Cite as: 512 U. S. 246 (1994)
Opinion of the Court
men, 318 U. S. 1 (1943). Although the Court assumed that a railroad adjustment board would have jurisdiction under the RLA over this dispute, id., at 6, it concluded that the state law was enforceable nonetheless:
"State laws have long regulated a great variety of conditions in transportation and industry, such as sanitary facilities and conditions, safety devices and protections, purity of water supply, fire protection, and innumerable others. Any of these matters might, we suppose, be the subject of a demand by work[ers] for better protection and upon refusal might be the subject of a labor dispute which would have such effect on interstate commerce that federal agencies might be invoked to deal with some phase of it. . . . But it cannot be said that the minimum requirements laid down by state authority are all set aside. We hold that the enactment by Congress of the [RLA] was not a preemption of the field of regulating working conditions themselves . . . ." Id., at 6-7.
Thus, under Norwood, substantive protections provided by state law, independent of whatever labor agreement might govern, are not pre-empted under the RLA.
Although Norwood and Terminal Railroad involved state workplace safety laws, the Court has taken a consistent approach in the context of state actions for wrongful discharge. In Andrews v. Louisville & Nashville R. Co., 406 U. S. 320 (1972), the Court held that a state-law claim of wrongful termination was pre-empted, not because the RLA broadly pre-empts state-law claims based on discharge or discipline, but because the employee's claim was firmly rooted in a breach of the CBA itself. He asserted no right independent of that agreement:
"Here it is conceded by all that the only source of [Andrews'] right not to be discharged, and therefore to treat an alleged discharge as a 'wrongful' one that entitles him
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