Labor-Management Relations
Title VII of the Civil Service Reform Act
of 1978 (CSRA), established into law a system for federal employees
to form, join, or assist any labor organization, or to refrain
from any such activity, freely and without fear of penalty or
reprisal. Once formed, these labor organizations exclusively represent
the bargaining unit employees in all matters affecting their working
conditions. This portion of the CSRA U.S. Code (Chapter 71 of
Title 5 of the U.S. Code) is referred to as the Federal Service
Labor-Management Relations Statute (the Statute.)
On an exclusive-recognition basis, labor organizations
represent more than half of the non-postal federal work force.
Negotiated agreements, which cover nine-tenths percent of the
employees represented, increasingly determine personnel policies
and practices.
Although most local unions are nationally
affiliated, local officers and stewards are members of the installation's
workforce and have been elected or appointed to office by the
local union membership. Management is not involved in this selection
process.
The Statute requires supervisors to deal exclusively
with the certified labor union on establishing or modifying conditions
of employment affecting bargaining unit employees. This means
that supervisors and management officials cannot negotiate over
personnel policies, practices, or working conditions directly
with bargaining unit employees. Rather, these dealings must be
solely with the union officials representing them. Failure to
adhere to this requirement (known as bypassing the union) may
result in an unfair labor practice with management's actions being
reversed until the requirement to negotiate with the union, if
requested, has been satisfied.
Key elements of the labor-management program
are:
- Federal employees have the right to join or not to join any
labor organization. Unions with exclusive recognition have the
right and the obligation to represent all employees in an exclusive
unit. Third-party procedures are provided for resolving labor-management
disputes.
- An independent Federal Labor Relations Authority of three
members who serve five-year terms, subject to removal only for
cause, and a general counsel who investigates and prosecutes
complaints of unfair labor practices. The FLRA generally is
responsible for administering the federal government’s
labor relations program. As a result of the enactment of The
Foreign Service Act of 1980 (Public Law 96-465 of October 17,
1980), there is within the Federal Labor Relations Authority
a three member Foreign Service Labor Relations Board. The chairman
of the FLRA serves as the chairman of the FSLRB. The function
of the board in the foreign service is similar to that performed
by the FLRA in the civil service.
- The scope of matters subject to negotiated grievance and
arbitration procedures includes such adverse actions as discharge,
demotion, and long-term suspensions. The negotiated procedures
do not cover prohibited political activities, retirement, life
insurance or health insurance, suspension or removal for national
security, examination, certification or appointment, position
classification which does not result in loss of grade or pay
or any matter the union and agency agree to exclude. Concerning
matters covered by the negotiated grievance procedure with binding
arbitration is the sole procedure available to bargaining unit
employees—except that in adverse actions, unacceptable
performance and EEO discrimination cases the employee may use
either the negotiated procedure or the statutory appeals procedure
(but not both).
- Departments and agencies such as OPM and GSA, which issue
government-wide regulations, are required to consult over substantive
changes in any condition of employment with labor organizations
representing a substantial number of employees.
- The Act clarifies “management rights,” reserving
to agency officials the authority to make decisions and take
actions which are not subject to the collective bargaining process,
and excludes bargaining on federal pay and benefits or non-voluntary
payments to unions by employees. In the management rights area,
the Act: (1) prohibits agencies from bargaining on mission,
budget, organization, number of employees or internal security;
and (2) permits, but does not require, them to negotiate over
the methods, means and technology of conducting agency operations.
Management’s right to select or non-select from a promotion
certificate or to fill a position from any appropriate source
(internally or externally) is specifically stated. The Act contains
the basic rights of federal employees to form, join and assist
labor organizations or to refrain from these activities. It
also contains prohibitions against strikes and slowdowns, as
well as picketing which interferes with government operations.
Other key features and provisions of the federal
government’s labor relations program include:
- A special expedited procedure for most negotiability disputes,
i.e., to determine whether a particular matter falls within
the obligation to bargain.
- FLRA decisions and orders are subject to court enforcement,
including judicial review in unfair labor practice and negotiability
cases.
- Authority to make an employee whole in an unjustified or
unwarranted personnel action—including back pay plus attorney
fees.
