A federal labor board has agreed to review a second case that could force unions to abandon recruiting strategies that allow them to bypass elections in the workplace.

The National Labor Relations Board (search) voted Wednesday to review a complaint by some employees at a Cequent Towing Products' (search) plant in Goshen, Ind., against the United Steel Workers of America (search).

The National Right to Work Legal Defense Foundation (search) is representing the dissatisfied workers who complained they were unionized despite their opposition.

The company agreed to allow the union to bypass secret ballot elections in favor of a "neutrality agreement." That would let the union represent workers if a majority signed cards or petitions in what is called a "card check agreement."

Unions facing an increasingly difficult organizing environment have pursued such agreements to build membership more quickly and avoid years of litigation and bitter battles with employers.

"Workers who want a voice on the job need more protection, not less," said David Bonior, chairman of American Rights at Work (search), a new union-supported advocacy group. "By changing the law, the NLRB may further inhibit workers from exercising their freedom of association."

Critics say that the voluntary recognition method allows union organizers to bully workers into signing union authorization cards because companies often grant unlimited access to the workplace.

"Employees should be allowed to decide for themselves whether to unionize free of union and employer coercion," said Stefan Gleason, vice president of the National Right to Work Foundation.

Also this week, the labor board agreed to review a similar case brought by workers at Dana Corp., an Ohio auto parts maker, involving the United Auto Workers (search). Those workers also are represented by National Right to Work.