was going to start at 9:30 p.m. and asked Tucker to meet Giles at the dairy at 9 p.m.  When Tucker arrived, Giles had picket signs and picket instructions available.  A few minutes before 9:30 p.m. they put the picket signs on and established a picket line in front of the main entrance to the dairy facility.  Giles had drafted letters dated January 12 addressed to MMD to the attention of Jan Tenpas and Walt Aumen, officials of the Dairy.  The letters state this was to notify them on that date the Union commenced an unfair labor practice strike against Respondent and that a picket line has been established at their shared facility.  Giles delivered the letters by hand to Bob Doe the ranking supervisor at the Dairy at 9:30 p.m. on January 12.  Giles told Doe the letters were addressed to the named individuals and he asked him to deliver the letters, and Doe said he would take care of it.

 

Giles identified the picket sign the Union used during the strike.  The printed portion of the sign was a stock sign.  The sign read “Unfair” and then there's a blank space, and then it says Teamsters Union Local 639.  Giles inserted Respondent’s name in the blank space on the sign.[75]  Giles testified they used the sign that said “Unfair” for the strike at Respondent to signify that they were on an unfair labor practice strike.  Giles also identified picketing instructions which begin with, “You are helping to publicize the strike by Teamsters Local Union No. 639 against Quickway Transportation for their unfair labor practices.”  Giles testified he handed copies of the instructions to the members of the bargaining unit when they arrived at the picket line on January 12, 2007.  Giles testified the picketing that night was in front of the dairy, and that they were wearing the signs.  Giles testified there was no chanting going on.  Giles testified that around 11 p.m. the picket line was moved to the sidewalk in front of Gate 3 of the distribution center.  Giles testified they picketed the entrance and exit gates by walking back and forth within the crosswalk of the driveway entrances when there were trucks entered or exited the facility.  Giles participated in the picketing throughout the strike, and he was there every day at various points in time.  Giles testified while he was on the line he never heard any chanting.[76]  He testified the picket signs remained the same during the strike.

 

Cook testified he showed up for work at 4.m. the day of the strike and was intending to go to work that day, but when he saw the picket line he went on strike.  Cook confirmed his receipt of and Giles description of the unfair labor practice strike instructions as well as Giles description of the picket sign.  Cook participated in the picketing almost every day.  Cook testified, “I was on strike to try to get the work back, try to make more money, because I was upset for the owner/operators taking all of the work.”  Cook testified he thought if they had gotten a contract the strike would have ended and they would have gone back to work.  Cook testified he did not understand the dispute in negotiations between the Union and the Company at that time to be between hourly pay versus miles and stops pay.  Cook testified the dispute was they were trying to stop the owner operators and temp drivers from stealing work from us.  Cook testified, “My understanding was the work that came off the dairy, was supposed to be all company drivers and this was‑‑ the purpose of getting a contract was to stop them from taking the work that we would be running.”[77] 

 

Cook testified the owner operators were running varied runs before the NNJ runs began in that they were given the same runs as the company drivers.  Cook testified he earned the most money by running the longer distance runs due to the increased mileage.  Cook testified he thought the use of owner operators decreased his income because they were giving them the longer runs to NNJ.  Cook told the dispatcher he was willing to take the run, but he would just give it to the owner operators.  Cook testified he was not getting those runs unless an owner operator was not available.  Cook testified he remembered calling Ortt in the morning and asking if he needed Cook to take a run, and Ortt said an owner operator had taken it.[78] 

 

Tucker testified he went on strike because of the unfair labor practices, the firing of Angelo Jackson and the diverting of bargaining unit work.  He testified there was no other reason he went on strike.[79]  He testified if Respondent and the Union reached a contract it would have helped resolve the strike because it would help stop the unfair labor practices by the company.  Tucker testified he did not run layover runs to New Jersey while employed by Respondent, but he did run non-layover runs to New Jersey.  He testified Respondent’s use of owner operators affected him, because sometimes if there was a second run that he could run, then it might not be available if it had been given to an owner operator.  Tucker also testified that in some cases, just to make a load for an owner operator, Tucker may have been deprived of stops on his loads.  Tucker testified he did not recall when this occurred, but he recalled it happening and he brought it up during negotiations with Ortt attending a negotiation session to answer his question.  Tucker testified Ortt did not agree with him because Tucker was asking to be paid for the stop because it would have fit in his load. 

 

9. Contract negotiations January 2007

 

            Giles testified the January 15, 2007, session opened with Hanson stating they were working on a mileage grid.  Giles notes read Hanson stated, “we’ve been working on a final offer. A mileage grid - bands.  Also some other economic proposals and language, but let’s focus on the economics.  We have some language on the shoe allowance that we talked about B-4.  We had also talked about the 72 hours notice of picketing.”  During the meeting, Respondent presented a two page document, entitled “Company’s Economic Proposal, January 15, 2007.”  The proposal included a mileage matrix.  Giles testified based on the work sheets Respondent had provided the mileage matrix proposal came to a rate of $18.99 an hour.  Giles testified that Hanson asserted the January 15 proposal was a 12.3 percent increase.  Giles responded why not add the 12.3 percent increase to the hourly rate Giles had calculated for a floor of $21.25 an hour under Respondent’s mileage matrix.  Hanson responded they could not do that, they do not have it any where in the company.  Giles told Hanson that he was going to have to do something to resolve the hourly pay versus mileage and stops. 

 

            As reflected by Giles’ notes, Hanson stated they had a huge philosophical difference.  Hanson stated he thought the drivers would love the pay package.  Giles stated you do not know them.  Giles stated, as reflected in his notes, “You're in an area where hourly pay, H and W, health and welfare, a pension paid by the employer, and they also expect sick leave.  None of that's here.”  The notes reflect Cannon stated we put together this proposal and it was Respondent’s final offer.  Giles stated we do not accept.  Hanson asked Giles to let the drivers decide, and Giles stated it would be rejected 100 percent.  Giles’ notes reflect that towards the end of the meeting, Giles stated they were not getting anywhere, and asked if Respondent wanted to meet the next day.  Hanson responded, “I don’t think it would do any good.  I don’t know where the compromise lies then.”  Cannon asked Giles if he was going to take Respondent’s proposal to the members for a vote, and Giles stated no they had two members there to ask them what they think of it.  Cannon said they are only seven percent of the group, that it was not fair to the other 93 percent.  Giles asked what happens after it is rejected?  Cannon replied as reflected in the notes, “we’re one step closer to getting through to the end.”  At the end of the meeting, Giles asked if this was Respondent’s last, best, and final offer, and both Cannon and Hanson responded that was correct.  Respondent’s written January 15, 2007, economic proposal includes a proposed a matrix pay system for the drivers based on a 5 year agreement.  In the first year for the first two grids, drivers whose routes were 0 to 75 miles were to receive $.55 a mile, and 76 to 150 miles, $.52 a mile.  There were four grids in all with routes of over 300 miles receiving $.46 per mile.  All of the drivers were to be paid $17 a stop for the first year, with $.25 increases per year. 

