Running Head: Comprehensive Case Study 1

Running head: Comprehensive Case Study
Comprehensive Case Study: Smoking Ban on Domestic Flights Student Name Baker College Center for Graduate Studies
Abstract This case study examines the role the Association of Flight Attendants and its members played in creating a less discriminatory workplace. It also examines the two decade battle to prohibit smoking on airplanes. The study uses these labor issues and other examples to uncover strategies for both the airline and the union. It was concluded that many different approaches could have been taken in resolving the smoking dispute. It was also concluded that choosing a different strategy could have created the opportunity for the airlines, its employees and their union to have realized mutual gains and which would have built a more trusting work relationship as a result.
Comprehensive Case Study: Smoking Ban on Domestic Flights Table of Contents Introduction..4 Background..4 AFA-CWA..5 Labor Issues6 Literature Review.7 Civil Rights Act...7 OSHA..8 AFA-CWA Strategies..8 Tobacco Companys Strategies9 Analysis.10 Policy Change10 Discussion..11 Current Smoking Issue...............13 Synthesis14 Airlines Future Strategies14 Recent and Future Policies17 Conclusion.18 References..19
Comprehensive Case Study: Smoking Ban on Domestic Flights Introduction This comprehensive case study is an examination of the Association of Flight AttendantsCWA and their members efforts in the many battles to improve working conditions at United Airlines and as a result affected airlines across the world. This study will examine the changes made in discriminatory policies and practices and the improvement of the workplace from a health and environmental standpoint created in part by the flight attendants and their union. Their plight has significantly and eternally changed policies that affect every individual traveling and/or working on passenger airplanes. Background United Airlines was one of the Big Four airlines in the United States that controlled commercial travel for a great deal of the 20th century and has continued to be one of the chief United States airlines (Century of Flight, nd). In 1930, United Airlines, then called Boeing Air Transport, hired eight nurses as the first flight attendants for the airline (United Airlines, 2007). By 1945, the Association of Flight Attendants- CWA (AFA-CWA) was established to assist flight attendants in eliminating discriminatory practices and aid in the creation of a healthy workplace (Association of Flight Attendants-CWO, 2010). In the twentieth century, several laws were passed that provided legitimacy, structure, and governance to the union movement (Jackson, Schuler, & Werner, 2009, p. 512). Some of the most significant union laws created were the National Labor Relations Act (Wagner Act), the Labor Management Relations Act (Taft Hartley Act) and the Labor Management Reporting and Disclosure Act (Landrum-Griffin Act).
Accordingly, in 1964, the Civil Rights Act passes and flight Attendants use Title VII of the Act to challenge discriminatory policies based on gender, race, age, weight, pregnancy and marital status (Association et al, 2010). Moreover, the Occupational Safety and Health Act (OSHA) was enacted by Congress in 1970, with two broad goals: (1) to guarantee safe and healthful working conditions for working individuals; and (2) to supply a framework for research, education, training, and information in the field of work-related safety and health (Cihon & Castagnera, 2008, p. 228). Specifically, these two labor laws made it possible for the AFA-CWA to change policies and working conditions at United Airlines and airlines across the country. AFA-CWA The Association of Flight Attendants-CWA is the world's largest labor union organized by flight attendants for flight attendants and currently represents nearly 50,000 flight attendants at 21 airlines (Association et al, 2010). The AFA-CWA is the only flight attendant union exclusively representing flight attendant's requirements and concerns affiliated with the AFLCIO, the 13-million-member American labor federation (Association et al, 2010). The goal of the AFA-CWA is to use collective bargaining techniques for better pay and benefits, healthier working conditions, fair work rules, and improved safety on the job (Association et al, 2010). Collective bargaining consists of negotiations between an employer and a group of employees or union to determine the conditions of employment, governed by federal and state statutory laws, administrative agency regulations, and judicial decisions (Cornell University Law School, 2011). When collective bargaining breaks down and an agreement cannot be reached or the employer simply will not listen, unions will often look to a third-party or the government for assistance in labor dispute resolution.
