There are two strands of federal labor preemption, Garmon and Machinists. As the Supreme Court explained in Boston Harbor:
When we say that the NLRA pre-empts state law, we mean that the NLRA prevents a State from regulating within a protected zone, whether it be a zone protected and reserved for market freedom, see Machinists, or for NLRB jurisdiction, see Garmon.
Machinists preemption applies to conduct that Congress meant to leave entirely unregulated – unregulated by the Board and also by states and localities. Thus Machinists preemption applies to conduct that is neither protected nor prohibited by the Act; conduct that Congress meant to leave to the “free play of economic forces.” Garmon preemption, on the other hand, applies to conduct that Congress intended to be regulated by the Board. It is a doctrine of deference to the administrative agency that Congress set up to administer the Act. Thus, the Court held in Garmon:
[T]he unifying consideration of our decisions has been regard to the fact that Congress has entrusted administration of the labor policy for the Nation to a centralized administrative agency, armed with its own procedures, and equipped with its specialized knowledge and cumulative experience: ‘Congress did not merely lay down a substantive rule of law to be enforced by any tribunal competent to apply law generally to the parties. It went on to confide primary interpretation and application of its rules to a specific and specially constituted...
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