No More COVID? NLRB GC Revises Manual Election Procedures


With the declared end of the COVID-19 national and public health emergencies, the General Counsel of the National Labor Relations Board has revised the protocols for manual (i.e. in-person) elections.

In July 2020, the GC issued a memo, GC 20-10, that provided guidelines for conducting elections during the pandemic. Traditionally, manual elections are strongly favored, but mail ballot elections were permitted more often in light of COVID-19. But with the end of the COVID-19 emergency declarations, the GC now suggests the following manual election protocols going forward:

  • Individuals should not participate in an in-person election or related meetings if they have symptoms of COVID-19.
  • If an individual who has participated in an in-person election/meeting develops COVID-19 symptoms within 10 days, they should notify the assigned Board Agent.
  • If the CDC or local/state authority determines that masks are necessary in the area where the election takes place, all individuals must wear a mask. If required and the NLRB Region or the employer has masks available, they are encouraged to offer them to the election participants. If masks are not required, participants may choose whether to wear them.
  • Participants are encouraged to maintain reasonable physical distance, avoid overcrowding, and use hand sanitizer.