Federal Comments

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.

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.

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.

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.

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.

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]

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.

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.