One of Barack Obama's first official acts when he was sworn in as president was to sign Executive Order 13496, which mandated that all government contractors and subcontractors notify workers of their right to form a union and engage in collective bargaining. The political meaning of the action was immediately apparent. Obama's campaign had strong support from organized labor, and he was giving something back as a symbol of his intention to follow-through with the pro-labor platform on which he campaigned.
It took the Department of Labor more than 18 months to finalize the regulations to implement that order. In the meantime, some of the Obama administration's other promised labor reforms have stalled. But the DOL regulations, which apply to all companies that enter into new or modified government contracts after June 21 are being characterized as aggressively pro-union, and are likely to result in unexpected pitfalls for employers.
Choose Your Words
Experts are also concerned with the wording of the notice.
Prepare for Enforcement
At press time, the OFCCP had yet to institute any enforcement actions against contractors who are in violation of the notice requirement. However, all signs point to a high likelihood of aggressive enforcement.