dissenting:
Because I believe that the majority opinion seriously misreads the statute which controls this case, I consider it my duty to dissent. The opinion of the majority holds that the EEOC must bargain over a proposal which, under the Federal Labor Relations Authority’s (FLRA’s) interpretation of the statute, is a total nullity. The majority holds that incorporation into the collective bargaining agreement of a promise to comply with applicable regulations, including OMB Circular A-76, does require that all “contracting-out” decisions be subject to grievance determinations, but that such a provision affects neither management’s authority to contract out nor the existing union remedies for violations of that regulation.1
The FLRA essentially held that (1) management has a right to make determinations regarding contracting-out; (2) such determinations must be made in accordance with applicable regulations; (3) violations of such regulations are already grievable under the Civil Service Reform Act of 1978 without regard to the necessity of making them grievable in a collective bargaining agreement; and thus (4) a provision in a collective bargaining agreement requiring adherence to such regulations does not infringe the agency’s specific, existing right to “contract out” because it does not make nongrievable matters grievable. The essential flaw in the FLRA’s reasoning — and the one adopted by the majority — is that, contrary to its assertion, violations of Circular A-76 and other regulations regarding substantive contracting-out decisions are not statutorily grievable. Hence, inclusion in a collective bargaining agreement of a promise to comply with the Circular’s terms would permit the union to seek arbitration on issues that are not now grievable, and would create arbitral review of determinations specifically entrusted by Congress to the EEOC and all other federal agencies. This far-reaching decision potentially affects every non-exempt federal agency.
The union plainly recognizes this; why else does it seek so strenuously to impose a collective bargaining provision that — the majority implicitly asserts — gives it nothing it did not already possess? Far from *853being a nullity, the decision of the majority seriously infringes on the authority, specifically reserved to the EEOC and all other agencies by Congress, “to make determinations with respect to contracting out.” 5 U.S.C. § 7106(a)(2)(E).
I. STANDARD OF REVIEW
The majority recognizes that “[rjeview of the Authority’s order shall be on the record in accordance with [5 U.S.C. § 706].” 5 U.S.C. § 7123(c). Section 706 provides:
The reviewing court shall—
(2) hold unlawful and set aside agency action, findings, and conclusions found to be—
(A) arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law; [or]
(C) in excess of statutory jurisdiction, authority, or limitations, or short of statutory right____
(Emphasis added.) Thus, the standard of review for FLRA decisions was spelled out recently by Justice Brennan in Bureau of Alcohol, Tobacco and Firearms v. FLRA, — U.S. -, 104 S.Ct. 439, 444, 78 L.Ed.2d 195 (1983):
Like the National Labor Relations Board, ... the FLRA was intended to develop specialized expertise in its field of labor relations and to use that expertise to give content to the principles and goals set forth in the Act____ Consequently, the Authority is entitled to considerable deference when it exercises its “special function of applying the general provisions of the Act to the complexities” of federal labor relations____
On the other hand, the “deference owed to an expert tribunal cannot be allowed to slip into a judicial inertia which results in the unauthorized assumption by an agency of major policy decisions properly made by Congress.” Accordingly, while reviewing courts should uphold reasonable and defensible constructions of an agency’s enabling Act, ... they must not “rubber stamp ... administrative decisions that they deem inconsistent with a statutory mandate or that frustrate the congressional policy underlying a statute. ”
(Emphasis added.) Applying this standard, the Court unanimously reversed the FLRA’s own construction of its enabling statute. The same principle calls for reversal here.
Courts should be especially cautious about giving undue deference to agency construction of enabling legislation when the particular provision being construed is one designed to act as a limitation on the agency. As this court recently pointed out,
When Congress’ intent is to delegate to the agency the task of supplying the meaning of the statutory standard in question, we are bound to accept the agency view if it is not arbitrary or capricious or inconsistent with underlying congressional intent. When Congress has not delegated this function to the agency, we must undertake full interpretive responsibility ourselves, and we look to the agency view as a relevant, but not controlling, principle. It remains for this court initially to exercise its responsibility to interpret the statute to determine whether Congress delegated the definitional function to the agency.