Labor Issues Since the passing of the Civil Rights Act of 1964, AFA members have been pursuing claims in violation of the Act, seeking equal and fair treatment. From approximately 1968 to 1975 multiple rules and regulations were changed by the Act as the union and its members tirelessly fought and lobbied for change. Age discrimination was a foremost concern for flight attendants, changing the average career from 18 months and changing the mandatory resignation of anyone between the ages of 30-35 (Association et al, 2010). Next, gender discrimination was an extremely important issue the union confronted. Pushed by the AFA, the courts determined the refusal of the airline in hiring male flight attendants illegal and also prohibited Uniteds nomarriage policy illegal (Association et al, 2010). Moreover, in 1984, a safety initiative by the AFA-CWA was beginning and included policies regarding floor lighting, less flammable aircraft interiors, and other cabin breakthroughs and safety standards (Association et al, 2010). There next plight would make history and change flying forever. In 1986, when management refused to listen, the AFA-CWA began to lobby Congress to prohibit smoking in airplanes. By using OSHA laws they stated it was a health risk to subject flight attendants to cigarette smoke during flights on a daily basis for extended periods of time. It was also a risk to the passengers, which included children and those who may be smoke sensitive. By 1987, the AFA-CWA received the ban on smoking for flights two hours or less. They continued to lobby Congress and the Federal Aviation Administration (FAA) for relief and in 1989, received the official outlaw of smoking in flights six hours or less. This was an enormous gain for the AFA-CWA and advocacy organizations that helped assist in the fight. By the year 2000 smoking was banned on all flights between the United States, both foreign and domestic (Chicago Tribune, 2000). During this time the FAA estimated that almost 98% of
international flights were already smoke- free due to voluntary decisions made by airlines (Chicago Tribune, 2000). In essence, the AFA-CWA did not take no for an answer, continued to fight, and eventually changed the way people travel in passenger airplanes around the world. Literature Review The AFA-CWA has relied upon the law in many instances to fight for a better workplace. One of the main laws the union and its members have depended on in many discrimination claims is the Civil Rights Act of 1964. This act became the foundation of modern federal equal employment opportunity (EEO) law (Cihon & Castagnera, 2008, p. 43). Additionally, the AFACWA employed the help of OSHA, the FAA, advocacy groups, and congress to assist in changing the law on smoking in airplanes. Civil Rights Act The Civil Rights Act of 1964 prohibits discrimination by employers, employment agencies, and unions on the basis of race, color, religion, sex, national origin, or pregnancy (Jackson et al, 2009, p. 121). Title VII of the Civil Rights Act is one of the several statutory laws that affect the employment relationship (Jackson et al, 2009, p. 121). Title VII provides individuals with reinstatement, back pay and compensatory and punitive damages (Jackson et al, 2009, p. 124). These laws have been used by AFA-CWA members to individually and collectively fight discrimination in the workplace and change policies. For instance, in Frank v. United Airlines, female flight attendants were required to weigh less than their male counterparts (Find Law, 2011). Clearly, this was a case of gender discrimination because there were two separate sets of rule for males and females doing the same job. In this class action lawsuit a $36.5 million settlement was reached in 2004, when it was deemed gender discrimination had in fact occurred (Lieff, Cabraser, Heimann, & Berstein, 2011).
OSHA The Occupational Safety and Health Administration (OSHA) conducts safety and health inspections, inspects accidents and alleged hazardous conditions, issues citation for violations, levies fines, gathers mandatory reports prepared by employers, and collects statistics on work injuries and illnesses (Jackson et al, 2009, p. 127). OSHA is the main enforcer of the Occupational Safety and Health Act and intends to reach the goal of a hazard-free workplace. The AFA-CWA required the assistance of OSHA to create the ban on smoking in airliners, ensuring a better quality of health for their members. However, first they needed to prove smoking in airplanes created unsafe working conditions for airline workers, mainly those who came in direct contact with the smoke--flight attendants. AFA-CWA Strategies The main strategy of the AFA-CWA in ensuring the health and safety of its members was persistence. The AFA-CWA not only lobbied congress and the FAA, but they also joined forces with several antismoking groups and cancer foundations (Pan et al, 2005). They urged the FAA and OSHA to conduct studies on cabin air quality in an effort to prohibit smoking on airplanes. The research council, part of the National Academy of Sciences, is a private, nonprofit institution that provides science and technology advice under a congressional charter (M.T., 2001). The group's air-quality committee, which was made up of medical professors and air-pollution specialists, heard presentations from various groups, including the FAA and the Association of Flight Attendants-CWA (M.T., 2001). The group also assessed literature and earlier studies conducted ever since the beginning of the process of eliminating smoking on all domestic flights which started back in the late 70s (M.T., 2001).
