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when there is a collective bargaining agreement it sets out what is being negotiated sometimes the employer and the Union will sign something that includes a zipper clause which states in essence that everything thats been bargained for and could be bargained for is sat out within this particular document namely the collective bargaining agreement often those agreements then will be tested later to determine whether the zipper clause is valid many courts have found them to be invalid because they dont constitute a waiver of all things that can be bargained for in the future that the agreement cannot be strong enough to cover every possible issue that can come up in the future and the clauses are either read very narrowly or determined to be invalid frequently by courts you