The U.S. Department of Labor recently issued a new rule requiring certain federal contractors and subcontractors to provide employees notice of their rights under the National Labor Relations Act, specifically their rights to join or not join a union. The new rule took effect on June 21, 2010, and implements President Obama’s Executive Order 13496, which he signed early last year.

The Order has two requirements for covered federal contractors and subcontractors.

(1) You must post a poster entitled "Employee Rights Under the National Labor Relations Act" along with other employee posters, and

(2) You must include the language of the employee notice requirement in all contracts.

Federal contractors and subcontractors are subject to the new rule unless the prime contract is less than $100,000 or the subcontract is below $10,000.

The new poster, which can be printed from the DOL website www.dol.go/compliance/topics/posters.htm, must be posted wherever other notices to employees about their jobs are posted. If you post notices for employees electronically, you must also post the required notice electronically. It must be placed in a comparable location at the same level of conspicuousness as other employee notices.

One way to satisfy this posting requirement is to order an "all-in-one" poster that meets the posting requirements for a variety of federal laws (e.g., OSHA, FMLA, FLSA, EEO/AA, etc.). The new poster will simply be included with the others that are required for employees to review. The preamble to the new rule makes clear that such an "all-in-one" poster from a commercial provider is acceptable