On Aug. 27, the National Labor Relations Board issued its long-awaited decision in
Browning-Ferris Industries (BFI) (362 NLRB No. 186), expanding the test for finding whether two or more entities constitute
"joint employers" for collective bargaining purposes. The NLRB held by a 3-2 vote
that, under the National Labor Relations Act, multiple enterprises may be joint employers
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