 

            Cannon testified he was informed by Giles the contract offer was voted down unanimously by the members on January 16, 2007.  Prevost’s testified Respondent implemented its January 15 offer shortly after the start of the January 12, strike.  However, the Union was never notified the offer was implemented.

 

            Giles testified Respondent’s January 15 offer was incomplete.  He testified there were still several language issues open.  He testified Respondent had advanced numerous work rules in November, and the Union had been waiting for language for the work rules since the beginning of negotiations.  He testified language issues involved the bidding and the carry forward of vacation, the work rules, the assignment of overtime and additional routes.[80]  He testified Respondent’s proposal in reduction of hours was still out there.  Giles testified these things had not been agreed to, and that he did not have Respondent’s position on these items.  Giles testified that, at the January 15 meeting, Hanson started the meeting by stating they had been working on a final offer, a mileage grid slash or dash bands, and some other economic proposals and language.  Giles testified that Hanson, “just blew right by it and went straight to the economics and we never came back to the language.  So Mr. Hanson knew that there were language issues still open in this, in this contract.”  Giles then conceded that he had Respondent’s prior proposals on these issues, and they had not been agreed to or had not been withdrawn.  He testified he had no basis to conclude Respondent had changed its position on those issues prior to that meeting.  Giles testified, “But the proposal that he gave me was everything that they were proposing to conclude the negotiations.  There were other items that were still open and were not addressed in that last offer.”  Giles testified, “They appeared to have been omitted, to me, and I think that there was a probably three or four times during the course of these negotiations that I said to Mr. Hanson, that nothing's agreed to until everything's agreed to.  Now, I think that he clearly started that meeting by saying to me, look, we got some things here, mostly economic, but there's some language too, and then we went right past the language.  The language was never addressed.” 

 

            At the time of the hearing, the parties last met on January 17, 2007, with a federal mediator.  Giles testified that during that session, the Company made a slight modification by proposing a conditional weekly guarantee on wages.  He testified there was still movement being made.  Giles characterized movement by the Union as significant and Respondent’s on January 17th as fairly small but he testified it was still movement.  As reflected in Giles’ notes near the outset of the January 17 session, Hanson stated that in economics there were five major areas of disagreement.  Giles notes read as follows:

 

            JH-We have, in the economics, 5 major areas of disagreement:

1-Producitvity pay-same all around the country. 40% union

2. O/T + Guarantees- We don’t pay o/t.  It’s factored into the pay structure.

3. P/H/sick leave- Co. gives 2 pers. Days, the Union want 6 p/h after 3 yrs + 12 sick days p/y.

4. H & W—We have offered a company plan, we would do L639 H & W but all have to contribute to the plan.

5. Pension- U has proposed 639 pension, has moved off of that & proposed Teamsters Nat’l 401 (k) w/defined contribution, we have an ESOP + have shown the value of that.  We also have a Co. 401 (k) plan w/a 50% match on 6% of emp. Contribution.

PG-Responds to the 5 above + rules + regs +bargaining unit work.

JH- A lot of the language issues will fall into place as we get it done.[81]

 

Giles testified on January 17, after meeting with the Respondent, Mediator Lynn Sylvester returned to talk with the Union, and Giles wrote in his notes the following:

 

LS- I told the Company that the answer to the question is somewhere in the middle.  The concept they are willing to discuss is:

Guaranteed weekly amount w/ the following

1 5 days of availability, including Sat.

2. Doesn’t apply to unexcused absences.

3 Could not refuse load if hours available.

 

Giles testified after Sylvester gave the Union this information, the parties again got together and talked.  Giles notes of that point of the meeting read as follows:

 

PG- Flesh out what your concept is. 

JH- Must be available to work 5 days including Saturday, doesn't apply on unexcused absences. Cannot refuse a load w/hrs available. 

PG- How would you determine the guarantee?

JH- It would be a weekly minimum.

PG- We're not any closer than we were five hours ago.  What about hours, miles and stops? 

JH- We're not interested in hourly wages. 

LS- It seems to me that what it comes down to is what the numbers are.

JH- 5 mos of thinking about it, I still don't know what the solution is.[82]

 

Giles testified then they took a break and Sylvester met with Respondent.  Giles’ notes reveal that when she returned she ended the session by stating:

 

LS –We’re at the end of the rope for today.  I’ve asked them to go back & look at some other things and I’ll stay in touch w/ the Co.

 

Giles testified he did not agree that there was no movement at the January 17 session.  However, Giles testified all Respondent ever proposed was miles and stops.  When asked if that ever changed from the beginning, Giles responded, “I don't think so, no.” 

 

            Cannon testified he recalled talking to Hanson about some type of daily or weekly guarantee.  When asked if Respondent made a formal proposal to the Union on that Cannon testified, “We did.”  However, Cannon then qualified his response stating it was a concept the Union did not accept contending Sylvester made the suggestion to Respondent.  Cannon testified they discussed it, but Respondent did not propose it.  He testified they discussed it at Sylvester’s suggestion, but “No, we did not discuss it with the union.”  Despite Cannon’s claim that Respondent did not discuss the guarantee with the Union, Hanson’s notes stated the following at page 202:

 

4:22 p.m. 

PG, Mr. Giles:  Flesh out concept. 

JHH:  Explained weekly guarantee.  They can't refuse loads, unexcused absences. 

 

It is reflected at page 203 of the notes:

 

PG:  Weekly guarantee ties to hours.  Will, and then 40 or 70 hours, won't agree to something that's not fair. 

JHH:  Eyes of the beholder. 

PG: (Talked about)

PG:  Boils down to we're not interested in mileage and you're not interested in hourly. 

JHH:  Can't figure out how to bridge that gap. 

