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10 • April 2014 www.concreteproducts.com Leading up to the Department of Labor's delay in issuing a new reporting rule that would change the long-standing interpreta- tion of "advice" under federal labor law, the Associated Builders & Contractors relayed strong criticism of the proposed measure to Labor Secretary Thomas Perez. Joining 53 other employer organizations, ABC reiterat- ed its strong opposition to proposal, while highlighting additional concerns. If fnalized, DOL's rule will greatly re- strict employers' relationships with labor relations advisers. Communication that was previously considered advice would Contractors, business community challenge DOL Persuader Rule now carry onerous requirements for em- ployers—most of whom are small busi- nesses without in-house legal counsel— and third-party advisors, now considered "persuaders," would be required to pro- duce forms for each of their clients or potentially face criminal charges. The letter criticized DOL's plan to issue its fnal persuader rule ahead of a separate rulemaking, set for later this year, to make signifcant changes to Form LM-21. The sig- natory groups recommended that DOL not move forward with fnalizing the persuader rule without frst addressing the potential- ly signifcant changes to the LM-21, which employers must fle when they pay a "per- suader"—a third party who speaks direct- ly to their employees about labor relations matters. The letter cautioned that failure to do so would demonstrate the agency's lack of understanding of both rules' employer impact. The letter also addressed the persuader rule's treatment of employers and trade associations that offer "seminars, webi- nars or conferences" that may trigger the proposed reporting requirements, pointing out that DOL did not include adequate compliance instructions. The inclusion of seminars, webinars and con- ferences in the proposed rule, coupled with the availability of content online, potentially subjects millions of individu- als to new disclosure requirements without clear instructions on what exactly must be disclosed. ABC and its members have long opposed the persuader rule because it eviscerates attorney-client privilege and infringes upon employers' right to free speech, freedom of association, and legal coun- sel. By finalizing the rule, DOL would curtail employees' rights to obtain bal- anced and informed input from both sides as they decide whether to be represented by a union. ABC also contends that the rule would also work hand-in-glove with the National Labor Relations Board's "am- bush" elections rulemaking, which hastens union elections and hands over personal employee data to union organizers. In addition to Perez, the letter was also shared with White House staff, the Office of Information and Regulatory Af- fairs, the committees of jurisdiction on Capitol Hill and several states' attorneys general. GOVERNMENT AFFAIRS REGULATIONS High Concrete Accessories are essential for a precision connection, with no more "on the spot" engineering. ◘ Quick, Easy Installation - saves time and money on labor during production and erection ◘ Solid Connection - fast, all- weather construction ◘ Uniform Appearance - consistent from piece to piece, job to job ◘ Noncorrosive/Nonreactive - prevents deterioration ◘ Compact Size - minimize reinforcing interference ◘ Versatility - standard and custom sizes/colors available that ft most any form and design ◘ Environmentally Friendly - leave-in place embedments eliminate the need to remove and dispose of materials after casting High Concrete Accessories have been used successfully by some of the largest precasters, in thousands of structures, across the US, since 1995. Our products are engineered to eliminate the need for make- shift embedments, cobbled together from cardboard, wood, Styrofoam or other scrap materials. Visit our website, or call us today so you can stop making embedments and start making more money! highconcreteaccessories.com 800-508-2583 High Concrete Accessories Alternative Stop Making Embedments . . . Start Making More Money! Concrete Products April 2014.indd 10 4/1/2014 11:38:27 AM