Rebutal Comments for NLRB Joint Employer NPRM

Executive Summary:

The HR Policy Association (“HRPA” or “Association”) is a public policy advocacy

organization representing the chief human resource officers of major employers. HRPA consists

of more than 375 of the largest corporations doing business in the United States and globally.

Collectively, their companies employ more than 10 million employees in the United States, nearly

9 percent of the private sector workforce. Since its founding, one of HRPA’s principle missions

has been to ensure that laws and policies affecting human resources are sound, practical, and

responsive to labor and employment issues arising in the workplace.

The Association previously submitted comments during the initial comment period for

consideration by the National Labor Relations Board (“NLRB” or “Board”) in connection with the

Notice of Proposed Rulemaking and Request for Comments, published in the Federal Register on

September 24, 2018, related to the joint employer standard applicable under the National Labor

Relations Act (“NLRA” or “Act”), hereafter “Notice”.1

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