Office of Labor-Management Standards (OLMS)
U.S. Department of Labor Employment Standards Administration
Office of Labor-Management Standards
Seattle District Office
1111 Third Avenue
Seattle, WA 98101
(206) 398-8099 Fax:(206) 398-8090
July 25, 2008
Mr. Robert Dockter, Treasurer
Glass Molders Plastics AFL-CIO
Local Union 139B
2205 N. Lombard
Portland, OR 97217
LM File Number: 025-818
Dear Mr. Dockter:
This office has recently completed an audit of Local Union 139B under the Compliance
Audit Program (CAP) to determine your organization's compliance with the provisions
of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). As
discussed during the exit interview with you on May 9,2008, the following problems
were disclosed during the CAP. The matters listed below are not an exhaustive list of
all possible problem areas since the audit conducted was limited in scope.
Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206 requires, among other things, that labor organizations maintain adequate records for at least five years by which each receipt and disbursement of funds, as well as all account balances, can be verified, explained, and clarified. As a general rule, labor organizations must maintain all records used or received in the course of union business.
For disbursements, this includes not only original bills, invoices, receipts, vouchers, and applicable resolutions, but also documentation showing the nature of the union business requiring the disbursement, the goods or services received, and the identity of the recipient(s) of the goods or services. In most instances, this documentation requirement can be satisfied with a sufficiently descriptive expense receipt or invoice. If an expense receipt is not sufficiently descriptive, a union officer or employee should write a note on it providing the additional information. For money it receives, the labor organization must keep at least one record showing the date, amount, purpose, and source of that money. The labor organization must also retain bank records for all accounts.
The audit of Local Union 139B's 2007 records revealed the following recordkeeping violation:
Disbursements to Vendors
Local 139B did not retain required documentation for vendor disbursements. No supporting documentation was kept by the union for fuel and telephone charges. These transactions totaled at least $3,775.00 during the fiscal year audited. As previously noted above, labor organizations must retain original receipts, bills, and vouchers for all disbursements. The president and treasurer (or corresponding principal officers) of your union, who are required to sign your union's LM report, are responsible for properly maintaining union records.
Based on your assurance that Glass Molders Plastics AFL-CIO Local 139B will retain adequate documentation in the future, OLMS will take no further enforcement action at this time regarding the above violation.
I want to extend my personal appreciation to Glass Molders Plastics AFL-CIO Local Union 139B for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance materials provided to you are passed on to future officers. If we can provide any additional assistance, please do not hesitate to call.
cc: Mr. Wallace Brown, President