An employer promulgated a total smoking ban in a carbon-black manufacturing plant without bargaining with the union.  An arbitrator ruled that the company had properly implemented the ban since management has a right to promulgate reasonable workplace rules and to plan and direct activities so as to “provide for maximum safety.”  Also, the arbitrator found that the no-smoking policy is reasonably related to legitimate management objectives, applies to everyone equally and does not dictate off-premises employee behavior.

96 LA 499 (1991).