 

E. Analysis

 

  1. The unlawful transfer of work to owner operators

 

a. Legal principles

 

            In Fibreboard Paper Products Corporation v. NLRB, 379 U.S. 203, 209, (1964), the Court stated, on the facts therein, that contracting out of work previously performed by bargaining unit employees is a subject about which the Act requires bargaining.  There the Court approved the Boards “directing the Company to resume its maintenance operations, reinstate the employees with back pay, and bargain with the Union.”  The Court stated at 214:

 

The facts of the present case illustrate the propriety of submitting the dispute to collective negotiation. The Company's decision to contract out the maintenance work did not alter the Company's basic operation. The maintenance work still had to be performed in the plant. No capital investment was contemplated; the Company merely replaced existing employees with those of an independent contractor to do the same work under similar conditions of employment. Therefore, to require the employer to bargain about the matter would not significantly abridge his freedom to manage the business.

 

The Court also emphasized that a desire to reduce labor costs was a matter “peculiarly suitable for resolution within the collective bargaining framework…”Id at 214.

 

            In First National Maintenance Corp. v NLRB, 452 U.S. 666, 686 (1981), the Court stated:

 

We conclude that the harm likely to be done to an employer's need to operate freely in deciding whether to shut down part of its business purely for economic reasons outweighs the incremental benefit that might be gained through the union's participation in making the decision, and we hold that the decision itself is not part of § 8(d)'s “terms and conditions,…”

 

The Court cited the facts of the case to show the limits of its holding.  In that case, the Employer decided to terminate its cleaning contract with a nursing home, and it had no intention of replacing the discharged employees or moving the operation elsewhere.  The employer’s sole purpose was to reduce its economic loss and there was no claim of antiunion animus.  The employer’s dispute was with the nursing home over the size of its management fee to be paid to the employer.  The Court noted the union was not selected as the bargaining representative or certified until well after petitioner's economic difficulties with the nursing home had begun.  Thus, the Court was not faced not faced with an employer's abrogation of ongoing negotiations or an existing bargaining agreement.  The Court noted the decision to halt the work at the location in question represented a significant change in the employer’s operation, not unlike opening a new line of business or going out of business entirely. Id at 687-688.

 

In Torrington Industries, Inc., 307 NLRB 809 (1992), the Board majority found the employer violated Section 8(a)(5) of the Act by laying off two bargaining unit employees and replacing them with a nonunit employee and independent contractors, without giving the union notice to bargain about the decision and the effects on unit employees.  The Board cited Justice Stewart’s concurring opinion in Fibreboard for the proposition that when all that is involved is the substitution of one group of workers for another to perform the same work at the same plant under the ultimate control of the same employer that such decision does not involve a change in the scope and direction of the enterprise and is therefore not a core entrepreneurial decision which is beyond the scope of the bargaining obligation.  The Board majority concluded that, given the circumstances, it did not have to address the issue as to whether labor costs were a factor of the employer’s decision to subcontract since the employer’s reasons had nothing to do with a change in the scope and direction of its business.  Rather, the employer simply replaced two employees hauling sand and stone with a nonunit employee and independent contractors.  The Board majority noted that no substantial commitment of capital or change in the scope of the business would be involved in negotiating with the Union over retaining the two bargaining unit employees to perform the work.  Therefore whether the decision to replace them was motivated by labor costs, it involved unit employees’ terms of employment and was not at the core of entrepreneurial control.

 

In Naperville Ready Mix, Inc., 329 NLRB 174 (1999), enfd. 242 F.3d 744 (7th Cir. 2001), cert. denied 534 U.S. 1040 (2001), the Board found the employer violated Section 8(a)(5) of the Act when in the midst of contract negotiations and within three days of a strike it instructed its attorney to draft documents setting up ten corporate shells, in which the titles of certain of the employer’s trucks were placed.  After examining the nature of the transactions, the Board concluded they were not arms length business arrangements, but rather stratagem designed to give the appearance rather than the effect of removing the employer from the ready mix business.  It was concluded the employer engaged in a type of subcontracting to subcontractors of its own creation.  It was found there was no major shift in the direction of the employer’s business, rather it continued to engage in the delivery of ready mix product to construction sites with the only difference the work that was being performed by bargaining unit drivers changed to being done by “owner drivers” through an elaborate subcontracting arrangement.  It was also noted that the employer did not engage in a significant redirection of capital in that before and after the purported sale of the corporations into which title of the trucks had been placed, the employer continued to bear financial risk because the new owners had not yet paid for the trucks.  Thus, the employer continued to use the same equipment in which it continued to have an ownership interest.  The Board stated, the employer’s basic operation remained unchanged, and it merely replaced the employees driving the trucks with other employees under the owner operator rubric, and in some cases it used the same employees under the new title, maintaining essentially the same control over them that it always enjoyed.  The Board concluded its motivation for engaging in this maneuver was its concern over the labor costs of a union contract.  The Board found for labor cost reasons the employer subcontracted the work to employees named as owners of the various corporations its attorney had set up.

 

In Overnite Transportation Co., 330 NLRB 1275, 1276 (2000), affd. in part, reversed in part 248 F.3d 1131 (3rd Cir. 2000) (nonpublished), the Board majority cited the rationale pertaining to subcontracting in Torrington Industries, supra. with approval.  In Overnite, the Board majority stated:

 

At issue here is a decision to deal with an increase in what was indisputably bargaining unit work by contracting the work to outside subcontractors rather than assigning it to unit employees.  We think it plain that the bargaining unit is adversely affected whenever bargaining unit work is given away to nonunit employees, regardless of whether the work would otherwise have been performed by employees already in the unit or by new employees who would have been hired into the unit.  In any event, it is not clear in this case that the Respondent’s current employees did not, themselves, lose work opportunities. Overnight, supra at 1276.[83]

 

Thus, the Board has held that a bargaining unit is adversely impacted when new work is subcontracted out rather than letting the unit expand. 

 

In Acme Die Casting, 315 NLRB 202 fn. 1 (1994), the Board majority noted that Torrington is not limited to circumstances where employees are laid off or replaced.  There, the employer was found to have violated the Act when subcontracting to avoid paying employees overtime.  Along these lines, in St. George Warehouse, Inc., 341 NLRB 904 (2004), enfd. 420 F.3d 294 (3rd Cir. 2005), an unlawful transfer of bargaining unit work to temporary employees was found when the employer stopped hiring bargaining unit employees, and replaced those who left with temporary employees.  There the employer had a practice of using temporary employees to supplement its work force, but after a union won an election, the employer stopped hiring bargaining unit employees and increased its usage of temporary employees thereby causing attrition in unit positions.  In Clear Channel Outdoor, 346 NLRB 696 (2006), a violation of the Act was found based on subcontracting of unit work, although no employee lost their job as a result of the subcontracting, and no current employee suffered a loss of wages.  However, it was noted that the parties could have negotiated an increase in the number of bills to be posted by unit employees, and they could have negotiated offering employment to unit employees who had been terminated rather than using subcontractors.

