Sean P. Redmond Sean P. Redmond
Vice President, Labor Policy, U.S. Chamber of Commerce


March 26, 2024


On March 21, Rep. Burgess Owens (R-UT) introduced the Start Applying Labor Transparency (SALT) Act in the U.S. House of Representatives. The legislation would improve reporting on union “salting,” a deceptive practice sometimes employed during union organizing campaigns.

As the U.S. Chamber previously observed, salting is an age-old labor technique that may be behind some of the relatively recent unionization efforts at traditionally non-union employers. Dating back at least 100 years, salting refers to the practice of union organizers or trained members applying for a job with an employer for the specific purpose of unionizing the employer’s workforce, as opposed to having a legitimate interest in the job for which they apply.

In many instances, employers are unaware that they have become the target of salting, and its employees may not realize the person pushing them to support unionization is really working for the union. The SALT Act would address the practice of salting by amending the Labor-Management Reporting and Disclosure Act (LMRDA), which Congress enacted in 1959 to improve transparency for employers and labor organizations and guarantee democratic practices for union members. 

The LMRDA does not currently require reporting from labor unions with respect to their use of Salts, and likewise, there is no reporting requirement for Salts themselves. In contrast, employers and their labor relations consultants must file reports on their agreements or arrangements. 

The employer report, known as the Form LM-10, and labor consultant report, the Form LM-20, must include the identities of the parties to the agreement, the object and terms and conditions of the agreement or arrangement, and the activities performed or to be performed pursuant to the agreement. The Form LM-20 must be submitted within 30 days of realizing the agreement. Moreover, receipts and disbursements between an employer and a labor relations consultant must also be disclosed on the employer’s Form LM-10 or the consultant’s Form LM-21.

In other words, when employers engage a consultant to navigate around the complexities of a union organizing campaign, both have to disclose all of those details above, which gives unions particular insight into the employer’s approach to the campaign. At the same time, if a labor union sends a "Salt" (a union organizer or trained union member) to an employer to convince people from the inside to support the union, there is no reporting requirement even though the Salt is trying to influence employees just as much as an employer’s labor consultant—if not more. 

The SALT Act would address this considerable imbalance by requiring reports from labor unions and individuals who act on their behalf as a Salt. This would improve the transparency Congress sought and make it easier for employers to know who they are hiring. Just as importantly, it would enable workers to know if the “colleague” urging them to join a union is, in reality, a self-interested activist getting paid by the union itself. 

About the authors

Sean P. Redmond

Sean P. Redmond

Sean P. Redmond is Vice President, Labor Policy at the U.S. Chamber of Commerce.

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