Jaggars-Chiles-Stovall, Inc.

JAGGARS-CHILES-STOVALL, INC. 697 Jaggars-Chiles-Stovall, Inc. and Dallas Typographi. cal Union No. 173. Case 16-CA-8323 May 21, 1980 DECISION AND ORDER BY CHAIRMAN FANNING AND MEMBERS JENKINS AND PENELLO On January 30, 1980, Administrative Law Judge Harold A. Kennedy issued the attached Decision in this proceeding. Thereafter, Respondent filed ex- ceptions and a supporting brief. Pursuant to the provisions of Section 3(b) of the National Labor Relations Act, as amended, the Na- tional Labor Relations Board has delegated its au- thority in this proceeding to a three-member panel. The Board has considered the record and the at- tached Decision in light of the exceptions and brief and has decided to affirm the rulings, findings, and conclusions of the Administrative Law Judge and to adopt his recommended Order. ORDER Pursuant to Section 10(c) of the National Labor Relations Act, as amended, the National Labor Re- lations Board adopts as its Order the recommended Order of the Administrative Law Judge and hereby orders that the Respondent, Jaggars-Chiles- Stovall, Inc., Dallas, Texas, its officers, agents, suc- cessors, and assigns, shall take the action set forth in the said recommended Order, except that the at- tached notice is substituted for that of the Adminis- trative Law Judge. APPENDIX NOTICE To EMPLOYEES POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government WE WILL NOT fail or refuse to supply Dallas Typographical Union No. 173 with informa- tion relevant and necessary to the performance of its obligations as bargaining representative of our employees. WE WILL NOT in any like or related manner interfere with, restrain, or coerce our employ- ees in the exercise of their rights guaranteed by Section 7 of the Act. WE WILL, upon request by Dallas Typo- graphical Union No. 173, provide the name and rate of pay of each employee at our Dallas, Texas, facility, including those classi- fied as foremen and assistant foremen, who perform production work involving the markup of copy continuing on through the 249 NLRB No. 108 printing press, excluding the making of mats, stereotypes, plastic plates, photoengraving and finishing operations beyond the printing press run. WE WILL furnish all other information rele- vant and reasonably necessary to the perform- ance of the Union's obligations as bargaining representative. JAGGARS-CHILES-STOVALL, INC. DECISION HAROLD A. KENNEDY, Administrative Law Judge: This case' is before me upon a complaint issued by the Regional Director for Region 16 of the National Labor Relations Board on March 23, 1979, alleging violation of Section 8(a)(5) and (1) of the National Labor Relations Act, as amended. The complaint, based on a charge filed by the Dallas Typographical Union No. 173, filed on February 9, 1979,2 alleges that Jaggars-Chiles-Stovall, Inc. (hereinafter JCS), violated the Act by refusing to supply wage rate data for all employees in a bargaining unit at its printing press facility in Dallas, Texas. I find that the Charging Party Union is entitled to such earn- ings information and, accordingly, recommend entry of an appropriate cease-and-desist order. Background-Undisputed Matters Respondent's answer and stipulations reached at the hearing eliminated many issues. Jurisdiction is not in question. Much of the testimony was not contradicted. JCS is engaged in the printing business with its office and place of business located at 5531 East University Boulevard in Dallas, Texas.3 Respondent admits that it grosses over $500,000 annually and that it purchases goods and/or services from out of State valued in excess of $50,000. Based on these facts and Respondent's answer, I find Respondent is an employer engaged in commerce within the meaning of Section 2(6) and (7) of the Act. The Union is admittedly a labor organization within the meaning of Section 2(5) of the Act. Labor relations between Respondent and the Union have been harmoni- ous over the years. The union has been the recognized collective-bargaining representative of Respondent's printing employees for many years. Respondent agrees that the following employees, described in paragraph 6 of the complaint, constitute an appropriate unit for pur- poses of collective bargaining within the meaning of Sec- tion 9(b) of the Act: The caption of the case was amended at the hearing so as to show the correct designation of the Respondent Company's name and the full name of the Charging Party Union 2 An amended charge was filed on July 9, 1979. a Robert Stovall, president of Respondent, described its business as fol- lows: Well, we're in the graphic arts business and basically we're typogra- phers. And we also have a printing department. And typography is a process through which we convert typed matter into pages for books or advertisements of magazines, grocery store ads. JAGGARS-CHILES-STOVALL,~~~~~~ I.67 _ _ 698 DECISONS OF NATIONAL LABOR RELATIONS BOARD All journeymen and apprentices involved with the markup of copy continuing on through the printing press, excluding the making of mats, stereotypes, plastic plates, photoengraving and finishing oper- ations beyond the printing press run, at the Re- spondent's Dallas, Texas facility .... In 1978 the Union and Respondent signed a collective- bargaining agreement covering the period of February 21, 1977, to June 30, 1981. The agreement was received in evidence as General Counsel's Exhibit 2. The Union requested Respondent to supply wage rates for all employees in the bargaining unit, but Respondent has refused to do so except for those who are members of the Union. 