The U. S. Poultry & Egg Association, National Chicken Council and National Turkey Federation submitted comments opposing the National Labor Relations Board's (NLRB) proposed rules governing representation procedures. The proposed rules, dubbed "quickie election rules" for their anticipated impact on the election process timeframe, were published in the Federal Register on February 6.
The comments were prepared by the Joint Poultry Industry Human Resources Council, which is made up of members from the U.S. Poultry & Egg Association, National Chicken Council and National Turkey Federation. Collectively, the three organizations represent 95 percent of the nation's poultry products, and their members generate more than 1.3 million total U.S. jobs.
Although the current procedures result in elections held within an average of 38 days, the proposed rules favor "rushed" elections and make other unreasonable changes in the unionization process. The poultry industry comments identify 23 issues with the proposed rule, many of which carry the unmistakable appearance of a denial of due process and certainly will serve to increase litigation and delay timely elections rather than speed the election process.
"Limiting the time period to seven days between the notice of hearing and the hearing presents an almost impossible sequence of events to satisfy timely,' commented the Joint Poultry Industry Human Resources Council. "There are no provisions in the National Labor Relations Act or the regulations that require "rushed" elections, although there are many provisions requiring "fair" elections. The proposed changes do not meet that goal."