Westinghouse Electric Corp.

National Labor Relations Board - Board Decisions

Jan 28, 1970

180 N.L.R.B. 981 (N.L.R.B. 1970)

WESTINGHOUSE ELECTRIC CORP.
Westinghouse Electric Corporation and International
Union of Elevator Constructors , Local No. 71,
AFL-CIO. Case 12-CA-4484
January 28, 1970
DECISION AND ORDER
BY MEMBERS FANNING, BROWN, AND JENKINS
On September 10, 1969, Trial Examiner Thomas
A. Ricci issued his Decision in the above-entitled
proceeding, finding that the Respondent had
engaged in and was engaging in certain unfair labor
practices 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
Decision and a supporting brief.
Pursuant to the provisions of Section 3(b) of the
National Labor Relations 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
Examiner 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 brief, and
the entire record in the case, and hereby adopts the
findings, conclusions, and recommendations of the
Trial Examiner.
ORDER
Pursuant to Section 10(c) of the National Labor
Relations 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, Westinghouse
Electric Corporation, Miami, Florida, its officers,
agents, successors, and assigns, shall take the action
set forth in the Trial Examiner's Recommended
Order.
TRIAL EXAMINER'S DECISION
STATEMENT OF THE CASE
THOMAS A. Ricci, Trial Examiner A hearing in the
above-entitled proceeding was held before the duiy
designated Trial Examiner on July 31, 1969, at Miami,
Florida, on complaint of the General Counsel against
Westinghouse Electric Corporation, herein called the
Respondent or the Company. The sole issue of the case is
whether the Respondent discharged an employee in
violation of Section 8(a)(1) and (3) of the Act. A brief was
filed after the close of the hearing by the Respondent.
Upon the entire record and from my observation of the
witnesses, I make the following
FINDINGS OF FACT
1. THE BUSINESS OF THE COMPANY
981
The Company has its principal place of business in
Pittsburgh, Pennsylvania, and operates through many
states, including Florida, its business is manufacture and
distribution of electrical and other products Annually it
receives goods and materials in its Florida operations
valued in excess of $50,000 directly from out-of-state
sources. I find that the Respondent is engaged in
commerce within the meaning of the Act and that it will
effectuate the policies of the Act to exercise jurisdiction
herein
II THE LABOR ORGANIZATION INVOLVED
International Union of Elevator Constructors, Local
No 71, AFL-CIO, is a labor organization within the
meaning of Section 2(5) of the Act
III. THE UNFAIR LABOR PRACTICE
John Devitt works on installation of elevators, a
category of employees called elevator constructors, and
has long been a member of the International Union of
Elevator Constructors. Many years a member of its Local
No. 1 in New York, he went to Florida, and in the winter
of 1968-69 was employed by Westinghouse, with a work
permit out of Elevator Constructors Local No. 71, of
Miami He was assigned to a new 16-story building - the
Regency Towers, in Ft Lauderdale, where the Company
was installing three elevators In addition to Devitt, and
other elevator constructor employees, there were two iron
workers, these were members of International Association
of Bridge, Structural, and Ornamental Iron Workers. One
of the iron workers was William Carter, long a member
of Iron Workers Local 272, of Miami, another was
Harold Mahoney, his helper. Like Devitt, Mahoney had
long been a craftsman in New York, member of Iron
Workers Local 580 there, and had recently come to
Florida, where he enjoyed a traveling card out of Iron
Workers Local 272.
On February 20, 1969, the Respondent discharged
Mahoney, and the next day released Devitt. The
complaint is silent as to Mahoney, it alleges that the
release of Devitt constituted a violation of Section 8(a)(3)
of the Act Samuel Eldon, superintendent of construction
for the Company, who personally made the decision to
dismiss Devitt, said at the hearing the reason was because
Devitt "conspired" with Mahoney, was attempting to have
the Ft. Lauderdale job run "like the New York area," and
because Devitt was the "source of trouble " To Devitt, at
the moment of discharge, he said the dismissal was
because his "attitude and work was completely wrong."
