Certain-Teed Insulation Co.

National Labor Relations Board - Board DecisionsAug 27, 1980

251 N.L.R.B. 1561 (N.L.R.B. 1980)

1561 of Ceistain 10-CA- opportu- PENELLO, nity TRUESDALE the ~ a t i b n a l Cbn Jarr es L. Rose issued the attached Decision in this Par1 3(b) briel's affirm find- Judge3 Pi~rsuant 10(c) latiois Order Corroration), succt:ssors, l(g): "(@) no-solicitation/no -- Respondent credib~lity Admini:,trative overrult, ur:less i s Standard Inc., (1950), 188 F.2d carefulll' " Me~nber Penello Ju~lge vlew mplied Unrco Incorpomfcd, 1 WILL no-solicitation/no-distribution 8(a)(l) L.abor 8 1, seq. I CERTAIN-TEED INSULATION COMPANY Certain-Teed Insulation Company and Glass Bottle Blowers Association of the United States and Canada, AFL-CIO Teed Corporation and Glass Bottle Blowers Association of the United States and Canada, AFL-CIO. Cases 14620, 10-CA-14670, 10-CA-14775, and 10-CA-14970 August 27, 1980 DECISION A N D ORDER BY MEMBERS JENKINS, AND June 19, 1980, Administrative Law Judge proceeding. Thereafter, Respondent filed excep- tions and a supporting brief,' and the Charging y and the General Counsel filed answering briefs. Pursuant to the provisions of Section of the Nat onal Labor Relations Act, as amended, the Na- tional Labor Relations Board has delegated its au- thor ity in this proceeding to a three-member panel. The Board has considered the record and the at- tached Decision in light of the exceptions and and has decided to the rulings, ings and conclusions of the Administrative Law and to adopt his recommended Order, as modified herein. ORDER to Section of the National Labor Relations Act, as amended, the National Labor Re- Board adopts as its Order the recommended of the Administrative Law Judge, as modi- fied below, and hereby orders that the Respondent, Certain-Teed Insulation Company (Certain Teed Athens, Georgia, its officers, agents, and assigns, shall take the action set forth in the said recommended Order, as so modi- fied: 1. Substitute the following for paragraph Promulgating and maintianing the May 25, 1979, distribution rule which was founcl unlawful herein." Respondent's motion to reopen the record is hereby denied. has excepted to certain findings made by the Law Judge. It is the Board's established policy not to an administrative law judge's resolutions with respect to credi- bility the clear preponderance of all of the relevant evidence con- vinces that the resolutions are incorrect Dry Wall Products, 91 NLRB 544 enfd. 362 (3d Cir. 1951). We have examined the record and find no basis for reversing his findings. does not adopt the finding of the Administrative Law that the wlicitation of grievances, in itself, is coercive, but would conclude. in of the surrounding circumstances, that there was an promise to remedy those grievances and that Respond- ent's actions were therefore coercive. 216 NLRB (1974). 251 NLRB No. 208 2. Substitute the attached notice for that the Administrative Law Judge. APPENDIX NOTICE TO EMPLOYEES POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government After a hearing at which all sides had an to present evidence and state their positions, Labor Relations Board found that we have violated the National Labor Relations Act, as amended, and has ordered us to post this notice. WE WILL NOT interrogate our employees con- cerning their union membership, activities, or de- sires or those of other employees. WE WILL NOT threaten employees with loss of benefits should they join or engage in activities on behalf of the Union. WE WILL NOT solicit grievances from employees nor promise to remedy such grievances. WE WILL NOT more stringently enforce break pe- riods because of employees' union activity nor tell employees that we are doing so. WE NOT issue disciplinary warnings to our employees because of their interest in or activities on behalf of the Union. WE WILL NOT direct our employees not to wear any union insignia in the plant. WE WILL NOT promulgate or maintain the May 25, 1979, rule which has been found to be unlawful. WE WILL NOT in any like or related manner in- terfere with, restrain, or coerce our employees in the exercise of the rights guaranteed them by Sec- tion 7 of the Act. WE WILL expunge from the personnel records the warnings issued to James Swords on June 6 and 18, 1979, and the written warning issued to Carl Veal on August 17, 1979. DECISION STATEMENT OF THE CASE JAMES L. ROSE, Administrative Law Judge: These consolidated cases were heard before me on March 20, 1980, in Athens, Georgia. In general, the General Coun- sel alleges, and the Respondent denies, that the Respond- ent engaged in certain conduct violative of Section and (3) of the National Relations Act, as amended, 29 U.S.C. 15 et Upon the record as a whole, including my observation of the witnesses, briefs, and arguments of counsel, I hereby make the following: I 1 CONCLUSIONS 2(2), (6), 11. 2(5) 111. 1979,' Certainteed (1980).