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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Parties had undisputed past practice that union representatives were allowed to access break rooms in non-public areas of the employer’s hospital without an escort. No unilateral change when the employer never imposed a requirement that representatives be escorted by a staff member to access break rooms or ever restricted representatives to public areas of the hospital.