In the usual language the complaint says Devitt was
discharged because he "assisted the Union and engaged in
union or protected concerted activities " It then details the
concerted activities to have been that Devitt informed
Foreman Jerry Perkins "the Respondent's hoisting
operations were in violation of its collective-bargaining
agreement with the Union." A more exact statement of
what the Respondent is said to have resented is that
Devitt and Mahoney favored a too literal enforcement of
conditions of employment set out in the union contracts,
both that of the Elevator Constructors and of the Iron
Workers, and that it was Devitt's conduct in turning to his
union for help towards this end that really caused his
180 NLRB No. 147
982 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
discharge . This is not a case where the antiunion, and
therefore illegal, animus is to be seen in any desire to
eliminate unions from the picture , to discourage union
membership as such, or to avoid the statutory duty to deal
with a labor organization . If ever there was a totally
unionized job this was it. The real purport of the charge,
and what the evidence strongly indicates , is that the
Company wanted to curb too technical and exact
enforcement of the contract terms . As the Respondent
puts it, what it wanted to stop , and what it had a right to
stop , was insistence upon working conditions which would
have been either illegal or contrary to the agreed-upon
terms in Florida , whatever they may have been in New
York.
The Case in Support of the Complaint ; Contract, or
Noncontract Conditions of Employment
Three separate aspects of working conditions came to
light during the hearing , either because the General
Counsel thought them important or because the Company
pointed to them as significant : ( 1) how is material to be
raised to the roof of a construction project?; (2) is there a
limitation upon the number of elevator doors that are to
be installed during a given workday?; and (3) is protective
scaffolding to be installed in elevator shafts while work is
in progress?
On January 20, 1969 , there were heavy materials to be
lifted to the roof of the Regency Towers. Devitt, with a
helper , was stationed on the sidewalk to attach the
materials to the cable of the crane used for hoisting;
Foreman Perkins, the supervisor as stipulated , was on the
roof giving instructions by two-way radio. Three
generators , three machines and three control boards went
up. Perkins then ordered Devitt to send up six metal
machine beams and three deflector sheaves. Devitt said
that according to the contract no more were to be raised
by crane, but Perkins repeated the order. The beams and
the sheaves were hoisted by crane and came to rest on the
roof. The raising of these beams and sheaves required 5
minutes.
The next day Devitt reported the incident to Eugene
Stevens, business representative of Elevator Constructors
Local 71, and on January 23 Stevens filed an intraunion
charge against Perkins, who is also a member of that
Local for using the derrick "on the outside of the
building" to lift the beams and sheaves to the roof. The
charge shows Devitt as the witness to the offense. A copy
of the charge was mailed to Perkins on January 26, and
was brought to the attention of Superintendent Eldon, as
well as all other persons on the job, shortly thereafter. It
was conceded at the hearing by the Respondent that this
raising of the beams and the sheaves by crane was a
violation of the express provisions of the Elevator
Constructors contract then in effect in the Miami area.
One day, up on the roof, Stevens told Perkins the
beams and the sheaves were improperly up there because
they had been lifted by crane; in consequence of this
position taken by the Union, they were brought down
again . There is some confusion in the record as to
precisely when this was done , but it is clear they were
downstairs again by Thursday, February 20. Devitt
testified , and no one contradicted him, that he was told to
do this 2 days before his discharge . He was released on
Friday morning , February 21. Hal Schlicker, an elevator
constructor who worked together with Devitt, testified
that sometime earlier , during February , Perkins spoke to
him about the charge filed against him in Local 71, and
said Devitt "was doing it." Schlicker also testified that
during the morning of Thursday, February 20, he was
occupied "hoisting the material [beams and sheaves] back
up again ." There remains unexplained the statement at
the hearing of Carter, the foreman iron worker, that he
understood from Superintendent Eldon on the morning of
the 21st that Devitt was to be released "because this
material we was speaking of in this room had to come
back down through the shaft and it could not come back
down here with it decked over." He was not the most
articulate witness, and I find that by Thursday, the 20th,
the materials in question had been brought down through
the elevator shafts and moved back to the sidewalk.
Eventually it went up again , but through the shafts, as,
apparently , the contract required . It was also stipulated
that the time required for bringing down the beams and
sheaves and placing them outside the building " took about
a day ' s work."