= recall unless ' namn the har "Cenainteed In- sularion Certainteed Corpomrion I conclude employ- 1 f testi- God- 8(a)(l) 1 8(a)(l). percep- I 1 information, allegi~ trs ~ h ( . how DECISIONS OF NATIONAL LABOR RELATIONS BOARD 1562 FINDINGS OF FACT AND OF LAW I. JURISDICTION The Respondent is a Maryland corporation engaged in various States in the manufacture and sale of installation materials. At its Athens. Georgia, facility, the Respond- ent annually sells and ships to points directly outside the State of Georgia finished products valued in excess of $50,000. The Respondent admits, and I find, that it is an employer engaged in commerce within the meaning of Sections and (7) of the Act. THE LABOR ORGANIZATION INVOLVED Glass Bottle Blowers Association of the United States and Canada, AFL-CIO (herein called the Union) is ad- mitted to be, and I find is, a labor organization within the meaning of Section of the Act. THE ALLEGED UNFAIR LABOR PRACTICES A. Background Facts The Union filed a petition for certification on January 22, and by Stipulation for Certification Upon Consent Election, an election was held among the Re- spondent's employees on February 15 and 16. The tally ballots shows that 180 votes were cast for and 144 against the Union; there were 2 challenged ballots. The Respondent's objections to conduct affecting the results of the election were overruled by the Board, and the Union was certified as the employee's collective-bar- gaining representative on March 13, 1980. Corporation, 248 NLRB 438 The matters at issue concern activity engaged in by su- pervisors and other agents of the Respondent from Janu- ary 16 through July 30. B. Analysis and Concluding Findings 1. Interrogation It is alleged that on January 16 B Team Shift Manager Ronald A. Swan interrogated employees concerning their union membership, activities, and desires. Swan ad- mitted that he sought out each individual employee prior to the election, to "let them know we were at their dis- posal if they had any questions concerning the union or the company and try to get any answers they might have questions for." However, Swan denied specifically that he ever asked any employees what they thought about the Union or how they intended to vote. The evidence concerning the Swan allegation is the testimony of Tony Morris. Morris stated that he had a conversation with Swan on or about January 16 in which the general subject matter of the Union was dis- cussed. However, he was unable to recall specifically any questions put to him. Thus when asked, "do you him (Swan) asking you how you felt towards the All dates are in 1979, otherwise indicated. Two different corporate appear in consolidated complaint herein. A company letterhead the name Corpomrion Group," thus i t appears that is the correct style. Union," Morris answered only "Yes, sir, I believe he did ask that." In view of Swan's denial, and the vagueness of Morris' testimony, 1 that there is insufficient evidence to sustain the allegation that Swan interrogated ees in violation of the Act. I will recommend that the complaint, insofar as it alleges interrogation by Swan, be dismissed. Charles Godfrey (who is no longer an employee) fied that in February, about a week prior to the election. Mike Hale, the personnel director, started a conversation with him in the hall, which continued in Hale's office. Hale asked Godfrey his opinion of how "our team would vote in the election." Hale followed this by asking frey how he was going to vote, and Godfrey gave an equivocal answer. This is alleged to be interrogation of an employee in violation of Section of the Act. While Hale was called as a witness, he did not specifi- cally deny the statement attributed to him by Godfrey, nor did he give another version of his meeting with Godfrey. Hale testified only in conclusionary terms that he did not "ever interrogate employees concerning their union membership or activities." Thus, the statements at- tributed to Hale by Godfrey are undenied on the record, in addition to which 1 found Godfrey to be a credible and reliable witness. Accordingly, I conclude that Hale did in fact interrogate an employee on or about February in violation of Section Dr. Faye Shapiro is a psychologist associated with a firm which does management consulting for the Re- spondent. Dr. Shapiro has worked with the Respondent about 2-1/2 years at all of its facilities. She testified that she was asked by the Athens plant manager to come t o Athens on March 20 and 21 (about a month following the election) "to try to get the tions and feelings of the people in relationship to how they saw the company, their job, their job satisfaction, tension, whether they felt they could ask for what they wanted, what they felt." Dr. Shapiro testified that she asked that employees be selected at random to be interviewed, and that in fact she did conduct individual interviews with