Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the American Short Line Railroad Association’s Petition for Waiver of Compliance regarding hours of service requirements (HOS). TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those covered by FRA’s HOS regulations.[1] For this reason, we have a vested interest in this waiver.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the FRA’s new information collection request (ICR) entitled “The Impact of Commute Times on the Fatigue and Safety of Locomotive Engineers”. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including train crews covered by FRA hours of service and fatigue regulations.[1] For reasons explained below, we support the intent of this ICR but urge changes to its scope to ensure fatigue issue affecting all train crews are being considered. 

Under NAFTA, USMCA’s predecessor, U.S. workers saw their industries decimated and their wages undercut. Americans are still today feeling the impacts of a trade agreement that did not work in their favor, and this country cannot afford to repeat this mistake. We understand that a number of TTD unions and the AFL-CIO have filed comments in this docket focused on broad labor concerns – we are therefore focusing our comments on the failure of the agreement to protect rail workers from unfair competition from Mexico.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the U.S. Department of Transportation’s (USDOT) Preparing for the Future of Transportation: Automated Vehicles 3.0 (AV 3.0) policy. 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 interest in the policy.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to DOT’s request for comments on the scope of its survey concerning the impact of automated vehicle technologies on the workforce. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including thousands of employees who may be impacted by vehicle automation.[1] For this reason, we have a vested interest in this study.

As DOT notes, the 2018 Consolidated Appropriations Act requires DOT and DOL to conduct a study of the impact of Advanced Driver Assist Systems (ADAS) and Highly Automated Vehicles (HAV) technologies on drivers and operators of commercial motor vehicles, including the labor and workforce impacts. TTD and its impacted unions fought hard to secure this report within legislation that otherwise provides hundreds of millions of dollars to further the development, testing, and deployment of autonomous vehicles. As we have written in a number of other DOT dockets, it is our position that if the federal government provides support for this technology it has an inherent obligation to support the millions of workers whose jobs may be put at risk. While only a first step, we are hopeful that this research provides a more complete picture to DOT, DOL and Congress on how automated vehicles could affect the professional drivers, maintenance workers and other employees in the affected industries nationwide.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comments on the American Trucking Associations’ (ATA) petition for federal preemption of California’s Meal and Rest Break rules. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those covered by FMCSA’s HOS regulations and California’s rules.[1] For reasons discussed below, we urge FMCSA to reject ATA’s petition.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on FMCSA’s advance notice of proposed rulemaking (ANPRM) concerning hours of service (HOS) regulations for drivers. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those covered by FMCSA’s HOS regulations.[1] For reasons discussed below, we urge FMCSA to maintain current HOS protections, and to reject efforts to eliminate the 30-minute rest break requirement or to weaken HOS protections for passenger carrying CMV drivers.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am writing today to express our support for the petition for rulemaking filed by the Association of Flight Attendants-CWA, which requests that DOT establish operational standards for cabin temperatures on commercial airplanes, both on domestic flights and international flights into the United States and its territories.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on DOT’s advance notice of proposed rulemaking (ANPRM) concerning air travel with service and support animals. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including airport and airline employees who interact with customers who seek to fly with their service and support animals.[1] We therefore have a vested interest in this rulemaking.

DOT has published this ANPRM in response to increasing conflict and confusion as it relates to air travel with service and support animals. Currently, the Air Carrier Access Act (ACAA) and its associated regulations define a service animal broadly—any animal that is individually trained or able to provide assistance to a person with a disability; or any animal that assists persons with disabilities by providing emotional support—and provide protections for passengers with such animals.

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.