[ v24 p773 ]
24:0773(76)CA
The decision of the Authority follows:
24 FLRA No. 76
U.S. CUSTOMS SERVICE
WASHINGTON, D.C.
Respondent
and
NATIONAL TREASURY EMPLOYEES UNION
Charging Party
Case No. 9-CA-50404
DECISION AND ORDER REMANDING CASE
The Administrative Law Judge issued the attached Decision in the
above-entitled proceeding, finding that the Respondent had engaged in
the unfair labor practices alleged in the complaint and recommending
that it be ordered to cease and desist therefrom and take certain
affirmative action. Thereafter, the Respondent filed exceptions to the
Judge's Decision and the Charging Party filed a response to the
Respondent's exceptions. /*/
We adopt the Judge's conclusion that the temporary details of
employees Beebe and Thomas were based upon their participation in
protected activities and that the reasons given by the Respondent for
the details were pretextual. Therefore, we adopt his conclusion that
the Respondent's conduct constituted a violation of section 7116(a)(1)
and (2) of the Federal Service Labor-Management Relations Statute (the
Statute), as alleged in the complaint.
The Judge, in addition to a cease and desist order, recommended that
the Respondent be ordered to make whole employees Beebe and Thomas for
any loss of overtime pay they would have earned but for their temporary
details. As the Authority has previously held, in order for backpay to
be authorized under the Back Pay Act, 5 U.S.C. Section 5596, there must
be a determination not only that an employee has been adversely affected
by an unjustified or unwarranted personnel action, but also that but for
the improper action the employee would not have suffered a loss or
reduction in pay, allowances, or differentials. Federal Aviation
Administration, Northwest Mountain Region, Seattle, Washington and
Federal Aviation Administration, Washington, D.C., 14 FLRA 644 (1984).
In this case, the Judge made his recommendation without applying the
test. It is not clear from the record before us whether the Judge's
recommendation meets the required standard.
Accordingly, we remand this case to the Judge for the limited purpose
of applying the standard to the facts of this case to determine, based
on the existing record, whether backpay is warranted.
ORDER
The complaint in Case No. 9-CA-50404 is remanded for action
consistent with the above.
Issued, Washington, D.C., December 23, 1986.
/s/ Jerry L. Calhoun, Chairman
/s/ Henry B. Frazier III, Member
/s/ Jean McKee, Member
FEDERAL LABOR RELATIONS AUTHORITY
-------------------- ALJ$ DECISION FOLLOWS --------------------
Case No. 9-CA-50404
U.S. CUSTOMS SERVICE, WASHINGTON, D.C.
Respondent
and
NATIONAL TREASURY EMPLOYEES UNION
Charging Party
R. Timothy Shiels, Esquire
For the General Counsel
Patricia Olson, Esquire
For the Respondent
William Corman, Esquire
For the Charging Party
Before: BURTON S. STERNBURG
Administrative Law Judge
DECISION
Statement of the Case
This is a proceeding under the Federal Service Labor-Management
Relations Statute, Chapter 71 of Title 5 of the U.S. Code, 5 U.S.C.
Section 7101 et seq. and the Rules and Regulations issued thereunder.
Pursuant to an amended charge first filed on August 22, 1985, by the
National Treasury Employees Union (hereinafter called the NTEU or
Union), a Complaint and Notice of Hearing was issued on October 18,
1985, by the Regional Director for Region IX, Federal Labor Relations
Authority, San Francisco, California. The Complaint alleges that the
U.S. Customs Service, Washington, D.C. (hereinafter called the
Respondent or Customs), violated Sections 7116(a)(1) and (2) of the
Federal Service Labor-Management Relations Statute (hereinafter called
the Statute), by temporarily transferring unit employees Loran Beebe and
Donald Thomas to different work locations because they had filed
grievances against Respondent under the negotiated grievance procedure.
A hearing was held in the captioned matter on November 18, 1985, in
Seattle, Washington. All parties were afforded the opportunity to be
heard, to examine and cross-examine witnesses, and to introduce evidence
bearing on the issues involved herein. The General Counsel and the
Respondent submitted post-hearing briefs on December 18, 1985, which
have been duly considered. /1/
Upon the basis of the entire record, including my observation of the
witnesses and their demeanor, I make the following findings of fact,
conclusions, and recommendations.