 

            In Sociedad Espanola de Auxilio Mutuo y Beneficiencia de P.R. v. NLRB, 414 F.3d 158, 166-167 (1st Cir. 2005), the court citing the Board’s decision in Acme Die Casting, supra enforced the Board’s finding of unlawful subcontracting holding that the subcontracting was a mandatory subject of bargaining even if it did not result in loss of union jobs.  The court stated:

 

     There is good reason for the Acme Die rule. Union members have an interest in an employer's subcontracting decision in addition to the potential for layoffs. This work provides bargaining unit members with the opportunity to obtain extra shifts (possibly at overtime rates) or to expand the size of the unit through the hiring of new employees. Considering these interests (and possibly others), the Board has reasonably concluded that the duty to bargain over subcontracting extends beyond the circumstance where the employer's subcontracting decision will result in the direct loss of union employment.

 

In Regal Cinemas, Inc., v. NLRB, 317 F.3d 300 (D.C. Cir. 2003), the court affirmed the Board’s finding that a movie theater operator violated Section 8(a)(5) of the Act by refusing to bargain over its converting to manager operated theaters and terminating its union represented projectionists.  The court in Regal Cinemas stated: 

 

      Here, the Board affirmed the ALJ's conclusion that the Fibreboard/Torrington approach governed Regal's decision to convert to manager-operated theaters and thereby eliminate the projectionist position. This conclusion stemmed directly from the ALJ's determination that Regal "has continued to operate the same business at the same locations and the only change is in the identity of the employees doing the work." JDA 16. On review, Regal maintains that the Board's decision cannot be sustained due to its reliance upon Torrington, a decision that, in its view, "creates a virtual 'per se' rule that is incompatible with the test established in First National Maintenance." Br. for Pet'r at 17. Because the Board's decision is both "reasonably defensible," Ford Motor Co., 441 U.S. at 497, 99 S.Ct. at 1849, and consistent with this court's precedent, see, e.g., Rock-Tenn, 101 F.3d at 1446, we reject Regal's challenge. Id. at 310.

                                                               * * *

     Although the instant case involves a transfer of unit work to managers and assistant managers, and not a transfer of unit work to an outside subcontractor, we find this distinction to be irrelevant. What matters, in our view, is that Regal, like the employer in Rock-Tenn, transferred " 'the same work' " performed by the union-represented projectionists to its managers and assistant managers " 'under similar conditions of employment,' " and did so, not because of technological change but, instead, to reduce its labor costs. Id. Given our conclusion that substantial evidence supports the finding that Regal's conversion to manager-operated theaters resulted in a transfer of bargaining unit work, we find the ALJ's legal approach, adopted by the Board to be ‘reasonably defensible.’ Ford Motor Co., 441 U.S. at 497, 99 S. Ct. at 1849. 

 

In Dallas & Mavis Specialized Carrier Co., 346 NLRB 253, 258 (2006), the Board citing Fibreboard Paper Products v. NLRB, supra., and Torrington Industries, supra., found the transfer of work for bargaining unit truck drivers to owner operators to be violative of Section 8(a)(5) of the Act.  The Board stated

 

We reject the Respondent's argument that the decision to replace employee drivers with owner-operators was a change in the scope, nature, and direction of its enterprise pursuant to First National Maintenance Corp. v. NLRB, supra. The Respondent's transfer of the Belvidere-Toledo run to the owner-operators involved “nothing more than the substitution of one group of workers for another to perform the same work.” Gaetano & Associates, 344 NLRB 531, 533 (2005) (citing Fibreboard and Torrington, supra). See also Naperville Ready Mix, Inc., 329 NLRB 174, 181 (1999), enfd. 242 F.3d 744 (7th Cir. 2001), …

 

In San Luis Trucking, Inc., 352 NLRB No. 34 (2008), the Board approved the judge’s findings that an employer violated Section 8(a)(1) and (5) of the Act by transferring a majority of its trucking work from its wholly owned subsidiary to another company.  In finding a violation of Section 8(a)(5) the judge concluded that the subcontracting of the work did not alter the employer’s basic operations as goods were still transported from the subcontractor to the employer’s stores and warehouse.  Rather, the essential difference was a change in the identity of the drivers who transported the grocery goods, and no capital investment was made by or contemplated by the respondent in connection with its decision, in that the respondent had all times maintained its subsidiary’s trucks in a state ready for activation.  The judge stated in San Luis Trucking, id., JD slip op. at 20-21 that:

 

     The Respondents' decision to substitute Unified for SLT to transport grocery goods for Factor Sales was motivated, at least in part, by labor costs, which are amenable to collective bargaining. This is demonstrated by the Respondents' reliance on SLT's alleged losses as a reason for the transfer of SLT's business to Unified. Dorsey Trailers, Inc., 321 NLRB 616, 616-617 (1996), enf. denied 134 F.3d 125 (3d Cir. 1998); Rock-Tenn Co., 319 NLRB 1139, 1139 fn.2 (1995);[84] Furniture Renters of America, Inc., 311 NLRB 749, 750 (1993) enf. denied 36 F.3d 1240 (3d Cir. 1994) ("labor costs were a factor in the subcontracting decision").
                                                   * * *

     Alternatively, ‘it is well established that an employer's subcontracting decision cannot be a legitimate entrepreneurial decision exempt from bargaining when, as here, antiunion considerations are at the heart of the alleged fundamental change in the direction of the corporate enterprise.’ Joy Recovery Technology Corp., 320 NLRB 357 fn. 3 (1995), enfd. 134 F.3d 1307 (7th Cir. 1998).  Thus, even if the Respondents' decision to subcontract SLT's transportation business to Unified were deemed to constitute a change in the scope and direction of the business, the decision would nevertheless be a subject of mandatory bargaining if it was motivated by antiunion considerations. The evidence demonstrates that the Respondents' decision to subcontract SLT's transportation business to Unified was motivated by and was in response to the union activities of SLT's drivers. [FN11] Accordingly, the Respondents' failure to notify the Union or bargain with it concerning the decision to subcontract SLT's work to Unified violates Section 8(a)(5) and (1) of the Act.

b. Respondent unlawfully diverted bargaining unit work[85]

 

            In the instant case, on March 27, Respondent began operations at Landover servicing about 200 Giant stores in Virginia, Maryland, Washington, D.C., and Delaware.  Respondent’s initial operations also included 10 Stop and Shop stores in Southern New Jersey. (SSJ).  On its initial assumptions, Respondent expected to operate with 21 drivers and 21 tractors, based on the idea drivers running short distance runs could perform two loads per day.  From the outset of the operation, in addition to its company drivers, Respondent used drivers hired through and employed by temporary agencies.  Respondent used temp drivers on a daily basis and their numbers fluctuated based on the rise and fall of the store orders for dairy products, with the heaviest usage of temp drivers on Saturdays and Mondays.  The temp drivers for the most part were scheduled the day before they were used, and could be procured with as little as two hours notice.  The temporary agencies controlled which drivers were sent to Respondent, subject to Respondent’s being able to reject a particular driver.

