As the use of arbitration as a dispute resolution mechanism continues to increase not only in the area of labor relations but also in other fields as well, the authority of arbitrators to issue remedies has likewise become a more important topic. The breadth of this power was established early on in labor-management arbitrations in the Steelworkers Trilogy.1 There the Supreme Court concluded that by entering into an arbitration agreement, a company and union could commission the arbitrator to bring an informed judgment to bear in reaching a fair resolution. The Court stated: "This is especially true when it comes to formulating remedies. There the need is for flexibility in meeting a wide variety of situations." 2 Although the remedial authority of a labor arbitrator is broad, its bounds are not always certain



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