4 The Testimony William Bates, chapel chairman at JCS,5 testified that over the years the Company had supplied monthly "earnings reports" to the Union. The reports contain the names of foremen and all members of the bargaining unit, including assistant foremen. The practice of the Company has been to furnish wage information only on those who are members of the Union. With respect to nonunion members, the Company has disclosed, as indi- cated on General Counsel's Exhibit 3, the earnings report for January 1979, only whether such employees had worked either on day or night shifts.6 Bates testified that he used the earnings reports in po- licing the contract, in preparing for future negotiations, and in assessing dues of the members of the union. On cross-examination he agreed that the list had been used in making deductions for union dues. At one time he said every member doing bargaining unit work for JCS was a member of the Union. He agreed that the Company fur- nished wage information on every employee while a member of the Union. Bates explained that the procedure for obtaining the wage information was as follows: The Union would send to him, the chapel chairman, a form containing the list of names of employees performing unit work. He would take the form to the Company's bookkeeping department where George Clower would fill out the wage and shift information. Thereafter the completed form would be re- turned to Bates, and he would then forward it on to the Union. Bates testified that around February I and 2, 1979, 7 he asked Bob Stovall, president of JCS, to supply wage in- formation on nonunion employees for the month of Janu- ary. Bates said Stovall's response was that he would be willing to submit earnings information only in the form that the Company had previously. Bates said he told Sto- 4 The Union requested earnings information on at least one employee, Calvin Wilson, who is no longer a member of the bargaining unit s Bates explained that chapel chairman is the equivalent of shop ste- ward. He said he had worked for Respondent since 1967 and had been on the negotiating committee that negotiated the current collective-bargain- ing agreement. Bates currently does "cold type makeup" but had previ- ously done "hot metal makeup" for JCS. I The reports are supplied each month and report the amount of wages of union members on a weekly basis. Some reports cover a 4-wcek period, and some cover a 5-week period. I All dates refer to 1979, unless otherwise indicated. vail that he needed the additional information in order "to police the contract."8 Bates said he thereafter spoke to Union President Ken Cowen and asked that he (Cowen) try to secure the nonunion wage information from Stovall. In March Bates spoke to Stovall again at which time he said Stovall reported that the Company had been no- tified by the NLRB that the Union had filed charges against it. Bates said that he again explained to Stovall that the Union needed the nonunion wage information, but that Stovall only "reiterated his statement that he would be willing to continued to furnish the report with days and nights by nonunion personnel and the amounts for union personnel." Bates indicated that he decided to press for the non- union wage information in early 1979 because he knew there were employees who worked on Saturdays and Sundays." Bates said he did not know if they were paid overtime or if at all. He said he was concerned about payment of overtime and that overtime work should be "given out in a fair and equitable manner" in accord with the contract. Bates also stated that he had become concerned about the possibility that an assistant foreman, who could do journeyman work on an hourly basis sub- ject to regulations applicable to journeymen (art. II, sec. 6, G.C. Exh. 3), might be working "in excess." Bates had initially indicated a concern about the wages of foremen who are paid straight salary but "may per- form production work to expedite the production sched- ule."'