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57 FLRA No. 118
U. S. Dept. of the Army, Corps of Engineers, U. S. Army Engineer District, Vicksburg, Mississippi and AFGE, Local 3310, AFL-CIO, et al, Case No. AT-RP-00037 (Decided December 3, 2001)
The International Federation of Professional and Technical Employees (IFPTE) sought review of the Acting Regional Director's (RD's) decision granting a petition to accrete certain employees into an existing bargaining unit. The RD found that, as a result of a reorganization, three geographically dispersed offices of employees had accreted into a bargaining unit represented by the American Federation of Government Employees, Local 3310 (AFGE). The Authority denied IFPTE's application for review.
The Authority explained that under § 7112(a) of the Statute, a unit may be determined to be appropriate only if it will: (1) ensure a clear and identifiable community of interest among the employees in the unit; (2) promote effective dealings with the agency involved; and (3) promote efficiency of the operations of the agency involved. In making determinations under § 7112(a), the Authority examines the factors presented on a case-by-case basis. In determining whether a community of interest has been established, the Authority examines factors such as the agency's mission, organizational and geographic structure, chains of command, working conditions, conditions of employment, and personnel and labor relations policies. The Authority further statd that it has not specified individual factors necessary to establish a community of interest and examines the factors presented on a case-by-case basis.
In accretion cases, the Authority also examines whether employees have been organizationally and operationally integrated. Determining whether employees are sufficiently integrated is based on, among other things, the degree of interchange between employees, the similarities in positions and duties, and the commonality of administrative and organizational functions, missions and chains of command. Here, IFPTE argued that there was an absence of precedent concerning the RD's determination that the employees in the proposed unit shared a community of interest. While the RD did properly consider the level of integration amongst the VCCO offices, she also properly relied on a variety of other factors to find that the employees shared a community of interest, including the centralization of personnel services and managerial authority. While IFPTE correctly pointed out that the Authority had not previously applied these principles to a situation where geographically separated employees work closely together through computer technology, IFPTE failed to establish that different principles were necessary to decide this issue.