 

            The NLRB election was held on June 22, and a certification of representative was issued for the Union on July 10, in a unit that included, “All full-time and regular part-time company driver employees and hostlers employed by the Employer making deliveries from its domicile at 5 S. Club Drive, Landover, Maryland…”.  Following the election, Respondent continued to use the temp drivers on a weekly basis.

 

The testimony of Respondent’s officials reveals that, sometime in June or July, MMD approached Respondent about the addition of NNJ runs, which was initially estimated at 35 stores, and then increased to 54 stores.  Cannon testified Respondent was informed the NNJ stores were going to be 500 and 600 mile roundtrips, and many of the new routes would require a layover for the driver.  Cannon testified the start of the NNJ runs was expected by Respondent to be in the latter part of August, but it was pushed back several times by MMD to the actual start date of October 16.

 

            As a result of the upcoming contract for the new runs, Cannon contacted and met with company driver Branch, after the June 22, election sometime in late June or early July, and he offered Branch a chance to convert to owner operator.  Cannon told Branch the pay as an owner operator was $1.13 a mile, $18 dollars a stop, and $.33 a mileage surcharge.  Cannon also discussed with Branch other requirements in that the owner operator would have to maintain at least $1,000 escrow account, and the possibilities of purchasing a license plate for the truck through Respondent.  Branch felt the money Respondent was offering was not sufficient for local runs, but agreed to convert to owner operator status when the longer NNJ runs began.[86] 

 

            On July 16, Branch met with Giles and showed him a copy of the “Independent Contractor Agreement” Cannon had given Branch.  Branch also discussed with Giles rates Respondent was offering Branch if he agreed to convert to owner operator status.  On July 17, Giles sent by fax to Taylor, a letter stating, “It has come to our attention that Quickway intends to offer or already has offered bargaining unit work to drivers and hostlers on an independent contractor, or owner-operator basis.  Such improper diversion of bargaining unit work would violate federal labor law and demonstrate bad faith on the part of Quickway in refusing to bargain with its certified collective bargaining representative.”  Giles went on to state that the Union demands Respondent immediately engage in good faith collective bargaining over any proposed change in Quickway’s operations, as well as to begin negotiations for a collective bargaining agreement.

 

            Cannon responded to Giles by letter dated July 28, in which Cannon stated the Respondent has equipment and needs for 26 to 27 company drivers, but only had 22 and had been supplementing the workforce with temporary employees.  Cannon stated the Respondent was actively seeking to hire additional company drivers to fill company trucks in an effort to cut costs by decreasing the use of temporary employees.  Cannon also told Giles that Respondent had been advertising for independent contractors in that they anticipated some additional runs that would require layovers.  Cannon stated Respondent did not have enough company drivers to perform its current work, and it did not have any sleeper cabs at Landover.  Cannon stated, “Using company route drivers is therefore not an option, and Quickway will have to supplement its workforce with independent contractors who have sleeper cab equipment.  Those independent contactors may also supplement any work that cannot be performed by route drivers with company equipment.  Suffice it to say, however, despite Quickway Transportation’s plans to use independent contractors, no work is being diverted or taken from bargaining unit employees.”

 

Respondent contracted with Thomas Purnell as its first owner operator out of Landover on August 8 and Purnell began running routes on August 10.  Purnell’s records show beginning August 14 through October 16, Purnell was working a full time schedule for Respondent equivalent to the full time schedule of the company drivers.  Purnell was running all local runs during this period, which theretofore had been performed by the company drivers or temporary employees.

 

Contract negotiations began on August 8.  Giles testified in preparing for negotiations, he obtained copies of four contracts which Respondent had at other terminals with other Teamster locals.  Giles testified that in all four contracts owner operators were covered by the collective bargaining agreement.[87]  During the August 8, session, Giles informed Respondent that while they may reach tentative agreements on specific proposals nothing was agreed to until they reached an agreement on everything.  The Union’s initial proposal on subcontracting was “that bargaining unit work could be subcontracted only if equipment and manpower were exhausted.”  Respondent’s initial proposal on subcontracting was included in a proposed management rights article, and it provided for unlimited subcontracting of bargaining unit work.[88]

 

Giles credibly testified, as reflected in his bargaining notes, that during the August 9, session, Hanson stated when and if Respondent obtained some additional work that involved layovers, they would come to the Union and compare having company drivers do the work versus using owner operators.  Giles responded he wanted it be perfectly clear that Hanson said they would come to the Union when the Company wants to use owner operators on layover runs and Hanson replied, yes, and that they were looking at owner operators to supplement the workforce now in place instead of using temps on some local runs.  The following is reflected at page 16, of Hanson’s notes:

 

JHH: Using o/o’s-replace rent-a-driver-may use in place of—our workforce exhausted.

MO: To cover the temp

CC: O/o’s can’t get into some stores- a handful

KT: Will take away from us –my runs

JHH: Not trying to take away from our drivers

PG: Only cannot be run by co. drivers?

 

Cannon testified there was a discussion that Respondent was going to replace the temporary agency drivers that Respondent was using to supplement their company driver fleet with owner operators.  Thus, Hanson’s notes reveal the Union was told that owner operators were just going to be used as temporary drivers were, that is to fill in for work when Respondent’s company driver work force was exhausted.  There is no claim that the Union was told that the owner operators were going to be scheduled on a full time basis to perform local runs.  Along these lines, Giles credibly testified he had a phone call with Hanson on August 15, during which Hanson told Giles that on August 10, Respondent sent out an owner operator on a regular route.  Hanson stated the company driver was off sick and the company offered the work to company drivers and it was turned down.