° He indicated on cross-examination, however, that being advised of the amount of overtime they worked, without regard to the amount of earnings, could be suffi- cient." Bates insisted that knowing the earnings paid to assistant foremen was essential, however. Said Bates: Assistant foremen are paid a percentage above jour- neymen wages. If he works overtime he's paid overtime on the basis of his pay, not journeyman scale, therefore, he would draw overtime on a- time and a half on his regular hourly wages. To know that he was being paid properly it would be necessary to know the amount. To know that the overtime was being distributed equitably we would need to know the number of hours. To compile as to whether the overtime pay and hours did corre- spond we would need to know them both. B Bates said he had asked for wage information on nonunion employees 2 years previously without success. I According to Bates, Doy Black and his son, James Black, were working on the weekend at the time. Bates said that James Black had told him that Doy Black was doing "personal work"for die Company at the time. He said no grievance had been filed on the issue, but that "the secrecy and the refusal of answers" aroused suspicion. to The contract (sec. 6, art. 11) also states that foremen "will not per- fiorm such work to reduce overtime or to maintain a smaller work force than otherwise would be required." Respondent and the Union, however, obviously do not agree on the interpretation of this language. Bates claimed that Havis "Tony" Harris had been performing "nearly full-time on [the] keyboard" and was thereby "depriving someone of a job." 1 Bates indicated that the Company was required under sec. 12, sec. V', of the contract to supply the number of hours worked at each loca- tion (chapel) and that the Company had not refused to do that because he did not recall ever asking for it. JAGGARS-CHILES-STOVALL, INC. 699 Bates originally testified that there were approximately 75 persons in the bargaining unit but on rebuttal revised the size of the unit to be from 54 to 60. He identified the position of several persons (most of whom were on the January earnings report in evidence, G.C. Exh. 3) as fol- lows: Paul Anthes, assistant foreman; Robert Gibbs, as- sistant foreman; Keith Heckethorn, assistant foreman; David Shindoll, assistant foreman; Frank Joy, assistant foreman; Robert Walker, lead (and head) machinist; Danny Bridwell, pressman; and Eugene Vessells, jour- neyman printer. Bates said there were two men on the earnings report who he recognized as being foremen and working on straight salaries. His testimony indicated that the foreman he had in mind were Henry "Derwood" Combs and Havis "Tony" Harris. He also indicated that Gibbs and Shindoll may also be foremen, but that he did not have the necessary information. 12 Kenneth Cowen, the president of Local 173, testified that he participated in the negotiation of the current col- lective-bargaining agreement signed by the Union and JCS. He said that eight employers were signatory to the agreement and that, therefore, his Union had authority over eight "chapels." Cowen said he had indicated to Stovall around August or September 1978, when the agreement was signed, that there were "possible contract violations" but that they were not pursued for "lack of information." He claimed that the Union needed the ad- ditional earnings information to "adequately police to contract" and "for other purposes," including "the amount of time worked by assistant foremen and fore- men and the loss of jobs that might result from this, and so forth." Initially, Cowen indicated that the other seven employers who had signed the contract had furnished the Union with sufficient earnings information, but he later modified his testimony. He said the Union got earn- ings information of all unit employees from four employ- ers (The Dallas Times Herald, the Wall Street Journal (all union members), Powell Printing (all union members) and Reilly Printing (all union members)), but he ultimate- ly conceded that he was not sure about receiving the earnings information on nonunion employees at the Dallas Morning News, the Typography Plus or at Ga- laxie Printing. Robert Stovall, president of JCS, appeared as a defense witness. He agreed that he had been asked by Chapel Chairman Bates on two occasions in early 1979 to fur- nish additional earnings information on JCS employees. Stovall said in each case he told Bates he would be will- ing to give the same wage information as he had in the past. Stovall denied that Bates had said anything about needing the information for either policing the contract or for handling of grievances. 12 The parties stipulated that Frank Joy, Paul Anthes, Robert Dendy, Keith Heckethorn, and Ed Cabeen were all assistant foremen. They also stipulated that Derwood Combs was a foreman, but the General Coun- sel's attorney denied having sufficient information to stipulate that Shin- doll, Harris, and Gibbs were also foremen or that Eugene Vessels was an assistant foreman. The January earnings report lists persons who are no longer in the bar- gaining unit (e.g., Calvin Wilson, maintenance superintendent). Bates indi- cated that he had simply asked Stovall for earnings reports on all those persons listed on the earnings report form. Stovall said he declined to furnish any additional earn- ings information on the basis that (nonunion) employees considered their earnings to be "privileged information." Stovall explained that 7 or 8 years ago the Company had begun supplying earnings reports to the Union "when everyone belonged" because it had said it "needed this information in order to compute the dues." Later on, he said, some of the employees who dropped out of the Union requested the Company not to report