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A number of major airlines have declared bankruptcy and have either ceased operations, or reorganized under bankruptcy protection. Airlines, like any business, are susceptible to market fluctuations and economic difficulties. The economic structure of the airline industry may contribute to airline bankruptcies as well. One major element in almost every airline bankruptcy is the rejection by the debtor of its current collective bargaining agreements with employees. After satisfying certain requirements, bankruptcy law permits courts to approve rejection of labor contracts by the debtor-employer. With this tool, airline managers reduce costs. Terms of an employee contract negotiated over years can be eliminated in months through Chapter 11. Terms of the Railway Labor Act, amended in 1936 to cover airlines, prevent most labor union work actions before, during and after an airline bankruptcy.