CWA, Local 1180, 13 OCB2d 12 (BOC 2020)
CWA sought to add the title Assistant Director, Hospitals, and OSA sought to add the title Associate Director, Hospitals, to their respective bargaining units. HHC argued that the titles are managerial and/or confidential and do not share a community of interest with titles in either bargaining unit. The Board found that, with certain exceptions, the employees in these titles are eligible for collective bargaining. As the titles share a community of interest with the existing bargaining units, the Board accreted the Assistant Director title to CWA’s bargaining unit and the Associate Director title to OSA’s bargaining unit.