Mealey's (May 3, 2018, 7:36 AM EDT) -- PHILADELPHIA — A voluntary reduction-in-force (RIF) program by a Delaware chemical company wasn’t subject to the Employee Retirement Income Security Act, a Third Circuit U.S. Court of Appeals panel ruled April 30, upholding dismissal of a class complaint by three participants (Mark Girardot, et al. v. The Chemours Company, No. 17-1894, 3rd Cir., 2018 U.S. App. LEXIS 10993)....