A day or two before Thursday, Mahoney, the iron
worker helper , told his foreman , Carter, that the shafts
would have to be scaffolded at various levels for
protection of the workmen . Again the testimony is
confused as to exactly at which levels he wanted the
scaffolding placed. At one point Carter quoted Mahoney
as saying the scaffolding had to be placed "three floors
above us and two floors below us," "to keep anything
from falling down on us." Later, in response to a leading
question by company counsel , he agreed Mahoney was
"demanding every other floor ." According to Mahoney,
when Carter told him he would have to work in the shaft,
he said "we have to have protection above and below us."
What the pertinent contract provided on this point is not
shown in this record by the contract itself, and Carter,
who has long worked in Florida , referred to it twice, once
that it "provides that every other floor in an elevator shaft
shall be scaffolded ," and once that it requires scaffolding
"two floors above and one floor below."
Mahoney also told Carter , either on February 18 or 19,
but surely before the morning of Thursday, February 20,
that the employees should install no more than two doors
per working day. The then applicable Iron Worker
contract said nothing about this matter, and Carter's
answer to Mahoney was that 8 hours' pay called for 8
hours' work , regardless of the number of doors installed.
Discharge of Devitt; Affirmative Defense and
Conclusion
Early on the morning of February 20 Foreman Carter
telephoned Superintendent Eldon to tell him of Mahoney's
announcement that there must be protective scaffolding to
safeguard iron workers in the shafts. There is a conflict in
testimony between Carter and Eldon as to what was said
between them . According to Carter , he told Eldon that
"Mr. Mahoney had told us that we had to deck the shaft
oval [sic-over] . three floors above us and two floors
below us," that there was no material available to do this,
that Mahoney had spoken of limiting the day's work to
two doors , and that Mahoney had also said "We are
going to run this thing like we run it in New York."
Eldon ' s answer to all this , still according to Carter, was
"We have got no material out there . The thing to do is let
Mr. Mahoney and Mr . Devitt go," "that we couldn't do
piece work , that there wasn ' t anything in the Contract
saying we could do two and get paid for a day." Carter
repeated more than once he had no recollection of himself
speaking Devitt's name when talking to Eldon on the
telephone.
WESTINGHOUSE ELECTRIC CORP. 983
Eldon's version of this conversation is that Carter ".. .
says, `Well, they have finally done it to us,' and I said,
`They done what?' and he said, `Well, you know this boy
Devitt and this Mahoney, my helper, they had been
advocating for some time that they were going to run this
job like they do in New York,' and I said, `Just what do
you mean?' This is when he told me that he would have to
scaffold every other floor and that we could set no more
than two entrances a day. . . . I told him that we could
not live with this. I says, 'Look, we pay you people for
working eight hours a day. It doesn't make a damn to me
if you set one or if you set ten fronts.' . . . I says, 'The
only thing I know to do is to remove the source of
trouble.' . So I said, 'The only thing I know to do
now, we will get rid of Mahoney.' " Eldon flatly denied
having said anything about releasing Devitt then. He
added that it was not until 2 or 3 p.m. that afternoon,
when Foreman Perkins called him to complain of Devitt,
that he decided to discharge the second man and
instructed Perkins to dismiss Devitt.
Between Carter and Eldon I credit the former as to
their telephone conversation early that morning. In his
story Carter continued that he did as Eldon ordered, and
went directly from the telephone to Perkins with the
instruction to discharge Mahoney and Devitt. He said
Perkins put the necessary money together to pay off
Mahoney then and there and sent a helper to tell Devitt
up on the roof to bring his tools downstairs, but that when
another employee warned Perkins he might have trouble
with the union, the foreman called the messenger back.
The incident is corroborated by Stevens, the business
representative of the Elevator Constructors, who testified
Perkins called him that morning to say he was going to
release Devitt, but that he, Stevens, then warned only
Eldon could fire Devitt, and not Perkins. And David
Taylor, the helper who was then present, called as a
witness for the Respondent, also testified that Perkins that
morning did send him to the roof to bring Devitt
downstairs. Perkins, the pivotal point for Eldon's version
of events, was not offered as a witness
The next morning, February 21, Eldon appeared at the
jobsite and discharged Devitt. When the employee asked
why he was being dismissed, as he himself recalled, Eldon
said "Because you are in a conspiracy with that iron
worker." Devitt denied the charge, and Eldon then said:
"Let's just say I don't like your New York attitude."
