NATIONAL LABOR RELATIONS BOARD

VII. PRINCIPLES ESTABLISHED 195
Where, however, two or more companies are closely interconnected
by interlocking directorates, common officers, or the like, so that they
are subject to a single, centralized control, the Board has found in
many cases that the employees of the companies so controlled constitute
a single unit. In Matter of Wag goner Refuting Company, Inc.,"
it was agreed by both of the unions involved that the employees of a
corporation and of a trust estate should be treated together. This
was denied by the respondents. After finding that the oil operations
of the two legal entities constituted a single enterprise, the Board
said:
* * * The testimony of members of both labor organizations clearly confirms
the finding which we have made above that all the oil departments comprise a
single business venture and that the separation of the Company and the Estate
into two legal entities is not carried over into the operations, management, or
ownership. The employees of the production, water, and casinghead gasoline
departments of the Estate and of the pipe-line department of the Company all
work in the oil field and, for the most part, live there. The Company's refinery
is located 21 miles away from the oil field, but its operations are entirely
dependent upon the other departments and its employees have by their
past organizational efforts shown a close contact with the employees in the field.
Cocanower, the general manager of all the oil departments, determines the
labor policies from a common general office, with the result that wages and
working conditions are similar.
It was then held that a single unit was appropriate."
However, the mere fact that two companies are interrelated does
not require a holding that their employees constitute a single unit.
In -Matter of Pennsylvania Salt Manufacturing Company, 71 it appeared
that a wholly-owned subsidiary of a chemical-producing
concern was engaged in producing electric power. Although it was
located on the premises of the parent company, and supplied the
latter with its entire requirements for steam, it was operated as a
separate business enterprise, and transformed most of the steam
power produced by it into electric power which was sold to other
customers. The Board held that the employees of the power company
should not be included in one unit with employees of the
chemical company.72
One factor which may require the inclusion in one unit of employees
even of competing companies which are not financially interrelated
is the fact that those companies have joined together for
the purposes of collective bargaining with a single representative
Matter of Waggoner Refining Company, Inc., and W. T. Waggoner Estate and International
Association of Oil Field, Gas Well and Refinery Workers of America, 6 N. L.
R. B. 731.
,0 See also : Matter of United Press Associations and American Newspaper Gui4/, 3 N. L.
R. B. 344; Matter of Whittier Mills Company and Textile Workers Organizing Committee.
3 N. L. R. B. 389; Matter of Pennsylvania Greyhound Lines et al. and The Brotherhood
of Railroad Trainmen, 3 N. L. R. B. 022; Matter of Mackay Radio Corporation of Delaware,
Inc. and Mackay Radio d Telegraph Company, a Corporation and American Radio
Telegraphists' Association, 5 N. L. R. B. 057; Matter of The Triplett Electrical Instrument
Company, The Diller Manufacturing Company, doing business under the firm name and
style of Readrite Meter Works and United Electrical and Radio Workers of America, Local
No. 714, 5 N. L. It. B. 835; Matter of Paragon Rubber Co.-American Character Doll Company
and Toy cE Novelty Workers Organizing Committee of the C. I. O., 6 N. L. R. B. 23
Matter of C. A. Lund Company and Novelty Workers Union., Local 1866 (A. F. of L.)
successor, 6 N. L. It. B. 423; and Hatter of Art Crayon Company, Inc. and its affiliated
company, American Artists Color Works, Inc., and United Artists Supply Workers,
7 N. L. R. B. 102.
I Matter of Pennsylvania Salt Manufacturing Company and Local Union No. 12055 of
District No. 50, United Mine Workers of America, 3 N. L. R. B. 741.
72 See also : Matter of Industrial Rayon Corporation, a Delaware Corporation, and Textile
Workers Organizing Committee, 7 N. L. R. B. 877, where it was held that the
graphical separation of the plants owned respectively by a parent and a subsi
corporation required a finding that employees in the two plants constituted separate units.