Pomona Progress BulletinDownload PDFNational Labor Relations Board - Board DecisionsMay 28, 1970182 N.L.R.B. 904 (N.L.R.B. 1970) Copy Citation 904 DECISIONS OF NATIONAL LABOR RELATIONS BOARD Progress Bulletin Publishing Company d/bfa Pomona Prog- ress Bulletin and Los Angeles Newspaper Web Press- men's Union No. 18 , International Printing Pressmen & Assistants Union of North America, AFL-CIO. Case 21-CA-8586 May 28, 1970 DECISION AND ORDER BY MEMBERS FANNING, BROWN AND JENKINS On November 14, 1969, Trial Examiner Martin S. Bennett issued his Decision in the above-entitled case, finding that the Respondent' had engaged in and, was engaging in certain unfair labor practices within the meaning of the National Labor Relations Act, as amend- ed, and recommending that it cease and desist therefrom and take certain affirmative action, as set forth in the attached Trial Examiner's Decision. Thereafter, the Respondent filed exceptions to the Trial Examiner's Decision and a supporting brief, and the Charging Party filed an answering brief. Pursuant to the provisions of Section 3(b) of the Act, as amended, the National Labor Relations Board has delegated its powers in connection with this case to a three-member panel. The Board has reviewed the rulings of the Trial Exam- iner made at the hearing and finds that no prejudicial error was committed. The rulings are hereby affirmed. The Board has considered the Trial Examiner's Decision, the exceptions and briefs, and the entire record in this case, and hereby adopts the findings,2 conclusions, and recommendations of the Trial Examiner.3 ORDER Pursuant to Section 10(c) of the National Labor Rela- tions Act, as amended, the National Labor Relations Board adopts as its Order the Recommended Order of the Trial Examiner, and hereby orders that the Respondent, Progress Bulletin Publishing Company d/b/a Pomona Progress Bulletin, Pomona, California, its ' The complaint, originally captioned "Donrey Media Group Western Properties d/b/a Pomona Progress Bulletin ," was amended at the hearing to reflect the correct name of Respondent 4 We correct the name "Robinson ,',' which inadvertently appears once in the Trial Examiner's Decision, to read "Richardson " ' 9 Contrary to our dissenting colleague , we expressly agree with the Trial Examiner's rejection of the Respondent ' s argument based on our decision in Jos Schutz Brewing Company, 175 NLRB No 23 There the dispute was patently a matter of contract interpretation Here the contractual grievance -arbitration procedure applies only to issues of contract interpretation and the contract is entirely silent as to the Chnstmas bonus To dismiss the complaint herein because of the availability of the grievance -arbitration procedure could result in a wholly new dispute over whether the issue is ' arbitrable , should either party choose to rely on the terms of the contract . We do not believe that the policies of the Act would be effectuated by substituting a new dispute for one which is clearly susceptible to resolution under the Act . Nor do we perceive how, in such circumstances , our declining to remit the dispute to an arbitration which may not be available tends to undermine or disturb the long harmonious relationship between the parties officers, agents, successors, and assigns, shall take the action as set forth in the Trial Examiner's Recommended Order. MEMBER BROWN, dissenting: In view of the long harmonious relationship between the parties, the absence of evidence of antiunion motiva- tion for the Respondent's action herein or any other unlawful behavior, the existence of a broad contractual grievance-arbitration procedure designed and successful- ly used to resolve disputes and differences between the parties, and the fact that the Respondent waived the time limit for filing grievances when it discussed the bonus matter with the Union and still seeks a final resolution of the dispute under the contract's grievance- arbitration machinery, I do not believe that the policies of the Act would be effectuated by further processing of this proceeding. I would accordingly dismiss the complaint. See Jos. Schlitz Brewing Company, 175 NLRB No. 23. TRIAL EXAMINER'S DECISION STATEMENT OF THE CASE MARTIN S . BENNETT , Trial Examiner : This matter was heard at Los Angeles, California , on August 26, 1969. The complaint , issued June 26 and based upon a charge filed May 21, 1969, by Los Angeles Newspaper Web Pressmen ' s Union No . 