Vanguard Interstate Tours v. ICC, 735 F.2d 591, 596 (D.C.Cir.1984); Trailways, Inc. v. ICC, 727 F.2d 1284, 1288 (D.C.Cir.1984).
If Congress intended a particular provision to limit the authority of an agency, deferring to an agency decision which eviscerated that provision would foil that legislative intent. When Congress limits the discretion of an agency, a court is remiss if it permits the agency to circumvent that limitation through construction of the statute.2 It is doubly remiss if in doing so it *854violates a clear grant of specific management discretion to another agency.
In Chapter 71 of Title 5 (“Labor-Management Relations”), which creates the FLRA, Congress specifically provided that “nothing in [Chapter 71] shall affect the authority of any management official of any agency ... in accordance with applicable laws ... to make determinations with respect to contracting out.” 5 U.S.C. § 7106(a)(2)(B) (emphasis added). This specific recognition of authority in all federal agencies affirmatively denies to the FLRA any authority to “affect” the authority of an agency to “contract out.” An FLRA decision which encroached on this specifically recognized power would thus violate the plain intent of Congress. Since Congress cannot have intended to give the FLRA discretion to erode the limitations it specifically placed on that Authority by statute, it cannot have intended that courts give great deference to the FLRA’s construction of such limitations.3 To the extent, then, that the FLRA’s decision exceeds its “statutory jurisdiction, authority, or limitations,” 5 U.S.C. 706(2)(C), it is not entitled to deference. This court “must undertake full interpretive responsibility [itself], and ... look to the agency view as a relevant, but not controlling, principle.” Vanguard Interstate, supra, 735 F.2d at 596.
II. ANALYSIS
Although the majority asserts that the plain language of the relevant statutory provisions supports its construction, see Maj. at 848, 851, the relevant language points plainly to exactly the opposite interpretation.
A.
Section 7106 provides:
(a) Subject to subsection (b) of this section, nothing in this chapter shall affect the authority of any management official of any agency—
(1) to determine the mission, budget, organization, number of employees, and internal security practices of the agency; and
(2) in accordance with applicable laws—
(B) to assign work, to make determinations with respect to contracting out, and to determine the personnel by which agency operations shall be conducted____
(b) Nothing in this section shall preclude any agency and any labor organization -from negotiating—
(1) at the election of the agency, on the numbers, types, and grades of employees or positions assigned to any organizational subdivision, work project, or tour of duty, or on the technology, methods, and means of performing work;
(2) procedures which management officials of the agency will observe in exercising any authority under this section; or
(3) appropriate arrangements for employees adversely affected by the exercise of any authority under this section by such management officials.
5 U.S.C. § 7106 (emphasis added). In other words, this section of the Act on its face specifically provides that nothing in Chap*855ter 71 can circumscribe management’s authority to make decisions regarding contracting-out, except for the limitations in § 7106(b). Subsection 7106(b) provides that management may negotiate (1) “procedures which ... the agency will observe in exercising [its reserved] authority,” (2) “appropriate arrangements for employees adversely affected by the exercise of [such] authority” (emphasis added), and (3) at its election, assignment of employees to particular work projects and the means of carrying out such projects.
Significantly, the FLRA did not attempt to construe the contract proposal at issue as relating to “procedures ... the agency will observe” in implementing its contracting-out decisions, a fact which the majority recognizes. See Maj. at 848 n. 12. Indeed, it is difficult to comprehend how OMB Circular A-76 could fit under the provisions of § 7106(b). The purpose and scope of that Circular are spelled out in its first paragraph:
Purpose. This Circular establishes Federal policy regarding the performance of commercial activities. The Supplement to the Circular sets forth procedures for determining whether commercial activities should be performed under contract with commercial sources or in-house using Government facilities and personnel.
