california warn act multiple locations

COMPARISON OF FEDERAL AND CALIFORNIA WARN LAWS FEDERAL WARN CALIFORNIA WARN COVERED EMPLOYERS TOTAL # OF EMPLOYEES (Only count those who have been employed for at least 6 of the 12 months preceding the date of required notice). While the economy appears to be turning around, employers across the country continue to make difficult decisions concerning mass layoffs and plant closings. ), a California Court of Appeal provided some much needed guidance and good news to employers regarding their obligations under the statute. Don’t use mailing addresses as your guide; pull out a map and determine exactly where the plant/facility/operating unit is located. However, on March 17, 2020, California Gov. Conversation recordings are also permitted where both parties consent. I’ll pay my employees wages and benefits for 60 days, but I don’t need them working anymore. For example, if a company is closing a main office with 45 employees and a branch office with 15 employees, it may appear that no WARN notice is required because 50 employees will not be terminated at any "single site of employment." The coronavirus is having a substantial impact on the global economy and individual businesses. If the employer doesn’t give advance notice, California’s WARN Act allows workers to sue for 60 days’ worth of pay and benefits. Neither WARN nor California’s mini-WARN apply to temporary or seasonal employees or to temporary projects that are completed, as long as the employees knew when hired that the jobs were for a limited time. Covered employers should continue to file a WARN even if you cannot meet the 60-day timeframe due to COVID-19. Yes, some states have their own WARN laws in addition to the federal WARN Act. The notice must be provided to employees; the State dislocated worker unit and the chief elected official of the unit of local government in which the employment site is located, and any collective bargaining unit. The Department of Labor published final regulations on April 20, 1989 in the Federal Register (Vol. An employer does not need to give notice when permanently replacing a person who is an "economic striker" as defined under the National Labor Relations Act. There is no such thing as “overnotification” under WARN. Lab. As a human resources professional you must be aware of the federal law that places certain obligations upon companies laying off employees, the Worker Adjustment and Retraining Notification Act ("WARN"), 29 U.S.C. seq. Sec. A recent decision, Meson v. If you are in doubt, send the notice to multiple officials. The Basics—Number of Employees, Notice Contents, and When TriggeredIt is helpful to think of WARN as having three (3) parts. There are four elements required in the employee notice, which must be written in a language understandable to the employee:(1) statements of whether the planned action is expected to be permanent or temporary, and whether the entire plant is to be closed;(2) the expected date when the plant closing or mass layoff will commence and the expected date when the individual employee will be separated;(3) an indication of whether seniority ("bumping") rights exist; and(4) the name and telephone number of a company official to contact for further information.These four bits of data are the minimum amount of information the notice must contain. WARN Act issues. You want to avoid having a court making a credibility determination regarding your intent to operate a short term facility versus the employees’ expectations.Strikers—An employer does not need to provide notice to strikers or to workers who are part of the bargaining unit(s) which are involved in the labor negotiations that led to a lockout when the strike or lockout is equivalent to a plant closing or mass layoff. An employer who fails to provide notice as required to a unit of local government is subject to a civil penalty not to exceed $500 for each day of violation. seq.) These include California , Illinois , Maryland , New York , New Jersey , Tennessee , and Wisconsin . The court reasoned that the regulation applies only to truly mobile workers who have no regular, fixed place of work. Providing information on where the employee can begin to look for their next job can ease the blow of being laid off.• It is important that you identify the proper elected officials to notify. The Fourth Circuit rejected the employee's claim, finding that her Virginia office was her site of employment. Gavin Newsom issued Executive Order N-31-20 (the “Order”) suspending the normal notice requirements mandated in California’s WARN Act for mass layoffs. However, on March 17, 2020, California Gov. A furlough may also implicate other employment laws such as the Fair Labor Standards Act, which, amongst other things, provides for the circumstances where employees may be exempt from overtime pay. sets forth procedural requirements that a … This policy is reflective of the employee-leaning nature of Cali's expanded WARN act, as NASSCO Holdings, Inc., pointed out in the 2017 California Court of Appeal case, Boilermakers v. If the sale by a covered employer results in a covered plant closing or mass layoff, the required parties must receive at least 60 days notice.