their earn- ings to the Union. He recalled that Robert Gibbs, Calvin Wilson, Doy Black, and Tony Harris were among those who made such a request. According to Stovall, there was an "understanding" among employees (expressed, he said, by L.C. Boyd, Robert Walker, Derwood Combs, and Walter Rosenboom) that wage information on non- union employees would not be reported to the Union. Stovall also undertook to explain the authority and re- sponsibility of certain JCS employees and officials. He identified Robert Gibbs (photo composition), David Shindoll (camera department), and Henry Combs (hot metal department) as salaried foremen and Tony Harris (photo typesetting and camera) as department head who supervised such foremen.13 He gave some detailed infor- mation on the authority of Harris, who fires, disciplines, directs, and evaluates work of employees, and Assistant Foreman Frank Joy (photo composition-night), Paul Anthes (directs "floor work"-night), Robert Dendy (leadman on keyboard), Keith Heckethorn (camera- night), Eugene Vessells (darkroom-days), and Ed Cabeen (linotype department-days). A number of Respondent's employees testified that they had requested the Company not to disclose their earnings to the Union, including the following: Robert Gibbs, Donald Cowdrey, Doy Black, Calvin Wilson, 4 Tony Harris, David Shindoll, Henry Combs, and L.C. Boyd. Nearly all of such witnesses had been members of the Union at one time but had dropped out.15 Harris tes- tified that it was generally known that the wage informa- tion of nonunion employees was not being disclosed to others. Chapel Chairman Bates resumed the stand on rebuttal and testified that he had recently asked 34 of Respond- ent's employees, including Witnesses Shindoll, Boyd, Combs, and Gibbs, whether they had previously request- " I have no doubt that Harris and Assistant Foreman Doy Black are supervisors under the Act. Black testified that he is salaried and in charge of customer service and overall plant production. I make no findings on the supervisors status of other assistant foreman-hourly paid employees (but working at different rates) who fill out time records when perform- ing production work, discipline employees for "poor work" and miscon- duct on the job, attend management meetings, direct work of others, and effectively recommended discharges-because it is not necessary to make such determination in the case. The Union is entitled to earnings informa- tion on all employees, including supervisors, who perform unit work Stovall said no two assistant foremen have the same authority as they work "in different areas of our operation" Joy does "very little" rank and file work, but all foremen and assistant foremen do some of it, he said. he asserted that the "supervisory responsibilities" of all assistant foremen were much the same except that Dendy, who has a "special training function," does not have "quite as much." 14 Plant Engineer Wilson has not been a recent member of the bargain- ing unit, but his name was on the list of those whose earnings was re- quested by the Union. 11 Cowdrey did not indicate that he had ever been a member of the Union JAGGARS-CHLES-STOVALL, INC. 699 700 DECISONS OF NATIONAL LABOR RELATIONS BOARD ed the Company not to divulge their earnings to anyone. He said he received a negative response from all except Gibbs who, he said, initially had stated that he did not recall asking the Company not to reveal such informa- tion. It was stipulated that all 34 employees polled by Bates were in the bargaining unit except for Shindoll, Gibbs, Heckthorn, and Mapes. Discussion and Conclusions The Board recently stated in Westinghouse Electric Corp., 239 NLRB 106 (1978), that: It is well established that a labor organization, obligated to represent employees in a bargaining unit with respect to their terms and conditions of employment, is entitled to such information from the employer as may be relevant and reasonably necessary to the proper execution of that obliga- tion.6 The right to such information exists not only for the purpose of negotiating a contract, but also for the purpose of administering a collective-bar- gaining agreement. The employer's obligation, in either instance, is predicated upon the need of the union for such information in order to provide intel- ligent representation of the employees. 7 The test of the union's need for such information is simply a showing of "probability that the desired information was relevant, and that it would be of use to the union in carrying out its statutory duties and re- sponsibities."8 The union need not demonstrate that the information sought is certainly relevant or clear- ly dispositive of the basic negotiating or arbitration issues between the parties. The fact that the infor- mation is of probable or potential relevance is suffi- cient to give rise to an obligation on the part of an employer to provide it.9 The appropriate standard in determining the potential relevance of informa- tion sought in aid of the bargaining agent's responsi- bility is a liberal discovery-type standard.1 0 6 Vertol Division Boeing Company, 182 NLRB 421 (1970); NL.R.B. v, Whirin Machine Works, 217 F.2d 593 (C.A. 4, 1954), cert. denied 349 U.S. 905 (1955). F W Woolworrh Co., 109 NLRB 196, 197 (1954), enfd 352 U.S. 938 (1956). N.L.R.B. v. Acme Industrial Co., 385 U.S. 432, 437 (1967) The Brooklyn Union Gas Company, 220 NLRB 189 (1975). '0 Acme Industrial Co.. supra. In Ohio Power Company, 216 NLRB 987, 991 (1975), it was stated that: Where the information sought covers the terms and conditions of employment within the bargaining unit, thus involving the core of the employer-em- ployee relationship, the standard of relevance is very broad, and no specific showing is normally re- quired; but where the request is for information with respect to matters occurring outside the unit, the standard is somewhat narrower (as where the precipitating issue or conduct is the subcontracting of work performable by employees within the ap- propriate unit) and relevance is required to be some- what more precise. See Curtiss-Wright Corporation v. N.L.R.B., 347 F.2d 61 (C.A. 3, 1965). In Westinghouse Electric, the Board ruled that an employ- er must furnish statistical data on minority and female employees in the unit, along with a list of charges filed against the company. The Board did not require it to fur- nish such information with respect to nonunit employees, however. The Board pointed out that the information with respect to unit employees was "presumptively rele- vant," but that the union "must ordinarily demonstrate more precisely the relevance of the data requested" on nonunit employees. Respondent defends its refusal to turn over the earn- ings information on all of the employees set forth on the list submitted to it by the Union on the basis that the Union's demand was "prohibitively broad." Respondent notes that the list includes "individuals who are admit- tedly supervisors and . . . individuals who are admitted- ly not in the bargaining unit" and contends that the Union has not demonstrated relevance for such informa- tion. Thus, Respondent argues, no duty to supply the re- quested information ever arose. Respondent also con- tends that the instant case is different from other cases involving a refusal to furnish information in that the Company's actions were based on "employees' ideas on privacy and confidentiality." Having considered the whole record, I am constrained to find Respondent's contentions to be without merit and hold that Respondent violated Section 8(a)(5) and (1) of the Act as alleged. First of all, I do not understand the Union to be asking for wage information on any employee who does not perform unit work. The name of Calvin Wilson (and pos- sibly others) was on the list, as pointed out by Chapel Chairman Bates, only by "oversight." Even though the Union may not have advised Re- spondent of the reasons for requesting the earnings infor- mation until the hearing, Respondent was called upon to furnish it because of its presumed relevance. In its recent Amphlett Printing Company decision (237 NLRB 955 (1978)), the Board found that the employer was required to furnish wage information on nonunit personnel even though it did not explain why it was needed until the hearing. The Board rejected the notion that the Union had "failed to adequately inform the Respondent as to the basis of its request for information," stating: We conclude that the Administrative Law Judge has, by his emphasis of minor inconsistencies in the Union's position in this case, failed adequately to consider the applicable test for determining whether Respondent was obligated to provide the requested information. Thus, the appropriate inquiry is simply whether the information was "potentially relevant" to the Union in connection with bargainable issues then being pursued. That the information appears unnecessary to an employer is obviously an inad- equate ground for refusal, particularly when (as here) the employer possesses clearly useful com- parative wage data and the union does not. Here, the Union requested information concerning the JAGGARS-CHILES-STOVALL, INC. 701 compensation paid to nonunit correspondents who furnish editorial material and perform editorial func- tions for the same employer-work virtually identi- cal to that performed by the editorial employees within the represented unit. In our view, informa- tion about such compensation is indeed potentially relevant. See our discussion of Northwest Publiction.s, Inc., 211 NLRB 464, 476 (1974), in Times-Herald Inc., 237 NLRB 922 (1978) Com- pare Temple-Ealex, Incorporated. e al., 228 NLRB 203, 204 (1977), where the relevancy requirement was discussed and applied in a context of unit erosiorn The Union is entitled to earnings information on assistant foremen and even foremen as they may, under the con- tract, perform unit work, which of course, would result in the loss of unit work for other employees. Such infor- mation is essential to the Union in policing of the collec- tive-bargaining agreement. See Globe Stores. Inc., 227 NLRB 1251 (1977); Northwest Publications, Inc., 211 NLRB 464 (1974); and Curtiss-Wright Corp. v. N.L.R.B., supra. Respondent's contention that the earnings