Teamsters Local 957 (Northwood Stone)

National Labor Relations Board - Board DecisionsApr 30, 1990

298 N.L.R.B. 395 (N.L.R.B. 1990)

TEAMSTERS LOCAL 957 (NORTHWOOD STONE) 395 General Truck Drivers, Chauffeurs, Warehousemen and Helpers of America , Local Union 957, af- filiated with International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, AFL-CIO and Northwood Stone & Asphalt Co. Case 9-CE-52 April 30, 1990 DECISION AND ORDER BY CHAIRMAN STEPHENS AND MEMBERS CRACRAFT AND DEVANEY On June 30, 1989, Administrative Law Judge Leonard M. Wagman issued the attached decision. The Respondent and the General Counsel filed ex- ceptions and supporting briefs. The National Labor Relations Board has delegat- ed its authority in this proceeding to a three- member panel. The Board has considered the decision and the record in light of the exceptions and briefs and has decided to affirm the judge's rulings, findings, and conclusions and to adopt the recommended Order as, modifled.' ORDER The National Labor Relations Board adopts the recommended Order of the administrative law judge as modified below and orders that the Re- spondent , General Truck Drivers, Chauffeurs, Warehousemen and Helpers of America, Local Union 957 , affiliated with International Brother- hood of Teamsters , Chauffeurs , Warehousemen and Helpers of America , AFL-CIO, Dayton , Ohio, its officers, agents, successors , and assigns , shall take the action set forth in the Order as modified. 1. Substitute the following for paragraph 1. "1. Cease and desist from entering into , maintain- ing, giving effect to , or enforcing provisions in, its collective-bargaining agreement with Northwood Stone & Asphalt, Inc., the Labor Relations Divi- sion of the Ohio Contractors Association, and the Associated General Contractors of America, Inc. that are unlawful under Section 8(e) of the Nation- al Labor Relations Act by filing a grievance and a lawsuit with the object of forcing Northwood Stone & Asphalt Co. to apply contractual provi- sions so as to require that the work of hauling RAP from jobsites be assigned only to drivers who are signatories to a contract with the Union." 2. Insert the following as paragraph 2(a) and re- letter the subsequent paragraphs. "(a) Withdraw the grievance filed on or about June 16, 1988, against Northwood Stone & Asphalt Co., and its lawsuit number C-3-88-590 filed on or about November 21, 1988, in the United States Dis- trict Court for the Southern District of Ohio, Western Division, insofar as that lawsuit is seeking to require Northwood Stone & Asphalt Co. to assign the work of removing RAP from jobsites only to drivers who are signatories to a contract with the Union." 3. Substitute the attached notice for that of the administrative law judge. APPENDIX NOTICE To MEMBERS POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government The National Labor Relations Board has found that we violated the National Labor Relations Act and has ordered us to post and abide by this notice. WE WILL NOT enter into, maintain, give effect to, or enforce provisions in, our collective-bargain- ing agreement with Northwood Stone & Asphalt, Inc., the Labor Relations Division of the Ohio Contractors Association, and the Associated Gen- eral Contractors of America, Inc. that are unlawful under Section 8(e) of the National Labor Relations Act by filing grievances and lawsuits with the object of forcing Northwood Stone & Asphalt Co. to apply contractual provisions so as to require that the work of hauling RAP from jobsites be assigned only to drivers who are signatories to a contract with the Union. WE WILL withdraw the grievance filed on or about June 16, 1988, against Northwood Stone & Asphalt Co., and our lawsuit C-3-88-590 filed on or about November 21, 1988, in the United States District Court for the Southern District of Ohio, Western Division, insofar as that lawsuit is seeking to require Northwood Stone & Asphalt Co. to assign the work of removing RAP from jobsites i The General Counsel has excepted to the judge's failure to order the Respondent to cease and desist from filing grievances and lawsuits to en- force the provisions of the parties' collective -bargaining agreement found unlawful and his failure affirmatively to order the Respondent to with- draw its grievance and lawsuit against the Employer. We find merit in the General, Counsel's exceptions as the remedy sought by the General Counsel is consistent with the ,fudge's findings. We shall amend the rec- ommended Order and notice accordingly 298 NLRB No. 48 396 DECISIONS OF THE NATIONAL LABOR RELATIONS BOARD only to drivers who are signatories to a contract with the Union. GENERAL TRUCK DRIVERS , CHAUF- FEURS, WAREHOUSEMEN AND HELP- ERS OF AMERICA, LOCAL UNION 957, AFFILIATED WITH INTERNATIONAL BROTHERHOOD OF TEAMSTERS CHAUFFEURS, WAREHOUSEMEN AND