hourly employ- ees. She testified, "I basically asked them about their feelings and perceptions in relationship to the company." And, "I asked questions as to their feelings about the union, and when they talked about the union, if they mentioned it first, then would talk to them about the union. But I didn't go in to ask them." She specifically denied that she asked employees how they voted in the election, but if an employee volun- teered this "I wanted to understand his feel- ings about the company more than I was concerned about anything that he did in the election because my task was t o ascertain the perceptions about the compa- ny." Although Dr. Shapiro denied the conclusionary tions that she had interrogated employees concerning their union activity, she did not specifically deny the timony of the employees who stated that during course of their interviews by her, she asked them ances appar- re- Thomas Bolton, credi- 8(a)(l) by ~f i ' . spondellt's t i bv Shaoiro sev-ral Colquilt's From 8(a)( 1 ). Duri ig Hale/Godfrey 2 led j o ) n igh t ?at cons electior~, therefoie 8(s)(l). Boltc~n i r ~ 8(a)(l). 8(a)(l) specific facl, griev- 8(a)(l) 8(a)(l), Chevrolet, Inc., president- 8(a)(1) 8(a)(3) per- CERTAIN-TEED INSULATION COMPANY 1563 they vc ted and why the employees voted in favor of the Union. whom I found to be a generally ble witness, testified that during the course of his inter- view Dr. Shapiro, she "asked me how did I vote, did I vote for the union." He told her that he had. "And then she asked me how I felt about we had a-if we had another election, how would I vote and what I felt about I told her I felt that if we had another election, it would end up the same way probably; that we'd win again." (At the time of the Shapiro interviews, the Re- ' objections to conduct affecting the results of the election were pending.) Similarly, Michael Lewis Colquitt testified that during the course of his interview Dr. she asked him on occasions how he voted in the election, a question which he sought to avoid answering. I credit specific testimony over Dr. Shapiro's general- ized denial, and find that she also interrogated him con- cerning his union activity. the credited testimony of the employee wit- nesses, denied only in conclusionary terms, I conclude that in fact during the course of her interviews with em- ployee: the month following the election, she did inter- rogate at least some of them in violation of Section 2. Threats the meeting, in Hale's office about week before the election, it is alleged that Hale threate employees. According to Godfrey's credited testimony, undenied by Hal-, Hale said, "If the union comes in, there might be a slowdown, expansion might be slower, advance- ment not be as fast, etcetera." While Godfrey tes- tified t this was in the course of discussing the pros and of the Union and was, he thought, Hale's opin- ion, I conclude that this statement, a week prior to the during an interview in which the employee was interrogated, transcends mere opinion. It in fact tells the employee that should the Union be selected as their bar- gaining representative there would probably be adverse consequences. I conclude that in the manner al- leged, Hale did threaten employees in violation of Sec- tion 3. Solicitation of grievances testified that during the course of his interview by Dr. Shapiro, among other things she asked him if the employees had had problems with supervisors, and why they had voted for the Union. He answered that the em- ployees had been given numerous promises which had not been kept. This is alleged to be solicitation of griev- ances violation of Section I corcur that the Respondent violated Section in this instance. Further, the very essence of Dr. Shapirc's interviews of employees, as testified to by her, was to solicit grievances from employees-to get em- ployees' "perceptions" about the Company and to "find out what was wrong." I conclude that the purpose, and the of Dr. Shapiro interviews was to solicit from employees. And she certainly had the ent authority to make effective recommendations to solve those grievances. Such action is violative of Sec- tion of the Act, and I so find. 4. Promise to remedy grievances It is separately alleged as a violation of Section that Dr. Shapiro promised to remedy the grievances of employees. At the very least, where a management con- sultant interviews employees singly during which griev- ances are solicited, it is implied that those grievances will be remedied. Such is violative of Section and I so find. Apple Tree 237 NLRB 867 (1978). 