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Federal Comments

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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NHTSA Should Include Labor in School Bus Seat Belt Studies

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) information collection request (ICR) regarding the use of seat belts on school buses. By way of background, TTD consists of 32 affiliate unions, several of whom represent school bus drivers and bus aides. [1] We therefore have a vested interested in the collection request.

Through this ICR, NHTSA plans on collecting information in order to understand the factors considered by state and local agencies when deciding whether to require seat belts on school buses, how these requirements are funded, and challenges that may occur. NHTSA states that it will collect this data through interviews, discussions, and a web-based survey.

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DOT Should Keep Safety and Labor Protections Out of Regulatory Review

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Department of Transportation’s (DOT) request for input regarding the agency’s review of its regulations, policy and guidance in order identify items that may cause unnecessary obstacles to transportation infrastructure projects. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation who are impacted by DOT regulations. [1] We therefore have a vested interested in the rulemaking.

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TTD Comments on Future of Commercial Autonomous Vehicle Regulation

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) solicitation for comment regarding highly automated commercial vehicles (HACV). By way of background, TTD consists of 32 affiliate unions representing 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.

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TTD Responds to FRA Autonomous Locomotive Studies

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration’s (FRA) Information Collection Requests (ICR) regarding locomotive automation. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation including those employed in the passenger and freight rail industries who will be impacted by automated train technology. [1] We therefore have a vested interest in this proceeding. Additionally, TTD strongly endorses the comments filed by the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD), a TTD affiliated union.

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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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