Pittsburgh Press Co.

DECISIONS OF NATIONAL LABOR RELATIONS BOARD Pittsburgh Press Company and Jesse Walker, Sr. Case 6-CA-9953 January 24, 1978 DECISION AND ORDER BY MEMBERS PENELLO, MURPHY, AND TRUESDALE On September 14, 1977, Administrative Law Judge Claude R. Wolfe issued the attached Decision in this proceeding. Thereafter, Respondent filed exceptions and a supporting brief, and the General Counsel filed limited cross-exceptions to the Administrative Law Judge's Decision. Pursuant to the provisions of Section 3(b) of the National Labor Relations Act, as amended, the National Labor Relations Board has delegated its authority in this proceeding to a three-member panel. The Board has considered the record and the attached Decision in light of the exceptions and brief and has decided to affirm the rulings, findings,' and conclusions 2 of the Administrative Law Judge, to modify his remedy,3 and to adopt his recommended Order, as modified herein. Respondent contends at length that the Adminis- trative Law Judge's finding that it discriminatorily suspended employee Walker in violation of Section 8(a)(3) and (1) is legally deficient for lack of evidence of independent union animus. This contention is clearly without merit. Respondent concedes that Walker was suspended for his statement, "As long as I'm Acting Shop Steward and when I become Shop Steward I will not let you work the men short." Respondent would have it that this statement was insubordinate. Contrary to Respondent, we agree with the Administrative Law Judge that Walker's statement was clearly an expression of Walker's intention to be an active union representative of the employees, and thus this statement was protected by the Act. Penalizing an employee for union-related conduct protected by Section 7 of the Act such as that considered here is inherently destructive of important employee rights and thus requires no proof of antiunion motivation. N.L.R.B. v. Great Dane Trailers, Inc., 388 U.S. 26 (1967). ORDER Pursuant to Section 10(c) of the National Labor Relations Act, as amended, the National Labor Relations Board adopts as its Order the recommend- ed Order of the Administrative Law Judge, as modified below, and hereby orders that the Respon- dent, Pittsburgh Press Company, Pittsburgh, Penn- sylvania, its officers, agents, successors, and assigns, 234 NLRB No. 83 shall take the action set forth in the said recommend- ed Order, as so modified: 1. Substitute the following for paragraphs 1(b) through (d): "(b) Assembling employees, in the absence of any union representative, for the purpose of encouraging them to select a steward to represent them in matters related to collective bargaining. "(c) Threatening employees with retaliation be- cause they have engaged in union and protected concerted activities for the purpose of collective bargaining or other mutual aid or protection. "(d) In any other manner interfering with, restrain- ing, or coercing employees in the exercise of the rights guaranteed them by Section 7 of the Act." 2. Substitute the following for paragraph 2(a): "(a) Make whole Jesse Walker, Sr., for any loss of earnings he may have suffered as a result of the discrimination against him. Backpay is to be comput- ed in the manner prescribed in the remedy as modified in the Board's Decision." 3. Add the following as paragraph 2(b) and reletter the subsequent paragraphs: "(b) Remove all references to the suspension of Jesse Walker, Sr., from his personnel file and other records." 4. Substitute the attached notice for that of the Administrative Law Judge. I Respondent has excepted to certain credibility findings made by the Administrative Law Judge. It is the Board's established policy not to overrule an Administrative Law Judge's resolutions with respect to credibili- ty unless the clear preponderance of all of the relevant evidence convinces us that the resolutions are incorrect. Standard Dry Wall Products. Inc., 91 NLRB 544 (1950), enfd. 188 F.2d 362 (C.A. 3, 1951). We have carefully examined the record and find no basis for reversing his findings. 2 Respondent also contends that the Administrative Law Judge erred in finding that it violated Sec. 8(aXI) of the Act when Night Foreman Harry Carter assembled the janitorial employees, in the absence of any union representative, for the purpose of encouraging them to select a steward. We do not agree. The complaint alleged that Respondent violated Sec. 8(aXI) because Carter threatened the employees with discharge for engaging in protected and concerted activities on behalf of the Union. The facts developed at the hearing showed that Supervisor Carter told the employees, at an employee meeting called by Carter on February 23, that he thought they should have a night steward and implied that the employees should not select Walker as steward because Respondent was "out to get him." Inasmuch as all the facts surrounding this event were set forth on the record, and the witnesses were examined and cross-examined without objection from Respondent, we find the issue to have been fully litigated, and as the finding clearly relates to the finding that Respondent discriminated against Walker because of his conduct as acting steward, we adopt the Administra- tive Law Judge's finding. Monroe Feed Store, 112 NLRB 1336 (1955). 