HELPERS OF AMERICA, AFL-CIO Damon W. Harrison Jr., Esq., for the General Counsel. Daniel N. Kosanovich and Theresa M. Muhic, Esgs (Lo- gothetis & Pence), of Dayton, Ohio, for the Respond- ent. DECISION STATEMENT OF THE CASE LEONARD M. WAGMAN, Administrative Law Judge. This case was tried in Dayton, Ohio, on April 12, 1989. The charge was filed on December 7, 1988.1 The Re- gional Director for Region 9 issued the complaint on March 23, 1989. The complaint alleges that the Respondent, General Truck Drivers, Chauffeurs, Warehousemen and Helpers of America, Local Union No. 957, affiliated with Inter- national Brotherhood of Teamsters, Chauffeurs, Ware- housemen and Helpers of America, AFL-CIO, had vio- lated Section 8(e) of the National Labor Relations Act (29 U.S.C. Â§ 151, et seq.) (the Act), by filing and process- ing a grievance alleging that the Employer, Northwood Stone & Asphalt Co., had violated article II, section 5; article III, section 10; and article VII, section 37 of the Ohio Highway-Heavy State Agreement between the Labor Relations Division of the Ohio Contractors Asso- ciation, the Associated General Contractors of America, Inc. and Ohio Conference of Teamsters of the Interna- tional Brotherhood of Teamsters, Chauffeurs, Warehou- semen and Helpers of America (the OCA agreement), to which the Employer had agreed to be bound and by in- stituting a lawsuit seeking to compel the Employer to comply with the arbitration determination- that it had violated article II, section 5 and article VII, section 37 of the OCA agreement. According to the complaint, the Union, by this conduct, had entered into, maintained, and had given effect to an agreement requiring the Em- ployer to cease and refrain from handling , using , selling, transporting , or otherwise dealing in the production of, or to cease doing business with, any other employer or person. On the entire record, including my observation of the demeanor of the witnesses, and after considering the briefs filed by the General Counsel and the Respondent, I make the following i All dates are in 1988, unless otherwise indicated FINDINGS OF FACT 1. JURISDICTION The Employer, with an office and place of business at Belle Center, Ohio, manufactures and installs asphalt and paving. During the past 12 months, a representative period, the Employer purchased and received at its Belle Center, Ohio facility products, goods, and materials valued in excess of $50,000 directly from points outside the State of Ohio. The Respondent admits, and I find, that the Employer is an employer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act. The Respondent also admits, and I find, that the Union is a labor organization within the meaning of Sec- tion 2(5) of the Act. II. ALLEGED UNFAIR LABOR PRACTICES A. The Facts The Employer consists of two firms, Northwood Stone & Asphalt Co., and Northwood Stone & Asphalt, Inc. Northwood Stone & Asphalt, Inc. is a general con- tractor engaged in highway construction , including as- phalt paving. Northwood Stone & Asphalt Company (Northwood Asphalt) manufactures asphalt, concrete, and crushed stone for highway construction. The manu- facturing company has six plants in Ohio. Its main office is at Belle Center, Ohio, where it also maintains a plant. The two firms have common ownership and officers, but are separate corporations. The contracting company (Northwood Stone) has been engaged in highway paving and construction since 1954. Since at least 1974, Northwood Stone has been bound by the OCA agreement. The most recent OCA agreement in the record before me was effective from May 1, 1986, until April 30, 1989. Northwood Stone was a member of the Ohio Contractors Association (OCA) in the late 1960s and early 1970s, but then dropped out of the organization until June 1988 . Northwood Stone has not assigned its bargaining rights to OCA. Northwood Stone has always contracted with owner- operators to haul reclaimed or recyclable asphalt product (RAP). Northwood does not utilize either its own equip- ment or its employees to perform this waste removal. The haulage agreements are embodied in standard indi- vidual 1-year agreements between Northwood Stone and owner-operators, who in effect subcontract to perform this haulage for the Ohio Department of Transportation and other customers of Northwood Stone. Northwood Stone does not apply the OCA agreement to the contract drivers engaged in hauling RAP. Northwood Stone pays the owner-operators at either a ton/mile rate or at an hourly rate. The owner-operators purchase and maintain their own trucks, hire, and pay employees to drive them. The owner/operators also obtain their own insurance and pay such taxes and make such withholding as may pertain to their haulage busi- ness . Northwood Stone does not withhold money from its payments to the owner-operators for