In Fibreboard Paper Products Corp. v. NLRB, 379 U.S. 203 (1964), the United States Supreme Court addressed whether an employer was required by the National Labor Relations Act to engage in collective bargaining prior to replacing maintenance workers with independent contractors. The statute requires an employer to "confer in good faith with respect to wages, hours, and other terms and conditions of employment." See 29 U.S.C.A. 158(d) (West 1998). The Supreme Court considered whether the phrase "terms and conditions of employment" encompassed the dispute and determined: "A stipulation with respect to the contracting out of work performed by members of the bargaining unit might appropriately be called a "condition of employment." The words even more plainly cover termination of employment which, as the facts of this case indicate, necessarily results from the contracting out of work performed by members of the established bargaining unit." (Fibreboard Paper Prods. Corp., 379 U.S. at 210.)