OMB Circular No. A-76 (rev. Aug. 4, 1983) (emphasis added). In other words, the Circular and its accompanying Supplement are designed to offer guidance to agencies in making the decision to contract out — i.e., to provide substantive policy-making criteria —not procedures for carrying out decisions already made. If (1) the Circular provides substantive criteria for contracting out, and (2) bargaining over substantive criteria for contracting out is prohibited by law, then (3) a collective bargaining proposal which purports to require an agency to meet substantive criteria is not negotiable. It therefore does not appear that the FLRA could rationally have based its decision on the “procedures” provision of § 7106(b). In any event — even assuming that the language could be twisted into supporting that position — the FLRA did not do so, and this court is prohibited from relying on a ground not advanced by the agency. See SEC v. Chenery Corp., 318 U.S. 80, 95, 63 S.Ct. 454, 462, 87 L.Ed. 626 (1943) (“administrative order cannot be upheld unless the grounds upon which the agency acted in exercising its powers were those upon which its action can be sustained”); NLRB v. Enterprise Association of Pipefitters, 429 U.S. 507, 522 n. 9, 97 S.Ct. 891, 900 n. 9, 51 L.Ed.2d 1 (1977) (Chenery rule “has not been disturbed” by subsequent decisions).
The majority attempts to escape this problem by arguing that, while the FLRA did not specifically find that this provision was procedural, it nevertheless used “similar” analysis to that used in cases involving procedures, i.e., its “direct interference” test. Maj. at 848 n. 12. The simple answer to this is that a test for determining the validity of procedural provisions is entirely irrelevant to the validity of substantive restrictions. Under § 7106, restrictions on procedures which indirectly affect contracting-out by management may well be proper because they fall within § 7106, but non-procedural restrictions which affect that right — whether directly or indirectly — are clearly not.
Moreover, the limited scope of the term “procedures” in subsection (b)(2) is emphasized by subsection (b)(1), in which Congress provided for bargaining over “the employees or positions assigned to any ... work project, ... or on the ... methods, and means of performing work,” but only “at the election of the agency.” Congress recognized the right of any agency to elect to bargain on some subjects that are not mandatory. Congress’ specific treatment of work projects belies the majority’s construction of the statute.4 It makes little *856sense to suggest that “contracting] out” any specific work project is a mandatory subject of negotiation when this subsection clearly provides that negotiation on “any work project” is “at the election of the agency.”
It may be that the key to the majority’s opinion is its footnote 12. Although the Authority itself did not hold that the proposal at issue was only “a procedure” under § 7106(b), the majority finds in that footnote that the proposal really is merely procedural, and hence the management rights provisions do not apply at all.5 But neither the Authority’s opinion — despite the majority’s divination of what that agency meant but did not say — nor the language and history of the statute lends any support to the notion that requiring compliance with substantive decision-making criteria, and subjecting such substantive decisions to arbitral review, is nothing more than a “procedure” for exercising authority to contract out.
B.
The majority, however, does not attempt to rely solely on a sua sponte finding that the provision at issue is procedural. Instead, it rests heavily on another limitation it finds in § 7106: the requirement that decisions regarding contracting-out be made “in accordance with applicable laws.” The majority perforce construes this to mean “in accordance with the other provisions of Chapter 71.”
It should first be pointed out that the FLRA in its opinion did not offer this interpretation of the statute as a basis for its decision, and thus the majority is not only speculating in relying on this as a ground, but is also ignoring the principles of Chenery, supra. The FLRA, in fact, heretofore has recognized that substantive decisions regarding management rights are not reviewable under the grievance procedure:
Under the plain language of section 7106(a), of course, “nothing” in the Statute shall “affect the authority” of an agency to exercise the rights enumerated therein. Hence, no matter could be grieved under a procedure negotiated pursuant to section 7121 of the Statute which would deny the authority of an agency to exercise its statutory rights under section 7106.
