Office of Labor-Management Standards (OLMS)
U.S. Department of Labor
Office of Labor-Management Standards
Cleveland District Office
1240 East 9th Street, Suite 831
Cleveland, OH 44199
(216) 357-5455 Fax: (216) 357-5425
April 26, 2011
Deborah Williams, Financial Secretary
Steelworkers Local 1915
3440 CO RD175
Clyde, OH 43410
LM Number: 028926
Dear Deborah Williams:
This office has recently completed an audit of Steelworkers Local 1915 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 April 13, 2011, 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.
The audit disclosed a violation of LMRDA Section 201(a), which requires that a union submit a
copy of its revised constitution and bylaws with its LM report when it makes changes to its
constitution or bylaws. Local 1915 amended its constitution and bylaws in 2000 but did not file
a copy with its LM report for that year.
Local 1915 has now filed a copy of its constitution and bylaws.
The union’s policy is that no lost time is paid unless wages are lost. Recordkeeping
requirements must support this policy to ensure that union funds are not erroneously expended.
For example, members could attach their time card information to lost time vouchers to ensure
that the dates for which lost time is paid corresponds with the dates taken off from work.
A fixed asset inventory should be taken and maintain to accurately account for the union’s assets.
This is particularly crucial for the safeguarding of high value items such as computers and other
items purchased with union funds, such as Labor Day T-shirts.
I want to extend my personal appreciation to Steelworkers Local 1915 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: Eric Creamer, President