The executive board hasn't made plans yet to meet to discuss whether to file the disclaimer, but if the Jan. 2 deadline passes, another authorization vote could be held to approve a later filing.
If the filing is made, the union would dissolve and become a trade association. That would allow players to file antitrust lawsuits against the NHL.
Negotiations between the NHL and the union have been at a standstill since talks ended Dec. 6. No bargaining is scheduled, and time is running short to save the season. All games through Jan. 14 have been canceled more than half the season. The New Year's Day Winter Classic and All-Star game already are victims of the lockout.
It is believed that a new labor agreement would need to be in place by about mid-January to salvage a 48-game schedule, the minimum in commissioner Gary Bettman's opinion for the season to proceed.
The NHL is already the only North American professional sports league to cancel a season because of a labor dispute, losing the 2004-05 campaign to a lockout.
The NHLPA now appears set to follow the lead set by NFL and NBA players. Both dissolved their unions during lockouts last year. The legality of the lockout is already set to be tried in U.S. federal court after the NHL filed a class-action lawsuit last week against the NHLPA. The NHL also submitted an unfair labor practice charge with the National Labor Relations Board.