taxes, unemploy- ment benefits, social security, or for other employee ben- efit programs. Northwood Stone's contracts with the TEAMSTERS LOCAL 957 (NORTHWOOD STONE) owner-operator's permits them to refuse its dispatcher and to haul for other contractors. RAP is obtained by scraping the surface of an asphalt surfaced road. A machine scrapes the asphalt off the road surface and deposits it on a conveyor belt which feeds it into a waiting dump truck. In 1988, approximate- ly 40 percent of the trips by Northwood Stone's contract drivers were for the removal of RAP to one of North- wood Asphalt's plants, where it was used in the produc- tion of asphalt paving material. Typically, Northwood Stone notifies its contract driv- ers the day before that they have been selected for dis- patch to haul RAP back to one of Northwood Asphalt's plants. Early on the following morning, the contract driver takes his dump truck to the designated jobsite. If he is first in line, he will get the first load of RAP off the conveyor belt. Otherwise, he gets in line and waits his turn at loading. Once loaded, the contract driver delivers his load of RAP to Northwood Asphalt's plant. He then either returns empty to the jobsite for another load of RAP, or picks up material to be transported to the job- site. If the driver is under instructions to pick up another load of RAP, he returns to the conveyor belt. The time a contract driver spends on a jobsite depends on the length of the line of trucks in front of him, the capacity of the trucks, and the thickness of the asphalt surface being scraped. On the first trip to the jobsite in the morning, the wait is approximately 15 or 20 minutes. On subsequent trips, the wait will be substantially re- duced. On a typical day, on which a contract driver is only hauling RAP, not more than 5 or 6 percent of his working time is devoted to waiting to load at the jobsite. The loading process may require from 2 to 10 minutes, if the scraper is working on a thin layer of asphalt. The usual loading time for a 16-ton truck is 4 minutes. Load- ing at the jobsite accounts for 1 to 2 percent of the driv- er's workday. The driving time from the jobsite to the asphalt plant is 20 to 25 minutes. At the plant, weighing and unloading RAP requires 3 to 5 minutes. Contract drivers hauling RAP spend approximately 90 percent of their worktime driving between jobsite and asphalt plant. In the last 3 years, Northwood Stone has had approxi- mately 600 jobs involving RAP. In all but two or three of the jobs, the contract drivers hauled the RAP to a Northwood Asphalt plant. On those two or three occa- sions, the contract drivers dumped the RAP at or near the jobsite. On June 3, Respondent filed a grievance against Northwood Stone for hauling RAP in violation of article II, section 5; article III, section 10; article VII, section 37; article XII, section 46; and article XIII, section 48 of the OCA. Of the contract provisions referred to in the grievance, the following are pertinent to the alleged vio- lations of Section 8(e) of the Act: ARTICLE II Scope of Agreement 5. This Agreement shall govern all forms of con- struction work which the Contractor performs in the State of Ohio and which comes within the juris- 397 diction of the Ohio Conference of Teamsters of the International Brotherhood of Teamsters, Chauf- feurs, Warehousemen and Helpers of America, and shall apply solely to employees employed directly and exclusively in construction. On site work shall include the hauling of waste material off the job site and shall include hauling of material from one work project to another work project. 6. This Agreement shall not apply to pick-up trucks assigned by the Contractor to engineering or technical employees, clerical employees, timekeep- ers, superintendents , assistant superintendents , super- visors in charge of any classes of labor or any su- pervisory personnel, and shall not apply to trucks used in greasing or repairing heavy equipment. ("Greasing" or "repairing" as used in this paragraph shall not be construed to include fuel trucks.) ARTICLE III Definitions 10. The term "owner-operator" includes a person or persons who own their own pieces of equipment and hire out said equipment to the Contractor for the performance of bargaining unit work herein. The term driver of leased equipment includes an "owner-operator" and a driver of equipment owned by another person who hires out or leases one or more pieces of equipment to the Contractor for the purpose of performance of bargaining unit work herein. 