1. Crown Cork & Seal
In order for a violation of 8(a)(2) to be found, there must be domination or interference with a “labor organization”
In the absence of a “labor organization” can be no violation of 8(a)(2)
Per Section 2(5), for an entity to be labor organization it must “deal with” the employer
“dealing with” entails a bilateral interaction” between entity and employer

2. Socio-Tech System Board found no “dealing”
absence of a “bilateral relationship”
Socio-tech committees and bodies essentially had full delegation from the employer, albeit within their jurisdiction and subject to employer policies
Production Teams
Production, quality, safety, attendance, training, maintenance, not lost time discipline
High Level Committees
Membership from teams and management
Make recs to upper mgmt but often implemented before rec
Committees exercised “supervisory” authority
Interactions with upper level management are between two management bodies
Typical management structure in which higher levels of mgt. approve recommendations or actions of lower levels of mgt.