"For many employers, this important term will already be explicitly addressed in their CBAs.... These employers can stop a traditional contract interpretation challenge due to the unambiguous written terms of the contract.... [If] an existing CBA remains silent or ambiguous as to this term, the intent of the parties will be left to the judgment of a court. The Supreme Court provided a list of areas that a court should evaluate before coming to a conclusion as to the intent of parties. But relying on an ambiguous term is a dangerous and arbitrary way to contract[.]" [M&G Polymers v. Tackett, No. 13-1010 (U.S. Jan. 26, 2015)]