Findings of Fact
The NTEU has been the exclusive representative in a nationwide
consolidated unit of the Respondent's employees. The unit includes,
among other employees, the custom inspectors working in the various
ports within Respondent's Seattle, Washington District.
At all times material herein the NTEU and the Respondent have been
parties to a collective bargaining agreement which contains a negotiated
grievance procedure applicable to unit employees.
Mr. Loren Beebe, one of the alleged discriminatees, has worked in the
Seattle District's Anacortes port as an inspector since 1971. He has
served as president of the Seattle Chapter of NTEU. His most recent
participation in protected activities was in connection with grievances
challenging the Respondent's failure to award him overtime work during
the fiscal year 1984. In February 1985, the NTEU elevated one of his
grievances to arbitration. /2/ The grievance challenged Respondent's
staffing practice at the Anacortes port which resulted in Mr. Beebe
being deprived of overtime work opportunities. In addition to the
grievance which was elevated to arbitration, Mr. Beebe filed 21
additional grievances between June 25 and July 31, 1985, contending that
he has lost overtime work opportunities because of the use of
intermittent inspectors. These latter grievances are currently at the
second step of the grievance procedure, awaiting a decision by District
Director Robert Hardy.
Mr. Donald Thomas, the other alleged discriminiatee, has worked in
the District's Seattle port for the past 12 years. He has formerly been
the Chief Steward for the Seattle Chapter of the NTEU. Like Mr. Beebe,
he felt that his overtime earning for the 1984 fiscal year had been
improperly limited by Respondent and, like Mr. Beebe, he filed a
grievance concerning such limitation. In April 1985 the NTEU invoked
arbitration on Mr. Thomas' grievance. Subsequently, in October 1985,
the parties entered into a settlement of the grievance, wherein the
Respondent agreed to pay Mr. Thomas the sum of $820.96. Mr. Robert
Hardy, the District Director, served as the hearing official at the
second step of the grievance procedure on Mr. Thomas' grievance.
In connection with the filing of grievances by other employees within
the unit, the only evidence bearing thereon appears in the testimony of
Mr. Robert Hardy and Senior Customs Inspector Gerald Bergquist. Thus,
Mr. Hardy testified that "lots of other inspectors" have filed
grievances, "fifty percent" of which "concerned the denial of overtime."
Mr. Bergquist, who was currently at the Harbour Island Port testified
that he filed a grievance in August of 1985 concerning the "denial of
overtime assignment." The grievance at the time of the hearing herein
was at the 3rd step of the grievance procedure.
Other than the grievances of Mr. Beebe and Mr. Thomas, there is no
record evidence indicating that any other grievances had been elevated
to the final step of the grievance procedure, i.e. arbitration.
The record further reveals that overtime earnings represent a
considerable portion of a custom inspector's income. Each year an
inspector is entitled to earn up to $25,000 in overtime, a figure that
is calculated on the fiscal year ending on September 30. Both Mr. Beebe
and Mr. Thomas are high overtime earners. Thus, as of early September,
1985, Mr. Beebe had earned approximately $19,000 to $20,000 in overtime
while Mr. Thomas had earned approximately $23,500 in overtime wages.
In order to insure that no inspector exceeds the $25,000 statutory
overtime "cap" the Seattle District keeps daily records of each
inspector's overtime earnings, using a daily "cap" of $68 to gauge the
pace of each inspector's overtime earnings, since $68 x 365 equals
$24,820, approximately the yearly salary overtime "cap." As a
consequence, an inspector's opportunity to earn overtime increases as
the year progresses. Thus, the first day of the fiscal year an
inspector is not allowed to earn more than $68 in overtime. The second
day, assuming that he has not worked overtime, his daily cap would have
doubled to $136. The record further indicates that overtime
opportunities in the Seattle District increase as the fiscal year
progresses because the District's busiest season begins in June, with
August and September the last two months of the fiscal year, being the
busiest months.
The Seattle District overtime assignments are made on a daily basis.
Each day an inspector informs his supervisor as to whether he wants to
work overtime that day, making himself either "available" or "not
available." The assignments are then distributed inversely to the
inspectors' cumulative overtime overtime earnings, that is, the top
earner is at the bottom of the list.
Every two weeks the Respondent issues a "1911 Overtime Report" for
each inspector, showing the inspector's overtime assignments and his
overtime earnings for that two week period. The report also shows the
port where the inspector worked during that two weeks and the
inspector's hourly overtime rate, a rate that remains the same
regardless of the port where the inspector maybe working.