3 The Administrative Law Judge inadvertently specified interest to be paid at 7 percent; however, interest will be calculated according to the "adjusted prime rate" used by the U.S. Internal Revenue Service for interest on tax payments. Florida Steel Corporation, 231 NLRB 651 (1977). See Isis Plumbing & Heating Co., 138 NLRB 716 (1962), for rationale on interest payments. We shall also modify the recommended Order and notice accordingly and correct certain inadvertent errors contained therein 408 PITTSBURGH PRESS COMPANY FINDINGS AND CONCLUSIONS NOTICE To EMPLOYEES POSTED BY ORDER OF THE NATIONAL LABOR RELATIONS BOARD An Agency of the United States Government WE WILL NOT suspend our employees because they have engaged in union or other protected activities. WE WILL NOT assemble our employees, in the absence of any union representative, for the purpose of encouraging them to select a steward. WE WILL NOT threaten our employees with retaliation because they have engaged in union and protected concerted activities for the purpose of collective bargaining or other mutual aid or protection. WE WILL NOT in any other manner interfere with, restrain, or coerce our employees in the exercise of the rights guaranteed them by Section 7 of the Act. WE WILL make whole Jesse Walker, Sr., for any loss of earnings he may have suffered as a result of our discrimination against him, together with interest. WE WILL remove all references to the suspen- sion of Jesse Walker, Sr., from his personnel file and other records. PITTSBURGH PRESS COMPANY DECISION STATEMENT OF THE CASE CLAUDE R. WOLFE, Administrative Law Judge: This proceeding was heard before me at Pittsburgh, Pennsylva- nia, on June 1, 1977, pursuant to a complaint issued on April 22, 1977,1 based on charges filed on February 14 and amended on April 21. A motion to strike one allegation of the complaint was made by General Counsel at the hearing and was granted. The remaining allegations of the com- plaint allege that Pittsburgh Press Company, herein called the Respondent, violated Section 8(a)(I) and (3) of the National Labor Relations Act, as amended, by suspending Jesse Walker, Sr., for 3 days, and by threatening employees with discharge for engaging in statutorily protected activi- ties. Respondent duly denied the commission of unfair labor practices. Upon the entire record,2 including my observation of the demeanor of witnesses as they testified, and after due consideration of the parties' posttrial briefs, I make the following: I. JURISDICTION The Respondent is a Pennsylvania corporation engaged in the publication of a daily newspaper known as The Pittsburgh Press at its Pittsburgh, Pennsylvania, facility. The Respondent, during the 12 months immediately preceding the issuance of the complaint, a representative period, received gross revenues in excess of S500,000 in the operation of its business, has been a member of national news services, advertised nationally sold products, and has published nationally syndicated features. The Respondent is, and has been at all times material to this case, an employer engaged in commerce within the meaning of Section 2(6) and (7) of the Act. n. THE LABOR ORGANIZATION Service Employees International Union, Pittsburgh Lo- cal No. 29, AFL-CIO, herein called the Union, is a labor organization within the meaning of Section 2(5) of the Act. m. THE ALLEGED UNFAIR LABOR PRACTICES A. The Facts At all times material to this case, the Respondent and the Union have been parties to a collective-bargaining agree- ment covering the employees involved herein, including Jesse Walker, Sr. Walker, the Charging Party, is a daylight janitor at the Pittsburgh facility, and has been an active union member for 12 years. At the time of the controversy, the Union's steward was employee Edward Griffin. In the latter part of the week prior to his vacation, Griffin posted a notice that, in his absence, he was appointing Walker as acting steward. The week of Griffin's vacation commenced on February 7. On February 8, Walker's foreman, Marion Johnson, called the plant and left word for Walker to call him at home when he came in. Walker did so. There is a dispute between Walker and Johnson as to what was said during the conversation. Walker testifies that all Johnson told him was that he would not be coming in because he was ill, and asked Walker to take his place as foreman in his absence. Johnson denies that he told Walker he would be the foreman or acting foreman in Johnson's absence. He states that he told Walker that he was sick and would not be in, that all the men that were needed were working and they knew their assignments, but he wanted to be sure Walker knew that because he did not need any men and did not want any called in. According to Walker's uncontroverted testimony, after he talked to Johnson he called employee Mixon, who was not scheduled to work that day, in to take Johnson's place as a janitor because Building Superintendent Richard Lauth had earlier said that he did not want working foremen. Walker did not change into his normal work clothes but wore a tie, leisure trousers, a sweater, and I All dates herein occurred in 