The Department of Labor (DOL) has published notice in the Federal Register that the “NLRA Rights” poster has been submitted to the White House Office of Management and Budget (OMB) for review and continued use without change. OMB is likely to approve the poster for another three-year period and, assuming they do, nothing will happen.
Officially called the “Notification of Employee Rights Under Federal Labor Laws Complaint Process,” the poster is required to be displayed by federal contractor employers, subject to certain exceptions, and notifies employees of their right to organize and bargain collectively with their employers. Note that this is in addition to the “EEO is the Law” poster.
Under the Paperwork Reduction Act (PRA) “information collection requests,” which can include required notices and posters, must be reviewed by OMB to ensure that the requirement is necessary and that the burden on employers is balanced with the public interest. Typically OMB will approve the use of such information collection requests for a period of three years.
Approval for the current NLRA Rights poster is set to expire at the end of this month, on August 31, 2019. However, approval for use is automatically extended if necessary, so long as the agency submits the material for review prior to the expiration date. So there will be no “gap” in the requirement and covered federal contractor employers will still be required to display the poster after August 31 if OMB does not provide approval before that date.
For more information about this requirement, visit DOL’s website here. If you are interested in submitting comments regarding DOL’s request you may do so online at RegInfo.gov. Comments are due by September 20, 2019. And of course, Biddle consultants are available if you have any questions or concerns.
