EMPLOYER INTERFERENCE, RESTRAINT, COERCION; INTERFERENCE WITH DECERTIFICATION OR RIVAL UNION PETITION – Employer Favoritism/Absence of Strict Neutrality

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Employer did not violate its duty of strict neutrality during a decertification election campaign when it failed to prevent non-employee organizers from the union seeking to decertify the incumbent from accessing non-public areas of the employer’s hospital on every occasion. The employer responded promptly to each of the incumbent union’s complaints about unauthorized access by the rival union. Nor did the employer’s requirement that non-employee organizers of the incumbent union, but not the rival union, sign in and wear identification badges to access non-public areas violate the duty of strict neutrality because the requirement affirmed the incumbent’s status as the exclusive representative and did not tend to influence employees to support the rival union.