dissenting:
Petitioner Prill asks this court to set aside an order of the National Labor Relations Board denying him reinstatement and *958other relief. The Board determined that Prill’s employer, Meyers Industries, Inc., did not commit an unfair labor practice by discharging Prill, because the conduct for which Prill was discharged was not “concerted activity]” under section 7 of the National Labor Relations Act (“NLRA” or “Act”), 29 U.S.C. § 157 (1982). Meyers Industries, Inc., 268 N.L.R.B. No. 73, 115 L.R.R.M. 1025 (Jan. 6, 1984) (hereinafter referred to as “Meyers ”). In my view, the Board reached a result that seems to me compelled by section 7. If Prill’s actions might be called “concerted,” almost any actions might be so characterized and the qualifying word that Congress wrote into the statute would effectively be removed from it. But, in any event, the Board’s interpretation of the provision is reasonable and should be upheld without hesitation.
I.
The majority does not purport to disturb any of the Board’s findings of fact in this case. It is therefore common ground that Prill was discharged for refusing to drive an unsafe vehicle and entering safety complaints about the vehicle to his employer and to state authorities. See Meyers at 15, 115 L.R.R.M. at 1030. It is also common ground that “Prill alone refused to drive the truck and trailer; he alone contacted the Tennessee Public Service Commission after the accident; and, prior to the accident, he alone contacted the Ohio authorities. Prill acted solely on his own behalf.” Meyers at 16, 115 L.R.R.M. at 1030. Moreover, it is undisputed that as to a similar complaint made in Prill’s presence by another driver, one Gove, about the same vehicle, “the judge correctly made no factual finding that Prill and Gove in any way joined forces to protest the truck’s condition.” Meyers at 16-17, 115 L.R.R.M. at 1030.
In the course of applying section 7 to this case, the Board overruled its decision in Alleluia Cushion Co., 221 N.L.R.B. 999, 1000 (1975), which had held that “where an employee speaks up and seeks to enforce statutory provisions relating to occupational safety designed for the benefit of all employees, in the absence of any evidence that fellow employees disavow such representation, we will find an implied consent thereto and deem such activity to be concerted.” The Board held that “the concept of concerted activity first enunciated in Alleluia does not comport with the principles inherent in Section 7 of the Act,” and asserted that it would instead rely “upon the ‘objective’ standard of concerted activity— the standard on which the Board and the courts relied before Alleluia.” Meyers at 11, 115 L.R.R.M. at 1028-29. The Board then proceeded to set forth a definition of concerted activity that “is an attempt at a comprehensive one, [but] we caution that it is by no means exhaustive. We acknowledge the myriad of factual situations that have arisen, and will continue to arise, in this area of the law.” Id., 115 L.R.R.M. at 1029. The Meyers reformulation is as follows: “[i]n general, to find an employee’s activity to be ‘concerted,’ we shall require that it be engaged in with or on the authority of other employees, and not solely by and on behalf of the employee himself.” Id. at 12, 115 L.R.R.M. at 1029 (footnote omitted).
The majority does not dispute that, if the Meyers test is valid, Prill’s conduct is not concerted activity and therefore cannot be protected under section 8(a)(1) of the Act, 29 U.S.C. § 158(a)(1) (1982). The majority also refrains from holding that Prill’s conduct was concerted activity under section 7, and claims to “express no view on whether, under § 7, the Board may adopt the Meyers test as an act of discretion.” Maj. op. at 948 n. 46. Nonetheless, invoking SEC v. Chenery Corp., 318 U.S. 80, 63 S.Ct. 454, 87 L.Ed. 626 (1943), the majority sets aside the Board’s order and remands this case to the Board on the grounds that “the Board misinterpreted the law in two respects.” Maj. op. at 948. First, the majority argues that the Supreme Court’s decision in City Disposal Systems, Inc., — U.S.-, 104 S.Ct. 1505, 79 L.Ed.2d 839 (1984), “makes unmistakably clear that, contrary to the Board’s view in Meyers, neither the language nor the history of section 7 re*959quires that the term ‘concerted activities’ be interpreted to protect only the most narrowly defined forms of common action by employees, and that the Board has substantial responsibility to determine the scope of protection in order to promote the purposes of the NLRA.” Maj. op. at 952. Second, the majority states that “contrary to the view expressed by the Board, we find that the Meyers test does not represent a return to the standard relied on by the courts and by the Board before Alleluia, but instead constitutes a new and more restrictive standard.” Id. at 948. Because, in the majority’s view, the Board in its discretion could have adopted a definition of concerted activity under which petitioner’s conduct would be held to be concerted, remand is required. As I shall show, it is the majority rather than the Board that has misinterpreted the law, and in any event the Board’s alleged mistakes, if they existed, would be harmless error under the facts of this case.
