The National Labor Relations Board (“NLRB”) is sharpening its focus on “salting”—the practice of union organizers seeking employment with non-union employers to facilitate organizing campaigns. On July 24, 2025, the NLRB’s Acting General Counsel (“AGC”) William Cowen issued updated guidance that both clarifies and intensifies scrutiny around salting cases, altering how these matters will be investigated and litigated.[1] Employers and HR professionals should take note of this evolving landscape.
“Salting” is a union organizing strategy in which union representatives or pro-union employees—known as “salts”—apply for employment with a non-union employer for the specific purpose of organizing the workforce from within.[2] Unlike typical job applicants, salts are motivated not only by an interest in employment but also a desire to advocate for union representation or to gather evidence of unfair labor practices.[3]
Salting can take several forms. Often, salts will conceal their union affiliation and present themselves as regular applicants. In other cases, salts may choose to openly disclose their union ties or organizing intent during the hiring process, which can test whether the employer unlawfully discriminates based on union affiliation. Additionally, in some campaigns, multiple union organizers submit applications at once as a coordinated effort to maximize the organizing impact or overwhelm the employer’s hiring process.[4]
Salting is protected under...
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