1977, unless specifically noted otherwise. APPENDIX 409 z Errors in the transcript have been noted and corrected. DECISIONS OF NATIONAL LABOR RELATIONS BOARD highly polished shoes throughout the day, and spent his time checking to see that the work was going well and the employees were contented. On February 9, Walker again returned a call from Johnson at the beginning of the shift. Again, their respec- tive accounts of what was said differ. Walker says that Johnson said his back was hurting, asked Walker to replace him as foreman for that day, and told him that men had been standing around not doing their work, specifically naming an employee who had been seen sleeping on the job and one who was just standing around on an occasion when Lauth passed by. According to Walker, he told Johnson he would take care of it and the conversation ended. Johnson testified that, when he talked to Walker on February 9, he asked how things had gone and Walker replied there had been no problems. Whereupon, Johnson told him there was "only one thing" that he had heard from Lauth3 via telephone on February 8, and that was that Lauth had seen one of the janitors in the truckdrivers' area. Johnson avers that he told Walker this was no big thing because that was where janitors sit when they have nothing to do. On cross-examination, Johnson amplified this testimony and stated that, in addition to this janitor out of his work area when Lauth saw him, another employee was doing nothing but sitting down in the service room. This latter employee is the same one that Walker says was reported to him by Johnson as sleeping on the job. Johnson terms the conversation about the two employees as just "general talk with Mr. Walker," and denies telling Walker that he was to act as foreman in Johnson's absence that day. After this conversation with Johnson on February 9, Walker called in Herman Frazier, who was not scheduled to work, to perform Walker's work. Throughout the day, he wore the same attire that he had the previous day, and performed none of his normal janitorial work. At or about 7:15 a.m., he was informed by another janitor that there was a desk to be moved. Walker went to Building Superintendent Lauth and told him that he had employee Mixon to wash the desk and assist Lauth and his helper in moving it. There was no further conversation between him and Lauth at the time. It appears from the record that it had been the practice in the past to post a notice informing employees when anyone was going to serve as acting foreman in the absence of the regular foreman. It also appears that the Respondent has s Lauth did not testify. I Although there was considerable evidence adduced about the route followed to the office, the layout of the office, where they each were positioned in the office, and the possibility of being overheard by someone, I find it of no probative value and will not further allude to it. I According to Johnson, he overheard Walker tell another janitor, Gilmore, on February 7, that if he was assigned to some place other than his regular assignment on the fourth floor he was to refuse. Johnson asked what was the matter and Walker repeated that he was telling the employee that if he was working on the fourth floor, Walker wanted him to work there, and no place else. Johnson told Walker that he was not the foreman and could not tell men where to work. Walker replied that it was his place to protect the men (an apparent reference to his duty as an acting steward), and if Johnson did not have enough men in he should hire some and not move men all over the place. Johnson repeated, in substance, that it was up to the foreman to control the work force. Walker denies talking to Johnson at all on February 7. Gilmore did not testify. "floaters" regularly employed, at least two of whom were on the job at 7 a.m. on February 8, whose duty it is to fill in whenever they are needed, such as in the case of an absent employee. At or about noon on February 9, according to Johnson, Lauth called him and reported that Walker had told Lauth that he had called Herman Frazier in to work on his off day after talking to Johnson about it. Johnson assured Lauth that he had not talked to Walker about anything like that. After ascertaining that Johnson would be in to work on February 10, Lauth said, "[W]ell, when you come in tomorrow, you have a meeting with him and make sure you get him straight on the rules, that he is not to call people in on his own." Walker acknowledges that he consulted with no one before calling Frazier in. Johnson returned to work on February 10. Walker was performing his regular duties as a janitor, at or about 7:15 a.m., when Johnson called him into the pressroom chair- man's office where the two of them had a private discussion.4 They agree that Johnson asked Walker who authorized him to call men in, and that Walker conceded that no one had. Then, according to Walker, Johnson remarked that Lauth was going to jump on Johnson about that, and Walker said, "Mr. Johnson, let's get one thing straight right now. As long as I'm Acting Shop Steward and when I become Shop Steward I will not let you work the men short." Then, testifies Walker, Johnson said, "[Y]ou are suspended as of