United States Postal Service

National Labor Relations Board - Administrative Judge Opinions

Jan 6, 2014

07-CA-098122 (N.L.R.B. Jan. 6, 2014)

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Detroit, MI
UNITED STATES OF AMERICA
BEFORE THE NATIONAL LABOR RELATIONS BOARD
DIVISION OF JUDGES
NEW YORK BRANCH OFFICE
UNITED STATES POSTAL SERVICE
and Case No. 7-CA-98122
LOCAL 295, DETROIT DISTRICT AREA LOCAL,
AMERICAN POSTAL WORKERS UNION (APWU), AFL-CIO
Kelly Temple, Esq., Counsel for the General Counsel.
Roderick Eves, Esq., Deputy Managing Counsel, Counsel for the Respondent.
DECISION
Statement of the Case
Joel P. Biblowitz, Administrative Law Judge: This case was heard by me on
November 14, 2013 in Detroit, Michigan. The Complaint herein, which issued on April 15, 20131
and was based upon an unfair labor practice charge and an amended charge that were filed on
February 11 and April 11 by Local 295, Detroit District Area Local, American Postal Workers
Union, (APWU), AFL-CIO, herein called the Union, alleges that the United States Postal
Service, herein called the Respondent, violated Section 8(a)(1)(5) of the Act by failing to furnish
the Union with information that it requested, which information was relevant to it as the collective
bargaining representative of certain of its employees, and unreasonably delayed in providing the
Union with certain other information that it requested.
I. Jurisdiction and Labor Organization Status
Respondent admits and I find that the Board has jurisdiction over it by virtue of Section
1209 of the PRA, and that the American Postal Workers Union, herein called the National
Union, and the Union have each been a labor organization within the meaning of Section 2(5) of
the Act.
II. The Facts
Since about 1990 the National Union has been recognized as the exclusive bargaining
representative of the unit employees, while the Union has been the servicing agent of the unit
employees at Respondent’s Detroit District facilities, including the George Washington Young
facility, herein referred to as GWY. Testifying for Counsel for the General Counsel was James
Stevenson, who is employed by the Respondent and is the clerk craft director (“the primary
point person for the filing of grievances”) for the Union. Erika Fields-Daniels, employed by the
Respondent as a mail processing clerk and RFI (Request for Information) assistant, and Crystal
Curtis, formerly Crystal Thornton, a labor relations specialist and Detroit RFI coordinator
employed by the Respondent. As there are substantial differences between the testimony of
Stevenson and that of Thornton and Daniels, their testimony will be described separately.

1 Unless indicated otherwise, all dates referred to herein relate to the year 2013.
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Stevenson testified that on February 7 he sent a request for information to the
Respondent requesting:
Provide the job ID and title for each administrative position at the GWY facility on the
administrative side of the GWY facility. Include the name and form 50 of the official job
holder for each position above. Provide the form 50 for each employee working on the
administrative side of the GWY facility. The employer still has not provided the requested
information from 1/11/13.
I have previously indicated that the information is relative to the investigation of
bargaining unit positions and or work on the administrative side of GWY.
He testified that he attached to this request Grievance No. 11-0-524, which was filed in 2012,
alleging Improper Use of 204Bs, stating, inter alia:
Management in an ongoing and continuing violation has unilaterally repudiated
provisions of the collective bargaining agreement and are improperly utilizing 204Bs 2 by
refusing to adhere to Article 37 3A.8 of the JCIM3 which states in part “No later than
June 1, 2012, 204-Bs in the Clerk Craft is restricted to the absence or vacancy of a
supervisor for 14 days or more.” Management is still utilizing 204-Bs in the clerk craft
improperly as many 204-Bs are being utilized in the same manner as before the contract
changed. The 204Bs are not filling a legitimate vacancy which meets the statutory time
period. Management’s failure to post and or fill vacancies does not give them the
unfettered right to utilize 204Bs stating they are covering a position which was never
posted or filled.
