1

Notice Time Frame

• 1993 – Board decision on UFLP charges from 1986-88 (Beverly I)

• 1994 – ALJ decision on UFLP charges from 1991 complaint (Beverly II)

• 1995 – ALJ decision on UFLP charges from 1993 complaint (Beverly III)

• 2000 – court decision• 2001 (July 23) –Board Order, 334 N.L.R.B. No.

79

2

One Integrated Employer

• Centralized Structure– Beverly's hierarchical management structure– Policy of limiting the authority of area and

individual facility managers by overall corporate standards

– central oversight of labor relations functions• labor grievances bump up to the regional level at

step three• Beverly dispatches regional human resources

personnel to individual facilities the minute a union organizational effort begins.

3

Authority of Board

• Board may use corporate-wide relief – when evidence suggests unfair labor practices

at numerous facilities – centralized management structure

4

Factors Supporting Corporate-Wide Remedy

• Number of facilities involved– 20 mentioned in case– 54 overall (of 895)

• Percentage of facilities– 6% of all facilities– 15% of unionized facilities

• Deep involvement of area (regional) managers at the facility

• Recidivism (repeated violations)