In Crawford County v. Pennsylvania Labor Relations Board, 659 A.2d 1078 (Pa. Cmwlth. 1995), the Court observed that the United States Supreme Court in a case involving the National Labor Relations Board had described terms and conditions of employment as matters germane to the working environment and not among decisions that lie at the core of "entrepreneurial control." The jail guards and employees at issue there had been permitted to smoke in all areas, and the employees' right to smoke was a work-related privilege. The Board states that it correctly determined that the Borough's ban on the employees' use of tobacco in or on Borough property was rationally related to the employees' duties and therefore was a mandatory subject of bargaining. Further, the Board found no support for the claim that the ban was intended to protect the health and safety of children and noted that if it was so intended it was not narrowly tailored to meet the purported interest. The Court addressed whether the implementation of a no-smoking policy in the Crawford County Jail was the mandatory subject of bargaining with the union: The courts have repeatedly held that we must defer to the PLRB's interpretation of its own statute against competing interpretations. This is so because the need for expertise and judgment in drawing the line between negotiable and non-negotiable proposals is ultimately within the unique jurisdiction of the PLRB, whose decisions, if supported by substantial evidence, and conclusions, based thereon, are reasonable and not capricious, arbitrary or illegal, must be sustained . . . . In this case, we believe the deference to the final order of the PLRB . . . is warranted. . . . Accordingly, we hold that the PLRB acted reasonably in concluding that the County committed an unfair labor practice by unilaterally implementing a total no-smoking ban on July 1, 1991 and that it failed to meet its burden demonstrating that the smoking ban in the jail facility was essential to the County's basic mission. Id. at 1082.