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Federal Comments

24-Hour Shifts For Railroad CMV Drivers are Unsafe and Unreasonable

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the exemption filed by the Association of American Railroads (AAR) and American Short Line and Regional Railroad Association (ASLRRA). TTD consists of 32 affiliate unions representing workers in all modes of transportation, including commercial motor vehicle operators in the railroad industry covered by FMCSA hours of service requirements.[1] We therefore have a vested interest in this exemption.

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FRA Must Reject CSX’s Unsafe Inspection Waiver and Attack on Carmen

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to CSX’s petition for a waiver compliance. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including railroad workers in both operating and inspection crafts who would be impacted by the granting of this waiver[1]. We therefore have a vested interest in this proceeding.

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ASLRRA Pilot Program Puts Workers and Rail Safety at Risk

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.

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FRA Must Add Conductors to Promising Fatigue Study

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. 

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USMCA Must Protect U.S. Rail Workers

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.

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TTD Urges USDOT to Put Working Families, Safety First in Automated Vehicle Policy

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.

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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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