- Dues withholding—based on voluntary allotments by employees—is
allowed at the exclusive union’s request. Allotments are
irrevocable for one year, and the withholding service is at
no charge to the employee or labor organization. Dues withholding
also is authorized for unions with 10 percent or more membership
in appropriate bargaining units where there is no exclusive
union.
- Official time for employees representing the union in negotiations
during regular working hours (including attendance at impasse
settlement proceedings), but the number of employees on official
time shall not exceed the number of management officials representing
the agency.
To assist in resolving negotiation impasses,
the mediation services of the Federal Mediation and Conciliation
Service are available, and unresolved negotiation impasses may
be referred to the Federal Service Impasses Panel, an entity within
the FLRA.
Supervisors and managers are excluded from
coverage under the program. They cannot be represented in dealings
with management by unions that represent rank-and-file employees.
(They may be covered instead by agency systems for intra-management
communication and consultation under Office of Personnel Management
guidelines.)
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Union Organizing
The Federal Service Labor-management Relations
Statute provides that an agency shall recognize a labor organization
as the exclusive representative of employees in a bargaining unit,
if that organization has been selected as the representative by
a majority of the unit’s employees who voted in a secret
ballot election.
For a union to represent employees, it must
first file a petition with the Federal Labor Relations Authority.
That petition must establish that at least 30 percent of the employees
in the proposed unit wish to be represented by the union as evidenced
by their signatures and that the unit is appropriate. To be appropriate,
a unit must insure a clear and identifiable community of interest
among unit employees, promote effective dealings with the agency,
and promote the efficiency of agency operations.
Employees already represented by a union may
petition the FLRA to be represented by another union or to be
unrepresented. A petition must be filed with signatures of at
least 30 percent of the employees in the unit asserting that the
exclusive representative is no longer the representative of a
majority of unit employees. Provided at least one year has elapsed
since a representation election was conducted, the FLRA will hold
an election and representation (or lack thereof) will be determined
by a majority of the ballots cast. A negotiated agreement between
labor and management bars another union from seeking to represent
the bargaining unit until shortly before the expiration of the
existing negotiated agreement. At that time (not more than 105
or less than 60 days prior to the expiration of an agreement of
three years or less), the FLRA will consider timely a petition
filed by a rival union.
In addition to determining questions of representation,
petitions may be filed to amend or clarify the description of
a bargaining unit, and to consolidate two or more bargaining units.
It is strongly recommended that activities file these later types
of petition upon any organizational changes which impact on the
bargaining unit’s definition.
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Bargaining Units
The bargaining unit is a group of employees
with common interests who are represented by a labor union in
their dealings with agency management.
Bargaining unit status (that is, whether the
position is in or out of the unit) pertains solely to the employee's
position in the agency—it does not take into consideration
whether the employee is a dues paying union member. As such, these
are two distinct groups. Bargaining unit members are employees
whose positions are included in the defined bargaining unit while
union members are employees who pay dues to the labor organization.
Bargaining unit employees may elect to join the local union and
pay dues either through direct payment to the union or through
automatic dues withholding, or they may decide not to join the
union.
Once a union has been certified as the exclusive
representative, though, it must represent all bargaining unit
members equally, regardless of their union membership. As such,
when the union and management negotiate a collective bargaining
agreement, its terms and conditions cover all employees in the
bargaining unit irrespective of their union membership.
There are, however, limited situations where
the union can favor union members over non-members by offering
certain services to only dues paying members. In these instances,
though, the services are not related to the employee's conditions
of employment. For example, a union can offer the services of
a tax attorney to only dues paying union members.
The Federal Service Labor-Management Relations
Statute specifically excludes certain positions from bargaining
unit coverage. Individuals employed as supervisors, management
officials and employees engaged in personnel work in other than
a purely clerical capacity cannot be included in a bargaining
unit. These individuals cannot be represented by unions and their
conditions of employment can be unilaterally set by management.
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Negotiations
The Federal Service Labor-Management Relations
Statute outlines the broad topics that must be negotiated with
a labor union, those that are reserved to management and those
that may be negotiated at management's election (see Management
Rights, below). The obligation to negotiate requires discussion
and consideration of the other side's proposals—it does
not compel either side to agree to a proposal or to make a concession.
Negotiations occur at various times and for
different reasons. The most prominent is the formal negotiations
for a collective bargaining agreement. These are full scope negotiations.