5. More strict enforcement of break periods Employee James Swords, the president-elect of the Union's Local 260, testified that his supervisor, Daniel Colquitt, talked to him about a month following the elec- tion. Swords testified that Colquitt called Swords into his office and said, "Have a seat. I wanted to call you in here to advise you of the fact that we think people are abusing breaks and I'm going to call all the people in my supervision in to make them aware of the fact that they're taking too long of a break and due to the fact that the elections over, they're going to be more strin- gent of abuse of breaktime." While Colquitt testified that he had told employees "lots of times" that break periods would be more strin- gently enforced, he did not deny the statement attributed to him by Swords, which implies that the more strict en- forcement of breaks was in retaliation for the election vote. Colquitt testified that he could not "recall" if he told employees breaks would be more strictly enforced in order to discourage union activity. Further, I credit Swords and found him to be a credi- ble and reliable witness. I find that shortly following the election he was told by his supervisor, and apparently in his capacity as president-elect of the Union, that because of the election outcome, breaks would be more strictly enforced. While the Company certainly has a right to enforce break periods, there is no evidence in the record that in fact employees were abusing break periods at all, much less in any meaningful or significant way. Thus, for a su- pervisor to call in the Union's observer and elect of the local and advise him that there would be a change in policy necessarily tends to interfere with em- ployees rights under Section 7, and I therefore find that the Respondent violated Section of the Act. 6. Verbal warnings to James Swords It is alleged that on June 6 and 18, the Respondent issued verbal warnings to Swords in violation of Section of the Act. While admitting the warnings, the Re- spondent denied that such were violations and in any event contends that consistent with its policy, after 6 months the warnings would have been expunged from Swords' record. The June 6 warning, according to Swords, undenied by the Respondent's witnesses, concerned events which took place a month previously: taking too long to I 1564 given any evrdencethat S bung glong unron 8(a)(3) from truck r2me Wil- viola- con- 4 I' * ve~xation. I # part hoe im- $ 2 ! 8(a)(3) t punl:e unfa~r fountl. 30, 8(a)(l) "5/25/79" B(aM1). Cir- DECISIONS OF NATIONAL LABOR RELATIONS BOARD form a job; improperly hanging scales; and spending the last few minutes of his shift standing by a water fountain eating peanuts. There is no evidence that any other employee was ever a verbal warning for such conduct. nor is there particular Swords was at fault in the ways contended by the Respondent. On the other hand, the uncontroverted evidence is that a week prior to having been given the verbal warning, as president-elect of the local Swords approached Supervi- sor Steve Sears telling Sears that two employees from Team C had advised him that they were harassed by supervisors who told them they were not allowed to talk about union affairs. Sears told Swords, "Well I don't know that any of my people are harassing them and I don't know anything about the union's business and I am not going to make any statement." Sears went on to say, "I'll have to check on it." It was a week later that Swords received the first verbal warning of his 4 years of employment. That Swords had not been talked to about any of these alleged infractions when they occurred, indicates that the incidents were not thought significant by management at the time. There is no evidence that the Company ever gave verbal warnings to other employees for the same or similar types of alleged infractions of rules. These fac- tors, with the fact that Swords was issued his first warning only 1 week following his presentation of a grievance to his supervisor concerning the employees' activity, leads me to conclude that the Company was motivated not by Swords alleged poor performance, but by his activity on behalf of the Union. Thus, I con- clude that the warning was an violation. Similarly, I conclude that the verbal warning issued to Swords on June 16 was given him because of his activity on behalf of the Union and not, as contended by the Re- spondent, because he was away his assigned place of work. On June 16 Swords saw a man, apparently driving a through the company parking lot, who had been a contractor on a swimming pool in which Swords had interest. Swords stopped him to ask a question con- cerning the work. Swords testified, I think credibly, that this conversation lasted no more than about 5 minutes. I discredit Maintenance Superintendent Ronald kins that he observed Swords talking for 15 to 20 min- utes. Indeed, had Swords in fact talked such a long period of time in the presence of Wilkins, and in ticn of company policy, it follows that Wilkins would have told Swords at the time and put an end to the Not only did he not do so, but he also failed to mention the event to Swords at the time. Such further suggests that the event was a justification for giving