MAP on the U.S. NLRB Proposed Rule on the Status of Graduate Student Workers

Minorities and Philosophy (MAP) is helping to spread the word about the National Labor Relations Board’s (NLRB) proposed rule that would overturn the 2016 Columbia decision, which held that students at private universities counted as workers for the purpose of the NLRA and were thus entitled to collective bargaining rights. In solidarity with graduate students that this rule would affect, we’re asking you to help delay this proposed rule by organizing your departments to write comments (the deadline is December 16).

The NLRB is proposing this rule of its own accord using rarely invoked powers, despite the fact that there is no petition currently before the Board on which it can rule. It is a clearly desperate attempt to interrupt the nationwide labor movement by whatever means possible.

The proposal claims that being a student excludes one from being a worker. But as we are all acutely aware, universities could not operate without graduate student labor. Indeed, universities increasingly rely on exploiting graduate student labor and adjunct labor to cut costs, which is all the more reason why graduate students are demanding collective bargaining rights.

Graduate worker unions across the country are responding to this challenge by writing public comments on the proposed rule. Each comment must be read and replied to by the NLRB, with the only requirement being that the comment be “unique” (so no copy and paste). The rule cannot be promulgated until all comments have been responded to. Everyone (including graduate students and faculty, US citizens and non-citizens) can submit a comment in any language. The more comments we submit, the longer the rule will be delayed (hopefully until a differently constituted NLRB is appointed after 2020).

Given this momentum in the sector, we’re writing to encourage you to organize your departments and colleagues to write comments opposing the proposed rule. Comments are open until December 16, 2019. Comments can be submitted online at, or by paper to the NLRB. Video comments are also possible.

For graduate workers, writing a comment is easy as 1-2-3:

  1. A statement directly addressing the proposed rule, eg: “Any proposed rule should recognize my status as an employee under the law.”
  2. A description of your position and the duties that you perform, including writing lesson plans, holding sections, grading, class organization, holding office hours, pastoral duties, and so on.
  3. A statement explaining how your work contributes directly to the intellectual and educational mission of the university and its social purpose.

If you wish, you could write an additional paragraph or two directly against one or more of the “arguments” made by the majority of the Board.

Sample comments (from Columbia) can be found here and here.

Graduate students at Columbia have also prepared a sample email and comment template to send to supportive faculty. Similar documents are in the works for undergraduate students and alumni.
Please don’t hesitate to contact us with any questions. We will be happy to answer them or pass them along to someone who can.

In solidarity, MAP International

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