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TTD Offers Recommendations for a Renegotiated NAFTA

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in response to the Office of The United States Trade Representative’s (USTR) notice requesting comments on the renegotiation of the North American Free Trade Agreement (NAFTA). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation.[1] For decades these working people have seen their industries and livelihoods gutted by bad trade deals, and today the threats to their jobs continue. We therefore have great interest in this proceeding.

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TTD Calls for FMCSA to Reject Hair Testing Petition

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in opposition to the petition that several truck companies jointly filed with the Federal Motor Carrier Safety Administration (FMCSA). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation and are subject to the Department of Transportation’s (DOT) drug and alcohol testing standards.[1] This includes members who work in the bus and truck industries and who comply with FMCSA’s testing regulations. We therefore have a vested interest in this proceeding.

The truck companies’ petition seeks exemption from 49 CFR 382.301, FMCSA’s regulations governing pre-employment controlled substances testing, and from 382.105, requiring that employers’ drug (and alcohol) testing programs comply with the procedures of DOT’s Part 40 standards. The petitioners seek these exemptions so that they can test prospective employees’ hair specimen, in lieu of urine specimen, in pre-employment drug tests.

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TTD Responds to Autonomous Vehicle Technology Proposal

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on NHTSA’s Notice of Proposed Rulemaking (NPRM) concerning vehicle-to-vehicle communications. By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation who will be impacted by the development and deployment of automated transportation. We therefore have a vested interested in the rulemaking.

Through this NPRM, NHTSA proposes to require that all light duty vehicles be equipped with vehicle-to-vehicle communications (V2V) systems. As proposed, these systems would transmit information including a vehicle’s speed, heading, and brake status from vehicle to vehicle in order to warn drivers of potential hazards. Critically, NHTSA states that the fusion of V2V and other technologies will “advance the further development of vehicle automation systems, including the potential for truly self-driving vehicles.”

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TTD Comments on Expansion of DOT Drug Testing Panel

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on DOT’s Notice of Proposed Rulemaking (NPRM) concerning changes to DOT’s drug and alcohol testing regulations. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, many of whom are required to undergo DOT drug and alcohol testing. We therefore have a vested interested in the rulemaking.

Through this NPRM, DOT proposes to add four semi-synthetic opioids, (hydrocodone, hydromorphone, oxymorphone, and oxycodone), which are commonly prescribed painkillers to its testing panel. DOT also proposes several other changes to Part 40, including expanded fatal flaws in sample collection, the elimination of blind specimen testing, and changes to regulations concerning Medical Review Officer (MRO) verification.

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TTD Responds to Proposed Security Training for Surface Transportation Employees

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on TSA’s Notice of Proposed Rulemaking (NPRM) implementing frontline transportation worker security training provisions mandated by Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Act). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including frontline employees in freight and passenger rail, public transportation agencies, and over-the-road bus (OTRB) service who would be subject to this training. We therefore have a vested interested in the rulemaking and can offer some unique perspectives as TSA seeks to implement this important and overdue requirement.

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TTD Supports Expanded America’s Marine Highway Program (AMHP)

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on MARAD’s Notice of Proposed Rulemaking (NPRM) concerning revisions to the American’s Marine Highway Program (AMHP). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including employees in the maritime shipping industry. We therefore have a vested interested in the rulemaking.

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TTD Supports Descriptive Identification Numbers on Oil Cargo Tanks

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on PHMSA’s Advance Notice of Proposed Rulemaking (ANPRM) concerning identification numbers on oil cargo tanks. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including rail employees who transport oil and emergency personnel who respond in the case of an accident.

In PHMSA’s ANPRM, the Administration seeks comments on regulations regarding the marking of identification numbers on cargo tanks carrying petroleum products. In issuing this ANPRM, PHMSA is fulfilling a requirement of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016, which directed the Administration to respond to a petition for rulemaking filed by the Commercial Vehicle Safety Alliance (CVSA), which proposed amendments to the Hazardous Materials Regulations (HMR). The notice also addresses a petition filed by the American Trucking Associations (ATA), which also proposes HMR amendments. In addition to the petitions, PHMSA requests comments on several other items relating to identification numbers.

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TTD Opposes Voice Calls on Airplanes

On behalf of the Transportation Trades Department, AFL-CIO (TTD) I write in response to the Department of Transportation’s (DOT) Notice of Proposed Rulemaking (NPRM) concerning the use of mobile devices to make voice calls while onboard a flight traveling within, to or from the United States. By way of background, TTD consists of 32 affiliated unions that represent workers in all modes of transportation, including several with aviation members who would be directly impacted by this proceeding.

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Answer of Labor Parties to Norwegian Air UK Limited’s Application for an Exemption

The undersigned labor organizations (“the Labor Parties”) oppose the contingent application of Norwegian Air UK Limited (“NAUK”) for exemption authority. Any exemption from the requirement that a foreign air carrier hold a foreign air carrier permit must be consistent with the public interest. Six months ago, DOT denied a previous request for an exemption by NAUK, finding that a grant of the carrier’s application would not be consistent with the public interest. Order 2016-6-22 at 2. For the reasons set out below, the Department should deny NAUK’s current request as well.

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Answer of Labor Parties to Norwegian Air UK Limited’s Request for Expedited Processing

BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, DC Application of NORWEGIAN AIR UK LIMITED for an exemption under 49 U.S.C. § 40109 and a foreign air carrier permit pursuant to 49 U.S.C. § 41301 Docket No. OST-2015-0261 ANSWER OF LABOR PARTIES TO NORWEGIAN AIR UK LIMITED’S REQUEST FOR EXPEDITED PROCESSING Edward Wytkind, President Transportation Trades Department, […]

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