Just last year the Board handed down a stinging decision to unions in Machinists Local Lodge 2777, 355 NLRB No. 174 (2010), wherein it found a rule requiring Beck objectors to renew their objections annually violated the duty of fair representation, because of the burden on objectors and insufficient rationale for the burden provided by the union.  Taking another look at the issue, the Board used the same analysis, but this time found the requirement to renew annually is lawful.  In International Union, United Automobile, Aerospace & Agricultural Implement Workers of America Local Union # 376 (Colt’s Manufacturing Company, Inc. et al.), 356 NLRB No. 164 (2011), the Board found an annual requirement to renew Beck objections was not burdensome because the potential objectors received at least four notices of the requirement over the course of a year, an additional notice should the objector fail to renew on time, and, in a notable difference from the 2010 Machinists case, were not subject to a fixed window period for objections.  Therefore, an objector under the policy in Colt’s Manufacturing would only be required to pay one month’s dues while he or she renewed the objection, which was in stark contrast to the system in Machinists in which an objector who failed to renew a objection during the window period was required to pay full dues for an additional eleven months.  Having found the burden of annual renewal was de minimis, the Board in Colt’s Manufacturing did not reach the issue of the union’s justification for the requirement.