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 Should the 2014 Election Rule be rescinded?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.


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