This process results in a written collective bargaining agreement
signed by both management and the union establishing various personnel
policies, practices, and conditions of employment. The agreement
is normally distributed to everyone at the installation affected
by its application. The document may be referred to as the contract,
the collective bargaining agreement or the labor-management negotiated
agreement. It is normally subject to renegotiations every three
years but is frequently automatically renewed (rolled over) from
year to year.
At times, negotiations arise as a result of
management proposed changes to bargaining unit employees' conditions
of employment (e.g., an agency reorganization, the introduction
of new equipment, changes in regulations of outside authorities,
etc.), which are not addressed in the parties' negotiated agreement
or where there is no current agreement. In these cases, when an
agency decides to make changes to conditions of employment during
the life of an agreement— sometimes called midterm bargaining—or
when there is no agreement, two types of negotiations may result:
- negotiations on the decision itself (substance bargaining);
and/or
- negotiations on the effects of the proposed change—normally
referred to as impact and implementation bargaining.
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Management Rights
Management rights is a term which defines
those areas over which management exercises exclusive decision-making
authority. These rights are spelled out in section 7106 of the
Federal Service Labor-Management Relations Statute. There are
two categories of management rights, “mandatory” or
reserved rights, and “permissive” rights.
Rights reserved to management under Section
7106(a)(1) governing general management practices include the
authority to determine the agency’s mission, budget, organization,
number of employees, and internal security practices. Reserved
rights under Section 7106(a)(2) governing employment practices
include the authority to: hire, assign, direct, lay off, retain,
suspend, remove, reduce in grade or pay, or take other disciplinary
action against employees, assign work, make determinations with
regard to contracting out, determine the personnel by which agency
functions will be performed, make selections from among properly
ranked and certified candidates for promotion or any other appropriate
source; and take whatever action may be necessary to carry out
the agency mission during emergencies.
Permissive rights under Section 7106(b)(1)
are those rights that management may bargain, but is not statutorily
required to do so. These include the numbers, types, and grades
of employee's or positions assigned to any organizational subdivision,
work project, or tour of duty and the technology, methods, and
means of performing work. (Note: Clinton administration orders
to require agencies to bargain over permissive rights—Executive
Orders 12871, 12983 and 13156—were overturned by a Bush
administration order, Executive Order 13203 of February 17, 2001.)
Even with respect to nonnegotiable “mandatory”
management rights, management must bargain, upon request, over
the procedures it will use in exercising these rights and on appropriate
arrangements for employees adversely affected by the exercise
of such rights. For example, in a reduction-in-force, the decision
to RIF is a management right, but how that RIF is conducted and
outplacement or other assistance for displaced employees are negotiable
issues.
When there is a question whether a proposal
is outside the duty to bargain because it involves a management
right or is subject to bargaining as a condition of employment,
the matter may be raised as a negotiability appeal to the Federal
Labor Relations Authority. Negotiability decisions of the FLRA
can be challenged in federal court.
A union may propose measures whose purpose
is to alleviate the adverse impact on unit employees of a management
action. If, however, the union’s proposal seriously interferes
with the exercise of a management right, the FLRA will apply the
“excessive interference” test. That test provides
that a union proposal whose purpose is to ameliorate the adverse
affects of a management decision is negotiable unless it impinges
upon a management right to an excessive degree.
Even where a proposal would violate management
rights, management is encouraged to discuss these proposals with
the union and attempt to resolve the union’s concerns while
preserving management’s rights.
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Employees' Rights
Employees have the right to form, join or
assist a union or to refrain from doing so. Employees are free
to exercise this right without fear of penalty or reprisal and
shall be protected in exercising this right.
Employees have the right to:
- act as a union representative, and in that capacity, to present
union views to agency management, the Congress or other authorities;
and
- negotiate over conditions of employment through their chosen
representative.
While typically an employee has no control
over whether he or she is in a bargaining unit, it is the employee’s
decision whether to be a union member, and if a union member,
how actively engaged. Additionally, management does not have a
say in which bargaining unit employee serves as a union official.
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Union Rights
Representational Rights—Several provisions
of the Federal Service Labor-Management Relations Statute address
the opportunities unions have in representing the bargaining unit
employees' interests. For example, the union is able to:
- negotiate with management in good faith concerning conditions
of employment for bargaining unit members;
- obtain data normally maintained by management that are reasonably
available and necessary to the union for full and proper discussion,
understanding, and negotiation of subjects within the scope
of collective bargaining;
- present its views to heads of agencies and other officials
of the executive branch of the government, the Congress, or
other appropriate authorities;
- have employees representing the union on official time when
negotiating agreements with management; and
- be represented at certain discussions management may have
with bargaining unit employees.