II.
A.
In this case, the Board has proposed and applied a new test which it regards as consistent with Congress’ intent in employing the words “concerted activities” in section 7 of the NLRA. As the majority recognizes, “the task of defining the scope of § 7 is for the Board to perform in the first instance as it considers the wide variety of cases that come before it, and, on an issue that implicates its expertise in labor relations, a reasonable construction by the Board is entitled to considerable deference.” NLRB v. City Disposal Systems, Inc.,--U.S.-, 104 S.Ct. 1505, 1510, 79 L.Ed.2d 839 (1984) (citations and quotation marks omitted). The question for decision would appear to be straightforward: is the Board’s new construction of section 7 reasonable or not? The anomalous character of the majority’s analysis is well shown by the fact that the majority never answers this question.
The Board’s reading of section 7 is, in my view, altogether reasonable, and neither City Disposal nor any other Supreme Court decision .suggests otherwise. In City Disposal, the Supreme Court upheld the Board’s Interboro doctrine, under which an employee’s assertion of a right created by a collective-bargaining agreement is treated as concerted activity. See Interboro Contractors, Inc., 157 N.L.R.B. 1295, 1298 (1966), enforced, 388 F.2d 495 (2d Cir.1967). The Court noted that the Board in Meyers had distinguished cases involving the Interboro doctrine from the run of section 7 cases because Interboro cases concern conduct that relates back to a collective-bargaining agreement, and concluded that “[t]he Meyers case is thus of no relevance here.” 104 S.Ct. at 1510 ,n. 6.1 That remark alone suggests, rather strongly one would think, that City Disposal does not control this case and certainly does not support the majority’s position.
The Court described the question to which its opinion was addressed as “whether the Board’s application of § 7 ... is reasonable.” 104 S.Ct. at 1510. The Court summarized the dispute over the Interboro doctrine as one that “merely reflects differing views regarding the nature of the relationship that must exist between the action of the individual employee and the actions of the group in order for § 7 to apply.” *960City Disposal, 104 S.Ct. at 1511 (emphasis added). As this language indicates, some real connection between the individual’s conduct and group action was presupposed by both contending viewpoints before the Court — and the Court in no way repudiated that threshold requirement. For, as the Court went on to say, the process of which the collective bargaining agreement is a part is “a single, collective activity,” which “extend[s] through the enforcement of the agreement.” Id. The “relationship” the Court identified between individual assertions of rights derived from a collective-bargaining agreement and group action was, moreover, essentially identical to the one it perceived between group action and the individual acts of “joining and assisting a labor organization, which § 7 explicitly recognizes as concerted,” Id. 104 S.Ct. at 1512. In the latter situation, the individual’s “actions may be divorced in time, and in location as well, from the actions of fellow employees. Because of the integral relationship among the employees’ actions, however, Congress viewed each employee as engaged in concerted activity.” Id. (emphasis added). In a footnote the Court added, “[o]f course, at some point an individual employee’s actions may become so remotely related to the activities of fellow employees that it cannot reasonably be said that the employee is engaged in concerted activity.” Id. 104 S.Ct. at 1512 n. 10. The Court briefly examined the legislative history of section 7, and, finding the Interboro doctrine “fully consistent with congressional intent,” id. 104 S.Ct. at 1513, concluded that “the doctrine constitutes a reasonable interpretation of the Act.” Id. 104 S.Ct. at 1516.
City Disposal establishes only that the Interboro doctrine, which presupposes a real and not imaginary relationship between individual conduct and group action as a condition precedent to finding concerted activity, is a reasonable interpretation of section 7. If the Board in Meyers had held that the Interboro doctrine is inconsistent with the meaning of section 7, I would agree that City Disposal would require us to reject the Board’s reasoning. If the Board had held that some other type of individual conduct that was equally directly related to group action could not be deemed concerted activity consistently with section 7,1 would agree that City Disposal would strongly suggest the Board was wrong. But that is not what happened here.
Meyers repudiated the Alleluia doctrine, which deems individual protest grounded in a worker protection statute to be concerted activity whether or not any other employees are involved in the protest. Alleluia’s test for concerted activity required less than a “remote” relationship between individual and group activity — it required no relationship at all. City Disposal is therefore completely consistent with the Board’s determination that “the concept of concerted activity first enunciated in Alleluia does not comport with the principles inherent in Section 7 of the Act.” Meyers at 11, 115 L.R.R.M. at 1028.