Among the organizations and individuals that assisted the AFA-CWA were John Banzhaf III, founder of Action on Smoking and Health (ASH) (Holm & Davis, 2004). Banzhaf began to pressure regulators to mandate separate smoking and non-smoking sections on domestic flights (Holms & Davis, 2004). The FAA never responded so the Civil Aeronautics Board (CAB) was petitioned for relief (Holm & Davis, 2004). The CAB is in charge with the economic regulation of airlines and responsible for issuing the rule requiring airlines to provide separate sections for smokers and non-smokers (Holm & Davis, 2004). This small victory gave them strength for a much larger battle. Tobacco Companys Strategies In 1986, Congress abandoned the Stevens Bill, which proposed that all federal workplaces be smoke-free; so why did it prohibit smoking on airline flights (Pan, Barbeau, Levenstein, & Balbach, 2005)? Perhaps it was because of the AFA-CWA tireless efforts related to the health and welfare of its people. It could have been the many supporters they rallied in favor of a smoking ban or just the cold hard facts that smoking is dangerous and unhealthy on airplanes. However, the resistance, the tobacco industry, knew they were in for a battle and secured five sympathetic unions into their plight, creating Tobacco Institute Labor Management Committee (LMC) in 1984 (Pan et al, 2005). This committees goal was to block attempts for smoke-free legislation and increases in tobacco taxes (Pan, 2005). Their four part strategy consisted of the following: Broaden the public issue to overall indoor air quality, Challenge scientific community to deal honestly with environmental tobacco smoke, Demonstrate the unintended, negative economic and social ramifications of the ban, Rely on third-parties to communicate LMCs position (Pan et al, 2005).
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This strategy failed for many reasons. The attempts to broaden the issue from smoking to indoor air quality failed because AWA-CWA were more concerned about the health effects of smoking (Pan et al, 2005). Additionally, this attracted support from many other organizations such as Americans for Nonsmokers Rights, other health advocacy groups, and members of congress (Pan et al, 2005). Another reason the tobacco companies failed is because they to present credible negative ramifications that would result from smoke-free airlines (Pan et al, 2005). Analysis The main issue in this case study is the protection of the health, well being, and fair treatment of flight attendants. While the AWA-CWA fought for the safety of their members, they also created a safer environment for passengers, including children and the elderly. As the federal law was passed United States airlines were forced to ban smoking, although some had already done so on their own accord. As a result, many other international airlines willfully followed suit and prohibited smoking on their flights. Policy The FAA enforces its policy that prohibits smoking on all domestic flights which is applicable to air carriers on all scheduled passenger flights (Justia, 2000). Civil fines for smoking on an airline flight vary from a $2,200 fine for smoking in an airplane seat or cabin to a $3,300 fine for smoking in an airplane bathroom (Tobacco Public Policy Center, 2008). Tampering with a smoke detector mounted in an airplane restroom is punishable by a $2,200 fine (Tobacco et al, 2008). The law applies to cigars, pipes, and even the new electronic cigarettes. According to federal regulations the smoking ban applies to all foreign flights as well as domestic flights. The policy for foreign passenger flights states:
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Foreign air carriers shall prohibit smoking on all scheduled passenger flight segments: between points in the United States, and between the U.S. and any foreign point. A foreign government objecting to the application of paragraph (a) of this section on the basis that paragraph (a) provides for extraterritorial application of the laws of the United States may request and obtain a waiver of paragraph (a) from the Assistant Secretary of Transportation for Transportation Policy, provided that an alternative smoking prohibition resulting from bilateral negotiations is in effect (Justia, 2000). This means that even if a country allows smoking on their airplanes, if they are arriving or departing from the United States they must adhere to the smoking ban. If a foreign airline receives special arrangements, then they are still required to have a perfectly working ventilation system and a nonsmoking section for as many individuals wish to be accommodated (Justia, 2000). Discussion In the prior discrimination cases leading up to the smoking ban, flight attendants fought for fair treatment from their employers. Victories and policy changes concerning weight, age, gender, marital status, and pregnancy, set the stage for a battle that would span more than two decades (Association et al, 2010). Each successful policy change obtained individually or collectively only added to the momentum of the union and the unions agenda. However, there may have been several different approaches that could have been used in the resolution of the airline smoking issue. Arguably, the airline smoking issue could have been resolved much faster if common sense were applied to the situation. It is basic common sense that 150 passengers in a limited space, using fire and filling the air with smoke could be potentially dangerous and probably
