NLRB Orders Vote for Housekeeping Workers to Join Multi-Hospital Union at Doctors Hospital of Manteca

The National Labor Relations Board (NLRB) Regional Director for Region 32 has directed an Armour-Globe self-determination election for approximately 28-30 environmental services (EVS) employees at Doctors Hospital of Manteca in California. The February 6, 2026 decision allows housekeeping workers to vote on whether they wish to join an existing bargaining unit represented by Service Employees International Union-United Healthcare Workers West (SEIU-UHW).

The existing unit covers employees across seven hospitals owned by Tenet Healthcare in California, including Desert Regional Medical Center, Doctors Medical Center of Modesto, Emanuel Medical Center, John F. Kennedy Memorial Hospital, San Ramon Regional Medical Center, and Hi-Desert Medical Center. The unit structure is non-conforming under the Board's Health Care Rule (29 CFR § 103.30), which establishes eight appropriate bargaining units for acute care hospitals.

Regional Director Christy J. Kwon determined that the EVS workers constitute a "distinct and identifiable voting group" and share sufficient "community of interest" with the existing unit, particularly with certified nursing assistants (CNAs) at the facility. The decision emphasized the high degree of functional integration between EVS employees and CNAs, who interact four to eight times per shift on patient room cleaning, sanitation, and related tasks. When EVS staff are unavailable, CNAs perform some housekeeping duties, demonstrating the interdependence of their work.

The employer, Doctors Hospital Manteca, Inc., opposed the petition, arguing that EVS employees do not share a community of interest with the existing unit and that adding them to a non-conforming unit would be inappropriate. The Regional Director rejected these arguments, finding that the existing bargaining history—which already includes EVS employees at three other Tenet hospitals—supports the inclusion. The decision also noted that EVS employees and CNAs share common terms and conditions of employment, including the same health insurance plan, 401(k) retirement plan, similar uniforms, and comparable work schedules.

The Armour-Globe election procedure, established through Board precedent in the 1940s, permits unions to add unrepresented employees to existing units through a self-determination vote. This approach is particularly significant in healthcare settings, as the decision cited St. Vincent Charity Medical Center (2011) and Rush University Medical Center v. NLRB (2016), which established that self-determination elections do not violate the Health Care Rule because they avoid proliferation of bargaining units by adding employees to existing units rather than creating new ones.

The election is scheduled for February 17-18, 2026, at the hospital's administrative conference room. Eligible voters include those employed during the payroll period ending January 24, 2026. Environmental Services Leads may vote subject to challenge, as their supervisory status remains unresolved. If a majority votes for union representation, the EVS employees will be added to the existing multi-facility bargaining unit and SEIU-UHW will represent them in collective bargaining alongside other healthcare workers at Tenet facilities across California.

Key Points

• Scope: Election covers approximately 28-30 housekeeping/environmental services employees at 73-bed acute care hospital in Manteca, California
• Legal Framework: Decision applies Armour-Globe self-determination election doctrine, requiring employees to be distinct voting group sharing community of interest with existing unit
• Community of Interest Analysis: Regional Director found high functional integration between EVS workers and CNAs through frequent work-related contact, shared responsibility for patient room cleanliness, and common terms of employment
• Non-Conforming Unit: Existing bargaining unit spans seven Tenet Healthcare hospitals with varying employee classifications at each facility, already including EVS workers at three locations
• Health Care Rule Exception: Self-determination elections do not violate Health Care Rule's anti-proliferation mandate because they expand existing units rather than create new ones
• Election Schedule: Voting occurs February 17-18, 2026; eligibility based on January 24, 2026 payroll period
• Supervisory Status: Environmental Services Leads may vote subject to challenge pending resolution of supervisory determination
• Impact: If successful, EVS workers will join SEIU-UHW's existing representation of healthcare workers at seven Tenet California hospital facilities

Primary Source Author: Christy J. Kwon, Regional Director, NLRB Region 32

Primary Source: Decision and Direction of Election, Case 32-RC-376933

Primary Source Link: https://apps.nlrb.gov/link/document.aspx/09031d4584178ed3

Supplemental Links

• NLRB: What We Do - Conduct Elections
• 29 CFR § 103.30 - Health Care Rule
• Rush University Medical Center v. NLRB, 833 F.3d 202 (D.C. Cir. 2016)
• American Hospital Ass'n v. NLRB, 499 U.S. 606 (1991)
• SEIU-United Healthcare Workers West
• NLRB Case 32-RC-281210 - Previous Doctors Hospital of Manteca Representation Case
• Armour & Co., 40 NLRB 1333 (1942)
• Globe Machine & Stamping Co., 3 NLRB 297 (1937)
• St. Vincent Charity Medical Center, 357 NLRB 854 (2011)
• Warner-Lambert Co., 298 NLRB 993 (1990)