Beyond that, I do not think that City Disposal establishes that the Board has discretion to adhere to the Alleluia doctrine.2 Nor is there any basis in the language of section 7 for the majority’s suggestion that “the case of an employee who is discharged for conduct required by laws designed for the benefit of all employees may be distinguishable from the judicial decisions that have rejected the theory of implied concerted activity in other contexts.” Maj. op. at 953 n. 72. City Dis*961posal makes clear that the words “concerted activities” were intended to reach individual conduct that is linked to group activity in any of several ways, but it reaffirms the longstanding rule that there must be both group activity and a clear nexus between that activity and the individual’s conduct. The Alleluia doctrine destroyed the statutory requirements of group action and a nexus between that action and the individual’s conduct, thereby reading the word “concerted” out of section 7 altogether. The City Disposal Court’s careful effort to ground the Interboro doctrine in the language of section 7 confirms the proposition that “§ 7 ... should be read according to its terms.” Ontario Knife Co. v. NLRB, 637 F.2d 840, 845 (2d Cir.1980). There is no reading of section 7 “according to its terms” that would allow a finding of concerted action in this case or in Alleluia-type cases generally.3 Therefore, while I agree with the majority that the Board believed it had no discretion to adhere to the Alleluia doctrine, in my view the Board’s belief was entirely correct. Since an individual’s appeal to a statute about worker protection involves other workers only in the sense that they “should” be concerned with such protection, it is difficult to see how that case differs from one in which an individual protests about any matter that, in the estimation of the Board or a court, “should” be of concern to other workers. Thus, by sleight of hand, Board or judicial policy replaces congressional policy, individual behavior becomes group action, and the requirement that activity be “concerted” drops from the law.
Thus, in Meyers the Board found that “under the Alleluia analytical framework, the Board questioned whether the purpose of the activity was one it wished to protect and, if so, it then deemed the activity ‘concerted,’ without regard to its form. This is the essence of the per se standard of concerted activity.” Meyers at 9, 115 L.R.R.M. at 1027. This per se standard presumes that what “ought to be of group concern,” id. at 10, 115 L.R.R.M. at 1028, is for the mutual aid or protection of other employees, and therefore that when an individual employee protests over some such matter he is engaging in concerted activity. Id. at 10, 115 L.R.R.M. at 1028. The Board contrasted this approach with the practice of the Board and the courts before Alleluia, which “generally analyzed the concept of protected concerted activity by first considering whether some kind of group action occurred and, only then, considering whether that action was for the purpose of mutual aid or protection,” Meyers at 4-5, 115 L.R.R.M. at 1026, and held that the Alleluia approach was “at odds with the Act.” Id. at 10, 115 L.R.R.M. at 1028.
Precisely the same understanding informs City Disposal, where the Court noted at the outset that an employee’s assertion of a right derived from a collective-bargaining agreement falls “within the ‘mutual aid or protection’ standard, regardless of *962whether the employee has his own interests most immediately in mind.” City Disposal, 104 S.Ct. at 1510-11 (citation omitted). Had the Court accepted the reading of section 7 that the Board in Meyers identified as underlying the Alleluia doctrine, it could simply have said that because rights contained in a collective-bargaining agreement are secured for the mutual aid or protection of all employees who work under that agreement, an individual’s assertion of any such right must be deemed to be concerted activity. In fact, however, the Court drew no inference from the finding that the “mutual aid or protection” standard had been met. Instead, the Court based its decision that the Interboro doctrine is a reasonable interpretation of section 7 on the integral relationship between the process of collective bargaining — which is indisputably concerted activity — and the assertion of rights based on a collective bargaining agreement. City Disposal, then, contains no suggestion that it is within the Board’s discretion to adhere to the Alleluia doctrine or to any other theory of “constructive” concerted activity that is not grounded in the language of section 7.
B.
