January 17, 2018


National Labor Relations Board

1015 Half Street, SE
Washington, D.C. 20570


Members of the National Labor Relations Board,


Consistent with the National Labor Relations Board’s (NLRB) request for public input regarding the Board’s 2014 Election Rule, the Workforce Fairness Institute (WFI), an organization devoted to educating workers, employers and citizens about issues affecting the workplace, submits the following for publication in the Federal Register.


The Board’s decision to modify election procedures located at 29 CFR parts 101 and 102 was among the most misguided rulings the NLRB created during the Obama presidency.


By shortening the timeframe for union elections to as few as 11 days, the decision allowed labor organizers to quietly garner support to form a collective bargaining unit, then ambush business owners with elections shortly thereafter.  With such little time to prepare, employers are unable to provide their employees with thoughtful information about the positive and negative aspects of unionization and the serious implications it could have on their lives.


Unionization is a serious decision with real consequences and employees deserve to be fully informed before casting such a monumental vote.


  1. Should the 2014 Election Rule be retained without change?


    1. WFI Response: No.  The NLRB should not retain the 2014 Election Rule without change.


  1. Should the 2014 Election Rule be retained with modifications?  If so, what should be modified?


    1. WFI Response: No.  Whereas the 2014 election rule strips America’s workers of their freedom to cast informed votes regarding the unionization of their workplace, the NLRB should rescind the rule. 


  1. Should the 2014 Election Rule be rescinded?  If so, should the Board revert to the Representation Election Regulations that were in effect prior to the 2014 Election Rule’s adoption, or should the Board make changes to the prior Representation Election Regulations?  If the Board should make changes to the prior Representation Election Regulations, what should be changed?


    1. WFI Response: Yes.  The Board should revert to the original regulations that were in place prior to the 2014 Election Rule’s adoption.  Jobmakers should be allowed the necessary time to properly educate workers on the potential benefits and implications of collective bargaining agreements, and workers ought to know all the facts before casting a vote that could change their livelihoods.


WFI appreciates the NLRB’s request for information on this critical issue and is encouraged by the Board’s willingness to examine the shortcomings of this ruling.




Heather Greenaway

Workforce Fairness Institute



The Workforce Fairness Institute is an organization committed to educating voters, employers, employees and citizens about issues affecting the workplace.  To learn more, please visit: http://www.workforcefairness.com.


To schedule an interview with a Workforce Fairness Institute representative, please contact Ryan Williams at (202) 677-7060.


Tell Congress: Stop the PRO Act

WFI is working to prevent passage of the so-called Protecting the Right to Organize Act (PRO Act)—a wholesale labor reform package that takes the current careful balance of labor rules and tips it greatly in the favor of labor bosses and forced collective bargaining.

The PRO Act robs workers of the right to a secret ballot to form a union, forces union contracts on workers without a vote of approval, and expose workers’ personal contact information to union bosses seeking to organize a workplace. And that’s just the start.

Help us speak out against this woefully misguided and blatantly anti-worker legislation. Review and send the message below to your members of Congress today.

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WFI Key Vote Letter: Opposition to PRO Act

— 02.10.2020 —
Dear Speaker Pelosi and Minority Leader McCarthy: On behalf of the Workforce Fairness Institute (WFI), I am writing to share our organization’s vehement opposition to H.R. 2474, the Protecting the Right to Organize Act (PRO Act). WFI has serious concerns with the broad, overreaching nature of this legislation and the many ways in which it would undermine worker freedom and privacy, while simultaneously threatening businesses and entire industries that keep America’s economy thriving. Please note that WFI will include votes on the PRO Act and its amendments on our Congressional Labor Scorecard, which scores and ranks legislators based on their activity associated with workplace issues. WFI was established to fight for American employees and employers as well as our entire economy. We believe in worker empowerment, the right of workers to be fully informed of the options available for worker-involvement in the workplace, and the right to freely choose whether to organize or not. No individual or group – government, a union or an employer – should be able to intimidate or restrict workers’ in exercising these rights. In an attempt to boost flailing union membership at the expense of workers’ rights, the PRO Act would upend decades of established U.S. labor law and institute myriad anti-employee and anti-employer policies that have already been soundly rejected—by Congress, various federal agencies, or the courts. Among its most blatant affronts to workers’ rights, the PRO Act would eliminate the right to a secret ballot when determining whether to unionize and enforce a “card check” system, exposing workers to the potential for harassment, intimidation, and coercion. The PRO Act would also enforce binding arbitration in union negotiations by a government- appointed bureaucrat; repeal and eliminate right-to-work laws in 27 states, force workers to fund union activities regardless of whether they support them; and threaten the ability of individuals to operate as independent contractors, eliminating traditional economic and employment opportunities and threatening the independence and flexibility of the emerging gig economy. On top of all that, the PRO Act would force all workers’ personal and home contact information to be provided to a union during organizing campaigns – in an electronic, searchable format no less, with no limit on what a union can do with that information. WFI believes in advancing sensible policies that protect and preserve the rights of both employees and employers, and we welcome the opportunity to work with legislators who also support these efforts. However, the PRO Act does not achieve these goals and would instead threaten the rights of both while jeopardizing our entire economy. WFI urges members of the House to strongly oppose the PRO Act. Sincerely, Heather Greenaway Executive Director Workforce Fairness Institute See the letter here.
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