In an application for certification, the employer objected to the union reviewing the employee list, arguing it could be used for future organizing and that employees wished to remain anonymous.
The Board ruled that the union must be given access to the list to verify its accuracy, as the Board relies on it to determine union support.
The Board also ruled that the union could review the list without management present to protect the secrecy of union membership and solicitor-client privilege.
A representation vote was ordered.