The majority also claims, however, that City Disposal establishes that “the Board’s opinion is wrong insofar as it holds that the agency is without discretion to construe ‘concerted activities’ except as indicated in the Meyers test.” Maj. op. at 948. This claim is flatly wrong because the Board nowhere held or implied any such thing. The Board did not say that the Act requires the exact formulation it tentatively adopted — it said that the general, pre-Alleluia approach which considers “first, whether the activity is concerted, and only then, whether it is protected,” is “mandated by the statute itself.” Meyers at 10, 115 L.R.R.M. at 1028. That is simply another way of saying that section 7 does not authorize the Board to find concerted activity merely because one individual’s activity concerns matters that affect the well-being of other employees, and so falls within the “mutual aid or protection” standard. This is the only aspect of its legal analysis that the Board claims is “mandated” by the Act,4 and, as I have demonstrated in Part II-B supra, the Board’s view that section 7 leaves it without discretion on this point is entirely reasonable and fully consistent with City Disposal.5
C.
Even if I agreed with the majority that the Board’s opinion held that section 7 required it to adopt a definition of “concerted activit[y]” no broader than the Meyers test, and even if I were convinced that such a holding was erroneous, I would not remand in this case. On the facts as we must take them, there is in my view no definition the Board could propose that would, consistently with the language of section 7, afford petitioner relief. For there is no finding here that petitioner’s conduct was in any way related to group activity. In order to find concerted activity here, the Board would have been forced to hold that con*963cert can be presumed where two employees complain about the same piece of equipment on different occasions, merely because the second employee to complain was aware of the first employee’s protest. Obviously, the first employee’s protest would not be concerted even under this presumption. Hence the Board would be treating the second protest as concerted not because it was related to group activity but merely because it resembled another employee’s individual conduct. The language of section 7 does not admit of such a reading. Since the Administrative Procedure Act requires us to review with due regard for “the rule of prejudicial error,” 5 U.S.C. § 706 (1982), I would deny the petition and let the alleged infirmities in the Meyers test await challenge on another occasion.
III.
The second flaw the majority finds in Meyers is “a misreading of precedent in selecting the new standard.” Maj. op. at 953. The majority’s forced reading of the Meyers test wrongly presupposes that the Board intends that test to be exhaustive and resolves every doubt in favor of construing the Meyers test so that it appears as narrow as possible. The Board, it bears emphasizing, explicitly stated that the Meyers test is not meant to be exhaustive, and may be modified as the Board grapples with the “myriad of factual situations” that can be expected to arise under section 7. Meyers at 11, 115 L.R.R.M. at 1029. It is virtually certain that there is at least one category of cases the Board would treat as exceptions to the Meyers test: cases involving the assertion of rights under a collective-bargaining agreement (for the Board specifically distinguished the Interboro line of cases, see id. at 11, 115 L.R.R.M. at 1028). The Meyers test, as applied to the facts of this case, holds only that, Inter- - boro cases aside, the Board now requires (1) some evidence of intent to actually induce concerted activity, or (2) some evidence of mutual reliance on the conduct or support of other employees, or (3) some evidence of an actual agreement between employees to protest a given situation, as a condition precedent to a finding of concerted action. Nothing more than this can reliably be made out from Meyers, and the majority does not establish that this interpretation of section 7 runs counter to the case law.
The proof of this is that neither of the “two important respects” in which the majority finds the Meyers test “narrower” than “the standards traditionally applied by the Board and the courts to define concerted activity,” maj. op. at 954, can be established on the basis of the record and decision in the present case. The majority’s initial claim, that “the new definition will be strictly construed to include only activity clearly joined in or endorsed by other employees,” id. at 948, see also id. at 954, rests solely on the majority’s reading of the Board’s subsequent decisions in Mannington Mills, Inc., 272 N.L.R.B. No. 15, 117 L.R.R.M. 1233 (Sept. 21, 1984), and Allied Erecting & Dismantling Co., 270 N.L.R.B. No. 48, 116 L.R.R.M. 1076 (Apr. 30, 1984). See maj. op. at 948-949 & n. 48.6 In Meyers itself, the only indication given as to the Board’s standard in “endorsement” cases is the Board’s remark that “there is no evidence here ... that either [Prill or Gove] relied in any measure on the other when each refused to drive the truck.” Meyers 'at 17, 115 L.R.R.M. at 1030. That reveals only that no reliance will not constitute authorization — it does not tell us how much reliance will suffice. Similarly, the principal indication in Meyers as to the scope of the words “with ... other employees” in the Meyers test is the *964Board’s finding that “there is no evidence here that there was any concerted plan of action between Gove and Prill.” Meyers at 17, 115 L.R.R.M. at 1030.7 From this we can infer that the Board will not find a “concerted plan of action” where two employees complain about the same piece of equipment on different occasions, even though the second employee was aware of the first employee’s protest. The Board’s use of the words “concerted plan of action” suggests that some kind of agreement between the two must be established, but it remains unclear how express that agreement must be, for the record is barren of any evidence even suggesting agreement.