18, International Printing Pressmen & Assistants Union of North America, AFL-CIO, herein called the Union, alleges that Respond- ent, Progress Bulletin Publishing Company d /b/a Pomona Progress Bulletin,' had engaged in unfair labor practices within the meaning of Section 8(a)(5) and ( 1) of the Act. Briefs have been submitted by the General Counsel and Respondent . An unopposed motion by the General Counsel to correct certain errors in the transcript is hereby granted. Upon the entire record in the case , and from my observation of the witnesses , I make the following: FINDINGS OF FACT• 1. JURISDICTIONAL FINDINGS Progress Bulletin Publishing Company d /b/a Pomona Progress Bulletin , a Nevada corporation with its principal office and place of business at Pomona, California, pub- lishes a daily and Sunday newspaper . It subscribes to several interstate news services , annually enjoys a gross volume of business in excess of $200 ,000 and annually purchases goods and, materials valued in excess of $50,000 which are shipped to it from points outside the State of California . I find that the operations of Respondent affect commerce within the meaning of Sec- tion 2(6) and (7) of the Act. ' The complaint, originally captioned "Donrey Media Group Western Properties d/b/a Pomona Progress Bulletin," was amended at the hearing to reflect the correct name of Respondent 182 NLRB No. 135 POMONA PROGRESS BULLETIN 905 II. THE LABOR ORGANIZATION INVOLVED Los Angeles Newspaper Web Pressmen 's Union No. 18, International Printing Pressmen & Assistants Union of North America , AFL-CIO, is a labor organization within the meaning of Section 2 (5) of the Act. III. THE UNFAIR LABOR PRACTICES A. Introduction; The Issue Since 1946, the Union and its predecessor have been recognized as the representative of a unit of Respond- ent's employees identified herein as the press-stereo employees. These are approximately 25 to 35 in number out of a total complement of approximately 250 and the large majority is unorganized. In December 1968, Respondent unilaterally discontinued the payment of a Christmas bonus which had been made for many years. The General Counsel contends that Respondent has thereby refused to bargain within the meaning of Section 8(a)(5) and, derivatively, has engaged in unfair labor practices within the meaning of Section 8(a)(1) of the Act. Respondent contends that these are gifts which have always been discretionary and that the pay- ment was discontinued for a valid business reason which is treated below. As is readily apparent, it begs the question to term these payments as gifts. The issue turns upon whether they had become an integral part of the wage structure. B. Appropriate Unit and Majority Representation Therein The complaint alleges, Respondent admits, and I find that all foremen, men in charge, journeymen pressmen, and apprentice pressmen of Respondent, excluding office clerical and professional employees, guards, watchmen, and supervisors constitute a unit appropriate for the purposes of collective bargaining within the meaning of Section 9(b) of the Act.2 I further find that at all times material herein the Union has been, and now is, the representative of the employees in the above-described appropriate unit within the meaning of Section 9(a) of the Act. C. Bargaining History and Christmas Payments Respondent has relied herein on certain changes in working conditions over the years and these, accordingly, are set forth below. As noted, the Union and its predeces- sor have represented a unit of approximately 10 percent of the employees since 1946. The initial contract with the Union was signed in July 1964 and the current contract terminates June 30, 1970, with year to year renewal thereafter absent 60 days notice. Except for the instant dispute, relationships have been harmonious 2 There is one foreman in the unit The General Counsel expressly waives any remedy directed to him. with several grievances a year resolved under the griev- ance procedure of the contract. No contract has contained language concerning a Christmas bonus payment and the topic has never been raised at contract negotiations. Indeed, President and Business Agent Thomas Shirley of the Union testified that he had not been aware of the existence of this practice until he received complaints that no payments had been made at Christmas 1968. Respondent has made the following payments at Christmas over the years. Initially, in 1947, it gave all employees $25 per year for up to 5 years of service with the amount prorated to those with less than I year. In 1948, Respondent gave $25 to all full-time employees with more than 1 year of service and $10 to part-time'employees and those with less than 1 year. In, 1949, the payment was $20 for the first year plus $5 for each additional year up to 5; those with less than I year received $10. From 1950 through 1957, Respondent distinguished between employees who participated in its retirement plan and employees who did not. Those employees participating in the plan, both within and outside the unit, did not receive a Christmas payment; all others did. Thereafter, payments were made in 1950 and 1951 identical with those in 1949 but, as stated, only to those not participating in the retirement plan. In 1952, the payment was , $25 for the first year and $5 per additional year up to $40; a ham was also given. In 1953 no payments were made. In 1954 and 1955, the payment was identical with that of 1952, with part-time employees receiving a pro- portionately smaller amount in 1955. In 1956, the sched- ule was the same except that employees with less than 1 year of service received $5 a month up to $25 and part-time employees received a proportionate payment. Again, in 1957, the payment was $25 for the first year plus $5 for each additional year up to $40. In 1958, Respondent made a change by abandoning any distinction between employees under its retirement plan and those who were not. In 1958 , all full-time employees with more than 1 year of service received $25; those with 6 months to 1 year received $20; and those with less than 6 months received $15. Part-time employees received lesser sums. In 1959, all full-time employees received $35 for the first year plus $2 for each additional year. Part-time employees and those with less than 1 year of service received proportionately lesser amounts. In 1960, 1961, and 1962, all full-time employees received $25 for the first year plus $1 for each additional year. Those with less tenure and part-time employees received lesser sums . In 1962, the Union sought from Respondent and obtained for its unit employees coverage under a union sponsored retirement plan which, unlike Respondent's plan was noncontributory in nature. In 1963 and 1964, Respondent reverted to the 1959 schedule paying all full-time employees $35 for the first year plus $2 for each additional year, with smaller sums to those with less senority and part-time employees. 906 DECISIONS OF NATIONAL LABOR RELATIONS BOARD In 1965, Respondent increased the basic payment to $40 for the first year, plus $10 for each 5 years of employment, with lesser sums to part-time employees and those with less than 1 year of tenure. This schedule was followed in 1966 and 1967. No payment was made to anyone at Christmas in 1968 and no one was advised of the abandonment of this practice or custom. Respondent has adduced evidence that it abandoned Christmas payments for the following reason. After the Union''s noncontributory retirement plan was institut- ed in 1962, Respondent decided nevertheless to continue the Christmas payment to all employees because it wished to keep the benefits to employees not covered by the contract with the Union on an equal basis with those to the unit. Accordingly, everyone continued to receive Christmas payments. In 1968, Respondent initiated a new retirement plan for nonunit employees. This also is noncontributory and the benefits are comparable to those under the Union's plan. 'Respondent decided to discontinue the Christmas payment to nonunit employees and since unit and nonunit employees have for some years been treated equally, it decided' to drop the Christmas payment to unit personnel as well. Respondent also points to a number of other benefits not covered by any contract which are applied equally to both unit and nonunit personnel. These include health insurance, free advertis- ing, scholarship loan funds, free home delivery of the paper, and parking space. D. Subsequent Developments Business Agent Shirley 'testified that he was advised early in 1969 that no payments had been made at Christ- mas of 1968. He and Boris Cherbak, chapel chairman of the Union, duly met with General Manager Charles Richardson of Respondent and its industrial relations advisor, W. Paul Whaley, on February 17, 1969.3 According to Shirley, the basic purpose of this meeting was to resolve a dispute concerning overtime pay on the sixth day of work. After that matter was discussed, Shirley raised the topic of the Christmas payment, asking the reason for its discontinuance. Whaley immediately made the claim that this was not timely because the contract stipulated that grievances, had to be presented within 20 days. Richardson intervened and stated that Respondent would not rest upon this procedural techni- cality; this was, I find, obviously a waiver thereof. Richardson then told Shirley that this discontinuance of the Christmas payment resulted from Respondent's recent installation of the' new and improvised retirement- program for nonunit employees, as discussed above. Richardson contended that this brought nonunit employ- ees to a par with those in the unit with respect to working conditions. Shirley protested that the unit employees had traded, in prior negotiations , a portion of their pay raise for their improved pension program. ' Shirley erroneously placed this meetings on January 17, the record amply demonstrates that it took place on February, 17 Whaley did not testify herein. Whaley responded that a letter would be sent to the Union outlining Respondent's position on this issue. Cherbak corroborated Shirley herein. He, agreed that the principal purpose of the meeting was the dispute concerning overtime pay for the sixth day of .work. Thereafter, the Christmas bonus or payment was raised and the meeting ended on the note that Whaley would write the Union and outline Respondent's position, ther- eon. Richardson agreed as to those who were in attendance, but initially contended that the meeting was set up solely to check on nonpayment of the Christmas gift. Although initially contending that this was the sole topic of discussion, he later conceded that he vaguely recalled that the other grievance existed; he did not deny--that such a grievance had been raised. Richardson also admit- ted that he had disavowed any reliance upon the 20- day clause in the contract for