On Oct. 13, ABC submitted a comment letter the U.S Department of Labor’s Office of Management and Labor Standards regarding its proposed revisions to the LM-10 Employer Report form. Employers must file this form with the OLMS to disclose certain payments, expenditures, agreements and arrangements, including the hiring of outside labor relations consultants to help inform their employees regarding union organizing or collective bargaining, known as “persuader activities.”

The proposed revision would add a checkbox to the form for employers to disclose whether they are a federal contractor, as well as identifying information and the federal agency or agencies contracted for.

ABC opposed the proposed revision, arguing that the OLMS intends to improperly create a chilling effect on lawful persuader activities through this new disclosure requirement and has not demonstrated a need for the requirement to enforce the existing prohibition of federal funding for persuader activities.