Federal Comments

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Department of Transportation’s (DOT) request for input regarding the agency’s review of its regulations, policy and guidance in order identify items that may cause unnecessary obstacles to transportation infrastructure projects. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation who are impacted by DOT regulations. [1] We therefore have a vested interested in the rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Motor Carrier Safety Administration’s (FMCSA) solicitation for comment regarding highly automated commercial vehicles (HACV). By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation who will be impacted by the development and deployment of automated transportation. We therefore have a vested interested in the rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Railroad Administration’s (FRA) Information Collection Requests (ICR) regarding locomotive automation. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation including those employed in the passenger and freight rail industries who will be impacted by automated train technology. [1] We therefore have a vested interest in this proceeding. Additionally, TTD strongly endorses the comments filed by the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD), a TTD affiliated union.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in response to the Office of The United States Trade Representative’s (USTR) notice requesting comments on the renegotiation of the North American Free Trade Agreement (NAFTA). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation.[1] For decades these working people have seen their industries and livelihoods gutted by bad trade deals, and today the threats to their jobs continue. We therefore have great interest in this proceeding.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in opposition to the petition that several truck companies jointly filed with the Federal Motor Carrier Safety Administration (FMCSA). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation and are subject to the Department of Transportation’s (DOT) drug and alcohol testing standards.[1] This includes members who work in the bus and truck industries and who comply with FMCSA’s testing regulations. We therefore have a vested interest in this proceeding.

The truck companies’ petition seeks exemption from 49 CFR 382.301, FMCSA’s regulations governing pre-employment controlled substances testing, and from 382.105, requiring that employers’ drug (and alcohol) testing programs comply with the procedures of DOT’s Part 40 standards. The petitioners seek these exemptions so that they can test prospective employees’ hair specimen, in lieu of urine specimen, in pre-employment drug tests.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on NHTSA’s Notice of Proposed Rulemaking (NPRM) concerning vehicle-to-vehicle communications. By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation who will be impacted by the development and deployment of automated transportation. We therefore have a vested interested in the rulemaking.

Through this NPRM, NHTSA proposes to require that all light duty vehicles be equipped with vehicle-to-vehicle communications (V2V) systems. As proposed, these systems would transmit information including a vehicle’s speed, heading, and brake status from vehicle to vehicle in order to warn drivers of potential hazards. Critically, NHTSA states that the fusion of V2V and other technologies will “advance the further development of vehicle automation systems, including the potential for truly self-driving vehicles.”

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on DOT’s Notice of Proposed Rulemaking (NPRM) concerning changes to DOT’s drug and alcohol testing regulations. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, many of whom are required to undergo DOT drug and alcohol testing. We therefore have a vested interested in the rulemaking.

Through this NPRM, DOT proposes to add four semi-synthetic opioids, (hydrocodone, hydromorphone, oxymorphone, and oxycodone), which are commonly prescribed painkillers to its testing panel. DOT also proposes several other changes to Part 40, including expanded fatal flaws in sample collection, the elimination of blind specimen testing, and changes to regulations concerning Medical Review Officer (MRO) verification.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on TSA’s Notice of Proposed Rulemaking (NPRM) implementing frontline transportation worker security training provisions mandated by Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Act). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including frontline employees in freight and passenger rail, public transportation agencies, and over-the-road bus (OTRB) service who would be subject to this training. We therefore have a vested interested in the rulemaking and can offer some unique perspectives as TSA seeks to implement this important and overdue requirement.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on MARAD’s Notice of Proposed Rulemaking (NPRM) concerning revisions to the American’s Marine Highway Program (AMHP). By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including employees in the maritime shipping industry. We therefore have a vested interested in the rulemaking.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write to comment on PHMSA’s Advance Notice of Proposed Rulemaking (ANPRM) concerning identification numbers on oil cargo tanks. By way of background, TTD consists of 32 affiliate unions that represents workers in all modes of transportation, including rail employees who transport oil and emergency personnel who respond in the case of an accident.

In PHMSA’s ANPRM, the Administration seeks comments on regulations regarding the marking of identification numbers on cargo tanks carrying petroleum products. In issuing this ANPRM, PHMSA is fulfilling a requirement of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016, which directed the Administration to respond to a petition for rulemaking filed by the Commercial Vehicle Safety Alliance (CVSA), which proposed amendments to the Hazardous Materials Regulations (HMR). The notice also addresses a petition filed by the American Trucking Associations (ATA), which also proposes HMR amendments. In addition to the petitions, PHMSA requests comments on several other items relating to identification numbers.