the warning, and not the true reason. And this plies, and I conclude, that the warning was in retaliation for Swords' union activity and was violative of Section of the Act. The fact that the Respondent has a practice to ex- \ such verbal warnings from an employees' record after 6 months does not make these acts less unlawful, nor does such fully remedy the labor practices Thus I will recommend an appropriate order which will include that the warnings be expunged should they still be in Swords' personnel file. 7. Directing employees not to wear union insignia in the plant. The parties are in general agreement that in mid to late July, Tony Morris wore a baseball cap on which were the letters GBBA (Glass Bottle Blowers Associ- ation) and a lapel button reading AFL-CIO and GBBA. Between 10 a.m. and noon that day, Victor Blackmon, Morris' immediate supervisor, approached Morris and told him that Tom Lord, the maintenance engineering supervisor, "was mighty upset because one of his store- room employees were wearing union propaganda and that he would not have it." While Blackmon admits a conversation along these lines with Morris, and that Lord had expressed displeas- ure with Morris because he was wearing a union hat, Blackmon contends he did not tell Morris, or employee Gordon Scales, that they could not wear the union hats. Though the employees may not have been specifically directed to remove the union hats, Blackmon's statement to them that a high level supervisor was "disappointed" in them for wearing the union hats tends to interfere with their protected right in fact to wear them. And such certainly implies that supervision wants the employ- ee to cease the activity. I conclude that by confronting the employees as he did on or about July Blackmon interfered with their Section 7 rights, and thus violated Section of the Act. 8. The no-distribution no-solicitation rule It is undenied that the Company posted a notice dated which reads in material part: NOTICE T H E FOLLOWING COMPANY RULES A R E DESIGNED TO PROVIDE CERTAINTEED EMPLOYEES WITH AN ORDERLY WORK PLACE. THESE RULES SERVE AS A GUIDE- LINE ONLY, AND ARE NOT INTENDED T O COVER EVERY SITUATION. EVERY EM- PLOYEE SHOULD BE FAMILIAR WITH THESE. AS VIOLATIONS MAY RESULT IN DISCIPLINARY ACTION. YOUR COOPERA- TION WILL BE APPRECIATED. SOLICITATION OR UNAUTHORIZED DIS- TRIBUTION O F LITERATURE ETC. The General Counsel contends, and I agree, that such a broad prohibition of solicitation and distribution vio- lates Section While the rule does not expressly mention union solicitation or distribution as being prohib- ited, the general prohibition on company property could reasonably be interpreted by employees as forbidding union activity. The broad language of this rule gives the impression that all forms of solicitation o r distribution are prohibited on company property. As the Second I4ilton F.2d t ! ~ e c maintaining guari~nteed 8(a)(l) , k t . : Fremonr Inc. , issuej w h ~ c h 1:15 A-l l pickAng ~ ~ o t 3 About the restroom he empl3yee injur:i schetluled C o m . ~ a n y res- gest con- sug- ~ u ~ u s i 8(a)(3) 2(6) 10(c) benetits Unior~. Take Sec. Nationdl heretn shtill, Sec. 10248 Rrgulat~ons, Board tts conclus~ons. and ;III object~ons CERTAIN-TEED INSULATION COMPANY 1565 cuit :;aid in N.L.R.B. v. Harold Miller, Herbert Charles and Charles. Co-partners, d /b /a Miller-'Charles and Company, 341 870, 874, (2d Cir. 1965): The true meaning of the rule might be the subject of grammatical controversy. However, the employ- ees of respondent are not grammarians. The rule is at best ambiguous and the risk of ambiguity must be held against the promulgator of the rule rather than against the employees who are supposed to abide by it. The Respondent, as promulgator of the rule, is liable for ambiguity in the language, which could discour- age mployees from engaging in lawful union solicitation and distribution during breaktimes and in nonworking areas. Nor is there any evidence of a business necessity for such a broad proscription. I therefore conclude that by maintaining the above-stated rule, the Company has interfered with the rights of employees in Section 7 in violation of Section of the Stoddard-Quirk Manufacturing, Co., 138 NLRB 6 15 1962); Manufacturing Company, 224 NLR B 597 (1976). 