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Federal Comments

TTD Requests Extension on Hair Testing Proposal

Through this notice, HHS has issued proposed guidelines that would permit the use of hair follicles as a valid specimen for federally impelled drug tests. If adopted, employers would be able to conduct hair testing in concert with, or in lieu of, urine or oral fluid tests that have been previously approved by HHS. In issuing these proposed guidelines, the Department is acting to comply with Sec. 5402(b) of the Fixing America’s Surface Transportation (FAST) Act, which required that HHS develop guidelines for hair testing of commercial motor vehicle drivers. We write today to formally request that HHS hold a public, virtual, hearing on its proposed guidelines in order to discuss the proposal with impacted stakeholders and to further extend the comment period for 60 days.

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Coast Guard Must Consider Vessel Automation’s Consequences for Mariners

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Coast Guard’s request for information entitled “Request for Information on Integration of Automated and Autonomous Commercial Vessels and Vessel Technologies into the Maritime Transportation System.” TTD consists of 33 affiliate unions representing workers in all modes of transportation, including those in the commercial maritime industry. We therefore have a vested interest in this request.

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Revised AAR/ASLRRA HOS Exemption Request for Drivers Still Unsafe

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the exemption request filed by the Association of American Railroads (AAR) and American Short Line and Regional Railroad Association (ASLRRA). TTD consists of 33 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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COVID-19 Regulatory Relief Requires FRA Oversight

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s request for comment on a petition for a waiver of compliance filed by the American Public Transportation Association (APTA). TTD consists of 33 affiliate unions representing workers in all modes of transportation, including employees of APTA member railroads. We therefore have a vested interest in this petition.

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FRA Must Reject Unjustified Training Waiver

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s request for comment on its notice entitled Petition for Waiver of Compliance from Long Island Rail Road (LIRR). TTD consists of 33 affiliate unions representing workers in all modes of transportation, including impacted employees at Long Island Railroad. We therefore have a vested interest in this petition.[1] We also strongly endorse the comments of the Transport Workers Union of America, a TTD-affiliated union.

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TTD Petitions DOT for Passenger Face Mask Mandate

Dear Secretary Chao:   On behalf of the Transportation Trades Department, AFL-CIO (TTD) and our 33 affiliated unions across the transportation industry[1], I write today to petition the Department of Transportation (DOT) to expeditiously promulgate regulation to mandate the usage of masks or face coverings for passengers travelling with DOT-regulated commercial transportation providers during the course of the Presidential Declaration of Emergency for COVID-19.

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TTD: Increasing Railroad Classification Thresholds is Unwarranted

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on Montana Rail Link Inc.’s petition concerning changes to revenue thresholds for the classification of rail carriers. By way of background, TTD consists of 33 affiliate unions, including unions representing freight rail workers who may be impacted by the granting of this petition.

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FMCSA Must Not Modify Hours of Service Standards for Unproven Automated Technology

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comment on its notice Hours of Service of Drivers: Pronto.ai, Inc. (Pronto); Application for Exemption. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including drivers of commercial motor vehicles.[1] We therefore have a vested interest in this policy.

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To Protect Workers from COVID-19, DOT Must Pause Testing

Dear Ms. Kelly: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I call on the Department of Transportation to take immediate action to eliminate risks of COVID-19 contagion from continued random drug and alcohol testing of essential transportation workers. TTD consists of 33 affiliate unions representing workers in all modes of transportation covered by DOT’s drug and alcohol testing requirements, including those administered by FAA, FMCSA, FTA, FRA, PHMSA and USCG

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TTD Demands Immediate Federal Protective Measures for Frontline Transportation Workers

Dear Secretaries Chao and Scalia: It has now been over a month since the World Health Organization (WHO) declared the COVID-19 outbreak to be a pandemic. The United States alone has had over 670,000 confirmed cases and, tragically, over 34,000 deaths. Since this public health crisis began, TTD and our unions have consistently urged the federal government to take specific steps to protect frontline transportation workers and their families from exposure to this virus.

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