information should be kept confidential on the basis of employees' ideas on privacy and confidentiality must be rejected. It is not a new or valid defense. See for example, Utica Ob- server-Dispatch, Inc. v. N.L.R.B., 229 F.2d 575 (2d Cir. 1956), The Kroger Co., 163 NLRB 441 (1967); Curtiss- Wright Corp. v. N.L.R.B., supra; and Westinghouse Elec- tric Corp., supra. The Supreme Court's recent decision in Detroit Edison Co. v. N.L.R.B., 440 U.S. 301 (1979), relied on by Respondent, does not, in my view, compel a different result. True, the Supreme Court in that case stated that a Union's bare assertion of a need for data does not oblige the employer "to supply all information." But the information sought in that case-aptitude test questions, answer sheets, and scores-was far more sensi- tive than the wage information sought here, and Detroit Edison had made an adequate alternative means of grant- ing the union's request for the information sought. See Air Express International Corporation, 245 NLRB No. 69 (1979). CONCLUSIONS OF LAW I. Respondent is an employer engaged in commerce within the meaning of Section 2(6) and (7) of the Act. 2. The Dallas Typographical Union No. 173 is a labor organization within the meaning of Section 2(5) of the Act. 3. By refusing to supply earnings information on all employees performing production work at Respondent's Dallas, Texas, facility involving the markup of copy con- tinuing on through the printing press, excluding the making of mats, stereotypes, plastic plates, photoengrav- ing, and finishing operations beyond the printing press run, Respondent violated Section 8(a)(5) and (1) of the Act. THE REMEDY Having found Respondent engaged in unfair labor practices, I shall recommend that it cease and desist therefrom and take affirmative action designed to effec- tuate the policies of the Act. I shall recommend that Re- spondent supply the Union with earnings information on all employees doing unit work. I shall also recommend that Respondent cease and desist from failing and refus- ing to supply the Union with other information relevent and necessary to the performance of the obligation of collective-bargaining representative. The posting of an appropriate notice will also be recommended. Upon the foregoing findings of fact and conclusions of law, and pursuant to Section 10(c) of the Act, I hereby issue the following recommended: ORDER' 6 The Respondent, Jaggars-Chiles-Stovall, Inc., Dallas, Texas, its officers, agents, successors, and assigns, shall: 1. Cease and desist from: (a) Failing or refusing to supply the Dallas Typo- graphical Union No. 173 with information relevant and necessary to the performance by such Union of its obli- gations as bargaining representative of employees of Re- spondent. (b) In any like or related manner interfering with, re- straining, or coercing employees in the exercise of their bargaining rights through the above-named Union. 2. Take the following affirmative action found neces- sary to effectuate the policies of the Act: (a) Upon request furnish the above-named Union the following information: (I) The names and rates of pay of each employee, in- cluding those classified as foremen and assistant foremen, who performs production work at Respondent's Dallas, Texas, facility involving the markup of copy continuing on through the printing press, excluding the making of mats, stereotypes, plastic plates, photoengraving, and fin- ishing operations beyond the printing press run. (2) All other information relevant and reasonably nec- essary to the performance of the Union's obligation as a bargaining representative. (b) Post at its Dallas, Texas, facility copies of the at- tached notice marked "Appendix." 7 Copies of said notice, on forms provided by the Regional Director for Region 16, after being duly signed by Respondent's rep- resentative, shall be posted by it immediately upon re- ceipt thereof, and be maintained by Respondent for 60 consecutive days thereafter, in conspicuous places, in- cluding all places where notices to employees are cus- '^ In the event no exceptions are filed as provided by Sec. 102.46 of the Rules and Regulations of the National Labor Relations Board, the findings, conclusions, and recommended Order herein shall, as provided in Sec. 10248 of the Rules and Regulations, be adopted by the Board and become its findings, conclusions, and Order, and all objections thereto shall be deemed waived for all purposes " In the event that this Order is enforced by a Judgment of a United States Court of Appeals, the words in the notice reading "Posted by Order of the National Labor Relations Board" shall read "Posted Pursu- ant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board." JAGGARS-CHILES-STOVALL. INC~~~~~~~~~~~~~~~~~~~. 70 702 DECISONS OF NATIONAL LABOR RELATIONS BOARD tomarily posted. Reasonable steps shall be taken by Re- spondent to insure that said notices are not altered, de- faced, or covered by any other material. (c) Notify the Regional Director for Region 16, in writing, within 20 days from the date of this Order, what steps the Respondent has taken to comply herewith.