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Administrative Law Keyed to Lawson
United States Department of the Treasury, Bureau of Engraving and Printing v. Federal Labor Relations Authority
Citation:
995 F.2d 301 (1993)Facts
The Bureau of Engraving and Printing decided to relocate fourteen employees from one area to another within its facility. The National Treasury Employees Union, which represented these employees, requested bargaining over the impact and implementation of the relocation. The Bureau refused to bargain, claiming that the changes in working conditions were de minimis (too minor to require bargaining). The employees were moved to a new location that had different physical conditions, including poorer air quality, inadequate lighting, and increased noise levels. The union filed an unfair labor practice charge, arguing that these changes were more than de minimis and thus required bargaining under the Federal Service Labor-Management Relations Statute.
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