NLRB’s “Refined” Joint-Employer Test: What is “Indirect” Control? UPDATED By Fox Rothschild LLP on August 28, 2015 A quick update to yesterday’s post. For those wanting more information on yesterday’s NLRB ruling in Browning-Ferris Industries, 362 NLRB No 186, please see the Firm’s Labor & Employment Alert that was issued this morning.