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hazardous. There are many problematic issues that could come from this situation, including health problems. According to a 1989 nationwide survey of the flying public performed by the American Association for Respiratory Care, passengers, both smoking and nonsmoking, preferred nonsmoking air travel (Pan et al, 2005). Moreover, one would think the airline would want to keep the air as clean as possible to avoid employee illness and passenger complaints and lawsuits. Considering the high cost of employee absenteeism, healthcare, and costs associated with legal fees, it would be in their best interests to prohibit such a dangerous activity on board their airplanes. Possibly if the AFA-CWA would have compiled some additional statistical research of the monetary savings and problems that could be avoided by prohibiting smoking and delivered it directly to the board of directors of each airline, they may have paid more attention. Then, perhaps, the airline companies may have assisted in lobbying the federal government for the smoking ban. Another way the union would have received the attention and support of the airlines is to have had evidence. If they had several flight attendants that were adversely affected by inhaling smoke while on the job, then they could threaten to file a claim against the airline. This would give their initial claim more standing and would force OSHA and the FAA to get involved. Perhaps, this would have caused all of the unions to come together and lend zero support from any unions to the tobacco companies. In addition, the airline would not want word to get out in fear of damage to their reputation and the panic that passengers may begin to make the same claims seeking damages. The airline would not wish either of these scenarios to play out and most likely would have listed to the flight attendants problems and offered some sort of relief. A final theoretical solution to the airline smoking policy would have been to involve the welfare of children and infants. These individuals do not have the right to choose or the option
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to take a different form of travel. At the very least, the flight attendants union could have gotten smoking banned on flights with children and infants by stating the airlines support unhealthy environments in which minors exist. Again, this would damage their reputation and possibly make consumers think before subjecting their children to smoking flights. In sum, a key player in the smoking issue, the airlines, were remaining silent on the issue and were not listening to flight attendants pleas. It is the opinion of this case study that had the union received the support of the airlines, the law would have been created much earlier and the argument would not have lasted decades. Furthermore, many accidents associated with smoking on airplanes would have been avoided and many lives would have been saved. Current Smoking Issue Presently, there is much debate over the electronic cigarette, often called the E-cigarette, and its use on airline flights. The electronic cigarette does not require a lighter and does not give off any smoke. However, it does allow the user to blow out a water vapor that resembles smoke and this could make some individuals uneasy. The E-cigarette relies on a cartridge filled with nicotine and is delivered to the lungs and bloodstream by means of the water vapor. Concerns on whether second-hand water vapor is harmful are some of the issues that may arise from the use of these devices in such close quarters. Also, using devices that look and function similar to cigarettes may encourage some smokers to light up real ones creating several safety issues. The United States Department Transportation says the use of smokeless electronic cigarettes on airplanes is prohibited and plans to issue an official ban the spring of 2011, according to a letter from the Department of Transportation Secretary Ray LaHood obtained by The Associated Press (Felberbaum, 2011). This means those caught smoking E-cigarettes on airplanes will suffer the same fines and penalties as those who are found smoking real cigarettes
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on airplanes. However, in light of this new development, this has not stopped some individuals from testing the airlines E-cigarette policy, inhaling their smokeless devices, video tapping their results, and then posting it on social networking sites such as YouTube (Felberbaum, 2011). It is unknown whether these individuals were reprimanded for their behavior. However, at least two passengers are caught smoking old-fashioned cigarettes on airplanes every week, according to the Federal Aviation Administration (Barclay, 2011). Synthesis Considering the airlines remained neutral and silent during the smoking conflict their labor relations were virtually nonexistent. They refused to listen to the difficulties their staff members were subjected to and forced them to seek government intervention. In the future, the airlines should develop strategies to effectively deal with employee concerns, issues, and complaints. Airlines Future Strategies The first strategy airlines, like United Airlines, should examine is workplace cooperation. Workplace cooperation refers to the arrangements for establishing and improving relations between management and workers, within an enterprise (Heron & Noord, 2004). It involves both formal and informal communications to enable employees and management to meet, discuss their problems, and resolve them to the satisfaction of both parties (Heron & Noord, 2004). Workplace cooperation can assist airlines with flight attendants and their union in reaching a win-win alternative, instead of involving government intervention. Furthermore, by using workplace cooperation the airline can begin to build trust and confidence with the flight attendants and other employees which will enable them to talk through their differences and resolve problems unaided (Heron & Noord, 2004).