He testified that there is a job ID number for every position at the Respondent and each
employee, unit or non-unit, has a Form 50, official personnel action, which identifies the
employee’s official position, and he needs that information to determine whether the
Respondent is improperly employing 204Bs; “the Form 50 is the only dispositive document that
clearly demonstrates what position a person is supposed to be in.” In addition, he needed that
information for the non-unit employees as Article 37 is the only contract provision permitting
management to transfer a non-unit employee into a supervisory position, and he needs the job
ID and Form 50 to determine whether the employee is eligible for the position and whether the
Respondent is “manufacturing vacancies” in order to transfer certain employees.
He testified that he faxed this request to the Respondent and attached the Grievance
No. 11-0-524 to the RFI to show the relevancy of the request. As stated in his February 7 RFI,
he had made the same request, with the same grievance attached, on January 11 and he
received only about five job descriptions, rather than all the job descriptions that he had
requested. In response he wrote to the Respondent on January 28 stating that the information
that he asked for in his January 11 request had not been provided for the employees on the
administrative side of GWY, the non-bargaining unit employees. He testified that between
January 28 and February 7 he had a telephone conversation with Thornton and told her that he
had not received the requested information for the administrative employees and she asked
him, “What exactly are you trying to get at?” He testified that he is not required to reveal how he

2 Acting or temporary supervisors are referred to as 204Bs. The grievance alleged that the
Respondent was improperly using them as the contract had been changed so that 204Bs can
only be employed in those positions for from fourteen to ninety days.
3 The Joint Contract Interpretive Manual which explains possible ambiguities in the contract.
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is going to process his grievances, so he only told her that he needs the information to identify
the vacancies and “who is working over there.”
Stevenson initially received five job descriptions responsive to his request and by letter
from Thornton dated April 1 he received additional information. The letter from Thornton states,
inter alia:
This responds to the request for information for which you filed an unfair labor practice
charge before the National Labor Relations Board. The Board Agent provided a
statement of relevancy not provided by you previously stating that you were investigating
possible violations regarding the Administrative Side EAS performing bargaining unit
work. I’m in the process of pulling job descriptions which are the most responsive to your
request and it will take me at least ten (10) days to process this request.
As you are aware, EAS employees are outside the bargaining unit you represent and
any information needed for your investigation and/or grievance processing about EAS
employees performing bargaining work is not contained in the Form 50s or the Bid
Assignments. The Job Descriptions will identify the duties performed by the EAS
employees on the Administrative Side of the GWY.
Stevenson testified that this letter contained “some job descriptions at the GWY facility and
satisfied Item 1 of his February 7 information request. Prior to this letter, the Respondent had
never told him why it had not provided this information at an earlier time, or why it had taken so
long for them to provide this information to him. By letter dated April 11, Thornton sent
Stevenson some additional information relevant to his “RFI dated February 7, 2013, Final-
Administrative Side EAS and Clerk Information.” Stevenson testified that this provided
information regarding only one bargaining unit employee, and none of the non-bargaining unit
employees, and did not contain job IDs and titles as he requested in Item 1 of his February 7
request. Later in April, he had “a very heated exchange” with Thornton in a telephone
conversation about his information requests. He told her that she had not given him the Form
1723 and 50s that he had requested and she said that they weren’t relevant and she did not
have to provide it. He said that they were entitled to the information for the filing of a grievance.
She responded, “what are you trying to get at? Maybe we can get to it another way.” He told
her, “No, you cannot tell me how to present my grievance or how to prove my grievance. I
provided you relevance…you know what we need the information for…” To date, he has not
received the Form 50s or the Form 1723s for all employees working on the administrative side
of GWY, has not been told that there is no such information or that the Respondent does not
understand the relevance of the information he requested.
On cross examination, he testified that Article 37 of the contract discusses 204Bs, and
when Union members can bid on jobs while detailed as 204Bs, and that his grievance relates to
improperly utilizing 204B supervisors. When asked whether Thornton wrote to him after his
January 11 and February 7 requests, asking him to explain how the requested information was
relevant for the EAS employees, he testified that it was possible that he did receive such
requests. He also testified that the grievance that he attached to the information requests was
settled on about March 15. He further testified that Form 50s include employees’ social security
numbers, home address and other personal information, and in their heated telephone
conversation, Thornton never asked him which information he needed from these documents
while at the same time allowing her to protect the employees’ private information. He also
reiterated that he never received the Form 1723 for the EAS employees and that Thornton
never told him that the Respondent does not maintain these forms for EAS employees detailed
to another position.
