Unions and CB represent a structure and method to at least begin to gain control over practice and combat management systems that "threaten the quality of care of patients and diminish the quality of nurses’ working conditions" (Darr et al., 2002, p. 21). The expectation of frustrated nurses is that constraints imposed by labor law will compel management to reduce the current high patient-to-nurse ratios, abolish mandatory overtime, increase the safety of the environment, and improve their general welfare (Clark et al., 2001).