Comments on NLRB Joint Employer

Executive Summary:

The HR Policy Association (“HRPA” or “Association”) submits the following comments for consideration by the National Labor Relations Board (“NLRB” or “Board”) in connection with the Notice of Proposed Rulemaking and Request for Comments, published in the Federal Register on September 24, 2018 related to the joint employer standard applicable under the National Labor Relations Act (“NLRA” or “Act”), hereafter “Notice.”¹ The Association’s comments are particularly directed at the Board’s 2015 Browning-Ferris Industries decision,² and a recent ruling by the United States Court of Appeals for the District of Columbia regarding the Board’s BFI joint employer standard.³

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