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Workplace cooperation can take an assortment of types including information sharing, joint consultation committees, joint decision making committees, collective bargaining and a range of individual worker-manager interactions directly related to the immediate work processes (Heron & Noord, 2004). Another strategy the airlines should have attempted is bargaining. One of the main goals of the U.S. labor relations system is to allow employees to negotiate their terms and conditions of employment with their employer as a group, instead of individually taking or leaving whatever the employer offers unilaterally (Budd, 2010, o. 229). If the AFA-CWA and the airlines would have attempted to bargain they would have needed to determine the following: their interests (in this case it would be the health of members), options in achieving their interest (ban smoking), external benchmarks of fairness, the airlines interests, and their best negotiated agreement (BANTA) (Budd, 2010, p. 231). If the AFA-CWA could have created a shared interest in the smoking restriction, like the cost savings of health related issues of employees due to smoking, then the union could have used integrative bargaining. Integrative bargaining refers to solving joint problems by creating solutions for mutual gains (Budd, 2010, p. 241). Through the process of collective bargaining, flight attendants and the AFA-CWA would negotiate terms and conditions of employment with the airlines, and put these terms into written contracts, also called collective bargaining agreements (Budd, 2010, p. 229). The agreements can include a grievance procedure, agreed between workers and employer that indicate the steps to be taken to resolve workers complaints, thereby preventing those complaints from escalating into labor disputes (Heron & Noord, 2004). Moreover, grievance procedures enables complaints and problems to be handled within the organization and, provided the procedure is applied fairly and follows the required procedure, many objections can be determined on-the-spot, without any need for third-party intervention
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(Heron & Noord, 2004). According to Heron & Noord (2004), The establishment and operation of an internal procedure to handle grievances at enterprise level is a key element of a labor dispute prevention strategy, and also represents a good starting point for workplace cooperation. If the airline would have used a procedure similar to the before mentioned, then the issues related to the smoking restriction could have been handled quickly and within the realm of the organization. Then the airline could unite with the flight attendants, building a mutual trusting relationship, and petition the government jointly in the creation of federal law in this matter. Finally, most companies do not wish to involve a third-party, but rather settle disputes themselves. However, mediation is always option in reaching agreements in labor disputes. Mediation is a dispute resolution process in which a neutral third party, the mediator, helps negotiators avoid or resolve an impasse by reaching an agreement (Budd, 2010, p. 286). It also assists negotiators in staying away from government involvement. However, by definition mediators lack the authority to push a decision by commanding a resolution and forcing it on the negotiators; rather, mediation is basically assisted negotiation (Budd, 2010, p. 286). This is a voluntary procedure under the NRLA and employers are required to notify the Federal Mediation and Conciliation Services (FMCS) that they will be negotiating (Budd, 2010, p. 287). The FMCS will offer the assistance of a mediator; however either party can refuse this offer and locate a mediator of their choice (Budd, 2010, p. 287). Furthermore, the best way to avoid labor issues is by listening and striving for understanding. The airlines decision to ignore the complaints of workers and remain silent on the issue, left the decision in the hands of the government. Instead of conducting their own research and formulating their own conclusions, they allowed others to complete and execute these activities. In the future, an improved strategy would be to devise a task force to research
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problems and conclude results. If statistical research is done by a third-party it may not be reliable due to personal agendas or corruption. In large decisions that will affect many individuals, it is essential that research be valid and reliable, in order to make a clear and concise decision. Additionally, if any questions are raised as a result or in the future based on the decision, the research will serve as a foundation for the deliberation. Recent and Future Policies Recently, the AFA-CWA convinced Congress to pass legally binding seniority protection for airline workers involved in airline mergers (Association et al, 2010). The law prevents one group of airline workers from stapling another group of workers to the bottom of a seniority list and supplies a process for equitable seniority integration (Association et al, 2010). In addition, AFA-CWA won Family and Medical Leave Act (FMLA) coverage for flight attendants (Association et al, 2010). Congress corrects a technical error and includes flight crew workers coverage under the act even though they have a unique way of counting hours. Furthermore, the AFA-CWA secured a three year educational grant in 2010 from the FAA to create a model for flight attendant substance abuse recovery program (Association et al, 2010). These programs will assist in preserving the careers of flight attendants after they overcome their substance abuse issues (Association et al, 2010). In sum, the AFA-CWA has been hard at work in reforming policies and fighting for the rights of flight attendants. Currently, airlines have much more urgent issues related to flight than the effects of passenger smoking. Airlines and flight attendants alike are in constant fear of terrorist attacks, air rage, and other issues that could threaten the lives of employees and consumers. It is now, more than in previous years, that airlines and their employees need to work together to keep the airways safe. The airline, its employees, and their union must create terms of employment that
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they can agree on in order to focus more attention on safety issues. Airlines have already banned certain items and tightened security. Since 911 airlines have worked together with employees and have created many new policies to create safe flights for everyone. In the future, it seems the majority of new policies created will focus on cabin safety and protecting employees from illegal behavior on flights. Conclusion In summary, the AFA-CWA has tirelessly fought and assisted its members in the resolution of discrimination issues, health issues, and safety issues. The AFA-CWA with the assistance of others lobbied Congress and successfully received the ban on smoking in airplanes on all flights, international or otherwise. The perseverance of the union and its members paid off; however there were many different approaches that could have been applied to this situation. In choosing a different strategy it is possible the airlines, its employees and their union would have realized mutual gains and would have built a more trusting work relationship as a result. Moreover, in the future, the AFA-CWA will continue to fight for its members, working hard to lobby Congress in the changing of outdated policies and the creation of new ones.
