Today, the National Association of Manufacturers filed a reply to the National Labor Relations Board proposed rule to implement ambush elections. In the reply, the NAM asks the NLRB to certify that it has read and duly considered all the comments submitted in response to the Notice of Proposed Rulemaking.
In its initial comments on the proposed rule, the NAM contended the NLRB has failed to comply with the Regulatory Flexibility Act of 1980 and has not provided sufficient evidence the rules are necessary. Further, the NAM believes the volume of comments provided to the NLRB demonstrate the proposed rule will have a significant impact on small businesses. This calls into question the NLRB’s certification to the Small Business Administration that it will not have a significant impact on small business.
Joe Trauger is vice president for human resources policy, National Association of Manufacturers.
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