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As a mail processing clerk and RFI assistant, Daniels and Felicia Raheen, who is
employed as a secretary to the labor relations manager, receive the RFIs, whether hand
delivered or by fax, make copies of the document, stamp them as received, send a copy to the
Respondent’s RFI official; if the request was hand delivered, they give a signed copy back to the
union representative. Neither she nor Raheen have authority to deny any request for
information; only Thornton has that authority. She identified (as Respondent’s exhibit)
Stevenson’s January 11 RFI which she received and signed for, which was faxed to the office
and has her initials on the bottom. At the top of the document it states that it was received on
1/11 at 6:05 p.m., and that it was 1 of 1, and she testified that there was no attachment to it.4
She was shown the grievance that Stevenson testified he attached to the RFI and testified that
she is certain that it was not attached to the January 11 RFI. Stevenson hand delivered the
February 7 RFI and Raheen received it and initialed it. Shortly after it was received, she
received a call from Thornton asking about information requests, and she told Thornton about
the February 7 request. At Thornton’s requests, she read it to her and Thornton told her to send
a relevancy letter to the Union, which she did.
Thornton, testified that between January and April she was the Detroit RFI Coordinator
for the Respondent. She described her responsibilities at that time as including when to make
relevancy requests and request extensions of time to comply with the RFIs when necessary.
She coordinates the requests and issues the responses to them. She was given the Union’s
January 11 RFI by Daniels on about that date. It was a one page document; the grievance was
not attached to it. The first time that she saw the grievance was when it was settled by the
parties on March 15.5 Daniels identified an RFI filed by Stevenson on August 31, 2012 that she
received with the same grievance attached as Stevenson testified that he attached to the
January 11 and February 7 grievances, except that the 2012 attachment was Step 1A of the
grievance procedure, whereas the latter one was Step 2. Thornton responded to this RFI and
never was notified by the Union that her response was incomplete.
After receiving the Union’s RFI dated January 11, she wrote to the Union requesting an
extension of time for an additional fourteen days to compile the information due to the large
number of documents requested as well as the fact that she had to obtain the information from a
number of sources. As to whether she received a response from the Union for the request for an
extension of time, she testified, “No, not until January 28th, and I still didn’t get a response on my
extension.” In addition, on January 15 Thornton sent Stevenson a Request for Relevance
Explanation stating that his January 11 request seeks information outside the Union’s
bargaining unit and asks for the relevance of this request. It states further that the clerk craft
information requested will be provided. On January 24, Thornton sent Stevenson some of the
information that she collected, about thirty six pages: “There were more sent later. As I gathered
them, I was sending them as I got them.” She had to obtain this information from different post
offices and different departments. Although she sent this information to the Union she did not
provide the Union with any information regarding the EAS employees, who were outside the
unit, because the Union never established the relevancy of this information, and never
responded to her January 15 Request for Relevance.
On January 25 Thornton sent the Union a large packet of information including Form
50s, Form 1723s, job descriptions, position descriptions for certain EAS employees and bid jobs
for certain employees. By letter dated January 29 containing fifteen pages, Thornton sent