According to Eldon all he told Devitt was "Your attitude
is wrong and your work is unsatisfactory."
I think the evidence in its totality fully warrants the
inference Devitt was discharged because he wanted his
union's contract enforced, because he was the moving
factor which necessitated bringing the metal beams and
the sheaves down from the roof and up again via the
shaft, and because he acted through Local 71 to achieve
his objective. This was pure concerted activity, literally
action through a union, aimed at unqualified application
of contract terms, and therefore protected by the statute. I
find that by discharging Devitt on February 21, 1969, the
Respondent violated Section 8(a)(I) of the Act.'
Much of Superintendent Eldon's explanation of his
asserted reason for discharge was couched in elusive and
general terms. He spoke of Devitt having been a "source
'Eastern Illinois Gas and Securities Company, 175 NLRB No 108
There is no evidence in the record of union animus motivating the
discharge , and I therefore do not find that Respondent 's conduct also
constituted a violation of Section 8(a)(3) of the Act, as alleged in the
complaint
of trouble," wanting to bring "New York area
conditions" to the Florida job. The only complaint by
Devitt shown by true probative evidence on this record,
was his statement to Foreman Perkins, reiterated in his
report to Business Representative Stevens, and
implemented by his being the witness to the charge filed
against the foreman, that the beams and the sheaves ought
not have been hoisted to the roof by derrick. The
Respondent's first stipulation at the hearing was that
Devitt was correct in his complaint, that Perkins that day
violated the union contract Eldon may have chosen to
call this "trouble," and disconcerting imposition of "New
York conditions" at the Regency Towers construction
project, but his phrases could not alter the significant
facts. He said he was shocked to see the beams and
sheaves downstairs again late in February. He may well
have been, but the question here is not whether or not
there was economic, nor indeed equitable justification, for
the contractural clause which prohibited the hoisting of
such building materials by crane. So far as Devitt was
concerned, New York area conditions meant the union
agreement had to be lived up to, and nothing more.
The offensive behavior which the Respondent by
implication throughout the record sought to impute to
Devitt and thereby put him in an unfavorable light now,
was the desire to limit production work to only part of the
8-hour day, i.e., two elevator doors and no more. The
business of the protective scaffolding at various floors
served little for criticism even of Mahoney, who alone was
shown to have demanded' it. The proof would not support
a definitive finding that he asked for more than his own
union contract required, for Carter's testimony on that
point virtually conceded the scaffolding was necessary.
Here, as well as with respect to the hoisting of specified
materials, Eldon was equating the phrase "New York area
conditions" and its offensive connotation, with living up to
a union contract. It may well be that the Iron Workers
Union did not protest Mahoney's discharge for the very
reason that he demanded privileges beyond the contract
terms. But there is no evidence Devitt joined in such
improper demands. When Carter called to tell Eldon of
his problem on Thursday morning he did not talk about
Devitt at all, and yet it was at that very moment that the
superintendent ordered his immediate dismissal . With this
the credible testimony, I cannot rely upon Eldon's further
testimony that later that afternoon Perkins told him
Devitt was unhappy because Mahoney had been relieved,
and that this was the reason for the discharge the next
day. From Eldon this was pure hearsay on what is offered
as a critical part of the affirmative defense. Perkins, who
is supposed to have heard this from Devitt, did not testify.
It is probably true that at a much earlier date Devitt did
say that in New York a job like this would be 2 years in
the making . And he might even have been correct in the
appraisal. Against the direct annoyance caused Eldon by
bringing the local union to bear in enforcing the existing
contract, the isolated statement has little meaning in this
case.