10(a). The Contractor agrees owner-operator and drivers of leased equipment as defined in paragraph 10, falling under the separate check method for driver and equipment, shall be covered by Article XII and Article XIII of this Agreement. ARTICLE VII Subcontracting 37. All work covered under the scope of this Agreement to be performed on the job site shall be subcontracted only to an employer who is a party to a current, written collective bargaining agree- ment with, the union. In such subcontracts, provi- sion shall be made to require subcontractors to adhere to the conditions of this collective bargain- ing agreement. All such work assignable to employees covered under the scope of this Agreement not to be per- formed at the job site shall be subcontracted only to an employer who observes the wages, and benefits of overall cost established herein. No such work shall be subcontracted on terms that fail to require subsequent employers to adhere to these conditions. ARTICLE IX Arbitration 40. Subject to the limitations of Article VIII, all differences which the parties involved have been 398 DECISIONS OF THE NATIONAL LABOR RELATIONS BOARD unable to settle or adjust shall upon the request of either party, within forty-eight (48) hours from the giving of the decision is STEP 2, be referred to the Joint State committee which shall be established and composed as follows: (a) Both the Contractors and the Union shall each select three (3) members from their respective groups before the first day of July 1972, who shall constitute the Joint State Committee. There shall be two (2) alternate members selected by each group who will serve when needed to secure full represen- tation of either party on such Joint State Commit- tee. (b) A chairman shall be selected by the members of such Joint State Committee at each meeting thereof; such chairmanship shall alternate between a member of the Union group and the Contractor group at each meeting. (c) A meeting of such Joint State Committee shall be held as often as it shall be deemed neces- sary to dispose of its business. (d) However, it is understood and agreed that the State Joint Disputes Board will establish quarterly meetings to resolve pending grievances. It is further agreed that the Ohio Contractors Association, Labor Relations Division, and the Ohio Conference of Teamsters will formulate a standard grievance procedure form to be used in the construction in- dustry. (e) A majority vote of the Joint State Committee Shall be necessary to constitute a final decision of the unsettled differences referred to said committee. Such a majority decision shall be final and binding upon the parties involved. If any employer fails to abide by a majority deci- sion of the Ohio Joint State Committee, the Local Union, after giving the employer a seventy-two (72) hour written notice, may strike to enforce this Arti- cle. (f) In the event a deadlock occurs in the Joint State Committee the dispute, except in those in- stances set out in Paragraph 42 of this Article, may be referred to arbitration within forty-eight (48) hours from the giving of the decision of the Joint State Committee. An impartial arbitrator shall be se- lected by a majority of the Joint State Committee. In the event the Joint State Committee is unable to agree upon an impartial arbitrator as herein above provided, then the Contractors and the Union shall jointly submit a request to the Federal Mediation and Conciliation Service for a panel of arbitrators from which to select an arbitrator. Upon receipt of such a list, the representatives of the respective par- ties shall then select an Arbitrator therefrom by al- ternately striking off a name from said list until but one (1) remains. The privilege of making the first strike-off shall go to the party successfully calling the flip of a coin. (g) The arbitrator so selected shall hear the matter and render a written award within ten (10) days, unless extended by mutual agreement of the parties. Such award shall be final and binding upon the parties involved. The individual Contractor and the Local Union involved shall each bear one-half of the total costs of such arbitration. The Arbitrator shall have no power to modify, amend or abrogate this Agreement in any way. On June 16, Respondent and Northwood Stone met to discuss the hauling of RAP and the pending grievance. Northwood Stone argued that the hauling of RAP was not onsite work under the contract because it was not a waste product. According to Northwood Stone, RAP was a resource which returned to Northwood Asphalt's plant to be reused as an ingredient in the manufacture of road surfacing material. Respondent's position was that RAP was a waste product and that the removal of waste from a jobsite was onsite work covered by the subcontracting provision of the OCA agreement. Respondent mentioned a list of Teamsters haulers. Northwood Stone asked for the list and expressed an intent to use them on some projects to haul material. Respondent also stated that it would con- tact OCA for an opinion on whether RAP was waste and whether the hauling of RAP was onsite work, and would advise