Thomas Huber, the shop steward for the Machinists Union at G&H Products, Inc., was discharged for encouraging employees to engage in insubordination. He had told employees not to fill out a new system of time cards until the company handed over sufficient information to the union explaining the reason for new time cards. Pursuant to the labor agreement, the union contested the discharge through arbitration. The arbitrator heard evidence and testimony on the subject, including the union's contention that the discharge of Huber was a Section 8(a)(3) unfair labor practice of antiunion discrimination by the company. The arbitrator concluded that Huber had been disciplined for insubordination, not for exercising his rights as a union steward. He found no evidence of an unfair labor practice and upheld the discharge.

The union asked the NLRB to find that G&H had engaged in an unfair labor practice by discharging Huber. The company asked the Board to defer to the existing arbitration decision on the discharge.

What factors must the Board consider before it defers to an arbitrator's decision? Should the Board defer in this case? Decide. [G&H Products, Inc., 261 NLRB 298, 110 LRRM 1036]