AFGE Local 2782, 6 F.L.R.A. 314, 319-21 (1981) (footnote omitted). There is no suggestion in Local 2782 that the phrase “in accordance with applicable laws” can be used to permit grievance review of non-negotiable substantive decisions.6
But even assuming that the FLRA had proffered this interpretation,7 it could not *857withstand scrutiny. Congress provided that, except for § 7106(b), nothing in Chapter 71 shall affect management’s authority, “in accordance with applicable laws,” to make determinations with respect to contracting-out. To reach its conclusion that the whole grievance procedure is somehow excluded from that sweep, the majority must read the phrase “applicable laws” to include the remainder of Chapter 71. Thus, it in effect reads the statute as follows: “Nothing in this chapter [71], EXCEPT ALL THE OTHER PROVISIONS OF CHAPTER 71, INCLUDING § 7121 (PRESCRIBING GRIEVANCE PROCEDURES), shall affect the authority of any management official of any agency ... to make determinations with respect to contracting out ...” (italicized matter supplied). It is absurd to construe the act to say that “nothing" in the rest of Chapter 71 affects management’s right, but that the rest of Chapter 71 does affect that right. This construction is at variance with any reasonable interpretation of the statute. The majority points to nothing in the legislative history which indicates that specifically denominated, non-negotiable rights conferred on “management officials” were nevertheless to be subjected to grievance and arbitral review.
It may be that the majority is not reading the statute that broadly, that not all of the remainder of Chapter 71 falls under “applicable laws.” It may, perhaps, be suggesting simply that Congress’ (unarticulated) intent in § 7106(a) was to shield the decision-making process from negotiation, but not from subsequent review by labor arbitrators and the FLRA. Again, there is no shred of legislative history which indicates that Congress intended contracting-out decisions to be grievable. But the intent of Congress can be inferred from what it wrote. It did not say that contracting-out decisions (and the other management rights) are “non-negotiable.” Had it done so, grievance review arguably would still remain. Instead, it said that, except for § 7106(b), nothing in Chapter 71 can affect the right of the agency to make contracting-out decisions. The latter phrase would be singularly inept if what Congress meant was the former, and at least in the absence of clear Congressional intent or a manifestly unsound result this court should refrain from directly violating the express language adopted by Congress.
C.
Next, even if we assume that (1) the term “applicable laws” does include all the rest of Chapter 71, and (2) the exercise of a non-negotiable management right is subject to the grievance provisions, it is far from clear that a failure to comply with Circular A-76 would meet the definition of a “grievance” for purposes of 5 U.S.C. § 7121.
The term “grievance” is defined restrictively by Congress in 5 U.S.C. § 7103(a)(9)(C)(ii), as here relevant, to mean8 “any claimed violation, misinterpretation, or misapplication of any law, rule, or regulation affecting conditions of employment” (emphasis added).9 The term “conditions of employment” is also restrie*858tively defined to mean “personnel policies, practices, and matters ... affecting working conditions. ” 5 U.S.C. § 7103(a)(14) (emphasis added). Thus, even under the majority’s interpretation of the statute, a violation of agency regulations is a “grievance” under § 7103(a)(9)(C)(ii) only to the extent that such violation involves personnel policies and practices or the working conditions of the employees. These are plainly words of limitation — i.e., not all violations are grievable — and there is no indication that such limitation was inserted inadvertently.
The majority’s footnote suggestion that Circular A-76 may have something to do with personnel policies or practices is insubstantial.10 It must, then, be fitted (if anywhere) under the phrase “matters ... affecting working conditions.” But a contracting-out decision, even when it results in a loss of jobs, is not necessarily a decision affecting the working conditions of the employees. While ordinarily the term “working conditions” is to be broadly interpreted, see Independent Federation of Flight Attendants v. Trans World Airlines, Inc., 655 F.2d 155, 157 (8th Cir.1981), it nevertheless “has a ... specific meaning in the language of industrial relations,” Corning Glass Works v. Brennan, 417 U.S. 188, 202, 94 S.Ct. 2223, 2232, 41 L.Ed.2d 1 (1974), and clearly means “something less than the employment relationship in its entirety.” Southern Railway Co. v. OSHRC, 539 F.2d 335, 339 (4th Cir.), cert. denied, 429 U.S. 999, 97 S.Ct. 525, 50 L.Ed.2d 609 (1976). In interpreting the same term in another statute, the Supreme Court explained that “the element of working conditions encompasses two subfactors: ‘surroundings’ and ‘hazards.’ ” Coming Glass, supra, 417 U.S. at 202, 94 S.Ct. at 2232 (interpreting the Equal Pay Act). This court subsequently noted that only “surroundings” and “hazards” fall within the labor relations meaning of “working conditions,” Laffey v. Northwest Airlines, Inc., 567 F.2d 429, 452 n. 153 (D.C.Cir.1976), and in the FLRA we are dealing with a “labor relations” act. With reference to the term “working conditions” in yet another act, other circuits have held that the term refers to the “environmental area in which an employee customarily goes about his daily tasks.” Columbia Gas of Pennsylvania, Inc. v. Marshall, 636 F.2d 913, 916 (3d Cir.1980); Southern Railway, supra, 539 F.2d at 339. There is no indication that the term “working conditions” in the statute at issue here (which was used by Congress several years after the Coming Glass decision, presumably with knowledge of the meaning assigned to those words by the Court) was intended to have a different, much broader meaning than it enjoys in other labor relations statutes passed by Congress.11
