employees’ interests might become “so attenuated” that § 7 no longer applied, the Court held that it is for the Board in “the first instance” to consider the precise boundaries of the “mutual aid and protection” clause of § 7. Id. at 568. In this case, the Board held that participation in preparing the Report came within the ambit of § 7. The Board reasoned that since the Report dealt with, among other concerns, nursing staff shortages, it raised issues directly related to employee working conditions. The Board also stressed that the Report dealt with issues of sanitation that were of concern to hospital staff, as well as to patients; accordingly, the Board held, the Report was analogous to complaints concerning 11 (1976), enforced, No. 76-2496, 96 LRRM 2512 (3rd Cir. Sept. 16, 1977) (<HOLDING>). The Hospital contends, however, that the
holding protected threat by operating room nurse to complain to newspaper that proposed elimination of surgical residency program might require performance of surgical duties beyond her competence holding that a breach of duties that a fiduciary contractually assumes beyond those duties imposed by law is considered to arise out of contract holding that the plaintiffs challenge to a state law affecting the performance of her job duties was mooted when she left state employment holding that letter that was copied to the schools board of directors was written pursuant to her duties and was not protected speech holding that a plaintiff did not complain to the eeoc pursuant to official duties but rather as a citizen