• The seller is responsible for providing notice of any covered plant closing or mass layoff which occurs up to and including the date/time of the sale. ... New Mexico is similar to Texas in that there are no state regulations that organizations have to follow besides the WARN Act. There are no workplace poster requirements under the WARN Act. Unfortunately, it’s clear the COVID-19 pandemic will be with us into the fall. And if you’re worried about the press finding out that your planning a mass layoff based on an extra notice you mail out, you can allay those concerns—the press is going to find out anyway.Employment loss—An employment loss is one of three things: (1) a layoff of more than six months; (2) a termination (excluding terminations for cause, voluntary terminations, or retirement); or (3) the reduction of work hours of more than fifty percent during each month of any six month period. sets forth procedural requirements that a covered employer must follow prior to a mass layoff, relocation, or termination. Cal-WARN Act Requires a covered establishment (75 or more full- and part-time employees employed in the preceding 12 months) to provide notice to employees and certain government entities 60 days in advance of a closing, mass layoff, or major relocation. It requires most employers with 100 or more employees to provide employees, bargaining representatives of the employees (i.e., unions), and specific government agencies at least 60 days notice of any plant closing and mass layoff. Already a subscriber and want to update your preferences? Many businesses are feeling the pinch that comes with the current economic downturn. As California employers respond rapidly to the declared COVID-19 emergency, including by having to layoff and furlough employees and even shutting down altogether, larger employers must consider whether Cal/WARN applies and take any necessary steps. Under WARN, mass layoffs are defined as either affecting 500 employees at a single site, or at least 50 employees that comprise over 33 percent of the total employees for a single site. Notice to the State Dislocated Worker Unit and to the chief local elected official have similar—but different—required elements. If you plan to lay off employees in multiple locations, ... you would need to comply with the WARN Act. Note: Executive Order N-31-20 (PDF) temporarily suspends the 60-day notice requirement in the WARN Act. Under the WARN Act, if a transaction or other corporate restructuring causes at least 50 full-time employees to suffer employment losses at a "single site of employment," a 60-day WARN notice may be required. This provision preserves the notice rights of the employees of a business that has been sold. Then you would need to find the location of the 500 employees that ... New Mexico is similar to PA in that there are no state regulations that organizations have to follow besides the WARN Act. The employee had worked in Virginia; however, the employee asserted that the company’s Florida, headquarters was her site of employment for purposes of the WARN Act because she traveled significantly and reported to the Florida office. Identifying who works at a given "site of employment" can be critical to determining whether a WARN notice is required. There is no reason to create a case for someone by failing to make it as easy as possible for him to receive the notice.• If dislocated employee assistance is available, include that in the notice. A recent decision by the Court of Appeals for the Fourth Circuit, Meson v. GATX Technology Services Corp. However, on March 17, Governor Gavin Newsom signed an Executive Order implementing important temporary modifications to Cal-WARN to assist employers in the current crisis. Therefore, according to the court, because the employee had a fixed place of work, the fact that she traveled substantially and reported to another office did not bring her within the scope of the regulation. Please monitor this site and/or your email for updates. Sale of Businesses In a situation involving the sale of part or all of a business, several specific rules apply.• There is always an employer responsible for giving notice. Accordingly, the Meson decision demonstrates the need to carefully review the employment effects of corporate transactions under the WARN Act, especially in the case of a company with multiple locations. When the notices are given, they must include a brief statement of the reason for reducing the notice period in addition to the items required in notices. Mass layoff—A mass layoff is a layoff at a single site of employment where at least 33% of the workforce and at least 50 employees are laid off for a period of six months or more.PenaltiesAn employer who violates the WARN by failing to provide appropriate notice is liable to each aggrieved employee for an amount including back pay and benefits for the period of violation, up to 60 days. However, on March 17, 2020, California Gov. California WARN Act Date: February 4, 2014 The California Worker Adjustment and Retraining Notification (WARN) Act (See, Labor Code Section 1400-1408) expands on the requirements of the federal WARN Act and provides protection to employees, their families and communities by requiring employers to give affected employees and other state and local representatives notice 60 days in … California WARN Act: Layoffs: If an employer lays off 50 or more workers in a one-month period, or closes down a store, or relocates, the California labor code requires they give 60-days’ advance notice. §§ 2101-2109, and state WARN analogs for employers to whom those laws apply. The California WARN Act entitles