The public comment period on a proposed new regulation from the National Labor Relations Board (NLRB) governing joint employer status remains open for another 2 weeks, but the proposal has already received some harsh criticism – from the General Counsel of the agency himself! NLRB General Counsel Peter Robb released his comments just over one week ago stating that the proposed standard for joint employment liability wasn’t specific or demanding enough would improperly force some companies to bargain with unions. In pertinent part, Robb urged the agency’s Board to “articulate explicitly in its final rule that a joint employer finding in and of itself does not create legal liability for the unfair labor practices of its co-employer business partner and does not create a bargaining obligation.” He went on to cite the franchising industry and hospitals specifically as warranting a “more nuanced and different approach” to joint liability and encouraged the Board to clarify how an eventual rule applies in those contexts. The public comment period has been extended twice and remains open through close of business on January 14, 2019.