U.S. Department of Labor
Employment Standards Administration
Office of Labor-Management Standards
Seattle District Office
1111 Third Avenue
Room 605
Seattle, WA 98101 3212
(206)398-8099 Fax: (206)398-8090

June 20, 2006

Mr. Craig Gruenig, Business Manager
Laborers AFL-CIO
Local 238
1330 North Calispel Street
Spokane, WA, 99201

     Re: Case Number

Dear Mr. Gruenig:

This office has recently completed an audit of Laborers AFL-CIO 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 Craig Gruenig on May 17, 2006, 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 CAP disclosed that authorization for the salary amounts paid to your field agents could not be found in union records. I recommend that Local 238 document the authorized salary amounts in its bylaws or record them in meeting minutes or some other internal document (following discussion in the appropriate membership and/or executive board meeting). I have received your executive board minutes which recorded the authorization.

The CAP 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 constitution or bylaw changes are made. Local 238 amended its constitution and bylaws in 2001, but a copy was not filed with its LM report for that year. A copy of Local 238's constitution and bylaws has now been filed.

I want to extend my personal appreciation to Laborers AFL-CIO for the cooperation and courtesy extended during this compliance audit. I strongly recommend that you make sure this letter and the compliance assistance references I provided to you are passed on to future officers. If we can provide any additional assistance, please do not hesitate to call.


Michael Duvall
District Director

cc: Steve Harris, President