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Federal Comments

TTD Makes Recommendations for Study on Automated Driving Impacts

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.

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California Meal And Rest Break Requirements Must not Be Preempted

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.

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FMCSA MUST STAND AGAINST FATIGUED DRIVING AND PRESERVE HOURS OF SERVICE PROTECTION

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.

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DOT Must Address Unsafe Aircraft Cabin Temperatures

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.

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Sensible Guidelines Are Needed For Service Animals in Air Travel

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.

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Whistleblower Protections Must Be Enforced and Accessible

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.

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TTD Continues to Urge FMCSA to Consider Automation Concerns

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.

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FRA Must Not Ignore Safety and Worker Issues In Railroad Automation

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.

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TTD Urges Extreme Caution on Permitting Automated Transportation of Hazardous Materials

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.

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FAA Must Support Voluntary Safety Reporting Program

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.

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