Formal Discussions—Management has an
obligation to invite the union to attend any formal discussion
between one or more representatives of the agency and one or more
employees in the unit or their representatives concerning any
grievance or any personnel policy or practices or other general
condition of employment.
For a meeting to be considered a formal discussion,
it must include:
- one or more representatives of the agency (e.g., supervisor(s),
management official(s), personnelist(s), or attorney(s)); and
- one or more employees in the bargaining unit or their representative(s).
A meeting does not become a formal discussion
unless the subject concerns an individual's grievance or general
conditions of employment.
A discussion between management and a grievant
relating to a grievance is a formal discussion. The union must
be invited to attend even if the employee is representing him
or herself in the negotiated grievance proceeding.
Discussions with bargaining unit members about
general conditions of employment or personnel policies and practices.
Normal shop talk is not a formal discussion.
If the meeting meets the definition of a formal
discussion, the supervisor must invite the union to attend. Having
a shop steward who works in the office at the meeting in his or
her role as an employee does not meet this obligation. Rather,
the supervisor must invite the union to the meeting with the union
being free to designate whom it wants to act as its representative.
Finally, the union is allowed to participate
in these meetings by raising questions/comments/concerns, but
it cannot disrupt them.
Examination of Employees (‘Weingarten’
Meetings)—The union is entitled to represent bargaining
unit employees' at meetings in connection with an investigation.
This provision is often referred to as employees' "Weingarten"
rights, based on a Supreme Court decision. The Federal Service
Labor-Management Relations Statute establishes three conditions
for a "Weingarten" meeting:
- one or more agency representatives are examining (questioning)
a bargaining unit employee in connection with an investigation;
- the employee reasonably believes that the examination may
result in disciplinary action against the employee; and
- the employee requests union representation.
Once all three conditions have been met, supervisors
may generally not continue the examination without allowing the
employee his or her requested representation. Specifically, the
supervisor's options under these circumstances are:
- grant the request and notify the union that a meeting to
examine a bargaining unit employee is going to take place and
that the employee has requested union representation. If the
union attends the meeting, it must be allowed to make relevant
comments but cannot disrupt the meeting nor can it answer the
questions posed to the employee;
- discontinue the interview and rely on evidence already available
or information obtained from other sources; or
- offer the employee a clear choice to continue the interview
without representation, or have no interview.
"Weingarten" rights are not applicable
when management issues a disciplinary action since management
is not asking any questions. Additionally, the "Weingarten"
right does not come into play when engaging in performance counseling
as this does not concern disciplinary matters but, rather, performance
issues.
Finally, management, usually the installation
labor relations specialist, is responsible for annually notifying
employees of their "Weingarten" rights.
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Negotiated Grievance Procedures
The Federal Service Labor-Management Relations
Statute defines a negotiated grievance as any complaint by any
employee concerning any matter relating to the employment of the
employee, by any labor organization concerning any matter relating
to the employment of any employee or by any employee labor organization,
or agency concerning:
- the effect or interpretation, or a claim of breach, of a collective
bargaining agreement; or
- any claimed violation, misinterpretation or misapplication
of any law, rule, or regulation affecting conditions of employment.
Every negotiated agreement contains a negotiated
grievance procedure. This is the exclusive procedure for resolving
bargaining unit employees' grievances that fall within its coverage;
the union is the exclusive representative under this procedure.
Note: Negotiated grievance procedures do not apply to employees
serving probationary periods.
The negotiated grievance system is a full-scope
procedure. That is, it covers all matters falling within the definition
that are not specifically excluded by the Statute. (For example,
the negotiated grievance system cannot include grievances concerning
retirement, life insurance or health insurance, or the classification
of any position which does not result in the reduction in grade
or pay of an employee.) Management and the union can, through
collective bargaining, exclude any additional subject from coverage
of the negotiated procedure. For example, if the parties agree
that grievances over performance appraisals are to be excluded
from the negotiated procedure, these types of grievances would
then have to be raised under the administrative grievance procedure
or some alternative system developed by the parties.
