Comment on FR Doc # 2011-15307

As an HR professional and member of the Society for Human Resource Management (SHRM), I am writing to share my concerns with the National Labor Relations Board’s (“NLRB” or “Board”) proposal to alter its process for union representation.
I do not believe that the Board has properly established the need for changes to the election rules. Last year, the average time for a representation election for all petitions filed was 31 days. Even contested and other types of decisions have been issued well within the timeframe goals established by the General Counsel, making wholesale changes in the rule unjustifiable.
The proposed rules do not properly balance the rights of employees, employers and labor unions in the pre-election period, and the shortened timeframes deprive employers of their due process rights under the National Labor Relations Act. Communication with employees is a vital function in the workplace and I am concerned that these rule changes prevent employers from effectively communicating with employees about the unionization process.
The proposal also contains a provision precluding employers from addressing any issue that was not raised in the Statement of Position. Coupled with the shortened timeframe for producing the Statement of Position, this provision is detrimental to employers and likely to increase litigation related to election proceedings, rather than expedite them.
The NLRB proposal on union election rules is but one of several NLRB and federal agency actions affecting employers in recent months. Given the impact of these regulations on employers coupled with the lack of a rational basis for the proposal, I respectfully request that this proposal be withdrawn.
I appreciate your thoughtful consideration of this information. I strive every day to be in touch with our employees, to offer an open door, and to resolve issues and concerns face-to-face without the need for an intermediary.