dissenting.
I believe this case presents the rare situation in which it is appropriate for our *244Court to vacate an arbitration award. Therefore, I respectfully dissent.
Although our review of arbitration awards is — as stated by my colleagues in the majority — highly deferential, courts are nonetheless “neither entitled nor encouraged to simply ‘rubber stamp’ the interpretations and decisions of arbitrators.” Matteson v. Ryder Sys. Inc., 99 F.3d 108, 113 (3d Cir.1996). The federal courts retain a significant role in the review of labor arbitration awards and may vacate awards under certain circumstances. Id. at 113-14. One such circumstance occurs when the arbitrator shows “manifest disregard” for the terms of the collective bargaining agreement (“CBA” or “Agreement”) at issue. See, e.g., Major League Umpires Ass’n v. Am. League of Profl Baseball Clubs, 357 F.3d 272, 280 (3d Cir.2004), cert. denied, — U.S. -, 125 S.Ct. 861, 160 L.Ed.2d 769, 2005 WL 35841 (“[A]n award may be vacated if the arbitrator demonstrates manifest disregard for the CBA.”); Newark Morning Ledger Co. v. Newark Typographical Union Local 103, 797 F.2d 162, 165 (3d Cir.1986) (“[I]n that rarest case of manifest disregard of the [collective bargaining] agreement, the [court] must draw the line.”) (internal quotation omitted).
An arbitrator derives her/his authority from the terms of the CBA and the scope of the issues submitted by the parties. Major League Umpires Ass’n, 357 F.3d at 279. In this case, the CBA provides that an arbitrator’s decision is final and binding on the parties. CBA Art. XIV § 1 (Step 4). Importantly, the CBA also explicitly states that “[t]he arbitrator shall not add to, subtract from, or modify in any way any of the provisions, terms o[r] conditions of this Agreement.” Id. (emphasis added). Despite this leave-no-doubt language, it is undisputed that, in rendering an arbitration award in favor of the Union, the arbitrator modified the language in the CBA to include a provision allowing for “bumping” where no such provision exists in the actual text of the CBA.8 In doing so, the arbitrator violated the provision of the CBA that prohibited him from modifying its terms. He thus exceeded the scope of his contractually delegated authority. Pennsylvania Power Co. v. Local Union No. 272, 276 F.3d 174, 179 (3d Cir.2001) (vacating an arbitration award because the arbitrator exceeded his powers under the CBA by altering the CBA “in direct violation of [the CBA’s] provision that he had no power to do so.”); see also 9 U.S.C. § 10(a)(4) (providing that a federal court may vacate an arbitration award “where the arbitrators exceeded their powers, or so imperfectly executed them that a mutual, final, and definite award upon the subject matter submitted was not made.”). Because, “[s]imply stated, an arbitrator may not venture beyond the bounds of his or her authority,” Major League Umpires Ass’n, 357 F.3d at 279 (internal quotation omitted), I would vacate the arbitration award on this ground alone.
My colleagues in the majority recognize that the arbitrator’s “inexplicable quotation” of language not in the CBA was a clear violation of Article IV § 1 of that Agreement. They nevertheless conclude that the arbitrator’s award cannot be vacated because it was rationally based on the language of the CBA. I agree, of course, that an arbitration award must be upheld if it is in “any rational way” related to the language of the agreement. See, e.g., id. at 280. But I do not agree that this standard has been met here.
*245The arbitrator believed there was an incongruity between Brentwood Medical Associates’ (“BMA”) position that senior employees had no right to bump less senior employees in other work classifications and the bargaining-unit seniority rights provided for in the CBA. J.A. at 74. In resolving this purported incongruity and finding that the employee here could exercise her seniority rights and bump an employee in another classification, the arbitrator twice cited and discussed the language regarding the right to bump that he wrote into the very section of the CBA under review. Id. at 73-74. A comparison of the actual language of the CBA with the language used by the arbitrator (shown in bold) highlights the differences between the two.
Text Used in
Arbitrator’s Decision_Page
Actual Text of Collective Bargaining Agreement
Section
“... employees who exercise seniority rights and bump must have the skill, qualifications, abili- J.A. ty and physical fitness 73, 74 to perform all of the work remaining in that classification ...”
“The reduction will be accomplished in inverse order of seniority in the classifications affected, provided that the employees to be retained must have the skill, Art. VIII, qualifications, ability § 10 and physical fitness to perform all of the work remaining in that classification without training, and will assume the remaining schedule.”
