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Default Assumptions for LaborLab’s Union-Busting Cost Calculator

Default Assumptions for LaborLab’s Union-Busting Cost Calculator


LaborLab has developed a set of default assumptions for estimating the costs employers incur during anti-union campaigns. These assumptions provide the basis for LaborLab’s campaign cost estimates and are adjusted when additional information about a particular campaign, employer, attorney, consultant or other relevant actor or variable is available. The assumptions cover inputs including attorney and consultant billing rates and hours, supervisor and worker time lost to anti-union meetings, and supervisor-to-worker ratios. They are derived from academic research, interviews with attorneys and organizers, analysis of government records and other publicly available data and review of materials produced by anti-union consultants and attorneys.

These assumptions also serve as the default or recommended inputs in LaborLab’s union-busting cost calculator (see the infographic below for a quick summary). 

The calculator is intended as a resource for unions, employers, investors, journalists, researchers and others seeking to assess the economic costs of anti-union campaigns. Because most campaign expenditures are not publicly disclosed, the estimates necessarily rely on assumptions where campaign-specific information is unavailable.

LaborLab is committed to achieving the highest level of accuracy possible, and may periodically revise these assumptions as additional evidence becomes available, including information provided by practitioners, researchers, supervisors and workers. In particular, LaborLab welcomes the submission of attorney billing records, including those obtained through Freedom of Information Act (FOIA) requests, and invoices from consultants that exclusively provide “advice” and do not engage in reportable persuader activity. 

Table of Contents

Union-busting campaign scenarios and services

Before offering a detailed breakdown of the individual cost assumptions, we will first provide an overview of campaign scenarios and services and explain the limitations of publicly available expenditure data.  

Research conducted by the U.S. Department of Labor has estimated that employers hire third-party consultants or attorneys in approximately three-quarters of organizing campaigns.1 

To conduct these campaigns, employers either hire one or more attorneys, who provide both representation services and campaign services. Or they hire both attorneys and non-attorney consultants, who only provide campaign services. 

Campaign services provided by attorneys, non-attorneys or both include campaign planning and coordination, personnel and policy recommendations, supervisor coaching, and the preparation of anti-union messaging delivered by supervisors and distributed as campaign literature. Non-attorney consultants, and in rare cases, attorneys, may also communicate directly with workers.  

Representation services refers to legal tasks associated with the representation that attorneys provide to employers in NLRB proceedings, which include the negotiation or litigation of bargaining units. 

Spending on attorneys and non-attorney consultants are the best known anti-union campaign costs. That’s because they are direct expenditures and because the Labor-Management Reporting Standards Act (LMRDA) requires the disclosure of payments by employers to consultants if they perform certain services known as “persuader activities.” Consultants engage in persuader activities if they communicate directly with workers or collect information on them. 

Estimates of consultant and attorney fees

But these disclosures provide an incomplete picture of expenditures on anti-union campaigns. That’s because consultants and employers do not have to file disclosures if consultants only provide behind-the-scenes services, such as campaign advice and supervisor coaching. Moreover, employers also do not have to report spending on representation services (as distinct from campaign services) provided by attorneys. 

Spending on persuader services nonetheless provides a gauge for spending on consultants or attorneys for campaign services (but not representation services). Employers spent an average of $2,777 per eligible voter in union elections on consultants who provided persuaded services, according to a LaborLab review of the 93 NLRB election campaigns that LaborLab could match to 2024 LM-10 employer spending reports. Previous estimates have sought to capture spending on non-attorney consultants for campaign services, regardless of whether they have engaged in persuader activities or not. These estimates have ranged between $1,000 and $3,000 per worker in 2026 dollars. 

Some estimates have also sought to capture average spending on non-attorney consultants and attorneys whenboth are used. These estimates are inclusive of the cost of representation services provided by the attorneys, not just the cost of campaign services. They have ranged from approximately $4,000 to $6,500 per worker after adjustment for inflation.2 

Thus, there is good reason to believe that employers who wage significant anti-union campaigns may typically spend at least $4,000 per worker on campaign and representation services combined, though this cost may be lower for relatively short campaigns that target large bargaining units. 

Hidden costs

Scholars and practitioners have noted such estimates – and reports of spending on anti-union campaigns more generally – exclude some other important campaign costs, however.3 These additional costs are:  

  • the cost of time spent by in-house personnel who direct or coordinate the campaign, typically including human resources staff
  • the cost of time spent by supervisors and managers on campaign activities, including training, assessing employee union support and delivering anti-union messages;
  • the cost of time that workers lose to group and one-on-one meetings with supervisors and other campaign-related interactions
  • the cost of reduced productivity of workers (e.g. output per hour labored) resulting from the anti-union campaign (this is separate and on top of time lost entirely to anti-union meetings and other campaign activities); and
  • the cost of administrative expenses and materials associated with the campaign.

LaborLab’s incorporates these categories into its estimates using the default assumptions described in this report. Where campaign-specific information is available, users can replace the default values with observed or otherwise better-supported inputs. 

The following sections describe the assumptions and supporting evidence used to estimate each of the seven cost categories included in LaborLab’s calculator. A review of this evidence should make clear that these assumptions are conservative. 

Cost of third-party attorneys

Role

Attorneys typically provide two types of services during election campaigns: representation services and campaign services. 

Representation services

Representation services include negotiating a bargaining unit and election logistics through a stipulated election agreement or litigating those issues before the NLRB, as well as navigating election day itself. This work can require interviewing supervisors, communicating with the union, assembling lists of eligible voters, and filing bargaining unit and election-logistics proposals in a “statement of position,” as well as election-day/s representation and observance.” Absent a stipulated agreement, it can also include preparing witnesses, appearing before a hearing officer and submitting post-hearing briefs.4

Campaign services 

Campaign services can involve planning and managing the campaign, conducting opposition research on the union, identifying workplace grievances that may be motivating the organizing effort, coaching supervisors on how and what anti-union messages to deliver, making personnel and policy recommendations intended to reduce union support (e.g. terminating unpopular supervisors), preparing or editing anti-union speeches and literature, and helping build community support.5 Research suggests that management-side attorneys typically provide strategic campaign services rather than limiting their role to legal representation.6 

Attorneys are much less likely than non-attorney consultants to communicate directly with workers. Researchers have attributed this tendency in part to federal reporting requirements: direct persuader activity can trigger public disclosure requirements under the LMRDA, while “advice” and legal representation is exempt.7

Default assumptions

In the first and most common election scenario, the attorney/s reach an agreement with the union on the bargaining unit and election logistics, known as a stipulated agreement. 

Our default assumptions for campaigns in which the attorneys reach a stipulated election agreement are: 

  • Campaign period: Date the petition is filed through the election date or, if the election date is unavailable, the date the tally of ballots is issued. 
  • Hourly rate: $500 per hour per attorney. 
  • Weekly hours billed:
    • If non-attorney consultants are not used, 20 hours per week for one attorney of record and 15 hours per week per attorney for two or more attorneys of record. 
    • If non-attorney consultants are used, 10 hours per week for one attorney of record and 7.5 hours per week per attorney for two or more attorneys of record. 
  • Expenses: 
    • If an attorney is from out of town, a five-day on-site visit is assumed, with daily expenses of $300 and one $500 round trip. 
    • If an attorney is within a six-hour drive, no travel expenses are assumed. 

In the second election scenario, which is more time-consuming, the attorneys do not reach a stipulated agreement and formally challenge the bargaining unit or other election-related issues at a hearing. Our default assumptions for this scenario are the same as those above, with the following additional hours: 

  • 50 hours are added to the total hours billed by all attorneys combined for the first day of hearings (inclusive of preparation and post-hearing briefing)
  • Eight hours are added to the total hours billed for each additional day of hearings.

To incorporate these assumptions into the calculator, the additional hours are converted into average weekly hours. For one attorney of record, the additional hours are divided by the number of weeks worked. For example, if one attorney works for five weeks and a case involves one day of hearings, the additional 50 hours are divided by five, adding 10 hours to the attorney’s assumed average weekly hours.

Contingencies. Several factors can substantially increase attorney hours beyond these default assumptions. These include bargaining units encompassing numerous job classifications, unfair labor practice charges arising during a campaign, billed travel time and litigation over election objections or other post-election challenges. Appeals or requests for review of bargaining-unit determinations can also add significant attorney time. 