Employees filing grievances under the negotiated
procedure can elect to have the union represent them or they can
represent themselves. They cannot hire their own representatives
unless the union states that the private representative is acting
for the union. Even if the employee represents him or herself,
the union must be invited to attend any grievance meetings as
these are considered formal discussions.
The negotiated grievance procedure usually
begins with the grievant or his or her representative presenting
an informal grievance to the first-line supervisor. If not resolved,
the grievant can raise the matter up through the chain of command.
(Each negotiated agreement details the administrative steps of
the grievance process.) Once the final decision has been issued,
the matter can be raised to final and binding arbitration by the
union—an employee cannot raise a matter to arbitration.
A recent development concerning negotiated
grievances is the advent of alternative dispute resolution (ADR)
procedures. Under an ADR program, alternate means are introduced
to resolve employee complaints before a grievance reaches the
final stage. Some ADR processes include mediation, peer-panel
reviews, facilitation, etc. The goal of ADR is to provide an informal,
local method for amicably resolving disputes at the lowest possible
level without the need for invoking third party arbitration. For
more information on the Federal Labor Relations Authority’s
role in grievance procedures and for further information on ADR,
see Chapter 9.
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Unfair Labor Practices
An unfair labor practice (ULP) is normally
a violation of the Federal Service Labor-Management Relations
Statute. Anyone can file a ULP charge—an individual, an
employee, the union or management. The respondent to the charges,
though, will always be either management or the union. The vast
majority of ULP charges are filed by the union against management.
The reason for this is that management is usually the party which
takes the actions.
Unfair labor practice charges are filed with
the General Counsel of the Federal Labor Relations Authority.
The General Counsel investigates the charge to determine if there
is sufficient evidence to warrant issuing a complaint. If a complaint
is issued, a hearing is set and the parties go before an administrative
law judge (ALJ) with the General Counsel prosecuting. The administrative
law judge will issue a decision either finding that a ULP was
committed or dismissing the complaint. If either party is dissatisfied
with the ALJ's decision, the case can be appealed to the Authority.
If the agency is found to have committed a
ULP, various remedies can be assigned. The most common is a posting
stating that the agency committed a ULP and won't do it again.
Another remedy issued by the Authority is a reversal of the management
action that caused the ULP. For example, if management realigns
an office without giving the union an opportunity to bargain,
a ULP remedy may be to reverse the realignment and to require
management to bargain with the union. This is called a status
quo ante remedy. Tied into the status quo ante remedy can be a
make whole order with back pay. If the realignment discussed above
resulted in employees losing pay or allowances (e.g. differentials
or consistent overtime opportunities), the ULP remedy may include
back pay for these employees.
Management Unfair Labor Practices—Section
7116(a) of the Federal Service Labor-Management Relations Statute
(see Title 5 of the US Code) provides that it is an unfair labor
practice for management to:
- interfere with, restrain, or coerce employees in the exercise
by the employee of any right under the Statute;
- encourage or discourage membership in any labor organization
by discrimination in connection with hiring, tenure, promotion,
or other conditions of employment;
- sponsor, control or otherwise assist any labor organization,
other than to furnish, upon request, customary, and routine
services and facilities if the services and facilities are also
furnished on an impartial basis to other labor organizations
having equivalent status;
- discipline or otherwise discriminate against an employee because
the employee has filed a grievance, complaint, affidavit, or
petition or has given any information or testimony;
- refuse to consult or negotiate in good faith with a labor
organization;
- fail or refuse to cooperate in impasse procedures and impasse
decisions;
- enforce any rule or regulation (other than a rule or regulation
addressing prohibited personnel practices) which is in conflict
with any applicable collective bargaining agreement if the agreement
was in effect before the date the rule or regulations was prescribed;
or
- otherwise fail or refuse to comply with any provision of the
Statute.
