The applicant union applied for certification to displace the incumbent union representing technical paramedical employees and to expand the bargaining unit to include previously unrepresented professional paramedical employees.
The Board held that in a displacement application, a union cannot sweep in a group of previously unrepresented employees solely on the strength of its membership support in the incumbent's unit.
The Board found the incumbent's bargaining unit to be the appropriate unit, ordered a representation vote for that unit, and dismissed the application as it related to the unrepresented professional employees due to insufficient membership support.