The majority’s willingness to go beyond the confines of the record before us to consider how the Meyers test has been applied by the Board in subsequent cases is highly questionable. We are reviewing an order issued by the Board in this case, not a rule or regulation promulgated after notice-and-comment rulemaking, in which we must necessarily consider how the challenged rule will be applied in whatever cases are likely to arise. If the Meyers test, as applied to petitioner Prill, is a reasonable interpretation of the statute, the order should be sustained. The reasonableness of the Meyers test as applied in subsequent cases can and should be reviewed when the orders in those cases come before a court.
Moreover, even if these subsequent decisions could properly be considered here, there is simply no connection between this criticism of the Meyers test and the result reached in this case. The majority concedes that, even if the Board did misinterpret pre-Alleluia case law, remand would be inappropriate if that mistake clearly had no bearing on the substance of the decision reached as to petitioner Prill. See maj. op. at 956. Since there was no evidence that other employees in any way joined in or endorsed petitioner’s conduct, that branch of the majority’s critique cannot possibly affect the outcome here.
The majority’s second objection is that “it is not clear ... that the Meyers standard would protect an individual’s efforts to induce group action.” Maj. op. at 955. The majority notes that the Board declined to reach this question in a post-Meyers case, see id. at 955 n. 83, and proceeds to engage in the highly speculative enterprise of deducing, from the Board’s choice of citations, that the Board will not hold individual efforts to induce group action to be concerted. Id. The majority gives the impression that the Meyers test, whose wording is borrowed from the Ninth Circuit’s language in Pacific Electricord Co. v. NLRB, 361 F.2d 310 (1966) (per curiam), represents a conscious choice on the Board’s part to adopt a formulation that no other circuit has followed,8 while rejecting *965the predominant standard, which, according to the majority, is that set out in Mushroom Transportation Co. v. NLRB, 330 F.2d 683 (3d Cir.1964). The Mushroom Transportation standard differs from the Meyers test principally in that it explicitly states that “a conversation may constitute a concerted activity although it involves only a speaker and a listener, but to qualify as such, it must appear at the very least that it was engaged in with the object of initiating or inducing or preparing for group action or that it had some relation to group action in the interest of the employees.” 330 F.2d at 685.
The majority has overlooked the Board’s finding that neither Prill’s refusal to drive the truck nor driver Gove’s earlier refusal, to which Prill was an accidental and silent witness, was “intended to enlist the support of other employees,” Meyers at 17,115 L.R.R.M. at 1031. If the majority were right in thinking that the Meyers test eliminates the “inducement” category of cases from the definition of concerted activity, the Board would have had no need to make this finding.
The majority also slights the Board’s discussion of Root-Carlin, Inc., 92 N.L.R.B. 1313 (1951), which the majority cites as one of the leading cases holding that individual attempts to induce concerted activity are themselves concerted. The Board in Meyers relied on Root-Carlin as one of a series of cases it read as “defin[ing] concerted activity in terms of employee interaction in support of a common goal,” Meyers at 5, 115 L.R.R.M. at 1026 — cases the Board clearly approved. The Board plainly indicated that, at a minimum, individual efforts to induce group action that “involve[J only a speaker and a listener, ” id. at 5, 115 L.R.R.M. at 1026 (quoting Root-Carlin, Inc., 92 N.L.R.B. at 1314 (emphasis added by the Board in Meyers)), will be treated as concerted when the speaker, an employee, is addressing the listener, another employee.
Indeed, any fair reading of the Meyers opinion would treat it as incorporating the Mushroom Transportation standard, at least as applied by the court that framed it. It was precisely because the “interaction” among employees present in the conversation in Root-Carlin, Inc. was absent in Mushroom Transportation that the court in the latter case found that the individual employee’s conduct was not concerted. It reached that result, despite the fact that the discharged employee “had been in the habit of talking to other employees and advising them as to their rights,” 330 F.2d at 684, because there was no evidence that his “talks with his fellow employees involved any effort on his or their part to initiate or promote any concerted action to do anything about the various matters as to which [he] advised the men or to do anything about any complaints and grievances which they may have discussed with him.” Id. at 684-85. A finding of no concerted activity in the present case would seem to follow a fortiori from Mushroom Transportation — for in the present case there was not even a conversation between petitioner and another employee about common grievances, let alone one directed towards concerted activity.9
*966The “inducement” branch of the majority’s critique rests, then, on a misreading of the Meyers opinion. Beyond that, the only way in which this alleged error could possibly affect the outcome in this case would be if the Board could have held that where one employee overhears another employee’s complaint (as Prill did Gove’s), an effort to induce concerted activity on the second employee’s part should be inferred without more. Any such inference would be preposterous, and the majority has not pointed to a single case as so holding, let alone established a clear line of authority to that effect.10 Consequently, even if the majority’s dubious criticisms of the Board’s reading of the case law in Meyers prove well-founded, they are harmless error that cannot support a remand in this case.