Union Unfair Labor Practices—Section
7116(b) of the Federal Service Labor-Management Relations Statute
defines those actions which, if taken by the union, would result
in a ULP. The statute provides that it is an unfair labor practice
for the union to:
- interfere with, restrain, or coerce any employee in the exercise
by the employee of any right under the Statute;
- cause or attempt to cause an agency to discriminate against
any employee in the exercise by the employee of any right;
- coerce, discipline, fine, or attempt to coerce a member of
the labor organization as punishment, reprisal, or for the purpose
of hindering or impeding the member's work performance or productivity
as an employee or the discharge of the members duties as an
employee;
- discriminate against an employee with regard to the terms
of conditions of membership in the labor organization on the
basis of race, color, creed, national origin, sex, age, preferential
or nonpreferential civil service status, political affiliation,
marital status, or handicapping condition;
- refuse to consult or negotiate in good faith with a labor
organization;
- fail or refuse to cooperate in impasse procedures and impasse
decisions;
- to call, or participate in, a strike, work stoppage, or slowdown,
or picketing of an agency in a labor-management dispute if such
picketing interferes with an agency's operations, or
- otherwise fail or refuse to comply with any provision of the
Statute.
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Official Time
Official time is the time granted to an employee
by the agency to perform representational functions on behalf
of the union. Official time is granted without charge to leave
or loss of pay and is authorized only when the employee would
otherwise be in a duty status. Official time is considered hours
of work.
Official time must be granted to employees
representing a labor organization when engaged in collective bargaining,
to include attendance at impasse proceedings. The number of employees
for whom official time is authorized may not exceed the number
of individuals designated as representing the agency in the negotiations.
(Although the union can bargain for additional union negotiators
to be on official time.)
Official time cannot be granted for internal
union business.
The Federal Labor Relations Authority can
authorize official time for employees representing the union in
any phase of proceedings before the Authority. This would include
unfair labor practice proceedings, bargaining unit representation
proceedings, etc.
Official time for representing bargaining
unit employees on matters covered by the Statute may be granted
in any amount the agency and the union involved agree to be reasonable,
necessary and in the public interest. The amount and use of official
time for representational purposes is fully negotiable. The amount
of official time authorized to union representatives at the installation
is detailed in the parties' negotiated agreement or is set through
past practice.
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Strikes
Individuals who participate in a strike against
the government of the United States or the government of the District
of Columbia may not accept or hold a position in the government
of the United States (5 USC 7311). Such individuals are also not
considered employees within the meaning of the Act, 5 USC 7103(a)(2)(B)(v).
It is an unfair labor practice for a labor
organization to “call, or participate in, a strike, work
stoppage, or slowdown, or picketing of an agency in a labor-management
dispute if such picketing interferes with an agency’s operations”
or “to condone any activity described (above) by failing
to take action to prevent or stop such activity,” (5 USC
7116(b)(7)(A) and (B)). Further, the Act by definition excludes
labor organizations that engage in such activity from coverage
and thus from acting as the exclusive representative of employees,
(5 USC 7103(a)(4) (D)).
The FLRA is given the power when it finds
a labor organization that has either by omission or commission
willfully and intentionally violated section 7116(b)(7) of the
Act to “revoke the exclusive recognition status of the labor
organization . . .” or “take any other appropriate
disciplinary action,” (5 USC 7120(f)).
A strike by employees against the government
of the United States or the government of the District of Columbia
also constitutes a criminal violation (18 USC 1918). Any person
found guilty of violating this section of the law is subject to
a fine of not more than $1,000 or imprisonment of not more than
a year and a day, or both.
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Labor-Management Partnerships
Executive Order 13203 of February 17, 2001
revoked Clinton administration Executive Orders 12871, 12983 and
13156, which were designed to foster a partnership arrangement
between federal unions and management and which established the
National Partnership Council, made up of top agency officials
and presidents of federal unions, to oversee and promote partnership.
The 2001 order dissolved the Council and ordered
the Office of Personnel Management and heads of federal agencies
to rescind any orders, rules, guidelines or other policies implementing
the partnership program, “to the extent consistent with
law” and with any collective bargaining agreements in effect
at the time.
Later OPM guidance stated that the 2001 order
“does not prescribe any particular approach to labor-management
relations” and that it gave agencies “discretion to
adopt a labor relations strategy best suited to their own needs.”
Such strategies can include partnership arrangements, although
the prior mandate to use them no longer exists. OPM said, however,
that agencies are “strongly encouraged to establish cooperative
labor-management relationships.”
The order also had the effect of revoking
Clinton administration initiatives to require agencies to bargain
on subjects that are negotiable at an individual agency’s
discretion under federal labor law (see above).
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For More Information
You may obtain more information about labor-management
relations in the current edition of the Federal Employees
Almanac.
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