During July and August, 1985, while NTEU was pushing Mr. Beebe and
Mr. Thomas' arbitrations and while Mr. Beebe was filing his new overtime
grievances, Mr. Robert Hardy instituted an "inter-port awareness
program," which eventually sent Mr. Beebe and Mr. Thomas on temporary
assignments. The program, announced in an August 2, 1985 memo, called
for the detailing of inspectors to different ports to enhance their
experience and to promote uniformity within Respondent's Seattle
District. Mr. Beebe was temporarily traded for Charles Bowen of the
Seattle port, while Mr. Thomas was traded for Bruce Hasselbrock of the
Blaine port. The assignments began on September 3, 1985 and lasted
three weeks. /3/ These four employees were selected from a pool of more
than 80 inspectors working in the Seattle District. According to Mr.
Hardy, when he was informed that there would be surplus funds available
he decided to institute the transfer training program. The record
reveals that this was first such program in to Seattle District. In the
past, it appears that there had only been temporary transfers within the
Seattle District to cover employee absentees.
Neither Mr. Beebe nor Mr. Thomas had any desire to go on their
respective assignments. Mr. Beebe's was an unhappy experience that
forced him to spend two weeks 90 miles away from home, separated from
his wife, and living in a Seattle motel. Mr. Thomas has an eight year
old son who spends two or three nights each week with him. During the
three weeks he spent in Blaine, 125 miles from his home in Seattle, he
was separated from his son and his community. When Mr. Thomas found out
he was being sent to Blaine, he even tried to get an alternative
assignment in Los Angeles where, at least, he would be near relatives.
Their assignments were given to them without any prior warning or
discussion.
On the other hand, even before Mr. Hardy issued his August 2, 1985
memo, management knew that both Mr. Bowen and Mr. Hassebrock would
welcome the temporary transfer. Mr. Bowen had already attempted to fill
a job vacancy in Anacortes and his supervisor, Mr. Tom Coleman, admitted
that he wanted to go to Anacortes. While Bowen did not volunteer, in
the strictest sense of the word, the record indicates that he would have
if he had been given a chance. Mr. Hassebrock's supervisor also knew
that he was interested in being sent to Seattle. In July, 1985, before
he left on his three week vacation, Mr. Hassebrock told his supervisor,
Mr. Eberhardt, that he was "definitely interested" in a temporary
assignment to Seattle.
This difference in treatment continued once these employees arrived
at their temporary assignments. In Seattle, Mr. Beebe found himself
restricted by supervisors Mr. Jack Lopez and Mr. Terry Millhouse as to
the amount of "cargo discharge" work and "entering or clearing of
vessels" work he was allowed to do on overtime, even though he had
fourteen years of experience in that type of work and had been allowed
by Mr. Lopez and Mr. Millhouse to do that work during regular hours.
Mr. Hassebrock did not face similar limits on the type of overtime work
he was allowed to do, testifying that "I could work any overtime that
was available that I could do." Although Mr. Hassebrock testified that
he, too, did not do any "vessel and cargo discharges" it was only
because he did not have sufficient expertise for such assignments.
Moreover, even though both Mr. Beebe and Mr. Thomas were available to
work overtime every night, while Mr. Hassebrock was not available the
entire first week, both earned less overtime during their details than
either Mr. Bowen or Mr. Hassebrock.
NTEU challenged Respondent's discriminatory assignments of Mr. Beebe
and Mr. Thomas, filing the present unfair labor practice on August 23,
1985. On behalf of Respondent, Mr. Hardy replied to the charges in an
October 2, 1985 letter to Region 9 of the Authority, in which he offered
the "specific reasons for the temporary reassignment of each employee."
Mr. Hardy asserted that Beebe had been selected for the assignment so
that he could train Seattle employees on aspects of the "oil program,"
while Mr. Thomas, as the inspector commanding the "greatest knowledge"
of the Automated Commercial System (ACS), /4/ had been selected to shar
this expertise with employees in Blaine, Washington. That same month
Mr. Hardy also met with NTEU Chapter 164 President, Mr. William Keown,
and again asserted the some reasons for the assignments.
