Western Growers has submitted detailed comments to the Agricultural Labor Relations Board (ALRB) regarding the proposed regulations for implementing Assembly Bill No. 113 (AB 113). Below is a summary of key points in the comments:

1. Urgency of Finalizing Regulations: Western Growers emphasizes the importance of promptly finalizing the regulations, noting considerable delays since the initial discussions started in mid-2023. The delay has created uncertainty for employers and farmworkers alike, with some petitions lacking a clear legal framework for enforcement.
2. Right to Revoke Signature: The comments strongly advocate for ensuring that employees can revoke their union support signatures at any point before or during the certification process. This point is highlighted as crucial for safeguarding the rights and freedoms of employees in making their unionization decisions.
3. Transparency and Informed Consent: The association advocates for ensuring union authorization cards clearly inform workers of the effect of signing the card, including that doing so waives the employee’s right to a secret ballot election.
4. Limiting Authorization Card Validity: Western Growers proposes limiting the validity of authorization cards to a period directly related to a current worker’s employment to prevent outdated influence by former employees.
5. Verification of Signatures: The comments propose a dual verification process involving both union and company representatives to ensure the authenticity of signatures on union authorization cards.
6. Language Accessibility: To foster informed consent, it’s proposed that all authorization materials be available in the languages understood by the workers, accommodating the diverse linguistic needs of the workforce.
7. Reasonable Extension of Timeframes for Employer Compliance: Adjustments to the timeframes are suggested to better align with operational realities, such as extending the period for employers to submit worker lists and to file objections.

We will continue to keep our members informed on the progress of these regulations and related matters.