NATIONAL LABOR RELATIONS BOARD

VII. PRINCIPLES ESTABLISHED 193
( H ) GEOGRAPHICAL CONSIDERATIONS
The geographical arrangement of an employer's business may be the
basis of a finding that certain of its employees constitute a separate
appropriate unit. 59 Even where it appears that the geographical considerations
are not such as to require the divison of employees into
separate units, such division will be made when the state of the employees'
self-organization indicates its propriety. In Matter of American
Radiator Company, 6° the company operated two plants in one city,
which were two-and-a-half miles apart. In holding that the employees
in each plant constituted a separate appropriate unit, the
Board said:
* * * Conceivably, employees of the two plants could be included within the
same bargaining unit. However, none of the Buffalo plants have ever joined
together for the purpose of collective bargaining and the parties to these present
proceedings expressly repudiate any such desire. All the unions here involved
have organized on a single plant basis.el
The Board has held that geographical considerations -justify, for
example, a separate unit for employees at a company's plant, excluding
employees in its distribution branches; 62 the exclusion of employees
in a branch sales office; 63 and the exclusion from a plant unit
of men who spend most of their time installing machinery away from
the plant.94
However, the mere fact of geographical separation, which might
otherwise require separate appropriate units, may be overcome by the
presence of one or more of the factors which are discussed elsewhere
in this section. Among these factors are the form of self-organization,
the history of collective bargaining, and the central determination
of policy."
69 Matter of Erwin Cotton Mills Company and Textile Workers' Organizing Committee,
6 N. L. It. B. 595 (three appropriate units found ; one for the employees in three plants
in one town, one for those in one plant in a second town, and one for employees in two
plants in a third town) ; Matter of Industrial Rayon Corporation. a Delaware Corporation,
and Textile Workers Organizing Committee, 7 N. L. It. B. 877 (employees in
plants in two towns several hundred miles apart held to constitute two appropriate units)
Matter of Utah Copper Company, a corporation and Kennecott Copper Corporation, a
corporation, and International Union of Mine, Mill, and Smelter Workers, Local No. 392,
7 N. L. R. B. 928 (employees at two mills held to constitute an appropriate unit apart
from employees at a mine and plants 17 miles away) ; Matter of Jacob A. Hunkele, Trading
as Tri-State Towel Service of the Independent Towel Supply Company and Local. No.
40 United Laundry Workers Union, 7 N. L. R. E. 1276 (employees at Cumberland,
Maryland. held to constitute a unit apart from employees at Pittsburgh, Pennsylvania).
e4 Matter of American Radiator Company (Bond Plant and Terminal Plant) and Amalgamated
Association of Iron, Steel d Tin Workers, Lodges 1199 and 1629, 7 N. L. R. B.
452.
el See also: Matter of Associated Press and The American Newspaper Guild, 5 N. L.
It. B. 43 (separate unit for employees in three offices of a nation-wide news distribution
service) ; and matter of Postal Telegraph-Cable Company of Massachusetts and American
Radio Telegraphists Association, 7 N. L. It. B. 444 (separate unit for one office of a
telegraphic communication system).
Matter of Hoffman Beverage Company and Joint Local Executive Board of International
Union of United Brewery, Flour, Cereal, and Soft Drink Workers of America,
3 N. L. R. B. 584.
63 Matter of Lidz Brothers, Incorporated and United Wholesale Employees, (Local No.
65), 5 N. L. R. B. 757.
04 Matter of Diamond Iron Works and United Electrical Radio Machine Workers of
America., Local 1140, 6 N. L. R. B. 94.
Matters of Rossie Velvet Company and Charles B. Rayho/i and Textile Workers Organizing
Committee of the Committee for Industrial organization, 3 N. L. R. B. 804 (two
plants 40 miles apart) ; Matter of American Hardware Corporation and United Electrical
and Radio Workers of America, 4 N. L. It. B. 412 (four plants in groups of two, T4 of a
mile apart) ; Matter of Canadian Fur Trappers Corporation, Canadian Fur Trappers of
New Jersey, Inc.. Jordan's Inc., Morris Dornfeld doing business as 1Verth's Wearing
Apparel, and Department and Variety Stores Employees Union, LOCCLI 1115—A, 4 N. L. R.
B. 904 (three stores in one town and one in another) ; Matter of Todd Shipyards Cooporation,
et al. and Industrial Union of Marine and Shipbuilding Workers of America,
5 N. L. R. B. 20 (two plants in one State and one in another, where all were situated
on New York Harbor) ; Matter of American Woolen Company. Nat'l. and Providence
Mills and Independent Textile Union of Olneyville, 5 N. L. It. B. 144 (three mills