4 The Union’s copy of the RFI states that it was faxed 11/6/2013 and was 3/03.
5 The grievance number on the grievance and the settlement match.
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Stevenson a response to his January 28 letter alleging that Items 1 and 2 of his January 11 RFI
had not been provided. Her letter contained a listing of all EAS positions at GWY that were
vacant at the time as well as position descriptions of clerks in the unit. The letter also states:
“Once you have provided relevance for the information requested of non-bargaining members,
you will also need to pay us for the cost to pull this information.” The letter concludes by stating,
“However, the clerk craft information was provided.” She felt that with the January 29 letter to
Stevenson, she had satisfied his information requests for the clerks, and that Stevenson’s note
on the bottom of his February 7 RFI that “the information is relative to the investigation of
bargaining unit positions and of work on the administrative side of GWY” did not tell her
anything about why the requested information for the non-unit employees was relevant. She
was not in the office when the Union’s February 7 RFI was received, but Daniels read it to her,
and she told Daniels to send the Union another relevancy memo. On that day, another letter
was sent to Stevenson, repeating some of what was said in Thornton’s January 28 letter, that
the Union had to provide relevance for the information regarding the non-unit employees, and
that the clerk craft information was already provided. The first response that she received to this
letter was on March 27 when she was shown a copy of the unfair labor practice charge that the
Union filed in this matter. On that day, she received an email from the Board agent investigating
the Union’s unfair labor practice charge stating why the Union needed the non-unit information
that Stevenson had requested. She testified that neither Stevenson, nor anyone from the Union
had previously told her this explanation for relevance: “Had I had this information at that time on
February 7th, the information would have been provided.”
On April 1, Thornton wrote to Stevenson, inter alia:
This responds to the request for information for which you filed an unfair labor practice
charge before the National Labor Relations Board. The Board agent provided a
statement of relevancy not provided by you previously stating that you were investigating
possible violations regarding the Administrative Side EAS performing bargaining unit
work. I’m in the process of pulling job descriptions which are the most responsive to your
request…
Thornton sent Stevenson this information by letters dated April 1 and April 11. She testified that
she had a conversation with Christopher Ulmer, the president of the Union, about limiting the
information contained on the Form 50s for the EAS employees. She told him about the Privacy
Act and that the forms list addresses, social security numbers and other information that the
Union did not need and asked if the employees’ job titles was sufficient for the Union’s purposes
and he agreed. Rather than providing the Union with the redacted Form 50s, Thornton sent the
Union a listing of the EAS employees at GWY with their occupational code and title. Ulmer
testified that he had a conversation with Thornton in about April, and they discussed the
confidentiality of certain items contained in the Form 50s, such as employees’ addresses, and
he told Thornton that it wasn’t a big issue for him and that she could black out or cover up the
confidential items, “but we really wanted Form 50s to see exactly what the people’s official
positions and titles were.”
III. Analysis
It is alleged that the Respondent unreasonably delayed in furnishing the Union with job
descriptions and/or job ID for each administrative position on the administrative side of the GWY
facility from February 7 to April 3, and failed and refused to furnish the Union with the name and
Forms 50, and Form 1723 for each employee working on the administrative side of the GWY
facility, and Job ID and title for each administrative position on the administrative side of the
GWY facility. Section 8(a)(1)(5) of the Act requires an employer to furnish the union
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representing its employees with information that is relevant to the union in the performance of its
collective bargaining responsibilities, either in the administration of the existing contract, or in
formulating proposals for a new contract. Detroit Edison Co. v. NLRB, 440 U.S. 301, 303 (1979).
Information about terms and conditions of employment of employees in the bargaining unit is
presumptively relevant and necessary and must be produced. However, when the union’s
request concerns information about non-unit employees or operations, there is no such
presumption of relevancy to the union’s representation status, and the union has the burden of
establishing the relevance of the requested information. Ohio Power Co. v. NLRB, 216 NLRB
987 (1975), enfd. 531 F.2d 1381 (6th Cir. 1976); Duquesne Light Co., 306 NLRB 1042, 1043
(1992). A union satisfies this burden by demonstrating a reasonable belief supported by
objective evidence for requesting the information, Knappton Maritime Corp. , 292 NLRB 236,
238-239 (1988), and potential or probable relevance is sufficient to give rise to the employer’s
obligation to furnish the information. Shoppers Food Warehouse Corporation, 315 NLRB 257,
258 (1994).
With little difficulty, I credit the testimony of Daniels and Thornton over that of Stevenson.
