Multnomah County Corrections v. Multnomah County

Requirement of a minimum of 40 hours training for strike-prohibited corrections employees cannot be reasonably understood to relate to a matter of on-the-job employee safety under ORS 243.650.

Multnomah County Corrections Deputy Association sought judicial review of a decision of the Employment Relations Board that Multnomah County did not violate their duty to bargain in good faith in regards to a proposal which sought to create a minimum number of hours of approved annual training for county corrections employees. The Employment Relations Board found that the proposal did not directly impact on-the-job safety and therefore did not require mandatory bargaining under 243.650(7)(f). The Court of Appeals agreed and held that safety issues subject to mandatory bargaining for non-strike employees under ORS 243.650(7)(f) are only those that can reasonably be understood on their face to address matters related to on-the-job safety of strike-prohibited employees. The proposal at issue did not directly relate to on-the-job safety, and is therefore exempt from mandatory bargaining. Affirmed.