When a campaign involves these contingencies, additional attorney hours should be estimated where sufficient information is available. A union-side labor attorney familiar with the campaign may be able to provide an estimate of the additional legal work involved. In some cases, these contingencies can add dozens or hundreds of hours of legal work. These additional hours should be manually incorporated into the assumed weekly attorney hours. 

LaborLab can provide assistance in estimating additional attorney hours associated with these contingencies.

Justifications 

LaborLab’s default assumptions are based on interviews with five union-side labor attorneys and two management-side attorneys to date, exchanges with dozens of organizers, published research and other writings on union-busting, and court case records and billing information obtained by LaborLab. 

Start date

Employers are commonly advised to hire attorneys as soon as they become aware of organizing activity, which may occur well before a union petitions for an election.8 Nonetheless, LaborLab conservatively uses the petition-filing date as the default attorney start date.

Hourly rates

In the absence of public agreements or court records disclosing a law firm or attorney’s hourly rates, LaborLab’s review of agreements, legal intelligence reports, court records and interviews with attorneys suggest the following general patterns:

For partners, hourly rates charged to private-sector employers appear to begin around $500 per hour in the Midwest and South and $600 per hour on the East and West Coasts, while rates at the higher end can exceed $1,000 per hour. 

For associates, rates appear to begin around $250 per hour in the Midwest and South and $300 per hour on the East and West Coasts, while rates at the higher end can exceed $500 per hour.9

Published accounts of union-avoidance work are consistent with these ranges. In Confessions of a Union-Buster, Martin Levitt reported attorney rates ranging from $300 to $700 in 1995, equivalent to approximately $660 to $1,530 today.10 A 1995 study of management attorneys in union organizing campaigns similarly reported that one Southern attorney reported that rates at union-avoidance law firms ranged from $150 to $300 per hour in 1992, equivalent to approximately $360 to $715 today.11 

On this basis, LaborLab conservatively adopts $500 per hour as its default assumed rate for partner attorneys of record and $250 per hour for associate attorneys of record. 

Hours billed 

The number of hours attorneys bill during anti-union campaigns varies widely across campaigns, from week to week, and among attorneys. Representation services are often front-loaded, while campaign services may intensify over the course of the campaign. To account for this variation, LaborLab estimates attorney costs using average weekly hours over the campaign period. The default assumptions draw on the following evidence:. 

  • Interviews with practitioners. LaborLab’s Interviews with attorneys suggest that a law firm may bill approximately 30 hours for representation services when negotiations have average friction and a stipulated agreement is reached, thereby avoiding litigation of the bargaining unit. This 30 hours of work is often performed by one attorney of record in collaboration with one or more other attorneys working behind the scenes. Interviews also suggest that each management attorney working on a campaign may bill at least 10 to 15 hours per week, on average, for campaign services (as distinct from representation services), with substantially more billed in some campaigns. Over a five-week campaign, 30 hours of representation services averages six hours per week. Combined with 12 hours per week for campaign services, this produces an estimate of 18 hours per week for one attorney in a low- to-moderate intensity campaign. 
  • Study reporting the equivalent of $44,000 to $66,000 for an “inexpensive campaign.” A 1995 interview-based study of management attorneys estimated that an “inexpensive campaign” by a “small-to-medium size firm” using one attorney and no non-attorney consultants could cost between $20,000 and $30,000 at the time, equivalent to between about $44,000 and $66,000 today. The same study reported that an “all-out” campaign at the same-sized employer involving several attorneys could “easily exceed” $100,000, or about $220,000 today, while campaigns at large employers potentially could exceed $1 million, or about $2.19 million today.12 At an assumed rate of $500 per hour, costs of $55,000 for an inexpensive campaign and $220,000 for an expensive campaign works out to between 22 hours and 88 hours per week averaged over a five-week campaign.
  • Study reporting the division of time between representation and campaign services. The same study found that several attorneys reported spending 35% to 45% of their time on the “legal aspects of the campaign” and 55% to 65% of their time on other activities, and some of those legal aspects include campaign services.13 If the approximately 30 hours of representation work identified in LaborLab’s interviews represents 35% of total attorney time, total time would be about 86 hours in a typical campaign, or 17 hours per week over a five-week campaign for one attorney. 
  • Memoir and interviews indicating attorneys may work full-time on some campaigns. In Confessions of a Union-Buster, Levitt wrote that large law firms sometimes send junior associates to perform work previously performed by consultants like himself.14 Given that Levitt reported frequently working full-time on campaigns, this suggests that the junior attorneys similarly can sometimes spend up to 40 hours per week on a campaign. Some LaborLab interviewees have likewise identified campaigns in which management attorneys worked full time, including cases in which attorneys traveled from out of state and remained on site for weeks.  
  • Billing for travel time. Notably, the estimates above exclude the billing of travel time, a common practice for attorneys. Union-avoidance attorneys are often based in different states than the campaigns they handle and thus may bill extensively for travel. Depending on the number and length of trips, billed travel can add substantial hours to a campaign. For example, two 12-hour round trips would add 24 billable hours.15

Taken together, these sources suggest hours billed by an attorney range from about 17 hours per week for lower and moderate-intensity campaigns to 40 hours per week for intensive campaigns. LaborLab therefore uses 20 hours per week for a single attorney of record as a conservative default assumption for a campaign in which non-attorney consultants are not retained and the attorney provides all the campaign services. We lower this default to 10 hours for campaigns that also involve non-attorney consultants. This is on the presumption that services provided by non-attorney consultants tend to substantially lighten the campaign-services workload of attorneys, though there are cases that suggest our assumed reduction may be overly conservative.16

Number of attorneys of record as fractional estimate multiplier 

Attorneys of record listed on an NLRB case docket are often not the only attorneys providing representation or campaign services to an employer; additional attorneys may work behind the scenes and sometimes those attorneys may even belong to other law firms. Moreover, work is not necessarily divided equally among the attorneys working on an anti-union campaign.17 

Nevertheless, attorneys and organizers interviewed by LaborLab have suggested that the number of attorneys of record (partner or associate) can reasonably serve as a partial predictor of total attorney hours billed to an employer. LaborLab therefore estimates total attorney costs based partly on the number of attorneys of record. According to practitioners interviewed by LaborLab, total hours billed by the firm are generally higher in cases that involve more than one attorney of record, but usually not to the extent that they double with two attorneys of record, triple with three, and so forth. Based on the suggestion of interviewees, LaborLab accordingly reduces its default assumption from 20 to 15 hours per week per attorney when two or more attorneys of record are involved in campaigns without non-attorney consultants, and from 10 to 7.5 hours per week per attorney when two or more attorneys are involved in campaigns that also use non-attorney consultants. 

Due to limited data, and for the sake of simplicity, hours in cases involving more than  one attorney of record are allocated evenly to attorneys in the calculator’s interface and graphical output, by default.  But as mentioned, for campaigns involving multiple attorneys, it should be borne in mind that work likely was distributed unevenly between them. In such cases, it should also be understood that unknown attorneys working behind the scenes and sometimes even belonging to different law firms may have mostly or exclusively performed particular forms of work, especially campaign services. In these cases, our estimates may significantly understate the attorney fees of an employer.18

Additional hours billed for election hearings 

LaborLab assumes that at least 50 additional attorney hours are billed when an employer formally challenges a bargaining unit in a one-day election hearing, with eight additional hours for each subsequent hearing day. This assumption is based on interviews with attorneys and encompasses hearing preparation, time spent at the hearing and preparation of post-hearing briefs. Practitioners said major firms routinely have two or more attorneys present at hearings, meaning our default will significantly understate attorney hours in some cases.19 

Case evidence indicating that the assumptions may be conservative. In several campaigns for which LaborLab has obtained information about employer attorney expenditures, actual spending substantially exceeded what the default assumptions would predict. In one campaign involving 174 eligible voters, three law firms — only one of which, Ogletree Deakins, was listed as a firm of record — collectively billed the employer an estimated more than 100 hours per week, assuming an average rate of $500 per hour. This is nearly seven times the weekly attorney hours (and nearly seven times the total attorney fees) that LaborLab’s default assumptions would have predicted. Furthermore, the estimated 100+ weekly hours were billed over a longer timeline than our default assumptions would have predicted, with the employer hiring attorneys weeks before a petition was filed.