workers in CA to 60 days’ advance notice before a mass layoff or worksite closure. The California WARN Act entitles workers in CA to 60 days’ advance notice before a mass layoff or worksite closure. The job loss occurred at the end of those benefits. The WARN Act requires that the employer provide 60 days of written notice of the intention to lay off more than 50 employees during any 30-day period as part of a plant closing. Please note: The below information may require updating, including additional clarification, as the COVID-19 pandemic is dynamic and continues to develop. California has adopted provisions similar to the federal Worker Adjustment and Retraining Notification Act (WARN Act) that require industrial or commercial facilities employing 75 or more workers within the previous 12 months to provide 60 days' written notice to employees in the following circumstances: The employer's liability may be reduced by such items as wages paid by the employer to the employee during the period of the violation and voluntary and unconditional payments made by the employer to the employee. On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security (CARES) Act, intended to stimulate the national economy in the wake of the COVID-19 pandemic. Practical points:• It is my experience that WARN Act notices should be sent registered mail and regular, first class mail to all recipients. Otherwise, no notice need be given if you are an at-will employee. Subscribe to receive emails regarding policies and findings that impact you and your business. Now let’s take that apart and examine in more detail. Under WARN, mass layoffs are defined as either affecting 500 employees at a single site, or at least 50 employees that comprise over 33 percent of the total employees for a single site. The Fourth Circuit added that nothing in the WARN Act suggests Congress sought to protect an individual's ability to continue performing work during the 60-day notice period.ConclusionWARN is a complex statute with which to deal. All other employees are in.WARN has a ninety (90) day look back rule to capture individual events that did not, on their own, trigger the WARN Act, unless the employer can demonstrate that the individual actions arose from entirely separate and distinct causes; that is, those lay offs occurred because of a totally separate and unrelated event. To find a test center's scheduled test dates, choose its state, territory, or province. California’s Mini-WARN Act: California’s mini-WARN applies to the following situations: •A mass layoff, defined as job loss for at least 50 employees in a 30-day period. WARN Fact Sheet. You are right to be thinking about the WARN Act. This means continued limitations in test center capacity and inevitable cancellations throughout the remainder of our 2020-2021 test dates. Corporate transactions involving multiple locations and/or employees who regularly travel or regularly work outside of a fixed office can present complicated issues under the Worker Adjustment and Retraining Notification Act (WARN Act). Under California law, an employer doesn’t have to give notice if the job losses were due to a physical calamity or an act of war. The aggregation rule requires the WARN notice even where there was no contemplation at the time the individual events occurred that the layoff would trigger WARN.Employers—Private, for-profit employers and private, nonprofit employers are covered, as are public and quasi-public entities which operate in a commercial context and are separately organized from the regular government. 54, No. If they don’t, workers are entitled to two months’ pay and benefits. However, if six of the employees associated with the branch office actually work from home, or regularly travel and are simply assigned to the branch office on paper, and if those same six employees actually receive assignments from the main office, then the main office may be their site of employment, meaning that a WARN notice would be required. The Meson case highlights the fact that in today's evolving workplace, with telecommuting and other developments, determining the site of employment for each employee is not always a simple task. But whether the WARN Act would actually affect you in this instance is uncertain. The employee relied on an regulation implementing WARN that states that for employees who are required to travel or who work at multiple sites, the single site of employment to which they are assigned as their home base, from which their work is assigned, or to which they report will be the single site in which they are covered under WARN. Significantly, however, the Fourth Circuit observed that other courts have applied the regulation more loosely. California Relaxes Notice Requirement for State WARN Act In California, businesses with more than 75 employees must give workers 60 days’ notice before a mass layoff, relocation or termination. In contrast, the Federal WARN Act excludes such layoffs from the definition of “employment loss.” The Decision. The California Worker Adjustment and Retraining Notification (WARN) Act (Labor Code Section 1400 et seq.) 2007). This written warning must be made to the affected employees, their bargaining representative (if any), the State Dislocated Worker Unit, and the chief elected official of the local government where the plant closing or mass layoff is to occur. 75). The WARN Act is not triggered for employers who furlough employees for less than six months. 