The Respondent’s witnesses impressed me as well-spoken, credible and knowledgeable about
the subject, and their testimony was supported by other evidence. For example, Respondent
introduced into evidence Thornton’s Requests for Relevance, obviously an important matter as
part of the RFIs requested information about non-unit employees, yet Stevenson never
mentioned it in his testimony. In addition, Stevenson never mentioned Respondent’s request for
additional time to respond to his request, and I discredit Stevenson’s testimony that he attached
the 2012 grievance to the January 11 and February 7 grievances. I have credited Thornton and
Daniels on other issues and credit them on this issue as well, as they were certain that it was
not attached. Further, the marking atop the Respondent’s copy states that the RFI was 1 of 1,
while the marking atop the Union’s copy states that it was faxed in November and was 3 of 3. I
therefore find that Stevenson did not attach the grievance to the RFI.
As regards the RFIs for the unit employees, I find that Respondent furnished the Union
with the information that it requested for the unit employees, and did so in a timely manner. On
January 24 and 25, the Respondent sent the Union information responsive to its request for the
unit employees, and on January 29 it provided additional information responsive to the request
for the unit employees; the documents in these three responses totaled about one hundred
pages. In addition to notifying the Union of the amount that they owe the Respondent for
compiling this information, the letter concluded, “However, the clerk craft information was
provided,” and the Union never refuted this statement. Because there is no evidence that the
Union disagreed with Thornton’s statement on January 29 that all the craft (unit) information
was provided, and because I credit Thornton’s testimony that she furnished the Union with all
the information regarding the unit employees, I find that the Respondent provided the Union with
all the unit information that it requested. I therefore recommend that this allegation be
dismissed.
The law is clear that an employer is obligated to furnish the union with the requested
information in a timely manner, and this obligation “cannot be defined in terms of a per se rule.
What is required is a reasonable good faith effort to respond to the request as promptly as
circumstances allow.” Good Life Beverage Co., 312 NLRB 1060, 1062, fn. 9 (1993). In
evaluating the promptness of the response, “the Board will consider the complexity and extent
of information sought, its availability and the difficulty in retrieving the information.” Samaritan
Medical Center, 319 NLRB 392, 398 (1995). Although the Union made its information requests
on January 11 and February 7, Thornton wrote to the Union requesting a fourteen day extension
in which to respond because of the large number of documents requested as well as the
number of sources that she had to obtain the documents from. She did not receive a response
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to this request until January 28. In addition, on January 15 she sent Stevenson a Request for
Relevance as his January 11 request sought information outside of the bargaining unit. She
never received a response from the Union to this request, and was not informed of the
relevancy of this information until about March 27, when she received a letter from the Board
Agent handling the matter explaining the relevancy of the information requested. About one or
two weeks later she sent the Union a summary of the requested information, rather than the
Form 50s that it had requested, due to what she perceived as privacy issues related to the Form
50s. Based upon Thornton’s January 15 Request for Relevance, which went unanswered, I
credit her testimony that it was not until the end of March that she learned of the relevance of
the non-unit RFI, and as she furnished the Union with this information five and fifteen days later,
I find that this was a timely manner and recommend that this allegation also be dismissed. Silver
Brothers Co., Inc., 312 NLRB 1060, 1062 (1993); Spurlino Materials, LLC, 353 NLRB 1198,
1200 (2009).
Although I have recommended the dismissal of the unfair labor practice charges for the
reasons that the requested information was provided, and was provided in a timely manner,
there is one violation, although a minor one. While the Union requested the Form 50s, Thornton
provided the Union with a summary containing the employees’ names and their job titles,
whereas Ulmer told her that the Union wanted the Form 50s, but that she could cover up the
confidential information: “But we really wanted Form 50s to see exactly what the people’s official
positions and titles were.” Although a union is entitled to be given relevant requested
information, “it does not follow that the union is entitled to such information in the exact form or
on the exact terms requested.” United Aircraft Corp., 192 NLRB 382 (1971). However, in this
situation, the Union is entitled to view the non-confidential information on the Form 50, rather
than simply summarized by the Respondent, to be certain that the information is genuine. By
summarizing the contents of the Form 50, rather than furnishing the Union with the Form 50s
with the confidential information redacted, the Respondent violated Section 8(a)(1)(5) of the Act.
