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The University of Michigan Law School

         The University of Michigan Law School

 NLRB Comment Party with Michigan Parity Project


Date: 11/21/2019
Time: 11:00 AM to 02:00 PM
Sponsor: WLSA
Contact: Czwartacky,Rachel

Location: Hutchins Hall B60A, Media Room

Description: **Join Michigan Parity Project to write comments.** This fall, the Trump National Labor Relations Board proposed a new regulation that would say student workers — like teaching assistants and research assistants — aren't employees with a right to unionize under the National Labor Relations Act (NLRA). If the rule is finalized, it would roll back graduate student workers' right to organize a union, collectively bargain, go on strike, and fight for fair wages, decent benefits, and protections from harassment and discrimination.

Here's the good news: The rule isn't final yet, and we have a chance to fight back. Before a regulation can be finalized and have legal effect the NLRB (like any agency) has to solicit public input on their proposed regulations through a process called "notice and comment." The NLRB is legally required to review all comments and respond to this public input when it issues final regulations. A court can strike down a regulation if an agency like the NLRB doesn't property explain its reasoning, or if the regulation itself is inconsistent with the NLRA. Because courts can strike down regulations that are insufficiently responsive to public input, writing a substantive comment is an important way for student workers to influence the NLRB's decision-making process. What that means is that we have a voice — and we should use it.