The employer reported $497,697 in attorney fees and an additional $468,370 in non-attorney consultant fees associated with a campaign involving 174 eligible voters. 

This is likely an unusually resource-intensive campaign.20 The case nevertheless illustrates the extent to which actual attorney expenditures can far exceed LaborLab’s default estimates. It’s also consistent with the much greater number of hours (88 per week) suggested by the 1995 study for more “expensive” campaigns at a “small-to-medium size firm” and with other evidence reviewed above. 

Cost of non-attorney consultants

Role

Employers often hire third-party, non-attorney consultants to provide many of the same campaign services as attorneys, as distinct from attorneys’ representation services before the NLRB. In addition to providing behind-the-scenes advice, consultants may communicate directly with workers to influence their views on unionization, and they may collect information about the workers or the union. These last two activities are known as “persuader activities.” 

Under the Labor-Management Reporting and Disclosure Act (LMRDA), consultants (within 30 days of an employer agreement) and employers (by March 31 of the following year) are required to publicly disclose certain agreements and expenditures for such services. Consultants report such agreements on Form LM-20, while employers report covered agreements and expenditures on Form LM-10. Consultants also file annual Form LM-21 reports covering certain receipts and disbursements.

These reporting requirements are one reason that consultants, like attorneys, often work exclusively behind the scenes, filtering campaigns through supervisors and managers rather than communicating directly with workers.21 Another is that consultants know that supervisors can often be more credible messengers than outside strangers like themselves.22 Even when consultants engage in persuader activities, they often neglect to report them. 

Nonetheless, there are some cases in which consultants (in LM-20s and 21s for consultants) and employers (LM-10s) report persuader activities, albeit usually past the required deadline (30 days from agreement date in the case of LM-20s and March 31 in the case of LM-10s and 21s).23 Hourly rates and/or total expenditures reported in these forms should be used for estimates whenever available.

Default assumptions

  • Campaign timeline: Known or reported start date through the election date (or date the ballot tally is issued if election date is unavailable). In the absence of a known start date, petition-filing date should be the start date. (Note: start dates can be found in LM-20s and LM-10s if filed.)
  • Hourly rate or total spending: If reported in an employer LM-10, total spending should be used. If total spending is unavailable but hourly rate billed for consultant’s services has been reported in an LM-20, reported rate should be used. If neither is available, $400 per hour per consultant is assumed.24
  • Weekly hours billed:
    • Eight hours per day, five days a week. 
    • Note: If the consistency of the consultant/s work is in doubt and the campaign is at a small employer or extends over an unusually long period, reducing the assumed average to six or four hours per day should be considered. 
  • Expenses: 
    • Daily expenses of $300 per day and one $500 round trip per week throughout the consultant’s work period.

Justifications

Start date

LM-20 reports reviewed by LaborLab indicate that non-attorney consultant start dates tend to fall around the petition-filing date, sometimes a few days (or even a week or two after a petition is filed) but also often well before a petition is even filed. Therefore, unless a consultant’s actual start date has been reported in an LM-20, LaborLab uses the petition-filing date as the default start date. 

Hourly rates or total spending 

The median hourly rate billed to employers by consultancies for persuader services was $425/hr in 2025, while the average hourly rate was $427/hr, according to a LaborLab analysis of the 183 unique LM-20s filed in 2025. The overwhelming majority of observed rates fell between $350 and $475 per hour, with rates overall ranging between $187/hr and $625 per hour. 

Recent examples of rates charged by prominent anti-union consultancies are consistent with this range. LRI Consulting Services billed Stavola Asphalt Company/Arcosa $425 per hour and Cayuga Health System $525 per hour; East Coast Labor Relations billed Valuepoint Materials Solution $4,200 per day, equivalent to $525 per hour assuming an eight-hour work day; and RoadWarrior Productions billed Amazon $3,800 per day, equivalent to $475 per hour on the same basis. 

In the absence of an hourly rate reported in an LM-20 or total spending reported in an employer LM-10, LaborLab therefore conservatively assumes a consultant billing rate of $400 per hour. This is below both the median and average hourly rates in LaborLab’s analysis and toward the lower end of the range of commonly observed rates.

Hours billed

Workers and union staff frequently report consultants working full time on anti-union campaigns, and former union-avoidance consultant Martin Levitt describes full-time campaign work throughout his memoir. LaborLab’s comparisons of total spending reported in employer LM-10 reports with consultant work periods reported in LM-20 reports also indicate that full-time work is the norm. 

That said, consultants may work a fewer number of hours per day on average in some cases and also may cycle in and out for stints. This is more likely for work at small employers or during extended campaigns involving multiple consultants, though full-time work at small employers still appears to be typical. Consultants also frequently conduct “post-election work” for employers, such as to “union-proof” a victorious employer against a repeat organizing attempt or to guide a defeated one through bargaining (alongside one or more attorneys).25

With these patterns in mind, LaborLab’s default assumption is that consultants work eight hours per day, five days per week, from their reported start date — or the petition-filing date when no start date is available — through election day. LaborLab may lower assumed daily hours for campaigns at small employers where doubt exists as to the consistency of consultants’ work, even though consultants certainly have been known to work full time targeting tiny bargaining units – sometimes at a cost of $10,000 per eligible worker or more.26 We also may lower assumed daily hours for unusually long campaigns, particularly when consultant work began well before a petition was filed. (In pre-petition anti-union campaigns, assuming consultants perform four hours of work per day on average before a petition may be merited.) 

Lost paid time of in-house campaign leaders

Role

Employers commonly appoint one or more supervisors as campaign leaders to direct and/or coordinate the anti-union campaign. These teams typically include human resources professionals. One consultant writes that HR professionals have the “most to lose” if a union wins and that most HR professionals and operations managers wish to remain union-free.27 

Sometimes the campaign team is led or overseen by union-avoidance attorneys and/or non-attorney consultants hired by the employer. Other times the reverse is true.28 An anti-union manual by consultant Ben Johnson, a former union president, recommends a response team composed of representatives from an employer’s legal, HR and operations divisions, since the response team typically must coordinate the three fields. 29

Larger employers have often already created union-avoidance teams before an organizing campaign begins. An article published by the Society for Human Resource Management (SHRM), titled “HR’s Role in Forming a Rapid Response to Union Activity,” advises that the formation of a “rapid response” team “should occur prior to, and independent of, any suspected union activity” and that the team should include HR specialists and a “cross section of supervisors and managers.”30 

Default assumptions:

  • Campaign period: Date petition is filed to election date, or, if unavailable, tally-issued date. 
  • Daily paid hours spent on campaign:
    • Six hours if no non-attorney consultants are used.
    • Four hours if non-attorney consultants are used.
  • Hourly wage: $67 per hour
  • Number of campaign team members:
    • One leader for up to 50 workers; two for 51 to 100; three for 101 to 200; and one additional team member for every 200 workers after that, with a cap of eight campaign leaders for a bargaining unit of more than 1,200 workers. 

Justifications

Start date

Assembling a campaign team is often one of the first steps in an anti-union campaign and may occur well before an organizing effort reaches the petition stage. LRI Consulting advises employers to form such “campaign defense teams” as “quickly as possible,” describing them as the “hinge point” of winning an election.31 

On this basis, LaborLab conservatively uses the petition-filing date as the default start for the in-house campaign team when its actual start date is unknown.

Hourly wage

Human resources professionals, particularly employee relations or labor relations specialists, overwhelmingly play a key role in anti-union campaigns. As mentioned, SHRM advises employers to include HR specialists on campaign response teams. Similarly, an anti-union manual written by the founder of LRI Consulting states that “Most employers select the personnel director [human resources manager] as campaign manager.”32 

On this basis, LaborLab uses the hourly wage of a human resources manager as the default hourly wage of an in-house campaign leader. The Bureau of Labor Statistics reported an hourly wage of $67 for human resources managers in 2025.33

Number of in-house campaign leaders

HR specialists usually serve on campaign teams, often alongside other managers. In the absence of campaign-specific information, LaborLab therefore conservatively uses the typical number of HR professionals in a workforce as a starting point for estimating the number of in-house campaign leaders.