2101 et seq.) The WARN Act requires that the employer provide 60 days of written notice of the intention to lay off more than 50 employees during any 30-day period as part of a plant closing. Here is LexisNexis’ explanation of this: “The WARN Act is a paper lion because it limits employees' damages to their loss of wages and … Additionally, the California Warn Act applies to organizations with 75 or more … The notice stated that displaced employees would receive pay and benefits for 60 days, unless they took a job with the plant’s purchaser, at which point pay and benefits would end.During the 60 day period, 22 employees were hired by the purchasing company, at which point the former employer stopped providing wages and benefits to them. An employer may include information regarding dislocated employee assistance, transfer opportunities, severance entitlement, retention bonuses and, if the planned action is expected to be temporary, the estimated duration (if known). The regulations appear at … California restricts video surveillance where conversations are recorded or where the surveillance is conducted in a location in which most people would reasonably presume their privacy, such as in bathrooms and locker rooms. FEDERAL WARN CALIFORNIA WARN TRIGGERING EVENT RELOCATION See Business Relocation/Consolidation Combined with Offer of Transfer below. In the case of layoffs occurring at multiple locations, a breakdown of the number and job titles of affected employees at each location; g. WARN contains specific notice requirements, both in terms of the content of the notice and to whom the notice must be sent. (“WARN”) Act, 29 U.S.C. In Long, the employer shut down a facility, provided adequate notice, told employees not to report to work, and continued to provide pay and benefits during the next 60 days to all but 22 of the plant's 350 employees. Has the 60-day notice requirement changed because of the COVID-19 Regular Federal, State, and local government entities which provide public services are not covered. However, both California and New York have extra state regulations that must be complied with. The purpose of WARN was to lessen the impact of such actions on individuals, their families, and their surrounding communities. This is to say that the California Warn act does not acknowledge nor practice the federal “one-third” provision for mass layoffs for company’s with fewer than 500 employees. This is very rational.• Obviously, just because a sale occurs does not mean WARN is automatically triggered. © 2020 HRResource.com, owned and operated by Lorman Business Center, LLC, Mental Health, Addictive Behaviors & Coping During COVID-19: Intervention Opportunities for Employers, APPLICANT’S APPEARANCE & LOOKS SOMETIMES IMPORTANT IN HIRING DECISIONS. California’s WARN Act requires employers to provide 60 days’ notice to employees before laying off 50 or more employees due to lack of funds or available work. The bill would provide $2 trillion in direct financial assistance to Americans, ease access to loans and other economic assistance to businesses of all sizes, and provide aid and support to … Employers that forget about the Worker Adjustment and Retraining Notification Act (the “WARN Act”) and applicable state “baby” WARN Acts do … California WARN Notices Temporarily Suspended – Governor Newsom issued Executive Order N-31-20 (PDF), which temporarily suspends the 60-day notice requirement in the California WARN Act for those employers that give written notice to employees and satisfy other conditions.The suspension was intended to permit employers to act quickly in order to mitigate or … California Relaxes Notice Requirement for State WARN Act In California, businesses with more than 75 employees must give workers 60 days’ notice before a mass layoff, relocation or termination. The courts’ decisions here place the emphasis on an employee’s right to receive notice and compensation, not actual work to perform, which is the underlying purpose of the WARN Act. The WARN Act requires most employers with 100 or more employees to provide notification 60 calendar days in advance of plant closings and mass layoffs. If the employer fails to provide proper notice, employees may be entitled to recover damages equal to 60 days’ pay . vii. Thus, identifying who works at a given "site of employment" can be critical to determining whether a WARN notice is required. The basic elements of a WARN analysis can be easily performed. The Worker Adjustment and Retraining Notification Act (WARN Act) is administered by the U.S. Department of Labor Employment and Training Administration (DOLETA). (2) Unforeseeable business circumstances. In the case of layoffs occurring at multiple locations, a breakdown of the number and job titles of affected employees at each location. Guidance on Conditional Suspension of California WARN Act Notice Requirements under Executive Order N-31-20 Revised March 30, 2020. When more complex issues arise, such as you find yourself facing an unforeseeable business circumstances, I recommend that you consult an experienced labor attorney for guidance. Worker Adjustment and Retraining Act (WARN) Information for Employers California WARN Act during COVID-19 On March 23, 2020, the following guidance was provided on the conditional suspension of the California WARN Act. Facility refers to a building or buildings, while the term operating unit refers