NLRB Finds Employer and Union Pre-Recognition Agreement Was Lawful

By Edwin S. Hopson

In a press release issued December 6, 2010, the National Labor Relations Board announced that it had found, in a 2-1 decision, that an auto parts manufacturer, Dana Corporation, and the United Auto Workers union did not violate the National Labor Relations Act law by agreeing to ground rules by which the UAW would be recognized if a majority of employees signed cards in favor of it, and by creating a framework for any future collective bargaining agreements. The UAW had a long relationship with Dana and already represented workers at 9 of some 30 facilities Dana has in the United States.  The letter agreement applied to all of its non-union plants in the U.S.