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Reference: Association of Flight Attendants- CWA. (2010). Brief history: association of flight attendantscwa. Retrieved June 15, 2011, from http://www.afalax.org/default.asp?nc=2237&id=664 Barclay, E. (2011). Cigarettes, even smokless ones, still outlawed on U.S. flights. Retrieved June 21, 2011, from http://www.npr.org/blogs/health/2011/02/24/133997847/cigarettes-evensmokeless-ones-still-outlawed-on-u-s-planes Budd, J. W. (2010). Labor realtions striking a balance third edition. New York, NY: McGrawHill Irwin. Chicago Tribune. (2000). Smoking ban to cover international flights. Retrieved June 18, 2011, from http://articles.chicagotribune.com/2000-06-04/news/0006040075_1_smokingbanned-airline Cihon, P. J., & Castagnera, J. O. (2008). Employment & labor law 6th edition. Mason, OH: South-Western Cengage Learning. Century of Flight. (nd). United airlines. Retrieved June 15, 2011, from http://www.century-offlight.net/Aviation%20history/coming%20of%20age/usairlines/United%20Airlines.htm Cornell University Law School. (2011). Collective bargaining. Retrieved June 18, 2011, from http://topics.law.cornell.edu/wex/collective_bargaining Felberbaum, M. (2011). Electronic cigarettes banned on U.S. flights. Retrieved June 21, 2011, from http://www.huffingtonpost.com/2011/02/11/electronic-cigarettesban_n_821828.html Find Law. (2011). Frank v. united airlines. Retrieved June 18, 2011, from http://caselaw.findlaw.com/us-9th-circuit/1436481.html Heron, R. & Noord, H. V. (2004). National strategy on labor dispute prevention and settlement
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in Cambodia. Retrieved June 21, 2011, from http://www.betterfactories.org/content/documents/1/National%20Strategy%20on%20Lab our%20Dispute%20Prevention%20and%20Settlement.pdf Holm, A. L. & Davis, R. M. (2004). Clearing the airways: advocacy and regulation of smokefree airlines. Retrieved June 21, 2011, from http://www.ncbi.nlm.nih.gov/pubmed/14985614 Jackson, S. E., Schuler, R. S., & Werner, S. (2009). Managing human resources tenth edition. Mason, OH: South-Western Cegage Learning. Justia US Law. (2000). Smoking aboard an aircraft. Retrieved June 20, 2011, from http://law.justia.com/cfr/title14/14-4.0.1.1.29.html Leif, Cabraser, Heimann, & Berstein. (2011). United airlines. Retrieved June 18, 2011, from http://www.lieffcabraser.com/employment-law/case/136/united-airlines-lawsuit M. T. (2001, Dec 07). Report questions quality of air aboard planes. Wall Street Journal, pp. A.8-A8. Retrieved June 18, 2011, from http://search.proquest.com/docview/398786365?accountid=8473 Pan, J., Barbeau, E. M., Levenstein, C., & Balbach, E. D. (2005). Smoke-free airlines and the role of organized labor: A case study. American Journal of Public Health, 95(3), 398398-404. Retrieved June 18, 2011, from http://search.proquest.com/docview/215087194?accountid=8473 Tobacco Public Policy Center. (2008). Federal laws. Retrieved June 20, 2011, from http://www.law.capital.edu/tobacco/federal_laws.asp United Airlines Inc. (2007). Flight attendant history. Retrieved June 15, 2011, from http://uvsc.aviationuniversity.com/multimedia/pdf/era_10.pdf

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