*859It might be argued, on analogy to the National Labor Relations Act (NLRA), that contracting-out decisions do fall within the term “conditions of employment.” In one NLRA case, Fibreboard Paper Products Corp. v. NLRB, 379 U.S. 203, 210, 85 S.Ct. 398, 402, 13 L.Ed.2d 233 (1964), the Supreme Court interpreted the term — which is not defined in the NLRA — to include contracting-out. However, in the Federal Labor Relations Act, unlike the NLRA, Congress — which presumably was aware of both Fibreboard Paper and Corning Glass —chose to define the term strictly in a much narrower fashion: it means only personnel policies and practices and matters affecting “working conditions.” The meaning attached to a term in one statute, where Congress has not defined it, is irrelevant to its meaning in another statute where Congress has defined it. It is the phrase working conditions, not conditions of employment, which acts to narrow the scope of grievances under the FLRA.12
Since a violation of the regulation involved in this case would be grievable only to the extent it affected the environmental conditions under which employees work, it is difficult to see what sort of violation of Circular A-76 could have any effect on the working conditions — as opposed to the continued employment — of the bargaining unit employees. The Circular governs decisions regarding when agencies should contract out; it does not specify the internal agency personnel policies which would implement such decisions. It conceivably could result in the termination of an employee, but would have little or no effect on conditions in the workplace.
D.
The FLRA itself apparently recognizes that some claimed violations of the Circular will turn out to be non-grievable, but insists that each claimed violation must in the first instance go to an arbitrator.13 Under that approach, the arbitrator would decide whether or not the violation is grievable, subject to FLRA review.14 The FLRA has flatly refused to supply any guidance as to which parts (if any) of the Circular it thinks might be grievable. The EEOC sought such guidance in its petition for reconsideration,15 but the FLRA, finding that the request presented no “extraordina*860ry circumstances,” curtly denied it.16 Hence, under the FLRA’s construction, every alleged violation of the Circular, the basic purpose of which is to provide SUBSTANTIVE guidance for management decisions regarding contracting-out, must go to an arbitrator.
The FLRA’s cavalier, conclusory treatment of the EEOC’s legitimate request can be seen as an implicit admission that disclosure of the parts it considers might be grievable would amount to such an extreme denial of elementary managerial authority as to make it perfectly obvious that its construction is a plain violation of the intent expressed by Congress. The same conclusion can be reached with respect to the construction adopted by the majority here. The majority’s construction assures that every managerial decision with respect to “contracting-out,” if questioned, will ultimately be made, not by the agency, but by an arbitrator, subject to very limited review. This results in a complete negation of the intent expressed by Congress.
This interpretation of the grievance procedure offers the union a fertile source of weapons for obstructing or delaying contracting-out decisions, a situation Congress specifically sought to prevent. It is not difficult to visualize what will happen. The union can file a grievance, claiming that one of the technical standards of the Circular (wholly unrelated to working conditions) was not complied with. The claim as to that particular project must go to an arbitrator, who on a case-by-case basis will evaluate it. Assuming that the arbitrator correctly follows the law, the grievance will be denied. The union then will file exceptions to the award with the FLRA, and months — or, drawing on the experience of the National Labor Relations Board, even years — later, the FLRA may deny the exceptions. Review in the court of appeals may follow.17
Even if the grievance is eventually denied, and that denial is affirmed, the prolonged litigation will have cast a cloud over the agency’s contracting-out decision, subjected the decision to considerable delay, and wasted valuable agency assets on an essentially frivolous claim. This extraordinary potential for vexatious litigation will significantly infringe upon management’s specifically designated right to make contracting-out decisions.18 The majority’s *861construction thus fails to comply with Congress’ admonition that Chapter 71 “be interpreted in a manner consistent with the requirement of an effective and efficient government.” 5 U.S.C. § 7101(b).