9. The written warning to Carl Veal It is undenied that on August 17, the Respondent a "written warning" to Carl Veal, states in material part: On August 16, 1979, at approximately p.m. Carl entered the plant in unauthorized areas. As a member of C-Team, Carl was not scheduled to work on 8/16/79. His entry into unauthorized areas of the plant is a violation of company policy. Any future entry into unauthorized areas of the plant will result in further disciplinary action. Or August 16 Veal, along with other employees, was the Company's premises because the Company had yet recognized the Union, the Company's objec- tions to the election were still being considered. Veal had sandwich-board sign on the front of which was written, "CertainTeed Unfair to Southern Employees," and on the back, "Register with me for Color TV." I o r 2 p.m. Veal decided to g o into the plant to use restroom. The route from the employees' en- trance to the men's took him along the side of the production area, a distance of 60 yards. The Respondent argues that since Veal was not work- ing was not allowed to be in the plant; and, for an to walk through the production area when he is not scheduled to work could result in an accident o r to employees, particularly when wearing a sign such as Veal had. The uncontroverted evidence is that other employees from time to time g o to the plant when they are not to work and never have been disciplined for this. Further, there is nothing in the rules posted by the on May 25 which would indicate that employ- ees are prohibited from going in the plant to use the troom when they are not scheduled to work. Finally, aside from the Company's generalized conclusions cerning safety, there is no evidence in the record to that Veal posed a safety hazard to himself o r to others on 16. Given these factors, I find that the Company disci- plined Veal because he walked on company premises with a sign stating that the Respondent was being unfair in violation of Section of the Act, and should be expunged from his record. IV. THE EFFECTS OF THE UNFAIR LABOR PRACTICES UPON COMMERCE The unfair labor practices found above, occurring in connection with the Respondent's business, have a close, intimate, and substantial relationship to trade, traffic, and commerce among the several States and tend to lead to labor disputes burdening and obstructing commerce within the meaning of Section and (7) of the Act. V. REMEDY Having found that the Respondent has engaged in cer- tain unfair labor practices, I shall recommend that it cease and desist therefrom and take certain affirmative actions designed to effectuate the policies of the Act. Upon the foregoing findings of fact and conclusions of law, the entire record in this matter, and pursuant to the provisions of Section of the Act, I hereby issue the following recommended: The Respondent, Certain-Teed Insulation Company (Certain Teed Corporation), Athens, Georgia, its offi- cers, agents, successors, and assigns, shall: 1 . Cease and desist from: (a) Interrogating its employees concerning their union membership, activity, and desires of other employees. (b) Threatening employees with loss of if they joined the Union or engaged in activities on behalf of the Union. (c) Soliciting grievances from employees and/or prom- ising to remedy such grievances. (d) Threatening employees that break periods would be more stringently enforced because they voted in favor of the (e) Issuing disciplinary warnings to employees because of their interest in o r activities on behalf of the Union. (f) Directing employees not to wear any union insignia on Company premises. (g) Promulgating a rule prohibiting solicitation at times other than working hours, o r distribution of literature on the plant premises other than working areas. (h) In any like o r related manner interfering with, re- straining, o r coercing employees in the exercise of the rights guaranteed them by Section 7 of the Act. 2. the following affirmative action: In the event no exceptions are tiled as provided by 102 46 of the Rules and Regulations of the Labor Relations Board, the find- ings, conclusions, and recommended Order a provided in of the Rules and be adopted by the and become findings, Order, end thereto shall be deemed waived for all purposes. 18 "Appendi~."~ ' Court (c) the Regional Director for Region lo in Board" pursu- 20 of ~ ~- - - ~- - ~ ~- &e 1566 DECISIONS O F NATIONAL (a) Expunge from the personnel files of James Swords and Carl Veal, the warning they received, respectively, on June 6 and and August 17, 1979, if such warnings are still in their files. (b) Post at the Respondent's facility in Athens, Geor- gia, copies of the attached notice marked Copies of said notice, on forms provided by the Regional In the event that this Order is enforced by a Judgment of the United States of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations shall read "Posted ant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board." LABOR RELATIONS BOARD Director for Region 10, after being duly signed by Re- spondent's representatives, shall be posted by it immedi- ately upon receipt thereof, and be maintained by Re- spondent for 60 consecutive days thereafter, in conspicu- ous places including all places where notices to employ- ees are customarily posted. Reasonable steps shall be taken by Respondent to insure that said notices are not altered, defaced, or covered by any other material. writing within days from the date this Order, what steps Respondent has taken to comply herewith,