ÍV.
There have been protests in recent years that the “concerted activity” requirement produces such anomalous results that anything resembling a literal reading of section 7 should be abandoned. See, e.g., Gor-man & Finkin, The Individual and the Requirement of “Concert” Under the National Labor Relations Act, 130 U.Pa.L. Rev. 286 (1981); see also Illinois Ruan Transport Corp. v. NLRB, 404 F.2d 274, 281 (8th Cir.1968) (Lay, J., dissenting). It is a sufficient response that the choice to require that activity be concerted before it may be protected “is one decided by Congress when it drafted § 7. It is not a choice that can be undone by the courts for policy reasons.” E.I. du Pont de Nemours & Co. v. NLRB, 707 F.2d 1076, 1078 n. 2 (9th Cir.1983). Moreover, as the four dissenting Justices in City Disposal pointed out (without controversion by the majority), “[b]y providing an increased degree of statutory coverage to employees participating in that process, the labor laws encourage and preserve the ‘practice and procedure of collective bargaining.’ The fact that two employees acting together receive coverage where one acting alone does not is therefore entirely consistent with the labor laws’ emphasis on collective action. See NLRB v. Allis-Chalmers Mfg. Co., 388 U.S. 175, 180, 87 S.Ct. 2001, 2006, 18 L.Ed.2d 1123 (1967); Republic Steel Corp. v. Maddox, 379 U.S. 650, 653, 85 S.Ct. 614, 616, 13 . L.Ed.2d 580 (1965).” City Disposal, 104 S.Ct. at 1518 (O’Connor, J., dissenting) (additional citations omitted). Because what the Board did here was compelled by that congressional choice, I would uphold its order.11 I therefore respectfully dissent.
. Though the Second Circuit originated the In-terboro doctrine, that court found no inconsistency in rejecting the Board’s later efforts — of which Alleluia is one example — to find concerted activity in "any case in which a cause advanced by an individual would redound to the benefit of his fellow employees.” Ontario Knife Co. v. NLRB, 637 F.2d 840, 845 (2d Cir.1980). Writing for the court, Judge Friendly urged that "except in the context of agreements between an employer and his employees which are themselves the product of concerted activities, as in Interboro [,] § 7 ... should be read according to its terms.” Id. Interboro cases were treated specially because "a collective bargaining agreement ... is itself the result of concerted activity.” Id. That very rationale, of course, is central to the Supreme Court’s reasoning in City Disposal, see 104 S.Ct. at 1511. Hence Ontario Knife tends to confirm the validity of the distinction between the Interboro and Alleluia doctrines drawn by the Board in Meyers, and relied on by the Supreme Court in City Disposal.
. The majority denies that it is holding that the Board has discretion under section 7 to adopt the Alleluia doctrine. Fair enough. But the majority does not explain how its suggestion, that individual complaints relating to safety statutes are distinguishable from other individual complaints, can be reconciled with the language of section 7 except by reliance on one or both of the rationales the majority identifies as underlying the Alleluia doctrine. Thus, while not directly endorsing "the sweeping Alleluia principle,” maj. op. at 953 n. 72, the majority also fails to show that there is a middle ground between Alleluia and the general approach taken by the Board in Meyers which, consistently with the language of section 7, could result in a finding of concerted activity in this case.
. To be sure, there is one reading of section 7 which purports to be literal and which would ratify the Alleluia doctrine. That reading was suggested in the dissenting opinion in Illinois Ruan Transport Corp. v. NLRB, 404 F.2d 274, 281 (8th Cir.1968) (Lay, J., dissenting): "The words ‘concerted activity’ are directly related and defined in terms of their intended purpose of ‘collective bargaining' or other ‘mutual aid or protection.’ The phrases are interrelated and derive substantive meaning from each other." Id. at 288. On this reading, concerted activity may be found to exist "if there is some reasonable relationship connecting an employee’s conduct with the ‘mutual aid and protection’ of other employees and such activity is based upon rights collectively recognized within a bargaining agreement.” Id. at 289. In the dissent’s view, Illinois Ruan turned on the validity of the Interboro doctrine, see id. at 283, so Judge Lay was not required to take his interpretation further than he did. Clearly, however, once the meaning of "concerted activit[y]” is defined in terms of the words that follow it, activity is concerted either if it is "for the purpose of collective bargaining or other mutual aid or protection.” 29 U.S.C. § 157 (1982) (emphasis added).