now." Walker concedes he then told Johnson that he must be out of his mind. Johnson's testimony agrees with that of Walker, with certain varia- tions. Johnson's version is that, after Walker admitted no one had authorized him to call men in, the following conversation ensued: "I said to him, I told you on Monday5 that you are not the foreman and you have no authority to hire people in, or to direct work forces and what not. I said now if you can make me, if you can assure me that you understand this, and won't repeat it, I can let the matter drop.... he says to me, now let me get you straight . . . when I'm acting shop steward, and when I become shop steward, he says I don't ever intend to let you work this crew short. By then we had been talking softly then, and then his voice got loud and he began to shake his finger at me and he said that he wanted to get me straight. In the future, he intended to make sure that I didn't work the people short. I said to him, now, if this is going to be your attitude, I'll tell you what, you take three days off, you come back on Tuesday, and we'll discuss it at that Although I am somewhat disabled by the absence of any testimony of Gilmore on the matter, and the demeanor of Walker and Johnson when testifying on this subject gave me no clues as to which was the more credible on this conversation, I am persuaded that it is unlikely that Walker did not talk to his foreman Johnson at all on February 7, and the conduct of Walker described by Johnson is not inconsistent with both Walker's express objection, on February 10, that Johnson not try to overwork men, and Walker's expressed intent, on February 10, to prevent such occurrences. While I might not credit Johnson on other matters, I cannot conclude from either the record or his demeanor that he is incredible on all counts as General Counsel contends, and I credit Johnson's testimony with regard to the February 7 events. Although I credit Johnson in this instance, I do not agree with Respondent's contention that Walker is completely incredible. I am of the opinion that the parties' arguments on credibility are far too broad and give me little assistance in resolving testimonial conflicts. 410 PITTSBURGH PRESS COMPANY time..... His response to me was I'm not going anywhere, you must be out of your mind. I was acting shop steward." Thus, both are in agreement, except for immaterial and miniscule differences in wording, as to what Walker said and the fact that his suspension immediately followed. Johnson acknowledges that he would not have suspend- ed Walker (whom he concedes is a very satisfactory employee) because he called in Mixon and Frazier to work, and that he suspended Walker because of Walker's statements with regard to what Walker intended to do. Johnson states that he considered that Walker's statements, combined with the tone and manner in which they were delivered, constituted insubordination. That Johnson sus- pended Walker solely for his statements at the February 10 meeting and not because he had called men in is borne out by the testimony of Union Secretary-Treasurer Ralph Terry, called as a witness by the Respondent, who credibly testified that during the course of a grievance meeting on February 11, when he tried to settle the dispute informally between Johnson and Walker, Johnson said, "I don't give a damned [sic] about him calling the men in, it's the fact that it was the insubordination," and that he does not recall Johnson indicating that there would have been any form of discipline had Walker not made the statements Johnson deemed insubordinate. Indeed, the record is clear that Johnson had no intention of levying any discipline, even a reprimand, on Walker when the conversation of February 10 began. By Johnson's own testimony, Lauth merely told him to make sure Walker understood the rules relating to calling people in. This instruction by Lauth carries no hint of reprimand or other adverse action, and I do not believe that Johnson was going beyond these instructions and doing anything other than instructing Walker on the rules and making sure Walker understood them. That there was no intention to reprimand at the outset is evident from the statement of Johnson to Terry, quoted above, that he did not care about Walker calling the men in. I credit employee Frank Taylor's uncontradicted testi- mony that subsequent to Walker's 3-day suspension, on February 23, Foreman Harry Carter called a meeting of the night janitors wherein he told them that he thought the employees should have a night steward. There was none at the time. Carter stated that he had talked to Ralph Terry, who was not at this meeting, and it had been decided to ask the men if a lady shop steward would be acceptable. Carter mentioned a Mrs. Crawford, and the night janitors agreed she would be acceptable. Carter then explained the convenience of having a night steward right there to settle any differences that might arise, and added that "he didn't want to come up under the aggravation with Walker, because the company was out to get him, and he didn't want to be into that aggravation." Walker had come with Steward Griffin in 1976 to assist the night employees in getting contract proposals