I also find unconvincing Eldon's assertion at the
hearing that a further reason for dismissing Devitt that
day was for work incompetence. According to the
employee the superintendent said nothing to him about
unsatisfactory work at the moment of discharge, but
spoke only of " conspiring" with the "iron worker," and
his "New York attitude." And Eldon, while testifying,
first said he told the man "his attitude and his work was
completely wrong," and then corrected himself by saying
984 DECISIONS OF NATIONAL LABOR RELATIONS BOARD
he said "your attitude is wrong and your work is
unsatisfactory." Devitt testified there had never been any
complaints about his work, he had never been
reprimanded, and Perkins once told him he was doing a
"nice job." He also denied ever having been ordered to
return to his work station. Eldon, in support of the
asserted unsatisfactory work basis of discharge, said that
one day on February 13, Perkins reported to him that
Devitt had been away from his work station; he went on
to add he checked with Foreman Carter, who confirmed
Perkins; "He [Carter] complained about it, but there was
nothing ever really said about it." And again Perkins did
not appear to give body to the hearsay testimony, and
Carter, who did testify, was asked nothing about this
matter. Moreover, while denying he had ever
complimented Devitt, Eldon did concede he had referred
to him as "average," or "a reasonably fair mechanic." I
do not believe the quality of Devitt's work performance
had anything to do with his discharge.
In its posthearing brief the Respondent for the first
time advances still another defense, an argument predicted
upon a factual assertion not mentioned at the time of the
events and not suggested at all at the hearing. It contends
that Devitt' s union activity shown on this record was not
protected by the Statute and that therefore the Company
could discharge him with impunity. The Board's decision
in San Francisco-Oakland Mailer's Union, 172 NLRB
No. 252, upon which the Respondent relies for this
defense, is inapposite. The Respondent there was the
union , and the conduct which the Board found to be an
unfair labor practice was the union's internal act of
imposing fines upon members who were also supervisors
as defined in the Act. It is argued here that because the
conduct of Devitt' s union , Elevator Constructors Local
No. 71, might have been subject to Board prosecution
under the San Francisco-Oakland case, it follows that the
employee's appeal to his union was also unlawful and
made him fair game at the hands of the employer. But
Devitt is not the union; he is only a rank-and-file member,
and all he did, indeed all he had power to do, was inform
on Foreman Perkins. For all he knew, and all he was in a
position to control, the Union might have proceeded to
enforce the contract by the grievance procedure, or even
by strike. To hold, as the Respondent now argues, that he
committed an unfair labor practice and could be
discharged for it, would require an unwarranted extension
of the rule of San Francisco-Oakland. In fact, such a
theory would expose each and every workman who reports
employer contract violations to summary discharge. In
any event, the question of this case is one of motivation.
Why did Eldon discharge the man? He could hardly have
had this belated thought in mind, for he never mentioned
any such thing when he fired Devitt, said nothing about it
when the case was investigated , and gave no hint of such a
reason throughout his testimony . Indeed he insisted the
Union charge against Perkins had nothing to do with his
decision.
THE REMEDY
Having found that the Respondent violated Section
8(axl) by discharging John Devitt, I shall order the
Respondent to cease and desist from such conduct and to
offer Devitt immediate and full reinstatement to his
former or substantially equivalent position, without
prejudice to his seniority or other rights and privileges,
and to make him whole for any loss of pay he may have
suffered by reason of Respondent 's discrimination against
him, by payment to him of a sum of money equal to that
which he would normally have earned as wages from the
date of his discharge to the date of the Respondent's offer
of reinstatement, less his net earnings during the set
period, in a manner consistent with Board policy set out
in F W. Woolworth Company, 90 NLRB 289. Interest on
backpay shall be computed in the manner set forth in Isis
Plumbing & Heating Co., 138 NLRB 716.
Upon the foregoing findings of fact, and upon the
entire record in the case, I make the following:
CONCLUSIONS OF LAW
1. The Respondent is engaged in commerce within the
meaning of Section 2(6) and (7) of the Act.
2. International Union of Elevator Constructors, Local
No. 71, AFL-CIO, is a labor organization within the
meaning of Section 2(5) of the Act.
3. By discharging John Devitt for engaging in
protected, concerted activity, Respondent has interfered
with, restrained, and coerced its employees in the exercise
of the rights guaranteed in Section 7 of the Act, and has
thereby engaged in unfair labor practices proscribed by
Section 8(a)(1).
