EMPLOYER REFUSAL TO BARGAIN IN GOOD FAITH; UNILATERAL CHANGE (FOR NEGOT OF SPECIFIC SUBJECTS, SEE SEC 1000, SCOPE OF REPRESENTATION) – Change in Past Practice

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Union failed to establish that the employer breached or altered the parties’ written agreement or established past practice by changing the parties’ grievance procedure (the first element of a unilateral change case) when it referenced the grievance procedure but did not establish the terms or past practices of the procedure. A single isolated breach of a contract’s grievance procedure does not state a prima facie case for a unilateral change because it fails to establish that the violation has a generalized effect or continuing impact on unit members.