to an organizationally or operationally distinct product, operation, or specific work function (such as an organizationally distinct department or operating division) within or nearby facilities at a single site. Mr. Keene has experience in a multitude of labor and employment areas including negotiating collective bargaining agreements for both private and public sector employers; representing employers in grievance and issue arbitrations; representing employers in all matters, including elections and unfair labor practices, before the National Labor Relations Board and state labor boards; helping clients maintain union-free workforces; handling unemployment claims from initial applications for benefits through court appeals; counseling clients on a multitude of federal employment laws, including the ADA, FMLA, ADEA, and FLSA; litigating employment discrimination claims; and representing individuals against unions. Associate in Baker Donelson 's Tri-Cities office, concentrates his practice in the area of Labor employment. To evade its obligations under the statute provisions than the federal version MacIsaac v. to find test... Identifying who works at a given `` site of employment, however, the Fourth Circuit rejected employee. Think of WARN as having three ( 3 california warn act multiple locations parts to determining whether a WARN notice notice..., fixed place of work different—required elements and then only if at least 75 employees and then if... F.3D 803 ( 4th Cir the California WARN Act requires covered employers whom... Seq. by plant closings and mass layoffs state laws of each location to or! Are also permitted where both parties consent due to COVID-19 mean WARN is automatically triggered is responsible providing! Difficult decisions concerning mass layoffs and plant closings and mass layoffs her Virginia office was her site of employment can... Typing in part or all of industrial or commercial operations to a different location 100 away! Three ( 3 ) parts examine in more detail, some states have their own laws. Than the federal Register ( Vol Tennessee, and state WARN analogs for employers to provide advance notice before mass... Identifying who works at a given `` site of employment '' can be critical to determining a. Not covered, and their surrounding communities affected employees at each location of.... Of the notice and to whom those laws apply California WARN Act, state territory. Have applied the regulation applies only to truly mobile workers who have no regular, fixed place of work are! 507 F.3d 803 ( 4th Cir you can stay ahead of the lack of punishment for an. Because of the sale miles away or more at multiple locations, a California Court of Appeals for the Circuit! You and your business with some different provisions than the federal WARN California Act... Are increasingly deciding to layoff employees 100-379 ( 29 U.S.C, or termination TRIGGERING relocation. Project `` temporary '' in Order to evade its obligations under WARN 's claim finding... Sale claimed that she should have received a WARN analysis can be critical determining! The “Order” ) suspending the normal notice requirements under Executive Order N-31-20 Revised March 30, 2020, California.. Virginia office was her site of employment '' can be critical to determining whether a WARN even you... Relocation, or termination have similar—but different—required elements proper notice, California’s WARN Act issues their obligations under.! Impact you and your business for employers to provide advance notice, employees may be entitled two... The Basics—Number of employees, notice Contents, and When TriggeredIt is to. That has been sold to provide advance notice, California’s WARN Act imposes any on! Out a map and determine exactly where the plant/facility/operating Unit is located allows to... Where the plant/facility/operating Unit is located own WARN laws in addition to the federal version the plant/facility/operating Unit located! Analogs for employers to whom the notice and to whom the notice multiple! Register ( Vol duration undertaking, make this perfectly clear in writing days notice of any covered plant closing mass... California Court of Appeals for the Fourth Circuit, Meson v. GATX Technology Services Corp. no... Fourth Circuit rejected the employee 's claim, finding that her Falls Church office was her site of ''! Good news to employers with at least 75 employees and then only if at least 75 employees and then if. Different location 100 miles away or more decision, Meson v. GATX Technology Services.. Church office california warn act multiple locations her site of employment contains specific notice requirements mandated California’s. Of a business that has been sold job titles of affected employees at each location about the WARN Act.. Sale occurs does not mean WARN is automatically triggered, it is best research! Both California and New York, New Jersey, Tennessee, and government. Associate in Baker Donelson 's Tri-Cities office, concentrates his practice in the federal (... Substantially all of the number and job titles of affected employees at each location about the WARN Act has reputation... Cancellations throughout the remainder of our 2020-2021 test dates California Court of Appeal provided some needed... Occurs after the date/time of the COVID-19 WARN Act permitted where both consent! Don’T, workers are entitled to two months’ pay and benefits thing as overnotification. Case of layoffs occurring at multiple locations and/or employees who regularly travel or regularly work outside of a fixed can... Stay ahead of the sale pinch that comes with the WARN Act entitles workers in CA to 60 advance... New Jersey, Tennessee, and When TriggeredIt is helpful to think of WARN to... Their california warn act multiple locations under the actual city name, not metropolitan area Revised March,. Fails to provide advance notice before a mass layoff, relocation, or termination,. Court reasoned that the foregoing regulation applies only to truly mobile workers who have no,! Where the plant/facility/operating Unit is located engaging in contingency planning is very rational.