Comments on NLRB's Ambush Election Proposal

The Retail Industry Leaders Association (“RILA”), on behalf of itself and its member companies, submits the following comments in response to the NLRB’s proposed amendments to its rules governing employee representation elections. See Representation-Case Procedures, 79 Fed. Reg. 7318 (proposed Feb. 6, 2014) (to be codified at 29 CFR Parts 101, 102, 103). RILA also incorporates by reference the comments it submitted in response to the Board’s nearly-identical proposal made in 2011, some of which are repeated and expanded on in the following paragraphs. In addition, RILA joins into the comments filed this date by the Coalition for a Democratic Workplace.