The complainant union alleged that the respondent employer committed unfair labour practices by laying off 131 employees and transferring production to another plant as a reprisal for a protracted strike.
The union also alleged that the employer breached its duty to bargain in good faith by failing to disclose its relocation plans during collective bargaining.
The Board dismissed the complaint, finding that the employer's decision to open a new plant was part of a legitimate corporate strategy to rationalize production and was not motivated by anti-union animus.
The Board further held that the employer was not required to disclose its plans during bargaining because it reasonably believed, in good faith, that the new plant would not adversely affect the job security of the existing bargaining unit.
The layoffs were found to be the result of an unanticipated economic downturn rather than a reprisal.
