The union filed a complaint alleging the employer breached its duty to bargain in good faith during negotiations for a first collective agreement.
The union argued the employer's wage offer and refusal to agree to a Rand formula check-off were designed to prevent ratification.
The Board found that while the employer took a firm position on union security, it was a legitimate response to the union's pressure tactics, which included suggesting a production slowdown and contacting customers.
The Board concluded the employer was engaging in hard bargaining rather than surface bargaining, and dismissed the complaint.