IV. Conclusion
All of the above was recognized by the union; its apparent goal was to incorporate substantive contracting-out criteria (over which neither it nor management may bargain), into the collective bargaining agreement, which would make them grievable and hence would subject them to arbitral review. The union’s pursuit of this case is utterly inexplicable on any other basis.19 Yet the FLRA and the majority hold that contracting out and the other reserved rights already are covered by the grievance mechanism, and that the processes and criteria used by an agency in making contracting-out determinations must be reviewed by arbitrators and the FLRA through that mechanism. For the reasons set forth above, it is my view that such holding is completely contrary to the language of the applicable statutes, drastically undercuts the specific statutory right of management to contract out, and effectively guts the specific reserved limitations that Congress placed on the agency's duty to bargain and the authority of the FLRA.
I accordingly dissent.
. The FLRA has previously held that a proposal which purported to bind an agency to the specific terms of Circular A-76 as of the date of the proposal — thus, in effect, prohibiting the government from subsequently changing the regulation — was non-negotiable. See National Federation of Federal Employees, Local 1167, 6 F.L.R.A. 574, 577 (1981). In the instant case, the language at issue ("The [agency] agrees to comply with OMB Circular A-76”) can also be read, like that in Local 1167, to require compliance with the present terms of the Circular. The FLRA, however, apparently has interpreted the proposal only to require the agency to comply with the Circular as it is amended from time to time.
. In Department of Justice v. FLRA, 709 F.2d 724, 729-30 (D.C.Cir.1983), the FLRA tried to require bargaining by an agency over procedural protections for probationary employees. *854(The right to dismiss probationary employees is reserved to management under provisions in other parts of U.S.C. Title 5.) This court refused to defer to the agency’s construction of the labor relations provisions at issue. But in AFGE, Local 2953 v. FLRA, 730 F.2d 1534, 1547-48 (D.C.Cir.1984), we affirmed the agency’s decision that a proposal requiring National Guard units to ignore military efficiency when implementing reductions-in-force was non -bargainable.
. The majority relies for its highly deferential stand' — see Maj. at n. 11 — on National Treasury Employees Union v. FLRA, 691 F.2d 553 (D.C.Cir.1982), in which the Authority, with scrupulous concern for the limitations imposed on it by Congress, held that it could not order bargaining over a particular proposal without infringing on management rights. This court deferred to the Authority's interpretation. But that decision does not require us to uphold the Authority’s use of its interpretative power to emasculate specific Congressional restrictions on its authority.
. Congress did not define the term, "work project" in the Act. By analogy to the term "project works,” however, a "work project” may be considered to be a project that constitutes a part of the agency’s complete work load. See Ontario Land Dev't & Beach Protection Ass’n v. *856FPC, 212 F.2d 227, 232 (D.C.Cir.1954); cf. Chemehuevi Tribe of Indians v. FPC, 420 U.S. 395, 401, 95 S.Ct. 1066, 1071, 43 L.Ed.2d 279 (1975) (Congress recognized in definition that "project works” were limited to part of a whole project).
. If this is, in fact, what the majority is holding, then footnote 12 probably renders the remainder of the majority's opinion — particularly its discussion of the phrase "in accordance with applicable laws” — mere verbiage, because it is crystal clear that "procedures” for carrying out decisions are not within the management rights clause.
. The FLRA’s decision in Local 2782 dealt with a proposal for repromoting individuals who had been reduced in grade due to management cutbacks. It was not a case where substantive regulations were involved; the FLRA carefully pointed out, 6 F.L.R.A. at 321, that it involved simply “appropriate arrangements for employees adversely affected by management’s exercise of its authority under section 7106(a),” which are negotiable under the explicit provisions of 5 U.S.C. § 7106(b)(3).