 

Respondent signed its second contract for an owner operator with Lane on September 5,[89]  and entered a contract with the owner operator Walker on September 19.[90]  On September 27, the Union filed an unfair labor practice charge alleging Respondent had diverted and/or subcontracted bargaining unit work by using independent owner operator delivery drivers without bargaining in good faith with the Union.  The charge also alleged Respondent had engaged in direct dealing with employees.[91]

 

            The parties met on October 2.  Giles opened up the meeting talking about owner operators stating he was going to go to the NLRB for a Section 10(j) injunction.  Cannon testified Hanson stated Respondent had been subcontracting since the start by using temp drivers, and now Respondent was going to use owner operators doing the same type of work.  Cannon testified the Union made a claim that Respondent was taking stops off current loads to make up additional loads just to give owner operators work.  Giles credited testimony reveals that at the beginning of the October 2 meeting, Hanson responded to Giles’ concern about Respondent’s using owner operators, by stating Respondent had been subcontracting since they started the Landover operation by using temp drivers.  Hanson stated if someone feels cheated about this tell us.  During this session both Giles and Tucker accused Respondent of taking stops off company drivers’ loads, and Tucker’s in particular, and giving those stops to owner operators.

 

The discussion about owner operators continued later on during the October 2, session.  Giles again asserted that owner operators were being used to do bargaining unit work.  Hanson responded the Respondent was going to use owner operators on runs that require a layover.  Giles responded that any delivery made from that dairy was bargaining unit work, and that giving it to an owner operator without bargaining with the Union is a diversion of bargaining unit work.  Hanson responded owner operators were not company employees, and were not part of the bargaining unit.  Giles testified, “I responded by saying, look, when this bargaining unit was stipulated to, there were no owner operators but this was new work that should be bargained over.  I asked him specifically have you changed your position on what you told me in August, that the Company would bargain with the Union on the use of owner operators.  He responded, no, not on the new work.  I asked him to explain.”  Giles testified Hanson said “to the extent that they use owner operators, as they have used the temps, we will continue our past practice.  He then stated on the new work, we will come to the Union, and if able or not to run without a layover, we'll bargain over the new work and the cost, et cetera.”  During the discussion, Giles stated there were owner operators included in the bargaining unit at other Quickway locations and they were covered by the contract.  Giles asked Hanson if he intended intend to bargain with the Union over the use of owner operators.  Hanson “responded by saying, no.”  Hanson went on to state that he had never seen anything like the other Quickway locations where the owner operators pay Union dues but do not receive any benefits under the contract.  Giles ended the session at that time.  Hanson’s notes at page 47 read as follows concerning the discussion about owner operators:

 

            (general discussion re subk. & NJ runs)

-Co has subc BU work since start of operation

-Co uses o/os everywhere else

-Co will discuss new work with union to see if drivers want that work

-Co will decide when to add driver and equipment

-Co will cost new work by o/os vs. co. driver

 

            During October 3 session, the parties discussed proposed Article 15.09 concerning subcontracting.  Giles told Hanson concerning Article 15.09 that the Union maintains the Employer should have enough employees to do the work of the bargaining unit.  Hanson stated Respondent was not going to have its manpower needs dictated by the Union, and Respondent will decide when and who it hires.  Giles stated bargaining unit work should be covered by union members, and that Respondent should maintain enough drivers to do the work of the unit.  Hanson said if we do not have enough drivers to get the work done, then we will subcontract it.  Giles stated if the normal work of the union requires 25 people, the company should have 25 drivers, not 10 and say they can subcontract the rest.  Giles stated as to overtime, drivers who are off work should be offered over time before the company calls in a temporary or anyone else.  If the overtime is refused by the bargaining unit then a temporary would be allowed.  Hanson stated the Union was not going to tell them whether they have 18, 20, or 24 drivers that they were going to staff as they saw fit.  Giles stated if you are subcontracting every day you should be trying to hire someone.

 

During the conversation, Hanson stated he anticipated that they were going to start getting some NNJ work in about two weeks.  Hanson stated some of the routes were up to 500 plus miles, might have 6 stops on them, that on average they would be around 475 miles a trip with 5 stops.  He said they estimated that it would take 12 to 16 hours to run these trips.  Hanson stated 65 percent of the routes would take over 14 hours to run.  Hanson stated they had done some costing for the routes using owner operators versus company drivers with per diem and hotel, and that it would be 3.5 to 9.5 cents a mile less to use owner operators.  Giles asked what would the costs be without per diem and a hotel, and Hanson said he would have to figure that out.  Hanson told Giles Respondent calculated $25 per day per diem and $75 a day hotel costs if they had to layover someone without a sleeper cab.  Giles responded that $75 a night for a hotel could buy a lot of sleeper cabs.  Giles asked what Respondent was proposing to the owner operators and Cannon responded the stop pay was $1.33 a mile, and he said that was based on $1.13 a mile and $18 per stop.  Hanson said the tolls were the owner operator's expense.  Giles notes reflect that Hanson stated they were proposing to use owner operators for the New Jersey stores for all of the obvious reasons.  Giles asked if that included the New Jersey stores that were currently being serviced, and Hanson said no the new stores.  Giles asked if they were talking about the 54 new Stop & Shop Stores throughout New Jersey that are presently not being handled by Marva Maid, and Cannon replied yes.  Giles stated that some of the runs could be handled by the bargaining unit.  Giles mentioned two southern New Jersey runs with five stops each, one with 433 miles and the other with 479 miles that were being handled by the bargaining unit.

 

The parties again discussed Article 15.09 later on during the October 3 session.  Giles stated that Article 15.09 and the last sentence of Article 3, which provided for unlimited subcontracting was a major problem.  Giles stated the company was going to have to do something about it or this was all just a big waste of time.  Giles stated, if you think I'm going to negotiate a contract that allows unlimited subcontracting, then “I'm pissing in the wind.”  Hanson stated we now have 24 drivers, the work we started with, Respondent figured they would need 27 drivers and that was what they want to have.  Giles stated as new work is added, the Union wanted their membership to grow, and if work was doable with company drivers, the Union wanted to do it.  Hanson stated they were trying to do the Landover work with company drivers but the New Jersey runs make more sense with owner operators.  Giles stated they needed to agree on some language because the Union could not agree to open subcontracting language. 