together, and the record shows that Walker had been a candidate for steward in the past, had filed grievances, and had taken an active part in preparing and submitting contract proposals to the Union in past negotiations. e The Respondent's contention that Walker was indicating that he would continue to hire men in is rejected. Rather, Walker's remarks were clearly directed at what he would prevent Johnson from doing. I see no basis in the B. Conclusions I conclude and find that Johnson did tell Jesse Walker, Sr., to act in his place as foreman on February 8 and 9. During these 2 days Walker did no janitor work, dressed in a manner clearly indicating he was not performing his regular work, was told by Johnson to watch for certain employees' derelictions of duty, spent the 2 days observing the janitors to see that the work was done, and told Lauth that he had assigned Mixon to wash a desk and assist in moving it. There is no evidence that Lauth objected to either his attire or his actions in assigning work. Walker did not impress me as one who would deliberately, without any authorization from Johnson, assume the role of acting foreman and dress and function as one in the presence of the building superintendent. That he called in Mixon and Frazier was, in my opinion, consistent with the statement made to him by Johnson on February 7 that it was the foreman's job to determine how many men should work, where they were to work, and what they were to do. All that Johnson was really telling him in this regard on February 7 was that stewards could not do these things, but foremen could. Walker impressed me as more straightfor- ward and direct in his testimony regarding his telephone conversations with Johnson, and Johnson's testimonial demeanor on the topic was not as convincing as that of Walker. I therefore conclude and find that Johnson did tell Walker to act as foreman in his place and did not give Walker all the cautions about hiring in men on February 8 that Johnson claims he did. That Walker may have been mistaken in his comprehension of the scope of his authority when filling in for Johnson, and may have exceeded it by calling in Mixon and Frazier, does not militate against a finding that Johnson told him to act as foreman but, rather, reinforces it. The only question of substance to be resolved with regard to the suspension is whether or not Walker's remarks which precipitated his suspension were protected activity under the National Labor Relations Act. I am persuaded that they were. That Johnson considered them to be insubordinate does not make them so. Walker was not refusing to do anything, but was announcing his intention to be an active union steward making every effort he could to prevent Johnson from working a crew without what Walker considered a sufficient number of employ- ees, 6 which clearly implies the probability grievances would be filed. This, in my view, is protected union activity. Walker was an acting steward who had a right to protest what he conceived to be improper allocation of personnel and/or workload. Even if he were wrong in his interpreta- tion of what the collective-bargaining agreement permits or requires, Walker's activity was protected, e.g., Robert Martin Construction Co., Inc., 214 NLRB 429 (1974). The language used by Walker was temperate, contained no threat or offensive language, and cannot reasonably and objectively be viewed as insubordinate. Furthermore, the Board has long given union agents engaged in grievance credible evidence for any conclusion that Walker was, in his capacity as acting steward or steward, planning to hire in or call in anybody. 411 DECISIONS OF NATIONAL LABOR RELATIONS BOARD processing wide latitude in the selection of language they use in the course of such activity,7 and there is no requirement that a steward be servile, or even polite, in his presentation of complaints about his employer's conduct with regard to wages, hours, or other working conditions. I can comprehend no reason why Walker may not be just as aggressive in expressing his intention to function as a vigilant steward as he is permitted to be when actually engaged in that function as the Union's agent for purposes of enforcing the contract.8 Accordingly, I find that the suspension of Jesse Walker, Sr., for 3 days was motivated by his protected activity as a union steward on February 10, 1977, and is violative of Section 8(aX3) and (1) of the Act.9 Similarly, I find that the statements by Respondent's foreman, Harry Carter, an admitted statutory supervisor, on February 23 after Walker had been suspended, could not help but convey to his listeners that the Respondent did not want a steward as aggressive as Walker and was going to retaliate against Walker because of his activities as a steward. I find the calling together of employees, in the absence of any union representative, by a supervisor for the purpose of encouraging them to select a steward o to be interference with the employees' Section 7 rights in viola- tion of Section 8(a)(1) of the Act. I further find that Carter's statements with reference to the Company's intention to "get" Walker, who was known to the employ- ees as a very active union adherent, were calculated to impress