September 23, 2019
The Honorable Robert C. “Bobby” Scott
Chairman, Committee on Education and Labor
U.S. House of Representatives
Washington, DC 20515-6100

The Honorable Frederica S. Wilson
Chairwoman, Subcommittee on Health,
Employment, Labor and Pensions
Committee on Education and Labor

RE: Your September 10, 2019 Letter to NLRB Chairman
Dear Reps. Scott and Wilson,
On behalf of the American Staffing Association, we write to express concern with your September 10, 2019
letter to NLRB Chairman Ring regarding the agency’s outsourcing of certain services to a staffing firm which
purported to be a member of the association.
ASA represents the U.S. staffing industry with over a thousand members, including the largest firms in the
industry. What concerns us is the letter’s assertion that, if a staffing firm supplies workers to a government
agency to review public comments submitted to the agency that include comments submitted by a business
association to which the staffing firm belongs, the staffing firm presumptively has a conflict of interest that
violates the Federal Acquisition Regulations.
We disagree with that assertion and urge you to reconsider. Like all Americans, staffing firm owners and
managers have widely diverse political and policy views. The mere fact that their companies belong to ASA, or
any business organization, creates no inference that the firm endorses, or is even aware of, the positions the
organization has taken in its public comments. Much less can any bias or conflict be attributed on that basis to
the temporary and contract employees assigned to perform the document review in question.
Parenthetically, according to our records, the staffing firm in question, Ardelle Associates, has not been a
member of ASA for several years. We recently reached out to the firm to ask whether it might have rejoined as
part of another organization and they confirmed that they had not.
Yours very truly,
AMERICAN STAFFING ASSOCIATION

By: Edward A. Lenz
Senior Counsel
elenz@americanstaffing.net
703-253-2035
cc.

The Honorable John Ring
The Honorable Virginia Foxx