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Federal Comments

Whistleblower Protections Must Be Enforced and Accessible

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on OSHA’s notice regarding the administration of whistleblower statutes. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who are afforded protections under the statutes discussed in the notice.[1] We therefore have a vested interest in the proceeding.  

Through the request for comments, and its scheduled meeting, OSHA is seeking information on how it can improve customer service in its handling of whistleblower complaints, and how it can better explain the whistleblower laws it enforces. OSHA specifically highlights the Federal Railroad Safety Act, the Surface Transportation Assistance Act, the National Transit Systems Security Act, and Section 11(c) of the Occupational Safety and Health Act as the focus of this proceeding.

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TTD Continues to Urge FMCSA to Consider Automation Concerns

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Motor Carrier Safety Administration (FMCSA)’s solicitations for information on how its regulations may be affected by autonomous technology. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems.[1] We therefore have a vested interest in the notice.

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FRA Must Not Ignore Safety and Worker Issues In Railroad Automation

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration (FRA)’s solicitations for information related to the future of automation in the railroad industry. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including workers across all crafts in the railroad industry who will be impacted by automation. We therefore have a vested interested in the notice. [1] TTD also endorses the comments of the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division (SMART-TD), a TTD affiliated union.

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TTD Urges Extreme Caution on Permitting Automated Transportation of Hazardous Materials

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Pipeline and Hazardous Materials Safety Administration (PHMSA)’s solicitations for information on autonomous surface transportation of hazardous materials. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems, workers who transport hazardous materials, and first responders tasked with responding to incidents involving hazmat. We therefore have a vested interest in the notice.

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FAA Must Support Voluntary Safety Reporting Program

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the FAA’s Draft Advisory Circular AC 120-66C, Aviation Safety Action Program (ASAP). By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including several unions in the aviation sector who have members that participate in ASAPs at their place of employment. We therefore have a vested interest in the circular.

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Autonomous Vehicle Policy Must Address Worker and Safety Issues

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Transit Administration (FTA) and National Highway Traffic Safety Administration’s (NHTSA) solicitations for information on autonomous transit buses and autonomous vehicle design. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems. We therefore have a vested interested in the rulemaking.[1]

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TTD Comments on NHTSA Autonomous Vehicle Guidance

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the National Highway Traffic Safety Administration’s (NHTSA) A Vision for Safety 2.0 guidance regarding autonomous vehicles. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated driving systems. We therefore have a vested interested in the guidance.

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FMCSA Must Reject Unsafe Hours of Service Exemption for Oil Tank Truck Drivers

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the National Tank Truck Carriers, Inc. (NTTC) application for exemption from rest break regulations. By way of background, TTD consists of 32 affiliate unions across all modes of transportation, including both commercial motor vehicle drivers subject to FMCSA’s hours-of-service (HOS) regulations, and emergency personnel who respond in the event of an accident involving a CMV. We therefore have a vested interested in the rulemaking.

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TTD Opposes Unnecessary Barriers to Bus and Truck Safety Regulations

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Motor Carrier Safety Administration’s (FMCSA) Notice of Proposed Rulemaking (NPRM) regarding FMCSA’s rulemaking procedures. By way of background, TTD consists of 32 affiliate unions across all modes of transportation, many of whom operate commercial motor vehicles and are therefore subject to FMCSA’s regulations.[1] We therefore have a vested interested in the rulemaking.

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TTD Comments on Private Sector Participation in Transit

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to comment on the Federal Transit Administration’s (FTA) notice of proposed rulemaking (NPRM) encouraging private sector participation and investment in transit capital projects. By way of Background, TTD consists of 32 affiliate unions in the transportation sector, including those who may be affected by increased private participation in the public transportation space.

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