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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Enforceable past practice because here, unlike in Courier-Journal (2004) 342 NRLB No. 113 where the contract language authorized the employer to make changes in health care premiums during the contract and the employer had a past practice for more than ten years of making such changes during the successive contracts and hiatus periods between contracts, the County had a 27-year past practice of awarding retiree health subsidies.