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Federal Comments

Restore and Improve RSAC

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s request for comment on its announcement of a public meeting concerning the Railroad Safety Advisory Committee process. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including railroad employees. We therefore have a vested interest in this proceeding.

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Trump Administration ADS Framework is a Nonstarter

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Transportation’s request for comments entitled Framework for Automated Driving System Safety. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including drivers and other ground transportation workers whose safety, security, and livelihoods have the potential to be seriously impacted by the rollout of automated technologies.[1] We therefore have a vested interest in this policy.[1]

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Previous Administration’s AV Comprehensive Plan Should Be Left in the Past

Office of the Secretary of Transportation U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, DC  20590 RE:     Automated Vehicles Comprehensive Plan Docket No. DOT-OST-2021-0005 On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Transportation’s request for comments entitled Automated Vehicles Comprehensive Plan. TTD […]

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FRA Must Prevent Retaliation Against Employees

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FRA’s request for comment on its revisions to information collection request entitled “Federal Railroad Administration Alleged Violation and Inquiry Form.” TTD consists of 33 affiliate unions representing workers in all modes of transportation including rail workers. We therefore have a vested interest in this policy.

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Aviation and Rail Unions Call on President Biden to Appoint a New NMB

We, the undersigned unions representing hundreds of thousands of Americans working in the airline and rail industries, take pleasure in expressing our strong support of Deirdre Hamilton to serve as a Member on the National Mediation Board (NMB), and for sitting NMB member Linda Puchala’s reappointment to the board. We also urge you to make these appointments immediately. Unlike other federal agencies, the Trump-appointed NMB will remain in control until new board members are nominated and confirmed by the Senate. With each passing day, the Trump NMB is allowed more opportunity to suppress the voices of aviation and rail workers, stifle collective bargaining rights, and undermine the Biden-Harris pro-worker agenda.

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Replacing Hands-On Training for Rail Employees is Unsafe and Unwarranted

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s request for comment on a petition for a waiver of compliance filed by Illinois Central Railroad Company on behalf of Canadian National Railway Company. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including employees of Illinois Central/Canadian National railroads. We therefore have a vested interest in this petition

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TTD Calls for Prioritizing Vaccine Distribution to Frontline Transportation Workers

On behalf of the Transportation Trades Department, AFL-CIO (TTD), and the millions of workers we represent in all sectors of transportation, including the aviation, rail, transit, construction, school and over the road bus, maritime, and longshore industries, we strongly urge you to prioritize these frontline workers in the next phase (Phase 1b) of your COVID-19 vaccine distribution. Transportation workers have continued to provide essential services as COVID-19 has ravaged communities and taken nearly 300,000 American lives.

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TTD: HHS Hair Testing Proposal Falls Dangerously Short

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Health and Human Services (HHS) and Substance Abuse and Mental Health Services Administration’s (SAMHSA) notification of proposed Mandatory Guidelines for Federal Workplace Drug Testing Programs using Hair (HMG). TTD consists of 33 affiliate unions representing workers in all modes of transportation who are subject to federally mandated drug tests due to their employment. We therefore have a vested interest in the proposal.

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TTD Continues to Oppose Railroad Revenue Threshold Increase

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Surface Transportation Board’s proposal to modify revenue thresholds for the classification of rail carriers. By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers who may be impacted by the granting of this petition.

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TTD Opposes DOL’s Anti-Worker Independent Contractor Rule

DOL’s proposal would revise the agency’s interpretation on whether workers are considered employees or independent contractors under the Fair Labor Standards Act (FLSA). The proposal seeks to amend the existing multi-factor test used to determine a worker’s status, placing elevated emphasis on two core factors, including nature and degree of the worker’s control over the work (e.g. schedule, assignments, and ability to work for other companies) and the worker’s opportunity for profit or loss. DOL claims that the proposal will “benefit workers and businesses and encourage innovation and flexibility in the economy.”

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