4. The aforesaid unfair labor practices effect commerce
within the meaning of Section 2(6) and (7) of the Act.
RECOMMENDED ORDER
Upon the basis of the above findings of fact and
conclusions of law, and upon the entire record in the case,
I hereby recommend that Respondent, Westinghouse
Electric Corporation, Ft. Lauderdale, Florida, it officers,
agents , successors , and assigns , shall:
1. Cease and desist from:
(a) Interfering with, restraining, or coercing employees
in the exercise of their right to engage in concerted
activities for mutual aid and protection by discriminating
in regard to their hire, tenure of employment, or any term
or condition of employment.
(b) In any like or related manner interfering with,
restraining, or coercing employees in the exercise of their
right to engage in , or to refrain from engaging in, any or
all the activities specified in Section 7 of the Act.
2. Take the following affirmative action which I find
will effectuate the policies of the Act:
(a) Offer John Devitt immediate and full reinstatement
to his former or substantially equivalent position, without
prejudice to his seniority and other rights and privileges
and make him whole for any loss of earnings he may have
suffered by reason of Respondent's discrimination against
him, as set forth in the section of this report entitled "The
Remedy."
(b) Preserve and, upon request, make available to the
Board or its agents, for examination and copying, all
payroll records, social security payment records,
timecards, personnel records and reports, and all other
records necessary to analyze the amount of backpay due
and all other rights under the terms of this Order.
(c) Notify the above-named employee if presently
serving in the Armed Forces of the United States of his
right to full reinstatement upon application in accordance
with the Selective Service Act and the Universal Military
Training and Service Act, as amended, after discharge
from the Armed Forces.
(d) Post at each and every location where the
Respondent is currently installing elevators within the
territorial jurisdiction of Local 71 copies of the attached
WESTINGHOUSE ELECTRIC CORP.
notice marked "Appendix."' Copies of said notice, on
forms provided by the Regional Director for Region 12,
shall, after being duly signed by the Respondent's
authorized representative, be posted by Respondent
immediately upon receipt thereof, and be maintained by it
for 60 consecutive days thereafter, in conspicuous places,
including all places where notices to its 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.
(e) Notify the Regional Director for Region 12, in
writing, within 10 days from the date of this Decision,
what steps it has taken to comply herewith.'
'In the event that this Recommended Order is adopted by the Board, the
words "a Decision and Order" shall be substituted for the words "the
Recommended Order of a Trial Examiner" in the notice . In the further
event that the Board 's Order is enforced by a decree of a United States
Court of Appeals, the words "a Decree of the United States Court of
Appeals Enforcing an Order" shall be substituted for the words "a
Decision and Order "
'In the event that this Recommended Order is 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 the
Respondent has taken to comply herewith."
APPENDIX
NOTICE TO ALL EMPLOYEES
Pursuant to the Recommended Order of a Trial
Examiner of the National Labor Relations Board and in
order to effectuate the policies of the National Labor
Relations Act, as amended, we hereby notify our
employees that:
WE WILL NOT interfere with, restrain, or coerce
employees in the exercise of their right to engage in
985
concerted activities for their mutual aid and protection
by discriminating in regard to their hire, tenure of
employment, or any term or condition of employment.
WE WILL NOT in any like or related manner interfere
with, restrain, or coerce employees in the exercise of
their right to engage in, or refrain from engaging in any
or all the activities specified in Section 7 of the Act.
WE WILL offer John Devitt immediate and full
reinstatement to his former or substantially equivalent
position, without prejudice to his seniority and other
rights and privileges, and make him whole for any loss
of pay he may have suffered by reason of our
discrimination against him.
WE WILL notify the above-named employee if
presently serving in the Armed Forces of the United
States of his right to full reinstatement upon
application in accordance with the Selective Service Act
and the Universal Military Training and Service Act, as
amended, after discharge from the Armed Forces.
WESTINGHOUSE ELECTRIC
CORPORATION
(Employer)
By
(Representative ) (Title)
Dated
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.
If employees have any question concerning this notice
or compliance with its provisions, they may communicate
directly with the Board ' s Regional Office, Room 706,
Federal Office Building , 500 Zack Street, Tampa, Florida
33602, Telephone 813-228-7257.