Mr. Beebe was never informed of any alleged training duties and his
assignment to Seattle port involved absolutely no training of other
employees on the oil program. In fact, during Beebe's two-week
assignment his only involvement with the Oil Program was a one and one
half hour meeting with Customs Import Specialist Mr. Yamata wherein the
oil program was discussed. Mr. Beebe himself had requested the meeting
after he had learned of the temporary reassignment.
Mr. Thomas, like Mr. Beebe, did no training in his alleged area of
expertise, the ACS, while on assignment to Blaine. During his three
weeks in Blaine, Mr. Thomas spent only 30 minutes even discussing ACS
with Blaine employees.
Moreover, the evidence further establishes that Mr. Thomas was not an
expert on ACS and that, in fact, if such expertise were required, there
were more qualified inspectors available, including Inspectors Mr.
Barry, Mr. Bjork, and Mr. Bergquist. Mr. Thomas' first experience with
ACS (or its predecessor "ACCEPT") came in April, 1985 and he had a total
of only 15 minutes of on-the-job experience by September 3, 1985, when
he went to Blaine. During that time Mr. Thomas was the "outside man" at
Respondent's "transiplex" facility at the SEA-TAC airport. As both Mr.
Thomas and, later Inspector Mr. Jack Bjork testified, the "outside man"
's ACS responsibilities are limited to one day every other week, when he
relieves the "inside man," who is the one primarily responsible for ACS.
Mr. thomas had never been to any ACS training classes. /5/
Inspectors Mr. Robert Barry, Mr. Gerald Bergquist, and Inspector Mr.
Bjork, on the other hand, had a great deal of experience and training in
ACS and ACCEPT. /6/ Three years ago Respondent sent Mr. Barry to San
Diego for ACS training. He then returned to Seattle where he set up the
ACS program and trained the first journeymen inspectors. Mr. Barry had
also been the Seattle District's "training officer" from June 1983 to
January, 1985, coordinating the District's training programs and often
running specific training sessions. Because of his vast experience and
training in ACS, Mr. Barry needed only minutes to reacquaint himself
with ACS after being away from the system for two years. Inspector
Bjork has attended an ACS training session in May, 1985 along with 15
other inspectors and had been working since that time as the "inside
man" with Mr. Thomas at Transiplex. As noted earlier, it is the inside
man who has primary responsibility for, and handles, the bulk of ACS
work.
Inspector Bergquist has worked at Respondent's Harbour Island
facility as the Senior Inspector of the Harbour Island ACS unit from
June, 1985 to the present. Prior to becoming Senior Inspector, Mr.
Bergquist spent three weeks as acting supervisor of the ACS unit. At
Harbour Island, the ACS unit places between 6000-7000 monthly entries
into ACS. /7/ As Senior Inspector of the ACCEPT unit Mr. Bergquist's
responsibility included reviewing all ACS entries, and supervising the
inspectors and the sides who work on the ACS computer.
Following the testimony of Mr. Barry, Mr. Bjork and Mr. Bergquist in
the above respect, Mr. Hardy was recalled to the stand and offered new
explanations for selecting Mr. Beebe and Mr. Thomas for the temporary
details. With respect to Mr. Thomas, Mr. Hardy claimed that he had
important supervisory skills. Mr. Hardy also referred to Thomas'
"airport operation" experience, pointing out that it would be useful at
a border port. However, Mr. Thomas was instructed to work simply "as a
Senior Inspector in the Cargo Area." Moreover, with respect to knowledge
of airport operations, both Mr. Bjork and Mr. Barry, who appear to have
better ACS qualifications, also had working experience at the Sea-Tac
Airport.
With respect to Mr. Beebe, at the hearing, Mr. Hardy no longer
contended that Mr. Beebe was an oil expert, and instead claimed that
Beebe had been sent to Seattle to improve his allegedly poor performance
in a number of areas. However, Mr. Beebe received no training at all
while in Seattle. Mr. Hardy also claimed that Beebe's high overtime
earnings were causing a problem in staffing at Anacortes, suggesting
that Mr. Beebe might reach the $25,000 cap in September, making it
difficult to spread the overtime assignments. However, the evidence
establishes that Mr. Beebe had only $19,000-$20,000 in overtime when he
arrived in Seattle in September. Moreover, Mr. Hardy admitted that he
had begun a program in 1985 at Anacortes using intermittent inspectors
to handle overtime assignments in lieu of regular inspectors. There is
no evidence that the intermittent inspectors were unavailable in
September, 1985. However, Mr. Hardy further testified that the
intermittents were not qualified for all jobs.