Conclusions of Law
1. The Board has jurisdiction over the Respondent by virtue of Section 1209 of the PRA.
2. At all material times, the American Postal Workers Union, AFL-CIO and the Union
have each been a labor organization within the meaning of Section 2(5) of the Act.
3. The Respondent violated Section 8(a)(1)(5) of the Act by furnishing the Union with a
summary of employee names and job titles, rather than the Form 50s that it had requested with
confidential items being excluded.
4. I recommend that the remaining allegations of the Complaint be dismissed.
The Remedy
Having found that the Respondent violated the Act by furnishing the Union with a
summary of its employees and their job titles, it is recommended that the Respondent be
ordered to provide this information to the Union on the employees’ Form 50s, with confidential
information contained on the form excluded. Due to the de minimas nature of this violation, a
broad order is not warranted.
Upon the foregoing findings of facts, conclusions of law and on the entire record, I
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hereby issue the following recommended6
ORDER
The United States Postal Service, its officers and agents, shall
(1) Cease and desist from
(a) Furnishing the Union with a summary of employee names and job titles, rather than
the Form 50s that it has requested with confidential items being redacted.
(b) In any like or related manner interfering with, restraining or coercing its employees in
the exercise of the rights guaranteed them by Section 7 of the Act.
(2) Take the following affirmative action designed to effectuate the policies of the Act:
(a) Provide the Union with the Form 50s that it requested, in a timely manner, with any
confidential information blacked out.
(b) Within 14 days after service by the Region, post at its facilities in Detroit, Michigan,
copies of the attached notice marked “Appendix.”7 Copies of the notice, on forms provided by
the Regional Director for Region 7, after being signed by the Respondent’s authorized
representative, shall be posted by the Respondent and maintained for 60 consecutive days in
conspicuous places including all places where notices to employees are customarily posted.
Reasonable steps shall be taken by the Respondent to ensure that the notices are not altered,
defaced, or covered by any other material.
(c) Within 21 days after service by the Region, file with the Regional Director a sworn
certification of a responsible official on a form provided by the Region attesting to the steps that
the Respondent has taken to comply.
IT IS FURTHER ORDERED that the complaint is dismissed insofar as it alleges
violations of the Act not specifically found.
Dated, Washington, D.C. January 6, 2014
_________________________________
Joel P. Biblowitz
Administrative Law Judge

6 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 purposes.
7 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 National Labor Relations Board” shall read “Posted
Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the
National Labor Relations Board.”
JD(NY)–02-14

APPENDIX
NOTICE TO EMPLOYEES
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 Federal labor law and has
ordered us to post and obey this Notice.
FEDERAL LAW GIVES YOU THE RIGHT TO
Form, join, or assist a union
Choose representatives to bargain with us on your behalf
Act together with other employees for your benefit and protection
Choose not to engage in any of these protected activities
WE WILL NOT refuse to furnish Local 295, Detroit District Area Local, American Postal Workers
Union (APWU), AFL-CIO (“the Union”) the information that it requested in the form that it
requested.
WE WILL NOT in any like or related manner interfere with, restrain or coerce you in the
exercise of the rights guaranteed you by Section 7 of the Act.
WE WILL provide the Union with the Form 50s for certain of our employees, as it requested, but
excluding all confidential information about the employees.
UNITED STATES POSTAL SERVICE
(Employer)
Dated_____________ By__________________________________________________
(Representative) (Title)
The National Labor Relations Board is an independent Federal agency created in 1935 to enforce the National Labor
Relations Act. It conducts secret-ballot elections to determine whether employees want union representation and it
investigates and remedies unfair labor practices by employers and unions. To find out more about your rights under
the Act and how to file a charge or election petition, you may speak confidentially to any agent with the Board’s
Regional Office set forth below. You may also obtain information from the Board’s website: www.nlrb.gov.
477 Michigan Avenue, Federal Building, Room 300
Detroit, Michigan 48226-2569
Hours: 8:15 a.m. to 4:45 p.m.
313-226-3200.
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 ABOVE REGIONAL OFFICE’S
COMPLIANCE OFFICER, 313-226-3244.