upon them the Respondent's aversion to union activists and thereby restrained and coerced them in violation of Section 8(a)(1) of the Act. The implied threat to do unto others as was done unto Walker if they became activists is readily apparent. My conclusion in this latter regard is supported by the Respondent's acknowledgment that Walker was a very good worker. This being the case it could not be his work performance that aggravated the Respondent, and the only other real "aggravation" shown by the record is Walker's union activity for which he was suspended. CONCLUSIONS OF LAW 1. Respondent, Pittsburgh Press Company is an em- ployer engaged in commerce within the meaning of Section 2(2), (6), and (7) of the Act. 2. Service Employees International Union, Pittsburgh Local No. 29, AFL-CIO, is a labor organization within the meaning of Section 2(5) of the Act. 3. By suspending Jesse Walker, Sr., because he engaged in protected activity and in union activity, the Respondent herein violated Section 8(a)(3) and (1) of the Act. 7 Thor Power Toot Company, 148 NLRB 1379(1964). S If it were otherwise, any steward, acting steward, or employee would be in peril of disciplinary action each and every time he or she expressed an intention to file a grievance, to enforce a collective-bargaining agreement, or to engage in other protected activity without first politely securing permission to so do from an agent of his or her employer. Such a result would render the guarantees of Sec. 7 of the Act meaningless. I See Clara Barton Terrace Convalescent Center, 225 NLRB 1028 (1976), an analogous case. to Union Agent Terry characterizes such a procedure as illegal. There- fore, I cannot find that Carter's actions were with union permission. 4. By the acts of Harry Carter, its supervisor and agent, in restraining and coercing employees in the exercise of their Section 7 rights, the Respondent violated Section 8(a)( ) of the Act. 5. The unfair labor practices cited above have a close, intimate, and substantial effect on the free flow of com- merce within the meaning of Section 2(6) and (7) of the Act. THi ReMeDY I have found that the Respondent has committed certain unfair labor practices, and I will recommend that it be ordered to cease and desist therefrom and to take other appropriate actions to remedy its unfair labor practices. I therefore recommend that the Respondent be required to make Jesse Walker, Sr., whole for wages lost by reason of the 3-day suspension levied upon him, with interest computed thereon at 7 percent per annum in accordance with Florida Steel Corporation, 231 NLRB 651 (1977). 1 further recommend an order that all references to said suspension be totally expunged from all of Respondent's personnel and other records wherein the suspension is now noted, and that the Respondent be required to post the usual notice advising its employees of their rights and of "The Remedy" in this case. Upon the foregoing findings of fact, conclusions of law, and the entire record herein considered as a whole, and pursuant to Section 10(c) of the Act, I make the following recommended: ORDER " The Respondent, Pittsburgh Press Company, Pittsburgh, Pennsylvania, its officers, agents, successors, and assigns, shall: 1. Cease and desist from: (a) Suspending employees because they engaged in protected activities. (b) Discouraging union or other protected activities by suspending employees. (c) Restraining and coercing employees to refrain from fully exercising their Section 7 rights. (d) In any like or related manner interfering with, restraining, or coercing employees in the exercise of rights guaranteed to them by Section 7 of the Act. 2. Take the following affirmative action designed to effectuate the policies of the Act: (a) Make Jesse Walker, Sr., whole for any loss of pay he suffered by reason of his unlawful 3-day suspension, together with interest thereon at 7 percent per annum. (b) Post at its Pittsburgh, Pennsylvania, facility copies of the attached notice marked "Appendix." 12 Copies of said " 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. 102.48 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. 12 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 412 PITTSBURGH PRESS COMPANY notice, on forms provided by the Regional Director for Region 6, after being duly signed by the Company's authorized representative, shall be posted by it immediately upon receipt thereof, and be maintained by it for 60 consecutive days thereafter, in conspicuous places, includ- ing all places where notices to employees are customarily posted. Reasonable steps shall be taken by Respondent to insure that said notices are not altered, defaced, or covered by any other material. of the National Labor Relations Board" shall read "Posted Pursuant to a Judgment of the United States Court of Appeals Enforcing an Order of the National Labor Relations Board." (c) Preserve and, upon request, make available to the Board or its agents, for examination and copying, all payroll and other records necessary to compute the backpay due under this Order. (d) Notify the Regional Director for Region 6, in writing, within 20 days from the date of this Order, what steps have been taken to comply herewith. 413