Mr. Hardy's only explanation for failure to include these new reasons
in his October letter to the Region was that he had dictated the letter
rather hurriedly.
Discussion and Conclusions
The General Counsel, citing, among other things, the protected
activity of Mr. Beebe and Mr. Thomas, the timing of their details, the
fact that Mr. Hardy's reasons for their selection do not withstand
scrutiny, and the availability of more qualified teachers than Mr.
Thomas, takes the position that the details of Mr. Beebe and Mr. Thomas
were based solely on union animus and were therefore in violation of
Section 7116(a)(1) and (2) of the Statute.
The Respondent on the other hand takes the position that the General
Counsel has not established a prima facie case and therefore the
complaint should be dismissed in its entirety. Additionally, the
Respondent claims that the General Counsel has not established that the
reasons proffered for the selection of Mr. Beebe and Mr. Thomas were
"pretextual." Finally, the Respondent takes the position that even if it
is established that Mr. Beebe and Mr. Thomas' grievances and that Mr.
Hardy, the Distrtct Director, the person responsible for selecting Mr.
Beebe and Mr. Thomas for the temporary inter-port awareness program, was
well aware of their respective protected activities.
The record further establishes that Mr. Hardy made the decision to
select Mr. Beebe and Mr. Thomas for the temporary details without any
consultation with Mr. Beebe and Mr. Thomas concerning such details. In
contrast to the treatment accorded Mr. Thomas and Mr. Beebe, Mr. Hardy
sought input from the supervisors in the Seattle and Blaine Ports
relative to which employees should be detailed to the permanent
locations of Mr. Beebe and Mr. Thomas. /8/ Thus, while the swap was
voluntary as to Mr. Beebe and Mr. Thomas' temporary replacements, it was
mandatory as to Mr. Beebe and Mr. Thomas and resulted in undue hardships
upon them.
The record further reveals, that, according to Mr. Hardy, he selected
Mr. Beebe and Mr. Thomas for the inter-port transfers in order to
utilize their expertise in the ports of Blaine and Seattle. Thus, Mr.
Beebe was to train employees in Seattle on the "oil program" while Mr.
Thomas was to train the Blaine Port employees on the ACS system.
However, in practice, neither Mr. Beebe nor Mr. Thomas was programmed to
impart their alleged respective knowledge of the oil program and ACS
system to the employees working in the Seattle and Blaine Ports. In
fact the record further establishes that Mr. Beebe only contact with the
oil program while in Seattle was a one and one half hour discussion with
an import oil specialist which he requested after he had been informed
of his temporary assignment.
With respect to Mr. Thomas, who was allegedly selected for a
temporary detail to Blaine because of his ACS expertise, the record
reveals that he was far from an ACS expert, having had only fifteen
minutes on-the-job training on ACS. The record further reveals that
other employees were much more versed in the ACS system and that such
employees has actually undergone formal training on the ACS system.
Finally, with regard to Mr. Hardy's testimony that one of the reasons
for the temporary transfers of Mr. Beebe and Mr. Thomas was their
proximity to the $25,000 overtime cap, the record reveals that Mr. Beebe
as of September 3, had only earned nineteen or twenty thousand dollars
in overtime. Accordingly, multiplying $68 by 27, the remaining days of
the fiscal year, would therefore only give him less than $22,000 in
overtime earning for the entire fiscal year, several thousand dollars
less than $25,000 the overtime cap.
Based upon the record as a whole and particularly the foregoing
considerations, I find, contrary to the contention of the Respondent,
that the preponderance of the evidence supports the conclusion that the
temporary details of Mr. Beebe and Mr. Thomas were based upon their
participation in activities protected by the Statute, namely the filing
of grievances. I further find that the reasons assigned by Respondent
for their respective details were a pretext and that but for Mr. Beebe
and Mr. Thomas' participation in protected activities they would not
have been involuntarily detailed to the Blaine and Seattle Ports. In
such circumstances, I further find that the Respondents selection of Mr.
Beebe and Mr. Thomas for their respective details was based upon union
animus and hence violative of Section 7116(a)(1) and (2) of the Statute.
Accordingly, it is hereby recommended that the Federal Labor
Relations Authority issue the following Order designed to effectuate the
purposes and policies of the Statute.
