With the rise of contingent workforces over the last two decades, many employers have enjoyed the flexibility afforded by staffing companies which provide employees as needed, coupled with a reduction in HR compliance requirements afforded by those companies. A side benefit was the diminution of labor organizing, as NLRB policies effectively insulated franchisors, contractors and companies with staffed employees from potential organizing because the primary company was held not to be a joint employer with the staffing company or other party. However, in August of this year, the National Labor Relations Board