Local 1186 of Council No. 4 v. State Board of Labor Relations

The sole issue in this appeal is whether a board of education must negotiate with school employees over the secondary impact of a managerial decision to institute a smoke-free policy in the work place. We conclude that impact negotiation is required if implementation of the smoke-free policy has a substantial secondary impact on employee working conditions.

The relevant facts in this appeal may be summarized as follows. On September 28,1987, the defendant New Britain board of education (school board) approved a new policy that prohibited smoking at all times both inside the New Britain public…