Crown Cork

1
Crown Cork Seal

• In order for a violation of 8(a)(2) to be found,
  there must be domination or interference with a
  labor organization
• In the absence of a labor organization can be
  no violation of 8(a)(2)
• Per Section 2(5), for an entity to be labor
  organization it must deal with the employer
• dealing with entails a bilateral interaction
  between entity and employer

2
Socio-Tech System

• Board found no dealing
• absence of a bilateral relationship
• Socio-tech committees and bodies essentially had
  full delegation from the employer, albeit within
  their jurisdiction and subject to employer
  policies
• Production Teams
• Production, quality, safety, attendance,
  training, maintenance, not lost time discipline
• High Level Committees
• Membership from teams and management
• Make recs to upper mgmt but often implemented
  before rec
• Committees exercised supervisory authority
• Interactions with upper level management are
  between two management bodies
• Typical management structure in which higher
  levels of mgt. approve recommendations or actions
  of lower levels of mgt.