the presentation of griev- ances. I find that the Union took up a grievance concern- ing overtime pay with Respondent on February 17 and, further, raised the nonpayment of Christmas gifts or payments on this occasion. On February 26, Whaley wrote to the Union. His response was entirely silent concerning the Christmas gifts or payments and stated only as follows: In our meeting of February 17, • you 'raised the question on the new pension plan available to Prog- ress-Bulletin employees who were not covered under a union negotiated plan. We are `writing to outline the plan as it now exists. In 1949 the Progress-Bulletin 'made available to all employees who had' attained 30 years of age and had completed one year of service a Retirement Annuity Plan under a contract with the Aetna Life Insurance Company. At that time, the Progress- Bulletin reserved the right to change, suspend, or discontinue the plan at any time., In 1962, after long negotiations, the Union was successful in negotiating an agreement whereby the Aetna Plan was discontinued and the employer' agreed to 'contribute 750 per shift worked for each pressman to the IPP&AU of NA Employer Retire- ment Fund. Contributions to this fund have been continued up to the present time. As you are aware, in our last negotiations it was agreed that the contri- bution rate would be raised to $1.00 per shift, effective December 1, 1968. In order to present a,retirement plan more compara- ble with that which the pressmen have, and which would eliminate the contributory provisions of the former Aetna Plan, the Company 'initiated a new plan to be effective as of January 1, 1969. This new plan takes the form of a Pension Trust, to be funded by contributions from the Company, and has eliminated the contributory provisions of the previous agreement . Benefits to be paid under the plan will vary according to the length of service an employee has served prior to retirement. The plan is similar in several respects to the plan which was initiated,by the pressmen, and it was the desire POMONA PROGRESS BULLETIN 907 of the Company to make available to all employees a more uniform plan We hope this brief explanation will satisfy you that the Company was not giving its non-union employees special benefits Rather it was endeavor ing to bring them up to the level which you have been enjoying since 1962 If you have further ques- tions on this, we of course, will be very happy to discuss it further E Analysis and Conclusions As is apparent, Whaley failed to respond to the Union's protest concerning the Christmas payments except to stress that all employees were treated alike I find that this letter by Whaley did not answer the protest concerning the nonpayment of the Christmas gift except in an oblique manner This nonpayment by Respondent ultimately led to the filing of the instant charge Heretofore, all differences between the Union and Respondent have been settled pursuant to a grievance and arbitration provision in their contracts and the Union has never called a strike against Respondent The con- tract establishes a joint standing committee to resolve all questions as to the "construction to be placed upon any of the clauses of this Agreement or any alleged violations thereof " While a 20-day statute of limitations is discussed therein, I find, as noted, that this was expressly waived by Robinson Contrary to Respondent, I find that there was not an unwritten understanding between the parties concern- ing the payment of Christmas bonuses, whether to those in the unit or otherwise Indeed, Business Agent Shirley of the Union did not know of the existence of the Christmas bonus plan While Respondent euphemistically chooses to refer to these payments as a gift, the simple answer is that a yearend bonus, payment, or gift to employees which has been made each year for a long period of years has been held to constitute wages and here it has been paid since 1947 except for 1953 Indeed, the fact that the sum to each employee varies with his tenure demon- strates that this was remuneration and therefore a part of the employee's wages under the Act The Board has pointed out that "The realities of the industrial world establish that a year-end bonus which has become part of the employees' wage expectan- cy, though it may be paid at Christmas and therefore carry with it the Christmas spirit of gift giving, amounts fundamentally to deferred compensation for services performed during the preceding year " Niles-Bement- Pond Co , 97 NLRB 165, enfd 199 F 2d 713 (C A 2) It is true, as Respondent contends, that it has made unilateral changes in other areas without objection by the Union, but silence or acquiescence in those areas can hardly constitute a clear and unmistakable waiver with respect to being heard on the Christmas payments Indeed, this is not a case where the Christmas bonus was discussed in bargaining negotiations with the result- ing claim that the Union had waived its rights to be heard later The simple answer is that when Respondent unilateral- ly abandoned the bonus, the Union did ask to be heard on the matter One such meeting was