The new General Counsel of the National Labor Relations Board (NLRB), Peter Robb, has issued an internal memorandum among other things announcing that he is considering making fundamental changes to the structure of NLRB field offices, and that he hopes that these changes would be in place by October 1, 2018.

While Mr. Robb does not specify what these changes would include, it has been widely reported that he is seriously considering a proposal that would consolidate the 26 current NLRB regions into “districts,” with each district headed by a new official that would report directly to the Board’s General Counsel. As a result, the current Regional Director (RD) structure would be downgraded, impacting the broad discretion the RDs have currently to issue, prosecute, and resolve complaints in unfair labor practice cases.

Although General Counsel Robb has not made any formal reorganization proposal public, there is enough concern on the part of Congressional Democrats that he might move forward with the rumored changes that the ranking members of the U.S. House Committee on Education and the Workforce and the U.S. Senate Committee on Health, Education, Labor, and Pensions have sent letters to Mr. Robb requesting specific information about any proposal that would make fundamental changes to the structure of the NLRB.

The Robb memo, which also deals with other topics, is available on the NLRB website.

Members of the Center for Workplace Compliance (CWC) can read more here.