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🗞️ Bridge Cameras, Confidentiality Rules and a Union Fight: NLRB Judge Rules on American President Lines

An NLRB judge found that American President Lines violated federal labor law through a broad confidentiality policy, new bridge cameras on its ships and incomplete responses to a union's information requests.

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onthelaborfront

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🗞️ Bridge Cameras, Confidentiality Rules and a Union Fight: NLRB Judge Rules on American President Lines

A National Labor Relations Board administrative law judge has found that American President Lines, LLC and its affiliate, APL Marine Services, Ltd, violated federal labor law on three fronts involving the licensed deck officers who pilot its cargo ships. The case, brought by the International Organization of Masters, Mates & Pilots, centered on a 2024 onboarding policy that classified nearly all company documents, including logbooks and internal memos, as confidential and required officers to obtain written approval from a shore based fleet director before copying or sharing them.

Judge Christal J. Key applied the Board's 2023 Stericycle standard for evaluating workplace rules, concluding that the policy could reasonably discourage officers from exercising their right to share workplace information with their union, including documents officers had previously used to pursue grievances over pay and rest periods. The company maintained that the policy formalized existing expectations and protected sensitive material tied to its government cargo contracts. The judge found instead that the policy represented a genuine change to working conditions and was broader than necessary, since it covered routine paperwork unrelated to security or proprietary information.

The decision also addressed cameras installed inside the wheelhouse, or bridge, of seven newly acquired container ships, the first time the company's vessels had cameras facing inward toward officers' own work areas rather than outward for anti piracy purposes or toward equipment in spaces that are not staffed around the clock. The judge determined this was a material change requiring the company to bargain over its effects on officers' working conditions, and that the company's refusal to do so, based on a contract provision concerning reflagged vessels, did not satisfy its bargaining obligations because that provision did not address effects bargaining. A related set of disputes concerned the company's responses, or lack of them, to numerous union requests for information about camera locations, footage retention and monitoring duties, including questions about a separate set of cameras required under the Safer Seas Act, a 2022 federal law intended to address sexual assault and harassment aboard commercial vessels.

The judge dismissed several of the union's narrower information requests where the company's responses were found adequate, but identified violations in the broader pattern of withheld or incomplete answers. The recommended remedy requires the company to rescind the confidentiality provisions, bargain over the effects of the camera installations upon request, provide the outstanding information and post notices informing employees of their rights. The ruling is a recommendation to the full Board and remains subject to exceptions and further review.

Key Points

  • The confidentiality policy required officers to obtain written permission from a fleet director before copying, photographing or emailing any company document, including routine items such as timecards and policy handbooks.
  • The judge found the policy unlawfully broad under NLRB precedent and concluded it represented a material change that required bargaining with the union before it took effect.
  • New cargo ships added to the fleet in 2024 and 2025 were the first in the company's fleet to include cameras facing inward at officers' bridge workstations, rather than only outward facing cameras or those monitoring equipment in unstaffed areas.
  • The company's refusal to bargain over the effects of the camera installations, based on a contract clause about accepting reflagged vessels, was found insufficient because that clause did not address bargaining over effects.
  • Separate cameras required under the federal Safer Seas Act, intended to address shipboard sexual assault and harassment, generated additional information disputes about footage retention and access.
  • The judge found the company did not adequately respond to a number of union requests regarding camera locations, models, monitoring duties and disciplinary use, though some requests were found to have been answered sufficiently.
  • The recommended order calls for rescinding the policy, bargaining over the camera installations' effects, supplying the withheld information and posting employee notices for sixty consecutive days.

Primary Source Author: Christal J. Key, U.S. Administrative Law Judge, National Labor Relations Board Division of Judges

Primary Source: American President Lines, LLC and APL Marine Services, Ltd., Case 21-CA-347811 (NLRB Division of Judges, June 22, 2026)

Primary Source Link: https://www.nlrb.gov/case/21-CA-347811

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