Township of Upper Saucon v. Pennsylvania Labor Relations Board

In Township of Upper Saucon v. Pennsylvania Labor Relations Board, 152 Pa. Commw. 530, 620 A.2d 71, 75 (Pa. Cmwlth. 1993), the township switched all its police officers from a system of rotating shift schedules to a steady shift schedule. It did so unilaterally without negotiating with the police officers' bargaining unit. The Court affirmed the holding of the Pennsylvania Labor Relations Board that a unilateral change in a unit-wide scheduling system constituted an unfair labor practice. Stated otherwise, the issue of scheduling for the entire bargaining unit is subject to mandatory bargaining under Section 1 of Act 111.