. This interpretation arguably was advanced by the FLRA in National Federation of Federal Employees, Local 1497, 9 F.L.R.A. 151 (1982). In that case, the union proposed that "[w]ork assignments shall not be in violation of prohibited personnel practices nor any relevant law, rule, or regulation." The right to assign work is one of the management rights reserved under § 7106(a). The FLRA held that since the agency was required to exercise its management rights "in accordance with applicable law,” a contract provision binding it to do so did not interfere with its rights. 9 F.L.R.A. at 156. Implicit in this determination is the assumption that a violation of the work assignment regulations would fall within the grievance procedure of § 7121, the same argument relied on in this case; as demonstrated here, this view is at odds with the statutory scheme of the Act. But even assuming that the result in Local 1497 is correct, *857it does not control this case. The assignment of work to employees in that case — unlike the decision to contract out in this case — arguably does have an impact on "working conditions,” and hence might fall under the specific definition of "grievance” in § 7103(a)(9). See pages 857-858 infra.
. A statute that defines a term with the phrase "to mean” is generally restrictive; "to include" is generally expansive. The majority's description of the term "conditions of employment” as "expansive,” see Maj. at 845, is thus incorrect.
. The majority also notes that the definition of "grievance" also includes "any matter relating to the employment of any employee," 5 U.S.C. § 7103(a)(9)(B), and then asserts that a violation of substantive contracting-out criteria "surely falls within this definition.” Maj. at n. 18. But there is nothing "sure” about it. Again, the Authority has not made this claim and the majority offers no support. I note that under the majority’s apparent reasoning, the very decision to adopt a particular economic formula itself would be grievable, because it might at some time in the future, if implemented, have some effect on employment. There is no indication that Congress intended such decisions to be subject to arbitral review.
. The majority asserts that even if the Supreme Court’s interpretation of "working conditions” (see infra ) applies, failure to comply with the Circular’s substantive economic guidelines for making contracting-out decisions would nevertheless "undoubtedly fall under the umbrella of personnel policies or practices.” Not even the Authority in this case has suggested that substantive contracting-out criteria are transmuted into “personnel policies or practices” by virtue of the fact that they may at some point have some sort of impact on the continued employment of particular employees. Not surprisingly, the majority offers no support whatever for this extraordinarily broad reading. Had Congress intended the term "conditions of employment" to include "anything which has or may at some time in the future have an impact on the employment of an employee," it could easily have said so. It did not.
. The majority relies on Department of Defense v. FLRA, 685 F.2d 641 (D.C.Cir.1982), as sanctioning a “broad” construction of the phrase "conditions of employment” in the Act. That case, however, involved union proposals relating to (1) registration of employee automobiles, and (2) provision of certain consumer goods to employees in overseas post exchanges. Both provisions fall clearly within the scope of personnel practices and procedures, and neither even remotely interferes with any reserved management right.
I am unpersuaded by the majority's flat assertion — it is nothing more — that Congress' definition of "working conditions” in one statute simply "does not apply" in another statute. Noting that Congress did not elaborate on its definition in the statute’s legislative history, the majority just presumes that it must have meant something different in this statute than it meant when it used the identical phrase in other stat*859utes. But the most plausible explanation for the lack of discussion in the legislative materials is that Congress assumed that its use of the words "working conditions” — words that it had used previously and which the Supreme Court recognized have a definite, specialized meaning in the labor relations field — made it unnecessary to waste additional pages of its committee reports illuminating the obvious.
. I must note that, contrary to the majority's assertion, I do not "maintain! ] that grievances are restricted to claims involving surroundings and hazards.” See Maj. at n. 18. On the contrary, the statute at issue requires bargaining over (1) "personnel policies," and (2) personnel “practices,” as well as (3) “matters ... affecting working conditions.” 5 U.S.C. § 7103(a)(14).
. That would, as pointed out supra, submit each work project contracted out to mandatory negotiation, in violation of the purely elective negotiation provided for in § 7106(b)(1).
