Federal Comments

Dear Ms. Kelly: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I call on the Department of Transportation to take immediate action to eliminate risks of COVID-19 contagion from continued random drug and alcohol testing of essential transportation workers. TTD consists of 33 affiliate unions representing workers in all modes of transportation covered by DOT’s drug and alcohol testing requirements, including those administered by FAA, FMCSA, FTA, FRA, PHMSA and USCG

Dear Secretaries Chao and Scalia: It has now been over a month since the World Health Organization (WHO) declared the COVID-19 outbreak to be a pandemic. The United States alone has had over 670,000 confirmed cases and, tragically, over 34,000 deaths. Since this public health crisis began, TTD and our unions have consistently urged the federal government to take specific steps to protect frontline transportation workers and their families from exposure to this virus.

Dear Administrator Batory: On March 13th, the FRA opened the Emergency Relief Docket (FRA-2020-0002) for Novel Coronavirus (COVID-19), activating the provisions of 49 CFR § 211.45. These provisions grant the FRA wide latitude to expeditiously waive its regulations, including those that concern rail safety and the wellbeing and fair treatment of employees. For these reasons, we are carefully monitoring requests for relief made to the docket and may file additional comments on present or future petitions.

Stories of frontline public transportation workers contracting COVID-19 and tragically dying from the virus are already emerging around the country, and it will only get worse in the coming weeks and months. To ensure the best use of the emergency funding provided by the CARES Act and to protect the health and safety of the frontline workforce and traveling public, we request the following:

Dear Mr. Fulton: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to DOT’s request for comment on its document entitled “Ensuring American Leadership in Automated Vehicle Technologies: Automated Vehicles 4.0 (AV 4.0).”  TTD consists of 33 affiliate unions representing workers in all modes of transportation, including those who will be impacted by the development and deployment of automated vehicles. We therefore have a vested interest in this policy.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Canadian Pacific Railway’s (CP) petition for a waiver of compliance from the “hands-on” component of periodic refresher training required by 49 CFR 232.203(b)(8). By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers.[1] In responding to this notice, TTD strongly endorses the comments filed by the Transport Workers Union of America and the Brotherhood of Railway Carmen Division of the Transportation Communications Union/IAM

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Notice of Proposed Rulemaking (NPRM) concerning the transportation of liquefied natural gas (LNG) by rail. By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers and first responders.[1] In responding to this notice, TTD strongly endorses the comments filed by the International Association of Fire Fighters (IAFF) and the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division (SMART-TD).

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration’s (FRA) Notice of Proposed Rulemaking (NPRM) concerning Grade Crossing Action Plans. TTD consists of 33 affiliate unions, including unions representing railroad operating crews, workers who install and maintain crossing-grade signal systems, and first responders.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Aviation Administration’s (FAA) Advance Notice of Proposed Rulemaking (ANPRM) concerning Flight Attendant Duty Period Limitations and Rest Requirements. By way of background, TTD consists of 33 affiliate unions, including unions representing flight attendants, and unions whose members work cooperatively with flight attendants to maintain safety aboard commercial aircraft.[1] In responding to this notice, TTD strongly endorses the comments filed by the Association of Flight Attendants-CWA, the International Association of Machinists and Aerospace Workers, and the Transport Workers Union.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FRA’s request for comment on Norfolk Southern’s (NS) petition for a waiver of compliance concerning employee injury/illness forms. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including freight rail employees whose workplace injuries and illness are reported and documented via the regulation NS seeks relief from.