This added language informed the arbitrator’s belief (indeed it tipped the balance) that the position BMA took in the arbitration was inconsistent with the terms of the CBA, causing the arbitrator to question why language governing bumping was included in the agreement if, as BMA asserted, an employee whose classification was eliminated was not allowed to bump an employee in another classification.9 There was but one problem — the language with which the arbitrator believed BMA’s position was inconsistent was not part of the CBA.
■ I do not agree with my colleagues in the majority that the arbitrator’s reference, at the end of his decision, to the “ ‘plant-wide seniority’ system ... ingrained in Article VIII, Section 1 of the CBA”, J.A. at 75, is sufficient to support a conclusion that the arbitrator’s award draws its essence from the CBA notwithstanding his prior modification of the language of the agreement. The CBA defines seniority as bargaining unit-wide only generieally as follows: “Seniority shall be defined as the years, months and days an employee has worked with the Employer in the bargaining unit since the employee’s last date of hire by *246the Employer.” CBA Art. VIII § 2 (emphasis added).
The underlying dispute in this ease concerned whether an employee whose job classification had been abolished, and who was thus facing being laid off, could bump a less senior employee in another classification. The CBA contains a specific provision for “Layoff and Recalls,” see CBA Art. VIII § 10, and, as discussed above, it is that section that the arbitrator misquoted. The arbitrator’s award should not be upheld on the basis of the general language regarding bargaining-unit seniority in Article VIII, Section 1, when the arbitrator first rewrote the more specific language regarding layoffs that he should have been applying to resolve this dispute. To forgive the arbitrator’s Humpty Dumpty approach to the specific provision in play by referring to a general statement on seniority is akin to decreeing that the general call for mercy expiates the specific commandment not to kill.
Even assuming that the arbitrator’s added language could be separated from the rest of his decision, the award should still be vacated. When faced with the supposed disconnect between BMA’s position that bumping outside of one’s own classification should not be allowed and the bargaining-unit seniority rights outlined in the CBA, the arbitrator came down in favor of allowing bumping across classifications. He noted that there was no provision in Article VIII of the CBA, the section dealing with seniority, that would prohibit bumping. He also found that bumping across classifications was “consistent with arbitral authority which holds that, in the absence of any contract provision, it is almost universally recognized by arbitrators that senior employees who are governed by a ‘plant-wide seniority’ system, such as is imagined in Article VIII, Section 1 of the CBA[,] have the right to bump junior employees from their jobs in order to avoid their own layoff, provided they can perform the work of the junior employees.” Id. at 75 (internal quotation omitted).
Far from there being an “absence of any contract provision,” however, the CBA states that “[sjeniority shall ... apply only as expressly provided for in this Agreement.” CBA Art. VIII § 2 (emphasis added). In implying a right to bump because no contract provision prohibited bumping and because this result was consistent with general arbitration principles, the arbitrator again exceeded the scope of his powers by ignoring the CBA’s ban on applying seniority “only as expressly provided” in the Agreement itself. Ignoring plain language — least of all language that set the arbitrator’s authority' — -is a no-no of first rank. See United Paperworkers Int’l Union v. Misco, Inc., 484 U.S. 29, 38, 108 S.Ct. 364, 98 L.Ed.2d 286 (1987); Pennsylvania Power Co., 276 F.3d at 178.
In sum, the arbitrator in this case directly contradicted the plain language of the CBA and thus exceeded the scope of his powers by: (1) altering the language of the Agreement to include an express right to bump across classifications in defiance of the CBA provision prohibiting any modification of its language; and (2) reading into the CBA a right to bump because no provision of the CBA prohibited it in defiance of the CBA provision stating that seniority rights may only be applied as the CBA itself provides. To ignore the plain language of the CBA, and to rely on language not contained in it in reaching his decision, are the opposite of issuing an award that drew its essence from the CBA.
Our deferential standard of review in labor arbitration cases may mean that we uphold arbitration awards but for snow in August. But when an arbitrator rewrites *247a collective bargaining agreement as he did here (making manifest an utter disregard for the CBA’s actual words), or finds a meaning to exist because it is not expressed, and we uphold either sleight-of-hand, “deference” becomes a “rubber stamp.” If this arbitrator’s award evades vacating, what award does not? I respectfully dissent.
. In fact, the Union had unsuccessfully attempted to include a bumping provision in the CBA when negotiating its terms.
. The arbitrator wrote: "[I]f, as [BMA] asserts, reductions apply only '... in the inverse order of seniority in the classifications affected why was the “following language [inserted] to govern bumping, to wit: employees who exercise seniority rights and bump must have the skill, qualifications, ability and physical fitness to perform all of the work remaining in that classification ... [?]' " J.A. at 74.