. FLRA review of an arbitrator’s decision is very similar to judicial review of ordinary arbitral awards. It may set aside an award only on two grounds: “(1) because it is contrary to any law, rule, or regulation; or (2) on other grounds similar to those applied by Federal courts in private sector labor-management relations.” 5 U.S.C. § 7122(a). Thus, the majority’s construction assures that every managerial decision with respect to "contracting out,” if questioned, would ultimately be made, not by the agency, but by the arbitrator practically free of any real review.
. The EEOC explained its request for clarification in its letter requesting reconsideration:
For example, OMB Circular A-76 and other applicable laws and regulations concerning contracting out contain procedures for the guidance of management in the technical aspects of contracting out which do not directly affect conditions of employment ....
[I]t seems clear to us that the Union proposal at issue, is not, on its face, limited to conditions of employment .... Since the EEOC has many contracts with no direct or indirect impact on conditions of employment of bargaining unit members, we are asking the FLRA to explain in what fashion OMB Circular A-76 and other applicable laws and regulations concerning contracting out fall within the ambit of the scope of bargaining and the grievance resolution machinery under the Statute.
. The Authority finds that such a request does not establish "extraordinary circumstances” warranting reconsideration as required under section 2429.17 of the Authority’s Rules and Regulations. Rather, the Agency in essence is asking the Authority to make arbitrability determinations in the absence of a specific factual context. To the extent that an arbitrability question may arise in the future, the Agency may, of course, avail itself of the procedures set forth in section 7121 of the Statute for the resolution of such questions.
AFGE, Nat’l Council of EEOC Locals, 10 F.L. R.A. No. 1 (Mar. 18, 1983) (footnote omitted) (order denying reconsideration).
. Review in the court of appeals is governed by 5 U.S.C. § 7123(a), which grants review to:
[a]ny person aggrieved by any final order of the Authority other than an order under —
(1) section 7122 of this title (involving an award by an arbitrator), unless the order involves an unfair labor practice under section 7118 of this title____
(Emphasis added.) Thus, Congress specifically has removed FLRA actions approving or disapprdving most arbitral awards from direct judicial review. (Judicial review may still be available if the FLRA seeks judicial enforcement under 5 U.S.C. § 7123(b).) Without doubting the good faith of the FLRA, I note that should it later attempt to thwart the will of Congress by whittling away specifically reserved management rights through the use of case-by-case arbitration, there may be little the courts can do to correct it. The FLRA’s policy of forcing all alleged violations — whether ultimately found grievable or not — to go to an arbitrator in the first instance may effectively shield future decisions plainly inconsistent with the will of Congress.
. The EEOC in its brief explains the possible consequences of this kind of substantive review:
[A]n EEOC employee could challenge the agency’s contracting-out decision by arguing that the underlying comparative cost analysis [one of the standards set forth in the Circular] was flawed. If the issue went to arbitration, an arbitrator could decide that the analysis was inadequate under the [Circular’s] guidelines ... and therefore did not justify the Agency’s conclusion that the commercial activity in question could be performed most inexpensively by a private source. The ultimate result could be a ruling sustaining the employee's claim, and requiring the EEOC to *861reconsider its contracting-out determinations after conducting another comparative cost analysis.
Reply Brief for Petitioner at 3-4. Under the majority’s construction of the statute, avoidance of this scenario depends greatly on the good faith of the FLRA in subsequently holding such direct review of substantive decisions to be nongrievable. There is, however, nothing in the decision under review which rules out the possibility that the FLRA may wind up reviewing all such determinations in grievance proceedings.
. If, as the majority claims, it is entirely obvious from the statute that violations of the Circular are already grievable as a matter of law, why would the union waste its time, effort, and money in pursuing first the contract proposal and now this action? Even if the EEOC eventually agrees to the proposal — which would contradict the intent of Congress and which, even under the majority’s construction, the agency obviously is not required to do — the union’s remedies for violations of the Circular are, under the majority’s construction, exactly the same. It seems absurd to talk of "bargaining" over a proposal which the majority believes will impose no cost on the agency and confer no benefit on the employees.