held in February and this was followed by a letter on February 26, 1969, wherein the representative of Respondent merely explained that pension benefits to the nonunit employees had been improved, with a plan roughly comparable to that enjoyed by those in the unit and was entirely silent about the Christmas bonus That the payment was never referred to in negotiations and has never been reflected in language in a contract is not controlling in view of the fact that it has become a part of the wage expectancy For, as noted above, it amounts to "deferred compensation for services per- formed " during the previous year As it points out, Respondent has gotten along well with the Union over the years And its position that other benefits to its employees equitably warrant cessa tion of the Christmas bonus is not unreasonable But the answer to this is that this is properly a matter to be raised at the bargaining table with the representative of its employees Indeed, if Respondent has enjoyed amicable relations with the Union ais the representative of the employees in the unit, this appears all the more reason for giving the Union an opportunity to be heard before the fact rather than by taking this unilateral action Respondent has argued that this matter should be deferred to arbitration because of the long and amicable bargaining relationship Joseph Schatz Brewing Co 175 NLRB 23 The General Counsel points out in turn that in Schutz the employer claimed that his unilateral action was predicated upon a contractual privilege, with the union taking a contrary position as to the interpreta- tion of a disputed contract clause The Board also noted that the employer had offered to discuss the proposed changes with the Union prior to taking any action True, the instant contract has an extensive grievance and arbitration procedure, but this is limited to disputes arising as to construction of the clauses of the contract And this contract is entirely silent as to the Christmas bonus Therefore, a resolution of the alleged unfair labor practices does not turn upon an interpretation of any specific contractual provisions And even the availability of such a procedure does not preclude the Board from exercising jurisdiction herein N L R B v Strong Roofing & Insulating Co , 393 U S 357 I find, therefore, that by unilaterally discontinuing the payment of the Christmas bonus to unit employees Respondent has refused to bargain with the Union within the meaning of Section 8(a)(5) and, derivatively, Section 8(a)(1) of the Act Mississippi Steel Corp , 169 NLRB 647, enfd 405 F 2d 405 F 2d 1373 (C A D C ), Graven slund Operating Co d/b/a Washington Hardware & Furn Co , 168 NLRB 513, and American Fire Apparatus Co , 160 NLRB 1318 908 DECISIONS OF NATIONAL LABOR RELATIONS BOARD IV. THE REMEDY Having found that Respondent has engaged in certain unfair labor practices, I shall recommend that it cease and desist therefrom and take certain affirmative action designed to effectuate the policies of the Act. It has been found that Respondent has refused to bargain with the Union as the duly designated representa- tive of its employees in an appropriate unit. The record demonstrates that the 1965, 1966, and 1967 bonuses were identical. There is no claim of financial hardship or adverse economic circumstances in 1968. I shall there- fore recommend, as urged by the General Counsel, that Respondent pay each of its employees in the appropriate unit, except the foreman, the amounts for 1968 as computed under the 1965-67 formula, refrain from future unilateral action in this area, and, upon request, bargain concerning this topic. As pointed out, the Board's grant of remedial power is" a broad one. N.L.R.B. v. Strong Roofing, supra. Upon the basis of the foregoing findings of fact, and upon the entire record in the case, I make the following: CONCLUSIONS OF LAW 1. Progress Bulletin Publishing Company d /b/a Pomo- na Progress Bulletin is an employer within the meaning of Section 2(2) of the Act. 2. Los Angeles Newspaper Web Pressmen ' s Union No. 18, International Printing Pressmen & Assistants Union of North America , AFL-CIO, is a labor organiza- tion within the meaning of Section 2(5) of the Act. 3. All foremen , men in charge , journeymen pressmen, and apprentice pressmen employed by Respondent, excluding office clerical and professional employees, guards, watchmen , and supervisors , constitute a unit appropriate for the purposes of collective bargaining within the meaning of Section 9 (b) of the Act. 4. Los Angeles Newspaper Web Pressmen ' s Union No. 18, International Printing Pressmen & Assistants Union of North America, AFL-CIO, has been at all times material herein, and now is, the exclusive repre- sentative of all employees in the aforesaid appropriate unit , within the meaning of Section 9(a) of the Act. 5. By unilaterally discontinuing. the 1968 Christmas bonus to employees in the above unit , except the fore- man, Respondent has engaged in unfair labor practices within the meaning of Section 8 (a)(5) of the Act. 6. By the foregoing conduct , Respondent has engaged in unfair labor practices