The median HR-to-employee ratio was 1.98 HR employees for every 100 workers in 2025, according to a SHRM survey.34

Using this ratio as a starting point, LaborLab assumes one campaign leader for up to 50 workers, two for 51 to 100 workers, and three for 101 to 200 workers. Because campaign teams may not increase proportionately with bargaining-unit size, LaborLab then adds one campaign leader for every additional 200 unit members, up to a default cap of eight.

This declining leader-to-worker ratio is intended to account for economies of scale Also with these economies of scale in mind, LaborLab conservatively caps the number of in-house campaign leaders at eight. This is the number of campaign leaders that oversaw a campaign targeting a unit of 2,000 that LaborLab became familiar with. In that case, they were joined by at least five union-avoidance attorneys and seven non-attorney consultants. But there are reported cases of much larger teams of campaign leaders, especially at regional or national employers.35 

Indeed, national employers may appoint regional and national HR managers, executives, and employee/labor relations specialists as campaign leaders, on top of location managers. Notably, many of these managers – especially employee and labor relations specialists – tend to be union-avoidance experts and sometimes are former (or future) anti-union consultants. Where an employer is known to deploy national or regional managers, a significantly larger number of campaign leaders than our assumptions would predict should be considered. 

AutoZone, for example, recently deployed 11 national operations and human resources managers and 6 regional operations and human resources managers to wage an anti-union campaign against a unit of only 11 employees, on top of the store manager and assistant manager who were also enlisted in the campaign, according to LaborLab sources who provided evidence to back up the claim. In another scorched-earth case, Walmart flooded a store with 20 outside executives to counter an organizing campaign involving 18 technicians. This response force included a designated “labor team” that flew in from corporate headquarters.”36

Daily paid hours spent on campaign

LaborLab’s assumption that an in-house campaign leader spends an average of four to six hours per day on campaign activities is based on reports in anti-union manuals that this work can occupy much or all of a manager’s workday. One LRI Consulting manual states that “in most cases, the campaign will be a full-time job for the entire campaign period.”37 A survey of employers about their anti-union campaigns similarly found that human resources specialists tended to spend “at least” four hours per day on campaign activities, and, in some cases, worked on them full time.38 

On this basis, LaborLab assumes six hours per day for campaigns without non-attorney consultants and four hours per day for campaigns that use non-attorney consultants. The lower conservative assumption reflects LaborLab’s expectation that in-house campaign leaders generally invest less time in a campaign when non-attorney consultants are also providing campaign support or leadership, though this may not necessarily be the case.

Lost paid time of other managers and supervisors

Role

Anti-union consultants and attorneys emphasize that securing the cooperation and enthusiastic participation of front-line supervisors in anti-union campaigns is critical to their success. Supervisors may be directed by anti-union campaign teams to engage in activities including rating and reporting the perceived union support of employees on an ongoing basis; undergoing anti-union “education,” training and coaching, often alongside “dos and don’ts” legal education; holding one-on-one and group meetings with workers; distributing anti-union literature; and participating in campaign strategy meetings.39 

The common responsibility of supervisors to regularly gauge and report the perceived union support of their subordinates can be particularly time-consuming. In addition to putting workers under heightened scrutiny, supervisors may need to engage in open-ended conversations to elicit clues about their subordinates’ union sentiment rather than poll them directly.40 One HR Magazine article notes that supervisors must be told “they cannot interrogate employees,” but that they can still “lawfully position themselves to be aware of issues of concern to employees because employees will often open up … especially if the supervisor has strong people skills.”41

Default assumptions

  • Campaign period: Date petition is filed to election date or, if unavailable, tally-issued date. 
  • Employee-to-supervisor ratio (“span of control”):
    • One supervisor for every 12 workers.
  • Daily paid hours spent on campaign:
    • 1.5 hours if only an attorney is used.
    • One hour if both an attorney and non-attorney consultant are used.
  • Hourly wage: Industry-specific wage data available through the Bureau of Labor Statistics or, when unavailable, other wage-data sources such as ZipRecruiter or Salary.com.  

Justifications

Supervisor start date 

The involvement of supervisors in an anti-union campaign may not begin in earnest until a number of days after a petition is filed. But writings on union-busting suggest supervisors are likely to undergo at least some campaign training and be directed to engage in some degree of anti-union activity, such as gauging preliminary union support among their subordinates, shortly after an employer discovers organizing activity — which may occur before a petition is filed.42 On this basis, LaborLab’s default assumption is that supervisors begin campaign work on the petition-filing date, just as with attorneys, non-attorney consultants and in-house campaign leaders.

Number of supervisors

The typical “span of control” – the number of workers for every supervisor – varies by industry, and industry-level averages should be used where available. In the absence of such data, LaborLab assumes one supervisor for every 12 workers, based on Gallup and the Bureau of Labor Statistics data.43 

Daily paid hours spent on campaign 

Writings on union-busting suggest rank-and-file supervisors may spend hours of paid time on campaign-related activities each day.44 In Confessions of a Union-Buster, for example, former anti-union consultant Martin Levitt described calling in a key group of eight supervisors multiple times a day to discuss the union sentiments of their subordinates and directing them to speak to multiple workers, also the same day. The Associated Building Contractors, meanwhile, advises member contractors concerned about organizing to tell supervisors to talk to “everyone they supervise on at least a daily basis” and to “report regularly and promptly what they find out in their conversations with employees” about organizing activity.45 

A survey of employers about their anti-union campaigns found that supervisors spent an average of two hours per day, or 10 hours per week, on campaign activities.46 

Based on these sources, LaborLab conservatively assumes that front-line supervisors spend an average of 1.5 hours per day on an anti-union campaign that involves an attorney but no non-attorney consultant, and one hour per day on campaigns that include both an attorney and a consultant. We lower the assumed daily hours in the second scenario on the presumption that supervisors spend less time on campaign activities when non-attorney consultants are hired to perform some campaign work.

Lost paid time of workers

During an anti-union campaign, employers typically require workers to attend group meetings (often one per week) and may also hold one-on-one meetings between workers and supervisors and/or consultants to gauge union sentiment, deliver anti-union messages and distribute campaign materials.47 Workers may also lose time to interactions with anti-union coworkers who are permitted, sometimes tacitly, to campaign against the union on paid time. Previous studies have found that between one-third and one-half of employers help create or support “Vote No” committees of workers.48

Default assumptions

  • Campaign period: Date petition is filed to election date or, if unavailable, tally-issued date. 
  • Daily paid hours lost to campaign:
    • 0.17 hours (about 10 minutes)
  • Hourly wage: Absent direct knowledge, industry and occupation-specific wage data available through the Bureau of Labor Statistics or other wage-data sources such as ZipRecruiter or Salary.com. 

Justifications

Hourly wages

Absent direct knowledge, LaborLab adopts the average hourly wage of unit members based on industry and occupation wage data or job openings with pay rates. This information is available through sources including the Bureau of Labor Statistics, ZipRecruiter, Salary.com and Indeed.com. 

Paid time lost

Writings on anti-union campaigns and reports to LaborLab suggest that group meetings typically last between 30 minutes and 1 hour, and that employers usually hold them on a weekly basis over the course of a campaign.49 LRI Consulting’s anti-union manual recommends a minimum of six group meetings or presentations and notes that five or six group meetings during a campaign may equal “up to eight hours of work time” lost.50 A survey study similarly found that these meetings tend to last about an hour.51 

In addition, as discussed above, workers may participate in one-on-one meetings and other campaign-related exchanges with supervisors.52 These interactions collectively eat up at least an average of five or 10 minutes of work time per week, based on reports from organizers.  As previously mentioned, workers also may lose time to interactions with anti-union coworkers campaigning against the union on paid time.53

On this basis, LaborLab conservatively assumes employees lose an average of about 10 minutes per workday (.167 hrs) to the anti-union campaign, equal to 50 minutes of paid time per five-day workweek.