 

            When the October 4 session opened, Giles made a verbal proposal pertaining to the subcontracting of unit work.  Giles proposed the Employer agree the work of the bargaining unit shall include but not be limited to the delivery of dairy products from the Marva Maid Dairy in Landover, Maryland, to retail or wholesale facilities that are 500 miles or less in total mileage and can be run without a layover.  The Employer agrees that the deliveries now being made in New Jersey shall remain bargaining unit work.  After a break, Hanson stated as to the subcontracting that Respondent should have a full complement of drivers by next week.  Giles testified Hanson had previously said that would be 27 drivers.  Hanson stated if they had the full complement of drivers, it was their intent to run the work they originally bid on with company drivers and he hoped everybody would feel better.  Giles responded the Union’s proposal was made to protect the work the unit was handling when the Union filed the petition.  Giles stated his proposal gave definition to the work and there was new work that could also be run with the company drivers.  At the end of the meeting, Giles notes reflect he stated this will not continue much longer, the Union would be prepared to settle in the next round, and they would present a total solution to the Company.

 

            Giles called a union meeting on October 15, where a strike vote was taken.  During the meeting, Giles told the members there was an issue that was probably being overlooked that they needed to understand, that Respondent was subcontracting bargaining unit work, that the Union had filed unfair labor practice charges over this problem, and that the outcome of the negotiations did not mean a thing if Respondent continued to outsource their work and to subcontract it.  Giles told the membership if the Company continued to divert the work that they might have to take action to stop the diversion.  Giles discussed the complaint that issued over Jackson’s discharge, and that charges had been filed on the surveillance and the impression of surveillance.  Giles then opened the meeting to questions.  Strikers Tucker, Cook, Langhorn, and Keys corroborated Giles’ testimony that there was a discussion of the unfair labor practice charges during the meeting, including the diversion of work to owner operators, prior to the employees unanimously voting to authorize a strike. 

 

Respondent’s had 24 company drivers working the week of October 16, and Respondent had contracted with six owner operators by October 16.  Respondent’s records reveal following October 16, company drivers and owner operators regularly ran NNJ runs.  Respondent’s records reveal that between October 16 and December 30, there were 16 days in which owner operators ran non New Jersey routes referred to as local runs which prior to October 16 had been run by the bargaining unit; there were seven days in which owner operators ran SNJ routes which prior to October 16, had been performed by the bargaining unit; and there were nine days in which owner operators ran mixed SNJ and NNJ routes.

 

During the November 7, session, the parties came to a tentative agreement on subcontracting by agreeing to Article 15.09, based on Hanson’s verbal representation during the meeting that the work presently being performed was bargaining unit work.  At that time, as referenced above, company drivers were running some of the NNJ runs.  However, despite Hanson’s representation during bargaining that Respondent intended to run the runs other than the NNJ runs with bargaining unit members, the owner operators continued to run both the SNJ runs and local runs after October 16.  Toward the end of the December 8, session, the last meeting before the strike, Giles stated this was not going to last much longer, that they needed to wrap this up now, that they were not going to let this drag on for months.  Respondent refused Giles’ request for a quick resumption of negotiations stating earliest the they could meet was January 15, 2007.  At the end of the meeting, Giles stated, the “men and the union are really pissed over these ULP’s.  The Company needs to stop breaking the law.”

 

Cannon testified that in early December, Prevost had instructed him to begin preparations for a strike.  In this regard, during this time, Respondent continued to increase the number of owner operators contracting with additional owner operators on November 14, November 29, December 11, and December 21, and Cannon brought in drivers from outside company to train on Respondent’s Landover procedures.  On December 27, Region 5 issued a consolidated complaint against Respondent.  Included in the complaint for the first time was an allegation that Respondent since July 10, 2006, and at all times since then, has assigned work performed by the Union to other employees or independent contractors without prior notice to the Union and without giving the Union an opportunity to bargain in violation of Section 8(a)(1) and (5) of the Act. 

 

Giles testified a decision was made to go on strike in the last week of December.  Giles testified it was decided the strike would begin on January 12, 2007.  Giles credibly testified that, “What triggered the decision in the last week of December was the National Labor Relations Board issued a complaint against the Company over the diversion of bargaining unit work.”  Giles testified the parties reached tentative agreement on the subcontracting issue on November 7, and they bargained over economics and some other language issues after that date.  Giles testified he called the strike on January 12, 2007, because Respondent’s actions were contrary to what they had agreed to concerning subcontracting.  Giles testified, “If you look at all my bargaining notes and you see the progression of events, that led up to that tentative agreement, you will see that the Company understood the Union's concern over the subcontracting and the Union's willingness to, to allow limited subcontracting to allow the Company to operate in the event that there was a sudden vacancy or absence for some reason.”  He testified during this time Respondent continued hire additional owner operators and in mid December Respondent brought in 12 to 15 drivers from around the country to ride with bargaining unit members.  Giles testified, “I wasn't trying to stop this Company from offering service to its customer, to have service failures, but we were certainly nailing down the scope of the work and the fact that bargaining unit work should be done by bargaining unit members.  And they continued to hire more owner operators and divert additional work.”

 

The strike began at 9:30 p.m. on January 12, 2007.  Giles was present for the start of the strike, at which time he handed out picket signs using the term “Unfair” and he gave out printed instructions to the bargaining unit members stating “You are helping to publicize the strike by Teamsters Local Union No. 639 against Quickway Transportation for their unfair labor practices.”  On that same evening, Giles hand delivered two letters to officials of MMD notifying them that the Union had commenced an unfair labor practice strike against Respondent.  The testimony revealed that for the first two to three weeks of the strike that there was chanting among the picketers for a contract.

 

1. Respondent’s use of owner operators was presented

to the Union as a fait accompli

 

Sometime after the Union won its election on June 22, Cannon contacted Branch, informed him Respondent was in the process of acquiring some layover runs, and discussed with him the terms of Branch’s converting to owner operator.  The agreement Cannon presented to Branch during the meeting is entitled, “Independent Contractor Agreement.”  At page 9, of the agreement it specifically states, in bolded print, “CONTRACTOR NOT AN EMPLOYEE OF THE CARRIER.”  The agreement goes on to state, “It is expressly understood and agreed that CONTRACTOR is an independent contractor for the Equipment and driver services provided pursuant to this Agreement.”  Giles was presented a copy of this contract by Branch on July 16.  By letter dated July 17, to Taylor, Giles protested the diversion of any bargaining unit work to owner operators or independent contractors, and demanded immediate bargaining over any change in Respondent’s operations.  Cannon responded by letter date July 28, stating that Respondent had been advertising for independent contractors in that they anticipated some additional runs that would require layovers.  Cannon stated Respondent did not have enough company drivers to perform its current work, and it had no sleeper cabs at Landover.  Cannon stated, “Using company route drivers is therefore not an option, and Quickway will have to supplement its workforce with independent contractors who have sleeper cab equipment.  Cannon further stated the independent contactors may also supplement any work that cannot be performed by route drivers with company equipment.