within the meaning of Section 8(a)(1) of the Act. 7. The aforesaid unfair labor practices are unfair labor practices affecting commerce within the meaning of Sec- tion 2(6) and (7) of the Act. RECOMMENDED ORDER Upon the basis of the foregoing findings of fact and conclusions of law, and upon- the entire record in the case, it is recommended that.Respondent, Progress Bulle- tin Publishing Company d/b/a Pomona Progress Bulletin; Pomona, California, its officers, agents, successors, and assigns, shall: 1. Cease and desist from: (a) Unilaterally discontinuing payment of a Christmas bonus to the employees in the above appropriate unit, excluding the foreman. (b) In any like or related manner interfering with, restraining, or coercing employees in the exercise of the right to self-organization, to form labor organizations, to join or assist; the above-named or any other labor organization, to bargain collectively through representa- tives of their own choosing, to engage in concerted activities for the purpose of collective bargaining or other mutual aid or protection, and to refrain from any or all such activities, except to the extent such right may be affected by an agreement requiring member- ship in a labor organization as a condition of employment. 2. Take the following affirmative action designed to effectuate the policies of the Act: (a) Pay the 1968 Christmas bonus, as provided above, to all employees in the above appropriate unit, except the foreman. (b) Upon request, bargain with the Union concerning the payment of a Christmas bonus to employees within the appropriate unit. (c) Post at its offices at Pomona, California, copies of the notice attached hereto and marked Appendix.4 Copies of said notice on forms provided by the Regional Director for Region 21, shall, after being duly signed by Respondent, be posted immediately upon receipt thereof and maintained by it for 60 consecutive days thereafter, in conspicuous places, including all places where notices to employees 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. (d) Notify the Regional Director for Region 21, in writing, within 20 days from the receipt of this Recom- mended Order, what steps it has taken to comply here- with.5 In the event no exceptions are filed as provided by Sec 102 46 of the Rules and Regulations of the National Labor Relations Board, the findings, conclusions, recommendations, and Recommended Order herein shall, as provided in Sec 102 48 of the Rules and Regulations, be adopted by the Board and become its findings, conclusions, and order, and all objections thereto shall be deemed waived for all purposes. In the event that the Board's Order is enforced by a judgment of a United States Court of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations Board " shall be changed to read "Posted Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board " ' In the event this Recommended Order be adopted by the Board, this provision shall be modified to read. "Notify said Regional Director in writing within 10 days from the date of this Order what steps Respondent has taken to comply herewith." POMONA PROGRESS BULLETIN 909 APPENDIX NOTICE TO EMPLOYEES POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government WE WILL, upon request , bargain with Los Ange- les Newspaper Web Pressmen ' s Union No 18, International Printing Pressmen & Assistants Union of North America , AFL-CIO, as the representative of our foremen , men in charge , journeymen press men, and apprentice pressmen , excluding office cler- ical and professional employees , guards, watchmen, and supervisors concerning the payment of a Christ- mas bonus WE WILL NOT unilaterally discontinue the pay- ment of a Christmas bonus to the employees in the above unit , excluding the foreman WE WILL pay to all employees in the above appropriate unit , except the foreman , a Christmas bonus for 1968 , computed according to the 1965-1967 formula WE WILL NOT in any like or related manner interfere with , restrain , or coerce employees in the exercise of the right to self -organization, to form labor organizations , to join or assist the above named or any other labor organization , to bargain collectively through representatives of their own choosing , to engage in concerted activities for the purpose of collective bargaining or other mutual aid or protection , and to refrain from any or all such activities , except to the extent such right may be affected by an agreement requiring member ship in a labor organization as a condition of employ- ment PROGRESS BULLETIN PUBLISHING COMPANY D/B/A POMONA PROGRESS BULL ETIN (Employer) Dated By (Representative ) (Title) This is an official notice and must not be defaced by anyone This notice must remain posted for 60 consecutive days from the date of posting and must not be altered, defaced , or covered by any other material Any questions concerning this notice or compliance with its provisions , may be directed to the Board's Office, Eastern Columbia Building , 849 South Broadway, Los Angeles, California 90014 , Telephone 213-688-5200 Copy with citationCopy as parenthetical citation