With a new General Counsel's Memorandum, the NLRB has
increased the autonomy of Regional Offices to seek remedies against Employers
in "first contract" charges. On February 18, 2011, Acting General Counsel Lafe
E. Solomon issued memorandum GC 11-06 to each of the Regional Offices of...
N. Peter Lareau uses O.G.S.
Technologies, Inc., as a vehicle for examining Board and judicial precedent
about an employer's obligation to bargain over a decision to subcontract work
currently performed by employees represented by a labor organization. He
concludes that the Board majority erred in...