Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Aviation Administration’s (FAA) request for comment on the Installation and Operation of Flightdeck Installed Physical Secondary Barriers on Transport Category Airplanes in Part 121 Service. TTD consists of 37 unions in all modes of transportation, including those that represent flight, cabin crew, and ground personnel at airlines throughout the United States. TTD, along with its affiliate unions, has long fought for so-called secondary barriers or Installed Physical Secondary Barriers (IPSB) on transport category aircraft. While we are pleased the FAA finally has initiated a Notice of Proposed Rulemaking (NPRM), the FAA should take further actions related to the scope of the rulemaking, compliance timeline, and application to foreign air carriers, among other important steps.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Transit Administration’s (FTA) proposed changes regarding National Transit Database (NTD) safety and security reporting. TTD consists of 37 affiliate unions and their workers, including transit operators, maintenance workers, and other operations personnel. TTD endorses the comments by our affiliates, the Amalgamated Transit Union (ATU) and the Transport Workers Union of America (TWU), which are also filed in this docket.[1] In particular, as stated by ATU, implementation of data collection must capture both physical and other forms of assault.

The proposed changes would incorporate the updated definition of “assault on a transit worker” for the purposes of NTD reporting. The Bipartisan Infrastructure Law amended 49 U.S.C. 5302(1) to define “assault on a transit worker” as a “circumstance in which an individual knowingly, without lawful authority or permission, and with intent to endanger the safety of any individual, or with a reckless disregard for the safety of human life, interferes with, disables, or incapacitates a transit worker while the transit worker is performing the duties of the transit worker.”

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Motor Carrier Safety Administration’s (FMCSA) notice regarding the National Ground Water Association’s (NGWA) petition for exemption from FMCSA’s Entry-Level Driver Training (ELDT) requirements. These requirements are necessary to obtain a Class B license to operate a groundwater well drilling rig. TTD consists of 37 affiliate unions representing millions of transportation workers, including commercial motor vehicle (CMV) operators, who are subject to the FMCSA’s Commercial Driver’s License (CDL) requirements.

In its application, NGWA requests exemption from all ELDT requirements for individuals operating “any vehicle, machine, tractor, trailer, semi-trailer, or specialized mobile equipment propelled or drawn by mechanical power and used on highways to transport water well field operating equipment, including water well drilling and pump service rigs equipped to access groundwater.” The request would include exemptions from ELDT requirements including demonstrating proficiency in proper techniques for initiating vehicle movement, executing left and right turns, changing lanes, navigating curves at speed, and stopping the vehicle in a controlled manner.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Transportation’s (DOT) Request for Information regarding Buy America Requirements for Construction Materials. TTD consists of 37 affiliate unions representing workers in construction and manufacturing who are directly impacted by Buy America policies.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Motor Carrier Safety Administration’s (FMCSA) notice regarding the state of Alaska’s petition for a partial exemption from certain components of the FMCSA’s Entry-Level Driver Training (ELDT) requirements, as set forth in 49 CFR 380 Appendix A, Section A3.1, necessary to obtain a Class A license. TTD consists of 37 affiliate unions representing millions of transportation workers, including commercial motor vehicle (CMV) operators, who are subject to the FMCSA’s Commercial Driver’s License (CDL) requirements.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Transportation’s (DOT) request for information regarding drug and alcohol testing data. TTD consists of 37 affiliate unions representing workers across all modes of transportation.[1]

DOT requests information to determine if there is a broader audience for certain publicly available modal drug and alcohol testing data, and whether and how to make the information more readily available.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) Request for Comments on Transit Bus Automation Research and Demonstrations. TTD consists of 37 affiliate unions representing all kinds of transportation workers, including transit operators, mechanics, and other ground transportation workers whose safety, security, and livelihoods will be impacted by automated technologies. We therefore have a vested interest in making sure that the FTA invests in bus automation research and demonstrations that advance a future for transit and its employees consistent with the pro-worker and pro-union values of this administration.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Surface Transportation Board’s (STB) notice regarding its information collection request. TTD consists of 37 affiliate unions representing the totality of rail labor and its 105,000 workers across the country.[1] Our affiliated unions represent workers who perform every task on trains and railroad tracks and at rail yards. These workers are vital to keeping our railroad system operating successfully every day.

Expand the New Reporting Requirements to Address Self Inflicted Service Cuts
As discussed below, while TTD strongly supports the new reporting requirements set forth in the STB decision, TTD requests that additional information be required from Class I railroads to better understand the current rail service conditions and the impact employment decisions are having. Specifically, we request: a narrative description of employment data, employment data reported by craft in addition to job families, and data regarding specific causes for separation.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the U.S. Department of Health and Human Services’ (HHS) notice regarding the Mandatory Guidelines for Federal Workplace Drug Testing Programs. TTD consists of 37 affiliate unions representing workers across all modes of transportation.

The Mandatory Guidelines provide the scientific and technical standards for workplace drug testing for over 12 million federal employees and transportation workers in the public and private sector. The proposed Mandatory Guidelines would allow HHS to add and remove drug analytes and modify cutoffs without public notice or comment. The proposed guidelines also would change the definition of a substituted specimen to include certain specimens that are currently reported as “invalid.” Additionally, the proposal would redefine refusals to include failing to complete pre-employment testing. Lastly, the guidelines would hold that ingestion of food products containing a drug is not an acceptable medical explanation for a positive drug test.

The Transportation Trades Department, AFL-CIO (TTD), the Maritime Trades Department, AFL-CIO (MTD), the International Organization of Masters, Mates & Pilots (MM&P), the Marine Engineers’ Beneficial Association (MEBA), Sailors’ Union of the Pacific (SUP), Seafarers International Union of North America (SIU) and the American Maritime Officers (AMO) are pleased to respond to the Maritime Administration (MARAD) request for public comment on the Every Mariner Builds a Respectful Culture (EMBARC) policy. These unions represent the unlicensed and licensed mariners who work aboard sea year vessels. Collectively, we support the goals and intentions set forth by EMBARC and are committed to addressing systemic and cultural changes in the maritime industry to prevent incidents of sexual assault and sexual harassment (SASH) in a workplace that doubles as every mariner’s home.