This reading is not truly literal, for it makes the word "concerted” in section 7 utterly superfluous: so long as an individual’s conduct is for the "mutual aid or protection" of other employees it will always be deemed concerted. And both the Board in Meyers and the Supreme Court in City Disposal rejected this reading — the former explicitly, the latter implicitly but no less clearly. See infra p. 961.
. The Board did deny that “section 7, framed as it was to legitimatize and protect group action engaged in by employees for their mutual aid and protection, was intended to encompass the case of individual activity presented here.” Meyers at 18, 115 L.R.R.M. at 1031. At most, that denial is a claim that the result in this case is compelled by the language and purpose of section 7 — a claim that indubitably rests on a reasonable interpretation of the statute.
. FCC v. RCA Communications, Inc., 346 U.S. 86, 73 S.Ct. 998, 97 L.Ed. 1470 (1953), on which the majority relies in reaching the conclusion that remand is required here, is simply inapposite. RCA Communications holds that when an agen-ey reaches a result in the erroneous belief that the statute compels that result, the court should remand rather than reversing if that result might have been upheld had the agency instead relied on its discretion. Because the Board's discretion in interpreting section 7 is not broad enough to allow the Board to adhere to the Alleluia doctrine, or to hold that Prill’s conduct was concerted on any other theory, there is no basis for remanding this case. Remand would be "an idle and useless formality. Chenery does not require that we convert judicial review of agency action into a ping-pong game.” NLRB v. Wyman-Gordon Co., 394 U.S. 759, 766 n. 6, 89 S.Ct. 1426, 1430 n. 6, 22 L.Ed.2d 709 (1969).
. In addition, the facts of Ontario Knife Co. v. NLRB, 637 F.2d 840 (2d Cir.1980), which the Board cited as support for the Meyers test, rather clearly resemble those in Mannington Milts and Allied Erecting & Dismantling Co. Ontario Knife, which found no concerted activity in an individual employee's refusal to work, despite prior activity (in which the same employee was a participant) that was clearly concerted and related to the same issue involved in the refusal to work, see 637 F.2d at 842-43, suggests that at least this degree of strict construction has some authoritative support in the case law.
. What we can, I think, be confident of is that the Board does not mean that if the employer here had offered the keys to Prill’s truck to each of his assembled drivers one day, and each had refused to drive it, the Board would find no concerted activity. Under such circumstances, conscious parallelism would be very strong evidence of spontaneous but quite concerted activity. Cf. NLRB v. Washington Aluminum Co., 370 U.S. 9, 82 S.Ct. 1099, 8 L.Ed.2d 298 (1962) (holding a spontaneous walk-out protesting working conditions in a non-union plant concerted protected activity). The Board did say that "indi-, vidual employee concern, even if openly manifested by several employees on an individual basis, is not sufficient evidence to prove concert of action,” Meyers at 17, 115 L.R.R.M. at 1030, and those words could be taken to mean that even this degree of visible cooperation is not concerted activity. But that remark is dictum— and it will also bear a different, narrower, and more sensible meaning. I would give it that meaning.
. The Board borrowed the wording of its non-exhdustive Meyers test from that one-sentence opinion, but it also cited as supporting authority Judge Friendly’s trenchant opinion for the Second Circuit in Ontario Knife Co. v. NLRB, 637 F.2d 840 (1980). Judge Friendly recognized the "inducement” exception to the general rule that only concerted activity comes within section 7, which he traced to the fact that "§ 7 is not limited to concerted activity per se. Instead, it protects the ‘right to engage in ... concerted activities.' ” Ontario Knife Co., 637 F.2d at 844-45. Since workers have the right to engage in concerted activity, Judge Friendly agreed that "as the Third Circuit recognized in Mushroom Transportation Co. v. NLRB, 330 F.2d 683 (3 Cir.1964), employers cannot obstruct an employee's efforts to exercise those rights. Indi*965vidual activity can be protected, therefore, if it is ‘looking toward group action.’ Mushroom Transportation, 330 F.2d at 685.”