Productivity loss

Scholars and practitioners have observed that employers may incur significant productivity losses during anti-union campaigns.54

Default assumptions

  • Campaign period: Date petition is filed to election date or, if unavailable, tally-issued date. 
  • Loss rate
    • 5%
    • Note: Increase should be considered for production involving high degree of manual labor and decrease should be considered for low degree

Justifications

Philip B. Wilson, president of Labor Relations Institute, a prominent union-avoidance consultancy, has described a union election as a “stressful, complex process” that includes an “enormous loss of productivity.”55 A paper by three academics similarly identifies avoidance of potentially “disharmonious labor relations” and productivity losses associated with an anti-union campaign as an economic benefit that may result from voluntary union recognition.56 

The productivity loss estimated here is distinct from, and in addition to, paid employee time devoted directly to campaign activities. The latter consists of paid working time spent attending meetings or otherwise participating in campaign-related activities rather than performing normal work.57 

The productivity loss estimated in this section instead refers to reductions in output during time employees are still working. Such losses may result from campaign-related effects on morale, cooperation and concentration and/or if the employer slackens the pace of work during the campaign to curry favor with workers.

Drawing on a past survey of the cost of anti-union campaigns, LaborLab estimates the cost of a productivity loss by multiplying the productivity loss rate by the average hourly wages and benefits, by the number of workers, by the average daily number of hours worked (excluding daily hours lost entirely to anti-union meetings), by the average number of days worked during the campaign period.58

The referenced study found an average productivity loss of 8% during anti-union campaigns, although the magnitude varied considerably by industry and workplace. The study estimated losses of approximately 1% to 2% in continuous-process industries, where workers primarily monitor highly automated production; approximately 8% in industries involving a mixture of hand and machine operations by semi-skilled and unskilled workers; and as much as 15% in industries involving a “great deal of hand labor.”59 

Based on this, LaborLab conservatively assumes a default productivity loss of 5%. However, users should consider increasing or decreasing the rate based on industry and the nature of the work. In addition, there may be cases where anti-union campaigns do not result in any productivity loss at all, such as in one case LaborLab is familiar with where the perception of hyper-surveillance among workers during a campaign reportedly offset the negative impact that campaign-related distraction might otherwise have on productivity. 

In some services industries, productivity losses may manifest as reductions in service quality, fewer customers served per hour or some combination of the two. 

Administrative fees, materials and media

Employers must pay for or reimburse the cost of a range of administrative fees associated with an NLRB representation case, as well as the cost of campaign materials and media. 

Default assumption

  • 2.5% of external costs + cost of total paid time of supervisors spent on campaign activities

Justifications

Fees can include filing fees and deposition charges. Materials and media can include handouts, posters, buttons, T-shirts, anti-union websites, anti-union videos, text-messaging systems, and print and digital ads targeted at workers and, in some cases, the public more broadly.60 

As an example of the potential cost of one form of campaign media, a recent proposal that Reliant Labor Consultants, a prominent union-avoidance firm led by Joe Brock, submitted to Gordon Food Service stated that “typical communication costs,” inclusive of production and acting talent, are “$5,500 per video with an additionally hourly rate for set up and sending via text messaging platform.”61 Meanwhile, an engagement letter submitted by IRI Consultants (People Results) to Howmet Aerospace stated that a three-month texting campaign would cost an estimated $9,500 for the first three months and $550 per month after, with “content development/production billed separately”; development of a website would cost an estimated $26,600 including research; and site maintenance and updates would cost $6,600 annually.62

As an example of potential fees charged by a law firm, Barnes & Thornburg states in a contract that the firm may bill clients separately for filing fees, court reporters, phone and web conferences, messengers and couriers, photocopying and printing, data storage, e-discovery data hosting, litigation-support technology, computerized research and clerical services, among other things.63 

These costs vary widely depending on the campaign and rise with the intensity of the campaign and the number of workers targeted. 

Government Resources Consultants of America charges “an overall communication/administration charge” equal to 4 percent of the professional fees it bills for consulting work, according to its recent agreements with employers. 

With GRCA’s 4 percent fee as a reference point, LaborLab calculates the cost of fees and materials by multiplying the combined cost of paid campaign time for supervisors and managers, attorney fees and consultant fees, if applicable, by a small fraction.64

On the basis of data points referenced above, LaborLab set this fraction at a conservative 2.5% by default. 

Acknowledgments

LaborLab thanks the attorneys and organizers who provided information and feedback that helped inform our default assumptions, especially AK Alilonu.

Endnotes

1. “Overview/Summary. Persuader Agreements: Ensuring Transparency in Reporting for Employer and Labor Relations.” United States Department of Labor. Last accessed September 5, 2026. https://static.politico.com/24/b9/727920a748889063f7ce7213ab5d/persuader-rule-fact-sheet.pdf 

2.  Lafer, Gordon. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work Report. Pp. 41. Lafer compiled six estimates and provided them in $2004. The ranges provided here reflect their adjustment for inflation (July $2026). 

3.  Lafer, Gordon. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work Report. P. 14. (“These figures do not include the cost of anti-union letters, leaflets, posters, videos, buttons, t-shirts or other paraphernalia; the time of senior management devoted to planning the campaign; the time of supervisors spent communicating with, monitoring or reporting back on their subordinates; nor the time of employees in mandatory anti-union meetings, whether with individual supervisors or in larger groups. These estimates likewise exclude most of the expenses of attorneys and consultants apart from their hourly fees. If this full range of expenses were taken into account, the per-employee expenditure of anti-union employers would likely be significantly higher than the estimates provided here.”); Logan, John. 2006. “The Union Avoidance Industry in the United States.” British Journal of Industrial Relations. 44(4). P. 656. (After reporting that Catholic Healthcare West paid the consultancy Burke Group $2.8 million [$5.8 million in 2026$] for its services during an anti-union campaign 1998 , Logan noted that, “Other significant costs include employee time off to attend captive audience meetings and management time off to conduct group and individual meetings.”) 

4.  National Labor Relations Board Representation. CTM Legal Group Attorneys at Law. Last retrieved August 17, 2026: https://www.ctmlegalgroup.com/practice-areas/labor-and-employment/national-labor-relations-board-representation; Gordon, Lafer. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work; “Ambushed! The NLRB Changes the Rules.” The Practical NLRB Advisor. Ogletree Deakins. Last retrieved at: https://ogletree.com/practices-industries/traditional-labor-relations/

5.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4).Pp. 440-441;  Logan, John. 2006. The Union Avoidance Industry in the United States. British Journal of Industrial Relations. 44(4); Gordon, Lafer. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.”; 

6.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). Pg. 441. (“None of the attorneys we interviewed performed only the narrow function of legal counsel and, apparently, only a small number of attorneys in the region so limit their activities. Rather, the typical pattern is for the attorney to take an active role in formulating and implementing the campaign strategy,”)

7.  Kaufman, Bruce E. and Paula E. Stephan. 1995. Pg. 442. (“A third difference between lawyers and consultants is that the former typically refrain from talking directly to employees in the proposed bargaining unit about campaign-related issues, while consultants often hold such discussions. The reason is that Section 203 of the Landrum-Griffin Act requires that any consultant or ‘independent contractor’ employed by a finn whose object is to directly persuade employees as to the exercise of their rights to organize and collectively bargain must file a public financial disclosure form with the Department of Labor. Attorneys strongly resist registration because unions can then discover the large amounts of money firms are spending on union avoidance and reveal it to the employees as an anti-company campaign tactic — a consideration that consultants give less weight to, both because their hourly rate tends to be substantially less than that of attorneys’ and because directly talking to employees is marketed by consultants as a tactic that gives them a higher probability of victory.”)

8.  Wilson, Philip B. 2014. Left of Boom: Putting Proactive Engagement to Work. Labor Relations Institute. P. 43. (“… union authorization cards are the last step before a union files a petition. If you see authorization cards or leaflets, you have an organizing campaign on your hands. Contact your labor attorney immediately and get your counter-organizing campaign started.”) Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). P. 440; “What to Do When Union Organizing Starts.” 2022. Associated Building Contractors Handbook on Practical Labor Law. Pg. 12, 7 (The following statements from a guide for staff of local ABC chapters reflects the view that employers should hire an attorney as soon as they have concerns about union organizing activity, which often comes before a union petition is filed for an election and probably typically begins, at the latest, when the employer is presented with a demand for recognition, which comes before the union petitions for an election: “When contacted by a member company that thinks it has a union organizing problem, chapter staff should first tell the member to contact the chapter attorney or other labor counsel.  Appearing in a red box in the only all-caps text in the nine-page document, the business association guide also states earlier, “IT IS STRONGLY RECOMMENDED THAT EMPLOYERS OBTAIN EXPERIENCED LABOR COUNSEL TO ADVISE THEM IMMEDIATELY UPON RECEIVING A UNION PETITION BEFORE RESPONDING TO ANY REQUESTS FOR INFORMATION FROM THE UNION OR THE NLRB.”)

