Labor relations, labor law, and the legal aspects of collective bargaining have long been of concern to nurses employed in hospitals. The basic collective bargaining policy of the American Nurses’ Association, for example, dates back to 1946, when its convention adopted an “Economic Security Program.” Unlike some other professional organizations, the ANA not only proposed a “collective bargaining” program, but also explicitly referred to it as such, as it still does. The ANA’s 1946 statement on economic security called for collective action on such traditional collective bargaining items as a 40-hour work week, higher minimum salaries, and improved fringe benefits, as well as on more uniquely professional matters such as participation by nurses in the planning and administration of nursing services.