Judge Friendly’s statutory argument is a powerful one, and it indicates what is wrong with holding the Board to the standard of exactitude the majority demands of the Meyers test. The Board in Meyers focused, quite understandably, on the words "concerted activities” in section 7, and although it clearly indicated that it would treat at least some "inducement” cases as involving concerted activity, the majority is right in finding some difficulty in bringing such cases within the literal language of the Meyers test. But we are not to suppose that the Board will set that test in concrete, nor should we rush to assume that in a case in which “the right to engage in ... concerted activities” is before it, the Board will not adopt the Mushroom Transportation standard on the statutory grounds given by Judge Friendly in Ontario Knife. Here, that issue was not presented, because there was no evidence whatsoever that petitioner’s conduct was "looking toward group action.”
. The majority correctly notes that Prill talked • to other drivers about the defective brakes on his truck, see Tr. at 18, J.A. at 42, but there is no indication that these conversations concerned a common grievance, e.g., a pattern of shoddy *966maintenance by Meyers Industries that had prompted complaints from other drivers about their trucks, or that Prill sought to enlist the aid of other drivers in any way.
. The majority does cite a line of cases including Guernsey-Muskingum Elec. Coop., Inc., 124 N.L.R.B. 618 (1959), enforced, 285 F.2d 8 (6th Cir.1960), and Hugh H. Wilson Corp., 171 N.L. R.B. 1040 (1968), enforced, 414 F.2d 1345 (3d Cir.1969), in which the Board treated individual complaints as protected if they related to a matter of moment to other employees and if the individual was acting for the benefit of the interested group. See maj. op. at 945 & n. 24. But the holdings of those cases are little different (and, if anything, narrower) from one of the rationales the majority identifies as underlying the Alleluia doctrine: "the Board’s familiar view that an individual’s activity should be protected if it relates to a matter of ‘mutual concern’ to employees.” Maj. op. at 946. That rationale, as I show in Part II-A, reads the word "concerted" out of section 7, and finds no support in City Disposal. And, while that rationale may be "familiar,” it has also repeatedly been rejected by the courts of appeals; even when the courts have enforced the Board’s orders, they have generally done so because they found actual group activity to which the individual employee's conduct was immediately related. See, e.g., Hugh H. Wilson Corp., 414 F.2d at 1354 (finding concerted activity because "[i]n substance, the employees had a gripe. They assembled. They presented their grievance to management____”); Guernsey-Muskingum Elec. Coop., 285 F.2d at 12 (finding concerted activity because "a reasonable inference can be drawn that the men involved considered that they had a grievance and decided, among themselves, that they would take it up with management”).
. The majority’s suggested limitation of the Alleluia presumption of concerted activity to situations where the employee’s conduct is required by laws intended to benefit all employees cannot be linked in any way to the language of section 7, and is therefore completely unpersuasive. The policy considerations that underlie the majority’s suggestions should be addressed to the legislature or to the state courts as expositors of the common law. In this connection it *967is noteworthy that the recent adoption in some states of a "public policy" exception to the employment-at-will doctrine would appear to protect employees who find themselves in a predicament such as petitioner’s. See, e.g., Petermann v. International Bhd. of Teamsters, 174 Cal. App.2d 184, 344 P.2d 25 (1959); Palmateer v. International Harvester Co., 85 Ill.2d 124, 52 Ill.Dec. 13, 421 N.E.2d 876 (1981); Sventko v. The Kroger Co., 69 Mich.App. 644, 245 N.W.2d 151 (1976). Indeed, Michigan, where Meyers is located and where Prill was employed, has enacted a statute giving an employee who is discharged for reporting a suspected violation of federal or state law to a public body a cause of action for reinstatement with back pay. Mich. Comp.Laws Ann. §§ 15.361 to .364 (1981). That whistle-blowing statute, however, did not go into effect until after Prill was discharged, and it is also unclear whether the statute’s definition • of "public body" includes agencies of other states. See Mich.Comp.Laws Ann. § 15.361(d). Even before adoption of the whistle-blowing statute, there is some reason to think that Prill would have had a cause of action under state common law. See Trombetta v. Detroit, T. & I.R.R., 81 Mich.App. 489, 265 N.W.2d 385 (1978) (holding that allegations that an employee was discharged for refusing to falsify pollution control reports required by law to be filed with state agency state a claim for which relief can be granted under Michigan law). But it is not for us or the Board to pre-empt these developments.