"It is a violation of this provision for the Employer to lay-off fulltime employees in order to convert them to four hour guaranteed local cartage employees."
This is exactly what they did in Milwaukee. Work load never changed, partimers never missed a beat. They then laid off 10 drivers and made them 4 hour part-time cartage employees on Monday. They were recalled by Friday morning. The IBT had our back on this and were ready to serve notice. Keep track of all hours worked by part timers, bill counts, tonnage, overtime hours worked, etc. If there is one purpose the Part timers serve it is to keep the fulltimers working, they CANNOT lay off while the part timers are working! Doesn't hurt to make sure everyone is very safe on the dock as well.