9. As an example, Littler Mendelson’s engagement letter with the City of Peekskill, NY states that “the hourly rates of other attorneys in the Firm who may assist in representing you range from $305 to $1,760 and from $100 to $750 for non-attorneys. However, as a courtesy to the City we will bill at the following discounted rates: Shareholders-$550; Senior Counsel/ Special Counsel/ Of Counsel/ Counsel-$450; Associates-$400; and Paralegal rates will be capped at $275.” Last retrieved August 17, 2026: https://www.cityofpeekskillny.gov/DocumentCenter/View/2531/City-of-Peekskill-Engagement-Agreement-2025—Littler. Also cited in: Dayen, David. 2025. “Anti-Union Law Firm Tells Clients to Go Ahead With Illegal Union-Busting Tactic.” The American Prospect. Last retrieved August 17, 2026: https://prospect.org/2025/09/01/2025-09-01-anti-union-law-firm-illegal-captive-audience-littler-mendelson-rhode-island/

10.   Levitt, Martin and Terry Conrow. 2021. Confessions of a Union Buster. Xandland XL Press: Bullard, TX.  P. 5. 

11.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). P. 451. 

12.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). P. 443, 451. (The authors highlighted two examples of expensive campaigns at large employers that illustrate how the number of hours billed can reach such heights: “One was a campaign in a large regional airline that involved twenty attorneys who conducted extensive one-on-one personal interviews with every supervisor in the company; the second was a campaign at a large multi-plant utility where eight attorneys/consultants compiled a book with a detailed analysis of the likely voting behavior of each employee in the election unit.”)

13.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). P. 451. 

14.  Levitt, Marty and Terry Toczynski. 2021. Confessions of a Union-Buster. Xandland XL Press: Bullard, TX. P. 42. 

15.  Rothman, Jordan. 2025. “Policies On Billing For Attorney Travel Time.” Above the Law. Last accessed September 5, 2026: https://abovethelaw.com/2025/05/policies-on-billing-for-attorney-travel-time/

16.  Payments made by US Sugar Savannah Refinery to three law firms, for example, slightly surpassed those made to a consultancy even though the consultancy’s operatives appeared to worked full time during the campaign, according to an LM-10 form filed by the employer and a corresponding NLRB case docket. Only one law firm was listed as a law firm of record (Ogletree Deakins) on the NLRB election’s case docket. The other two – Barnes & Thornburg and Gunster Yoakley & Stewart apparently worked on the campaign behind the scenes. Original LM-10 filed December 13, 2024 and accessed August 18, 2026: https://olmsapps.dol.gov/query/orgReport.do?rptId=901374&rptForm=LM10Form; Amended LM-10 filed June 2, 2025 that removed and changed the attribution of some reported payments, likely after determining that some payments were exempt from reporting requirements (also accessed August 18, 2026): https://olmsapps.dol.gov/query/orgReport.do?rptId=917868&rptForm=LM10Form. Corresponding NLRB representation case: https://www.nlrb.gov/case/10-RC-333912

17.  For example, US Sugar Savannah Refinery hired three law firms to help prosecute an anti-union campaign in late 2023 and early 2024, according to an LM-10 form filed by the employer reporting that the three engaged in persuader activities. Only one law firm was listed as a law firm of record (Ogletree Deakins) on the NLRB election’s case docket. The other two – Barnes & Thornburg and Gunster Yoakley & Stewart apparently worked on the campaign behind the scenes. Original LM-10 filed December 13, 2024 and accessed August 18, 2026: https://olmsapps.dol.gov/query/orgReport.do?rptId=901374&rptForm=LM10Form; Amended LM-10 filed June 2, 2025 that removed and changed the attribution of some reported payments, likely after determining that some payments were exempt from reporting requirements (also accessed August 18, 2026): https://olmsapps.dol.gov/query/orgReport.do?rptId=917868&rptForm=LM10Form. Corresponding NLRB representation case: https://www.nlrb.gov/case/10-RC-333912

18.  This appears to have been the case when US Sugar Savannah Refinery reported using three law firms to handle campaign work, according to an LM-10 form filed by the employer and the corresponding NLRB case docket. Only one law firm was listed as a law firm of record (Ogletree Deakins) on the NLRB election’s case docket. The other two – Barnes & Thornburg and Gunster Yoakley & Stewart apparently worked on the campaign behind the scenes. Original LM-10 filed December 13, 2024 and accessed August 18, 2026: https://olmsapps.dol.gov/query/orgReport.do?rptId=901374&rptForm=LM10Form; Amended LM-10 filed June 2, 2025 that removed and changed the attribution of some reported payments, likely after determining that some payments were exempt from persuader reporting requirements (also accessed August 18, 2026): https://olmsapps.dol.gov/query/orgReport.do?rptId=917868&rptForm=LM10Form. Corresponding NLRB representation case: https://www.nlrb.gov/case/10-RC-333912

19.  Codd, Mark. 2020. Voice of the Employer: A Mixed-Methods Study of Winning Messages for NLRB Elections. PhD. dissertation, Nova Southeastern University. Davie/Ford Lauderdale, FL. P.157-158. (Cited in a dissertation written by a non-attorney consultant, a fellow non-attorney consultant interviewed for the study cautioned against challenging a bargaining unit because it “can be extremely expensive.”)

20.  In an amended LM-10 form, the employer later removed some reported payments and switched the organizational affiliation of a named attorney, presumably after determining that some payments were exempt from reporting requirements. Original LM-10 filed December 13, 2024 and accessed August 18, 2026: https://olmsapps.dol.gov/query/orgReport.do?rptId=901374&rptForm=LM10Form; Amended LM-10 filed June 2, 2025 and accessed August 18, 2026: https://olmsapps.dol.gov/query/orgReport.do?rptId=917868&rptForm=LM10Form. Corresponding NLRB representation case: https://www.nlrb.gov/case/10-RC-333912; NLRB case docket available at nlrb.gov: https://www.nlrb.gov/case/10-RC-333912

21.  Logan, John. 2006. “Lifting the Veil” on Anti-Union Activities: Employer and Consultant Reporting under the LMRDA, 1959–2001” in Advances in Industrial & Labor Relations. Emerald Publishing: Bingley, West Yorkshire, UK. Pg. 309. (“Because the coordination of union avoidance campaigns through front-line supervisors was the most prevalent form of consultant activity, the DOL’s new policy effectively eliminated from reporting and disclosure a major form of anti-union campaigning.”); Lawrence, A., & Williams, J. (1983a). “Union busters and the Law: Consultant and employer non-compliance with reporting requirements of the Landrum-Griffin Act in California.” Center for Labor Research and Education, Institute of Industrial Relations, University of California-Berkeley. (Cited in Logan 2006’s “Lifting the Veil.” Full names of researchers unknown. Logan summarizes the study as follows: “Another study of consultant activities in California found that less than one percent of employers and consultants engaging in reportable activity actually filed reports with the DOL.”);  Levitt, Martin and Terry Conrow. 2021. Confessions of a Union Buster. Xandland XL Press: Bullard, TX. Pg. 41. (A former consultant, Levitt wrote that “few union-busters” file LM-20 reports, because persuading workers through supervisors allows consultants to “easily slide out from under the scrutiny of the Department of Labor.”)

22.  Jackson Lewis. 1997. Winning NLRB Elections: Avoiding Unionization Through Preventive Employee Relations Programs. 4th Ed. Employment & Human Resources Management Professional Series. Jackson, Lewis, Schnitzler & Krupman: New York, NY. P.  Confessions of a Union Buster. Xandland XL Press: Bullard, TX. P. 10. 

23.  2023. “Busting the union busters: The need to improve transparency around union-busting activity.” Economic Policy Institute and LaborLab.

24.  If total spending has been reported in an LM-10, that amount can be directly inputted through using the “set total directly” option in the consultant cost section of the calculator.