Northwood Stone accordingly. The meeting concluded without resolution of the Re- spondent's grievance. However, Respondent expressed its expectation that Northwood Stone would comply if OCA agreed with Respondent. In a letter to the Union, dated August 24, OCA an- nounced its opinion that RAP was "waste material" and that "the hauling of this material is included under the existing agreement as on site work." The Union forward- ed a copy of the OCA letter to Northwood Stone's labor relations consultant. In its transmittal letter, the Union requested a statement of Northwood Stone's intention to accept OCA's view of the agreement, "or whether the Ohio Conference of Teamsters should arbitrate this matter." Approximately 3 weeks after receiving the Union's letter, Northwood Stone responded with a refus- al to abide by OCR's determination. On November 21, the Union filed a complaint in the United States District Court for the Southern District of Ohio, Western Division against Northwood Stone' and another employer, alleging that the' defendants had re- fused to abide by OCA's resolution of - pending griev- ances regarding the hauling of RAP, and thus had violat- ed the OCA Agreement. The matter is scheduled' for trial in 1990. B. Analysis and Conclusions Section 8(e) of the Act proscribes entry into "any con- tract or agreement, express or implied" whereby an em- ployer agrees not to handle products of, or agrees to cease doing business with , any other person . A proviso to this section exempts from this proscription an agree- ment between a union and an employer in the construc- tion industry with respect to work "to be done at the site of the construction ." As the court explained in National Woodwork Mfrs. Assn . v. NLRB, 386 U.S. 612 , 633-635 (1967), Section 8(e) was intended to supplement the exist- ing prohibitions against secondary boycotts. It does not TEAMSTERS LOCAL 957 (NORTHWOOD STONE) prohibit all union-employer agreements which may have the incidental effect of a cessation of business with other employers. Instead, Congress intended that Section 8(e) of the Act would embody the same distinction between lawful "primary" and unlawful "secondary" boycott ac- tivity contained in Section 8(b)(4) of the Act. Id. at 637- 639. Contract clauses which seek to effect primary objec- tives, such as the preservation or protection of the tradi- tional work of employees of the contracting employer are not within the proscription of Section 8(e) of the Act. Teamsters Local 89 (Robert E. McKee, Inc.), 254 NLRB 783, 785 (1981). However, the Board, in Retail Clerks Local 1288 (Nickel's Pay-Less Stores), 163 NLRB 817, 819 (1967), set out the applicable standard for deter- mining whether contract clauses violate Section 8(e) of the Act, as follows: [C]ontract provisions are secondary and unlawful if they are to have as their principal objective the reg- ulation of the labor policies of other employers and not the protection of the unit. Typical of such pro- scribed provisions are those which limit subcon- tracting to employers who recognize the union or who are signatory to a contract with it. In the instant case, article II, section 5 of the OCA agreement declares that : "On site work shall include the hauling of waste material off the job site and shall in- clude hauling of material from one work project to an- other work project ." Article VII, section 37 limits the subcontracting of such work "only to an employer who is a party to a current , written collective bargaining agreement with the union ." I find that article VII, sec- tion '5 of the OCA agreement "is a union signatory clause which is proscribed by Section 8(e) of the Act, unless it is saved by that section 's construction proviso." Teamsters Local 89 (Robert McKee, Inc.), supra, 254 NLRB at 786. The Board has refused to extend the protection of Sec- tion 8(e)'s construction proviso to union-signatory clauses which seek to include various types of transpor- tation work involving deliveries to, or pickups from, construction jobsites . Teamsters (AGC of California), 248 NLRB 808, 815-817 (1980). The Board's policy in this regard looks to the legislative history of the proviso which reveals that Congress included the construction industry proviso to "avoid tensions among groups of em- ployees at the same site" and that Congress exempted transportation to and from jobsites from the proviso be- cause employees involved in such work have only "inci- dental contact with the site ." Teamsters, supra, 248 NLRB at 816 . With rare exception , the haulage of RAP and other waste by the owner-operators in the instant case involves such "incidental contact" with jobsites. For the foregoing reasons, I find that the construction provi- so does not protect the secondary provisions of article VII, section 37 of the OCA agreement . Accordingly, I