EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; DEFENSES – Management-Rights Clause; Management Prerogative

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Staffing pattern determinations are managerial prerogatives, not subject to negotiations. Such determinations, however, do not include changes of the shifts of individual employees once the initial assignment has been made by the employer. The right to set staffing patterns is not a clear and unmistakable waiver of the right to negotiate shift changes; p. 10, proposed dec. The right to "assign" employees does not carry with it the inherent right to change a shift assignment after it has been made; p. 11, proposed dec.