25.  Levitt, Martin and Terry Conrow. 2021. Confessions of a Union Buster. Xandland XL Press: Bullard, TX.  P. 55.  Wilson, Phillip B. Left of Boom: Putting Proactive Engagement to Work. 2013. Labor Relations Institute: Broken Arrow, OK. Pp. 19-20. (“The bulk of our work is with companies after they have successfully defended themselves against a union organizing attempt (a boom event in an organization).” 

26.  For example, this appears to have been the case when Pye-Barker – which is majority-owned by the private-equity firm Leonard Green and Partners – apparently spent $9,495 per eligible voter ($67,168 / 7 eligible voters), $10,021 per eligible voter ($80,164 / 8 eligible voters) and $9,683 per eligible voter ($96,834 / 10) on three anti-union campaigns targeting petitioned-for units of between seven and 10 eligible voters. The cost of these campaigns may have been closer to roughly double those spending amounts if attorney expenses and other costs are taken into account. Private Equity Stakeholder Project reported on these campaigns in more detail. “Union busting at Leonard Green’s Pye-Barker.” 2026. Private Equity Stakeholder Project. Last retrieved September 7, 2026: https://pestakeholder.org/news/union-busting-at-leonard-greens-pye-barker/

27.  Wilson, Phillip B. Left of Boom: Putting Proactive Engagement to Work. 2013. Labor Relations Institute: Broken Arrow, OK. Pp. 19-20. (“Most HR professionals, and almost all operations people (even officers of very large companies)” answer “no” to the question, “you don’t want a union, right?” Wilson writes. In comments that exaggerate the impact of unionization on HR professionals, but nonetheless have some truth to them, he adds, “Human resources professionals have the most to lose when their workplace becomes unionized. Their jobs change dramatically, or they’re fired and a ‘labor’ person is brought in.”)

28.  Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). 441. (“… the typical pattern is for the attorney to take an active role in formulating and implementing the campaign strategy, although the degree of involvement ranges from near-complete control and orchestration of the campaign in some firms to a more subordinate role in others where the attorney functions as an advisor to top management, the personnel director, or an outside consultant.”)

29.  Johnson, Ben. 2021. Finding the Pearl in the Storm. Self-published. P. 29. (“Campaigns are predictable in their unpredictability; prepare for the unexpected. Designate and prepare a response team that coordinates the company’s legal, HR, and operations divisions. (Your needs may vary, but this is a typical arrangement.)”

30.   Segal, Jonathan A. 2022. “HR’s Role in Forming a Rapid Response to Union Activity: Do you have a message prepared if labor starts to organize your workplace?” HR Magazine. Spring Issue. Pp. 19-20. 

31.  Segal, Jonathan A. 2022. “HR’s Role in Forming a Rapid Response to Union Activity: Do you have a message prepared if labor starts to organize your workplace?” HR Magazine. Spring Issue. Pp. 19-20; Wilson, Phillip B.”How To Win (And Prevent) An Ambush Election: The Strategies and Tactics Needed to Win Elections Now.” White Paper. The Labor Relations Institute. P. 5. 

32.  Wilson, Donald P. 1997. Total Victory: The Complete Management Guide to a Successful NLRB Representation Election. LRI. Broken Arrow: Oklahoma. P. 69.

33.  Human Resources Managers. Occupational Outlook Handbook. Bureau of Labor Statistics. Last accessed: https://www.bls.gov/ooh/management/human-resources-managers.htm

34.  2025 CHRO Benchmarking: Insights to Power People Strategy. Data Brief. Society for Human Resources Management (SHRM). Available as of August 19, 2026 via: https://www.shrm.org/topics-tools/research/2025-chro-benchmarking–insights-to-power-people-strategy

35.  Anti-union consultant Marty Levitt described creating a “supervisor SWAT team” of 15 for a 500-worker unit in one campaign. Levitt wrote that the team “took charge of visiting the crews of uncooperative [with the anti-union campaign] foremen and making sure their workers got the same heavy doses of anti-union talk and subtle threats as everybody else.” Levitt, Marty and Terry Toczynski. 2021. Confessions of a Union-Buster. Xandland XL Press: Bullard, TX. P. 27

36.  Store management and workers reportedly took to calling the labor team “Nazi SS.” In addition to the 20 outside executives and managers, store managers, hourly department heads and Walmart’s shoplifting police were also reportedly enlisted in the anti-union campaign. The labor team reportedly held daily campaign meetings with the second two groups, with one associate who attended the meetings stating that, “We were basically spies.” Loss Prevention Lichtenstein, Nelson. 2009. “Why Wal-Mart Workers Need Free Choice Act.” In These Times. Last accessed September 7, 2026: https://inthesetimes.com/article/why-wal-mart-workers-need-efca; “Discounting Rights: Walmart’s Violation of US Workers’ Right to Freedom of Association.” 2007. Human Rights Watch. Last accessed Monday, September 7, 2026: https://www.hrw.org/report/2007/05/01/discounting-rights/wal-marts-violation-us-workers-right-freedom-association

37.  Total Victory: The Complete Management Guide to a Successful NLRB Representation Election. LRI. Broken Arrow: Oklahoma. P. 69.

38.  Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 15.

39.  Jackson Lewis. 1997. Winning NLRB Elections: Avoiding Unionization Through Preventive Employee Relations Programs. 4th Ed. Employment & Human Resources Management Professional Series. Jackson, Lewis, Schnitzler & Krupman: New York, NY. P. 168, 196; Wilson, Donald P. 1997. Total Victory: The Complete Management Guide to a Successful NLRB Representation Election. LRI. Broken Arrow: Oklahoma. Pp. 23 and 2 (One anti-union manual emphasizes that supervisors “must be properly trained and fully armed” and that anything less than a “positive and supportive” attitude towards the campaign is “unacceptable,” before going on to note that supervisors “can legally be dismissed or transferred during a campaign.”);  Logan, John. 2006. The Union Avoidance Industry in the United States. British Journal of Industrial Relations. 44(4): 651-675. P. 64, citing “Hughes, Charles. 1984. Union Free: A Systematic Approach. Dallas, TX: Center for Values Research, Inc. (According to Logan, Hughes, an anti-union consultant, wrote, “Every person in a leadership role must accept the union-free responsibility as part of the job, or leave … Disagreement with or deviation from this goal cannot be tolerated on the part of any manager or supervisor.’); Lafer, Gordon. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work. (“… under standard “union avoidance” strategy, supervisors are forced, on pain of termination, to engage each of the people under them in intimidating one-on-one anti-union conversations. Workers commonly report illegal threats being made in these meetings, since there are no witnesses present.” P 2; Kaufman, Bruce E. and Paula E. Stephan. 1995. “The role of management attorneys in union organizing campaigns.” Journal of Labor Research. 16(4). P. 447.

40.  “What To Do When Union Organizing Starts.” Date unknown but believed to be post-2020. ABC Chapter Handbook on Practical Labor Law. Associated Building Contractors (ABC). Pp. 12-13. (The guide states that as soon as an employer believes it has an organizing issue, supervisors should be told to “immediately increase their personal contacts with workers … to engage in informal conversations with them at every opportunity,” making a point of “talking to everyone they supervise on at least a daily basis,” and that the campaign leaders would be “kept fully informed on anything that supervisors learn about the organizing attempts or of any changes in attitudes, indications of union coercion, employee huddles, rumors, etc.” It further adds the employer “should set up a method for the senior management team and supervisors to report regularly and promptly what they find out in their conversations with employees” and that, “All leads should be immediately followed up in this hotline communication network.”)

41.  Segal, Jonathan A. 2022. “HR’s Role in Forming a Rapid Response to Union Activity: Do you have a message prepared if labor starts to organize your workplace?” HR Magazine. Spring Issue. Pp. 19-21.

42.  “What to Do When Union Organizing Starts.” 2022. Associated Building Contractors Handbook on Practical Labor Law. Pp. 12-13. (The guide states that as soon as an employer “thinks it has a union organizing problem,” management should hold a meeting to brief supervisors on the situation, “usually with labor counsel present” and “find out what they know about it.” It adds that supervisors should also be “talked to individually to ascertain exactly what they know of the union activity.”; Levitt, Martin and Terry Conrow. 2021. Confessions of a Union Buster. Xandland XL Press: Bullard, TX.  Confessions of a Union-Buster. P. 95, 168. (Levitt describes holding campaign kickoff meetings with supervisors as soon as he arrives on site.)