find those provisions are proscribed by Section 8(e) of the Act. Section 8(e) of the Act prohibits only "entering into" an agreement in which an employer agrees not to handle 399 products of, or agrees to cease doing business with, any other person . It is well settled under Board law that seeking to enforce such an agreement constitutes "enter- ing into" within the meaning of Section 8(e) of the Act. Teamsters Local 89 (AGC of California), supra, 254 NLRB at 785. I find that Respondent , by filing a griev- ance on June 16, and thereafter filing a lawsuit, sought to enforce article II , section 5 , article III , section 10,2 and article VII, section 37 of the OCA agreement during the 10(b) period , and thereby violated Section 8(e) of the Act. THE REMEDY Having found that Respondent has engaged in an 'unfair labor practice, I shall recommend that it cease and desist therefrom and take certain affirmative action to ef- fectuate the purposes of the Act. On the basis of the foregoing findings of fact and upon the entire record in this proceeding, I make the follow- ing CONCLUSIONS OF LAW 1. Northwood Stone & Asphalt Co. is an employer en- gaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act. 2. The Respondent, General Truck Drivers, Chauf- feurs, Warehousemen and Helpers of America, Local 957, affiliated with International Brotherhood of Team- sters, Chauffeurs, Warehousemen and Helpers of Amer- ica, AFL-CIO, is a labor organization within the mean- ing of Section 2(5) of the Act. 3. By entering into, maintaining, and giving effect to article II, section 5, article III, section 10, and article VII, section 37 of the Ohio Highway-Heavy State Agreement between Northwood Stone & Asphalt, Inc., the Labor Relations Division of the Ohio Contractors Association, the Associated General Contractors of America, Inc., and the Ohio Conference of Teamsters of the International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, Respondent has engaged in an unfair labor practice within the meaning of Section 8(e) of the Act. 4. The aforesaid unfair labor practice is an unfair labor practice affecting commerce and the free flow of com- merce within the meaning of Section 2(6) and (7) of the Act. On these findings of fact and conclusions of law and on the entire record, I issue the following recommend- ed3 Sec. 10(b) provides in pertinent part. That no complaint shall issue based upon any unfair labor practice occurring more than six months prior to the filing of the charge with the Board and the service of a copy thereof-upon the person against whom such charge is made... . s If no exceptions are filed as provided by Sec. 102.46 of the Board's Rules and Regulations , the findings, conclusions, and recommended Order shall, as provided in Sec. 102.48 of the Rules, be adopted by the Board and all objections to them shall be deemed waived for all pur- poses. 400 DECISIONS OF THE NATIONAL LABOR RELATIONS BOARD ORDER The Respondent, General Truck Drivers, Chauffeurs, Warehousemen and Helpers of America, Local Union No. 957, affiliated with International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America, AFL-CIO, Dayton, Ohio, its officers, agents, and representatives, shall 1. Cease and desist from entering into , maintaining, giving effect to, or enforcing provisions in its collective- bargaining agreement with Northwood Stone & Asphalt, Inc., the Labor Relations Division of the Ohio Contrac- tors Association, and the Associated General Contractors of America, Inc., to the extent found unlawful. 2. Take the following affirmative action necessary to effectuate the policies of the Act. (a) Post at its business offices and meeting halls copies of the attached notice marked "Appendix."4 Copies of a If this Order is enforced by a judgment of a United States court of appeals, the words in the notice reading "Posted by Order of the Nation- al Labor Relations Board" shall read "Posted Pursuant to a Judgment of the notice, on forms provided by the Regional Director for Region 9, after being signed by the Respondent's au- thorized representative, shall be posted by the Respond- ent immediately upon receipt and maintained for 60 con- secutive days in conspicuous places including all places where notices to members ale customarily posted. Rea- sonable steps shall be taken by the Respondent to ensure that the notices are not altered, defaced, or covered by any other material. (b) Sign and return to the Regional Director sufficient copies of the notice for posting by Northwood Stone & Asphalt, Inc., if willing, at all places where notices to employees are customarily posted. (c) Notify the Regional Director in writing within 20 days from the date of this Order what steps the Re- spondent has taken to comply. the United States Court of Appeals Enforcing an Order of the National Labor Relations Board."