An 'enlightened' view of employee committees under the Taft-Hartley Act

The Sixth Circuit Court of Appeals recently ruled, in NLRB v. Streamway Division of the Scott and Fetzer Co., that an in-plant representation committee, unilaterally established by the employer, was not a labor organization. Until 1959, when the Supreme Court decided NLRB v. Cabot Carbon. "labor organization" was narrowly construed, based on the traditional adversary model of labor relations. With Cabot Carbon, and some later Board decisions, the definition has broadened. Now, at a time when many employers are turning to employee committees, quality circles, etc., as ways of improving relations with employees, the Streamway decision takes on particular significance. In the following article, the author examines the statutory basis for determining whether an employee committee is a labor organization, within the meaning of the National Labor Relations Act. He also discusses the judicial and Board precedent for the more liberal definition of "labor organization" set forth in Streamway.