 

The parties met on August 8, for their initial negotiation session, at which time Respondent proposed for unlimited subcontracting as part of its management rights clause.  While Respondent had contracted with owner operator Purnell on August 8, it did not inform the Union of said contract during the meeting.  During the August 9, session, Hanson told Giles when and if Respondent obtained some additional work that involved layovers, they would come to the Union and compare having company drivers do the work versus using owner operators.  Hanson also told Giles Respondent was looking at owner operators to supplement the workforce now in place instead of using temps on some local runs.  Hanson’s notes reflect that he told Giles that Respondent was using owner operators to replace temporary drivers when Respondent’s work force was exhausted.  There is no claim that the Union was told that the owner operators were going to be scheduled on a full time basis to perform local runs.  Along these lines, Giles credibly testified he had a phone call with Hanson on August 15, during which Hanson told Giles that on August 10, Respondent sent out an owner operator on a regular route.  Hanson stated the driver was off sick and the company offered the work to company drivers and it was turned down. 

 

Thus, despite Giles July 17, demand to bargain, Respondent’s officials gave the Union no prior notice as to the actual contracting with an owner operator, and then misinformed Giles as to how owner operators were going to be used.  In this regard, Respondent contracted with Purnell on August 8, and despite representations to the Union that he was just going to be used to supplement the work that could not be performed by the bargaining unit, Respondent immediately placed Purnell on a full time schedule as part of the company driver rotation, performing work that had been theretofore been performed by the bargaining unit and temporary employees.[92]

 

            Following the August sessions, Respondent signed on two more owner operators in September, and on September 27, the Union filed an unfair labor practice charge of the diversion of unit work to owner operators.  At the start of the October 2, Giles informed Respondent that the Union was seeking 10(j) relief with the Board over the diversion of unit work.  Cannon testified Hanson responded that Respondent had been subcontracting since the start up by using temp drivers, and now Respondent was going to use owner operators doing the same type of work.  It is reflected in Giles notes of October 2, that Giles stated stops were being removed from existing runs and put on new trailers to create additional runs for owner operators.  During the discussion that followed, Giles again asserted that owner operators were being used to do bargaining unit work.  Hanson responded the Respondent was going to use owner operators on runs that require a layover.  Giles responded that any delivery made from that dairy was bargaining unit work, and that giving it to an owner operator without bargaining with the Union is a diversion of bargaining unit work.  Hanson responded owner operators were not company employees, and were not part of the bargaining unit.  Giles testified Hanson said “that to the extent that they use owner operators, as they have used the temps, we will continue our past practice.  He then stated on the new work, we will come to the Union, and if able or not to run without a layover, we'll bargain over the new work and the cost, et cetera.  Giles told Hanson there were owner operators that were included in the bargaining unit at other Quickway locations and they were covered by the contract.  Giles asked Hanson if he intended intend to bargain with the Union over the use of owner operators.  Giles testified, Hanson “responded by saying, no.”  Hanson went on to state that he had never seen anything like the other Quickway locations where owner operators pay union dues but do not received any benefits under the contract. 

 

            Thus, on October 2, Hanson told Giles that owner operators were not company employees, and were not part of the bargaining unit.  He told Giles to the extent Respondent used owner operators as they had temporary employees Respondent would not bargain over their usage, and he rejected Giles suggestion of possibly including owner operators in the collective bargaining unit as they were at Respondent’s other locations.  He made the statement that Respondent would bargain with the Union over the new work whether or not it involved a layover.

 

            During the October 3, session, Giles stated bargaining unit work should be covered by union members and Respondent should maintain enough drivers to do the work of the unit.  Hanson said if we do not have enough drivers to get the work done, then we will subcontract it.  Giles stated if the normal work of the union requires 25 people, the company should have 25 drivers, not 10 and say they can subcontract the rest.  During the conversation, Hanson stated he anticipated that they were going to start getting some NNJ work in about two weeks.  Hanson stated some of the routes were up to 500 plus miles, might have 6 stops on them, that on average they would be around 475 miles a trip with 5 stops.  Hanson stated they had done some costing for the routes using owner operators versus company drivers with per diem and hotel, and that it would be 3.5 to 9.5 cents a mile less to use owner operators.  Giles asked what would the costs be without per diem and a hotel, and Hanson said he would have to figure that out.  Hanson told Giles Respondent calculated $25 per day per diem and $75 a day hotel costs if they had to layover someone without a sleeper cab.  Giles asked what Respondent was proposing to the owner operators and Cannon responded the stop pay was $1.33 a mile, and he said that was based on $1.13 a mile and $18 per stop.  Hanson said the tolls were the owner operator's expense.  Hanson stated they were proposing to use owner operators for the New Jersey stores for all of the obvious reasons. 

 

            When providing the Union with the costs of the owner operators, Respondent’s officials failed to mention the owner operators were also being paid a fluctuating fuel allowance, and he incorrectly told the Union the owner operators were responsible for their own tolls.  Branch testified as an owner operator he was reimbursed for tolls at the rate of $100 to $150 per week.  Moreover, while Hanson represented the cost gains by using owner operators over company drivers was 3.5 to 9.5 cents mile, Miller, who had made the calculation for Respondent, stated the actual saving was 4.5 cents a mile, and that this calculation included the cost of renting or purchasing sleeper cabs for company drivers.[93]

 

It is a violation of Section 8(a)(5) of the Act for an employer to change a mandatory term or condition of employment without bargaining with a union.  Litton financial Printing Div. v NLRB, 501 U.S. 190, 198 (1991); NLRB v. Katz, 369 U.S. 736, 747 (1962).  In Bottom Line Enterprises, 302 NLRB 373, 374 (1991), enfd. 15 F.3d 1087 (9th Cir. 1994), the Board stated when parties are engaged in contract negotiations an employer’s obligation to refrain from unilateral changes extends beyond the mere duty to give notice and an opportunity to bargain.  Rather, it encompasses a duty to refrain from implementation at all, unless and until an overall impasse has been reached on bargaining for an agreement as a whole, absent two limited exceptions, that is if a union has in response to an employer’s diligent and honest efforts is seeking to delay bargaining, or when economic exigencies compel prompt action.[94]  In RBE Electronics of S.D., 320 NLRB 80, 81 (1995), the Board held as follows:

 

    Of course, there are certain compelling economic considerations that the Board has long recognized as excusing bargaining entirely about certain matters. The Board has limited its definition of these considerations to “extraordinary events which are 'an unfores