ORDER
Pursuant to Section 2423.29 of the Federal Labor Relations
Authority's Rules and Regulations and Section 7118 of the Statute, the
Authority hereby orders that the U.S. Customs Service, Washington, D.C.
shall:
1. Cease and desist from:
(a) Discriminating against Donald Thomas, Loren Beebe, or any
other unit employees with regard to temporary assignments,
details, or other conditions of employment because of their action
in filing grievances or participating in other activities
protected by the Statute. (b) In any like or related manner
interfering with, restraining, or coercing employees in the
exercise of their rights assured by the Statute.
2. Take the following affirmative action in order to effectuate the
pruposes and policies of the Statute.
(a) Make whole Donald Thomas and Loren Beebe for any loss of
overtime pay they would have earned but for their temporary
details during the period September 3, 1985 to September 21, 1985.
(b) Post at all its locations within the Seattle, Washington
District copies of the attached notice marked "appendix" on forms
to be furnished by the Federal Labor Relations Authority. Upon
receipt of such forms they shall be signed by the District
Director, and shall be posted and maintained by him for 60
consecutive days thereafter, in conspicuous places, including all
bulletin boards and other places were notices to employees are
customarily posted. Reasonable steps shall be taken to insure
that said notices are not altered, defaced, or covered by any
other material.
(c) Pursuant to Section 2423.30 of the Authority's Rules and
Regulations, notify the Regional Director for Region IX, in
writing, within 30 days from the date of this Order, as to what
steps have been taken to comply herewith.
/s/ Burton S. Sternburg
Administrative Law Judge
Dated: January 31, 1986
Washington, D.C.
--------------- FOOTNOTES$ ---------------
(*) The General Counsel's motion to disregard the Respondent's
exceptions and attached opposition to the Respondent's exceptions have
not been considered because they were filed untimely. Therefore, it is
unnecessary to consider the Respondent's response to the General
Counsel's motion.
(1) In the absence of any objection, General Counsel's Motion to
Correct Hearing Transcript, should be, and hereby is, granted.
(2) This arbitration is still pending.
(3) Mr. Beebe's assignment lasted only two weeks because of an
earlier scheduled vacation.
(4) ACS and its predecessor, ACCEPT, are computer systems which
Respondent uses to determine the extent to which an importer's shipment
will be inspected.
(5) Concerning Mr. Thomas' alleged ACS qualifications, Mr. Hardy
mistakenly recalled an ACS computer "demonstration" that Mr. Thomas had
given to him. However, Mr. Thomas testified that he never even
discussed ACS with Mr. Hardy and that the computer he had acquainted Mr.
Hardy with was the Sealand System, which is totally unrelated to ACS.
Mr. Thomas denied receiving any such ACS training and his denial stands
uncontradicted on the record.
(6) Unless otherwise noted, "ACS" will be used for all future
references of both ACS and ACCEPT.
(7) At the Transiplex, where Thomas gained his limited ACS
experience, there are only 2,000 entries each month.
(8) The supervisors indicated that they had employees under their
supervision who had indicated a desire for such training details.
APPENDIX
NOTICE TO ALL EMPLOYEES
PURSUANT TO A DECISION AND ORDER OF THE FEDERAL LABOR
RELATIONS
AUTHORITY AND IN ORDER TO EFFECTUATE THE POLICIES OF CHAPTER 71
OF TITLE
5 OF THE UNITED STATES CODE FEDERAL SERVICE LABOR-MANAGEMENT
RELATIONS
STATUTE
WE HEREBY NOTIFY OUR EMPLOYEES THAT:
WE WILL NOT discriminate against Donald Thomas, Loren Beebe, or any
other unit employees with regard to temporary assignments, details, or
other conditions of employment because of their action in filing
grievances or participating in other activities protected by the
Statute.
WE WILL NOT in any like or related manner, interfere with, restrain,
or coerce employees in the exercise of their rights assured by the
Federal Service Labor-Management Relations Statute.
WE WILL make whole Donald Thomas and Loren Beebe for any loss of
overtime pay they would have earned but for their temporary details
during the period September 3, 1985 to September 21, 1985.
. . . . . (Agency or Activity)
Dated: . . . .
. . . . . (Signature)
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 questions concerning this Notice or compliance
with any of its provisions, they may communicate directly with the
Regional Director of the Federal Labor Relations Authority, Region IX,
whose address is: 530 Bush Street, Room 542, San Francisco, CA 94108
and whose telephone number is: (415) 556-8106.