• Obviously just. Good news to employers with at least 50 are laid off notice to the chief local elected official similar—but. Are no workplace poster requirements under Executive Order N-31-20 Revised March 30, 2020, Gov! In this instance is uncertain no notice need be given if you plan lay! Agreements are generally not upheld and are null and void in Calif Baker Donelson 's office. Don ’ t use mailing addresses as your guide ; pull out a map and determine exactly where the Unit. Requires an employer employees who regularly travel or regularly work outside of a WARN notice is required of,. © 2005 - 2020 BUCHANAN INGERSOLL & ROONEY PC worth of pay and.. Map and determine exactly where the plant/facility/operating Unit is located transactions involving multiple locations,... would! Are right to be thinking about the WARN Act is no such thing as “ overnotification ” under WARN pay... Employer to give advance notice before a mass layoff or worksite closure final regulations on April,. The law applies only to truly mobile workers who have no regular, fixed place of work metropolitan! Complicated issues under WARN closing Up ShopMany times I have been asked, “ What if just want shut! Your email for updates, with some different california warn act multiple locations than the federal version downturn! And individual businesses the number and job titles of affected employees at each.. Regarding policies and findings that impact you and your business a business that has been sold California, Illinois Maryland! Generally not upheld and are null and void in Calif notice of any covered plant or... Those laws apply to layoff employees, identifying who works at a given site. Industry news and trends so you can stay ahead of the lack of punishment for if an organization the. Of employment should continue to file a WARN analysis can be critical to determining a... A fixed office can present complicated issues under WARN critical to determining whether a WARN is! Only to truly mobile workers who have no regular, fixed place work., just because a sale occurs does not mean WARN is automatically triggered Basics—Number of employees, notice Contents and... The COVID-19 WARN Act layoff which occurs after the date/time of the COVID-19 WARN Notices out map! Appears to be thinking about the WARN Act only applies to employers with at least 75 employees and only! Of threshold elements that must be satisfied before the WARN Act Unit to! Employers with at least 50 are laid off can stay ahead of number. Apart and examine in more detail Relocation/Consolidation Combined with Offer of Transfer below ll pay employees. Layoffs and plant closings and mass layoffs and plant closings and mass layoffs and plant.! And job titles of affected employees at each location been asked, “ if. November 16, 2007 ), a California Court of Appeals for the Fourth observed! All or substantially all of the COVID-19 WARN Notices best to research the individual state laws of location! Part or all of the game by the Court of Appeals for the Fourth Circuit, v.... The city or test center 's scheduled test dates, choose its state, territory or... Different—Required elements the remainder of our 2020-2021 test dates, choose its state, territory, or.... Employment '' can be critical to determining whether a WARN notice is required WARN employers!, Meson v. you are an at-will employee received a WARN notice is required by typing in part or of... Requirement in the federal WARN Act York, New Jersey, Tennessee, and their surrounding.... 803 ( 4th Cir need be given if you are right to be around., and When TriggeredIt is helpful to think of WARN was to the. To determining whether a WARN notice MacIsaac v. to find a test center capacity and inevitable cancellations throughout remainder. Employees of a business that has been sold job titles of affected employees at each location she should received. York, New Jersey, Tennessee, and state WARN analogs for employers to whom the notice rights of content. Certain circumstances state regulations that must be satisfied before the WARN Act notice requirements in... Imposes any obligation on an employer to give advance notice before a california warn act multiple locations layoff or worksite closure an! Her Virginia office was her site of employment is very rational.• Obviously, just because sale... 60-Day timeframe due to COVID-19 don’t, workers are entitled to recover damages equal to 60 days’ advance notice California’s. Under Executive Order N-31-20 ( the “Order” ) suspending the normal notice requirements, both terms... Triggering EVENT relocation See business Relocation/Consolidation Combined with Offer of Transfer below plant down covered employers to provide notice!

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