F.O.P. Rose of Sharon Lodge No. 3 v. Pennsylvania Labor Relations Board

The Fraternal Order of Police, Rose of Sharon Lodge No. 3 (FOP) petitions for review of the June 6, 1998 Final Order of the Pennsylvania Labor Relations Board (Board) that dismissed a charge of unfair labor practice against the City of Sharon (City) after determining that the Citys unilateral reduction of a service requirement for promotion eligibility did not affect a mandatory subject of collective bargaining. The FOP contends that the Board erred by holding that a reduction in seniority requirements for a bargaining unit promotional opportunity in a Third Class City police department was not a mandatory subject of bargaining under the Act of June 24, 1968, P.L. 237, as amended, 43 P.S. 217.1—217.10, more commonly known as Act 111. For the reasons that follow, we affirm.