43.  Harter, Jim. 2026. “Span of Control: What’s the Optimal Team Size for Managers?” Last accessed August 19, 2026: https://www.gallup.com/workplace/700718/span-control-optimal-team-size-managers.aspx

44.  What to Do When Union Organizing Starts.” 2022. Associated Building Contractors Handbook on Practical Labor Law. Pp. 12-13. (The guide states that as soon as an employer believes it has an organizing issue, supervisors should be told to “immediately increase their personal contacts with workers … to engage in informal conversations with them at every opportunity,” making a point of “talking to everyone they supervise on at least a daily basis,” and that the campaign leaders would be “kept fully informed on anything that supervisors learn about the organizing attempts or of any changes in attitudes, indications of union coercion, employee huddles, rumors, etc.” It further adds the employer “should set up a method for the senior management team and supervisors to report regularly and promptly what they find out in their conversations with employees” and that, “All leads should be immediately followed up in this hotline communication network.” Levitt, Marty and Terry Toczynski. 2021. Confessions of a Union-Buster. Xandland XL Press: Bullard, TX. P. 101. (Speaking of the role of supervisors in another campaign he oversaw, Levitt said, on p. 184, “Collectively the supervisors had made hundreds of individual letter deliveries, complete with the memorized explanations and probing questions and relentless follow-up that I ordered … Many were having to skip lunch to get everything done, union-busting assignments on top of their regular duties…”)

45.  “What To Do When Union Organizing Starts.” Date unknown but believed to be post-2020. ABC Chapter Handbook on Practical Labor Law. Associated Building Contractors (ABC). Pp. 12-13. (The guide states that as soon as an employer believes it has an organizing issue, supervisors should be told to “immediately increase their personal contacts with workers … to engage in informal conversations with them at every opportunity,” making a point of “talking to everyone they supervise on at least a daily basis,” and that the campaign leaders would be “kept fully informed on anything that supervisors learn about the organizing attempts or of any changes in attitudes, indications of union coercion, employee huddles, rumors, etc.” It further adds the employer “should set up a method for the senior management team and supervisors to report regularly and promptly what they find out in their conversations with employees” and that, “All leads should be immediately followed up in this hotline communication network.”)

46.  Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 15.

47.  Jackson Lewis. 1997. Winning NLRB Elections: Avoiding Unionization Through Preventive Employee Relations Programs. 4th Ed. Employment & Human Resources Management Professional Series. Jackson, Lewis, Schnitzler & Krupman: New York, NY. P. 168, 196; Bronfenbrenner, Kate. 2022. “In Solidarity: Removing Barriers to Organizing.” Testimony before the United States House Committee on Education and Labor; Bronfenbrenner, Late. 2009. “No Holds Barred – The Intensification of Employer Opposition to Organizing.” 2009. Economic Policy Institute. Last retrieved September 7, 2026: https://www.epi.org/publication/bp235/

48.  Lafer, Gordon. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work. P. 38. 

49.  Jackson Lewis. 1997. Winning NLRB Elections: Avoiding Unionization Through Preventive Employee Relations Programs. 4th Ed. Employment & Human Resources Management Professional Series. Jackson, Lewis, Schnitzler & Krupman: New York, NY. P. 167. 

50.  Wilson, Donald P. 1997. Total Victory: The Complete Management Guide to a Successful NLRB Representation Election. LRI. Broken Arrow: Oklahoma. Pp. 198-199, 80-83. 

51.  Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 14. Wilson, Donald P. 1997. Total Victory: The Complete Management Guide to a Successful NLRB Representation Election. LRI. Broken Arrow: Oklahoma. Pp. 219-287.

52.  Jackson Lewis. 1997. Winning NLRB Elections: Avoiding Unionization Through Preventive Employee Relations Programs. 4th Ed. Employment & Human Resources Management Professional Series. Jackson, Lewis, Schnitzler & Krupman: New York, NY. P. 167; Bronfenbrenner, Kate. 2022. “In Solidarity: Removing Barriers to Organizing.” Testimony before the United States House Committee on Education and Labor; Bronfenbrenner, Late. 2009. “The Intensification of Employer Opposition to Organizing.” Economic Policy Institute. 

53.  Lafer, Gordon. 2007. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work. P. 38. 

54.  Wilson, Philip B. 2013. Left of Boom: Putting Proactive Engagement to Work. 2nd Ed. Labor Relations Institute Inc.: Broken Arrow, Oklahoma. P. 18; 2025. National Labor Relations Advocates.“Union Risk – Ignored or Managed?” Last accessed July 11, 2026: https://nlradvocates.com/union-risk-ignored-or-managed/ (Costs of an anti-union campaign include “lost productivity.”); Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 14;  Freeman, Richard, Mark Barenberg and Joel Rogers. 2016. “The Legal, Economic and Business Case for Neutrality and Majority Verification of Worker Desire for Union Representation.” P. 5; “Union Risk – Ignored or Managed?” National Labor Relations Advocates. Last accessed July 11, 2026: https://nlradvocates.com/union-risk-ignored-or-managed/ (The anti-union consultancy notes that costs of an anti-union campaign include not only “meetings with employees” but also “lost productivity,” in addition to other expenses).  

55.  Wilson, Philip B. 2013. Left of Boom: Putting Proactive Engagement to Work. 2nd Ed. Labor Relations Institute Inc.: Broken Arrow, Oklahoma. P. 18.; 

56.  Freeman, Richard, Mark Barenberg and Joel Rogers. 2016. “The Legal, Economic and Business Case for Neutrality and Majority Verification of Worker Desire for Union Representation.” P. 5. 

57.  “Union Risk – Ignored or Managed?” National Labor Relations Advocates. Last accessed July 11, 2026: https://nlradvocates.com/union-risk-ignored-or-managed/ (The anti-union consultancy notes that costs of an anti-union campaign include not only “meetings with employees” but also “lost productivity,” in addition to other expenses)

58.  Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 14.

59.   Imberman, Woodruff. 1975. “How expensive is an NLRB Election?” MSU Business Topics. 23(3). P. 14.

60.  Lafer, Gordon. 2006. “Neither Free Nor Fair: The Subversion of Democracy Under National Labor Relations Board Elections.” American Rights at Work. P. 14. (Lafer notes that estimates of spending per worker by employers in anti-union campaigns have ranged from $600 to $1,600 per employee in 2006$ [between $1,081 and $2,884 in 2026$] and spending on consultants and attorneys combined has ranged from $2,500 to $3,700 in per employee in 2006$ [between $4,508 in 2026$ and $6,671 in 2026$]. He adds that these estimates of spending on union-busting do not typically “include the cost of anti-union letters, leaflets, posters, videos, buttons, t-shirts or other paraphernalia,” and that if these costs and other neglected costs, such as attorney fees, are factored in, the “per-employee expenditure of anti-union employers would likely be significantly higher than the estimates provided here.”; 

61.  Agreement can be obtained by clicking “See attached agreement” on Gordon Foods Service LM-20 result on the search.laborlab.us profile page for Reliant Labor Consultants/East Coast Labor Relations:  https://search.laborlab.us/?q=Reliant+Labor+Consultants&type=consultant. It also may be obtained by searching “East Coast Labor Relations” under the LM-20/21 Labor Relations Consultant search tab in OLMS’ Online Public Disclosure Room and clicking “View” under Attachments column for Gordon Foods Service LM-20 item: https://olmsapps.dol.gov/olpdr/#Persuader%20Reports/LM-20/21%20Labor%20Relations%20Consultant/. 

62.  IRI Consultants/People Results agreement can be found by searching “Howmet Aerospace” under the LM-10 Employer search tab in OLMS’ Online Public Disclosure Room and clicking “View” under the Attachments column for the 2025 LM-10 item.

63.  Contract with the County of Marin. Dated 2024. https://marin.granicus.com/MetaViewer.php?view_id=36&clip_id=13011&meta_id=1426972

64.  These agreements can be accessed through LM-20 results on Government Resources Consultants’s (GRCA) search.laborlab.us profile page or through OLMS’ Online Public Disclosure Room. 

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