In the September 1981 Cabinet reshuffle, Thatcher appointed Tebbit as Employment Secretary. This was seen as a shift to a 'tougher' approach to the trade unions than had been the case under Tebbit's predecessor, James Prior. Tebbit introduced the Employment Act 1982 which raised the level of compensation for those unfairly dismissed from a closed shop and prohibited closed shops unless 80% of relevant workers approved the arrangement in periodic ballots. It also removed trade unions' immunity from liability in tort – i.e. made trade unions liable for civil damages if they committed unlawful acts, and made injunctions possible against such acts. In his memoirs Tebbit said that the 1982 Act was his "greatest achievement in Government".