Get Updates


Federal Comments

TTD To FRA: There Is No Substitute for Physical Safety Inspections

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s notice regarding Union Pacific’s petition for extension of a waiver of compliance. TTD consists of 36 affiliate unions representing workers in all modes of transportation, including carmen and other rail workers who work on lines covered by this waiver.[1]

In its petition, UP requests to extend a 2017 waiver of compliance to continue using wheel temperature detectors (WTD) on a segment of UP track to measure potential safety improvements and cost reductions on brake testing and maintenance. This waiver differs from current rules that state that extended haul trains are permitted to move a train up to, but not exceeding, 1,500 miles between brake tests and inspections. 49 CFR 232.213(a). In addition, current rules require that equipment with defective or insecure power brakes only be moved from the place at which the defect or insecurity was first discovered to the nearest available place at which the repairs can be made (49 CFR 232.15 and 49 U.S.C. 20303), and each car in a train must have the air brakes in effective operating conditions unless the car is being moved for repairs in accordance with 49 CFR 232.15 (49 CFR 232.1 03(f)).

Read More

DOT Research and Development Must Include Workers

By Admin

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 on its (FY) 2022-2026 Research, Development, and Technology (RD&T) Strategic Plan. TTD consists of 36 affiliate unions representing workers in all modes of transportation, including those directly affected by the DOT’s policies and programs. Specifically, the next wave of research initiatives funded by the agency as a result of the RD&T Strategic Plan will have a profound effect on the future of mobility, work and jobs in this industry. We therefore have a vested interest in the results from this important proceeding.[1] We also want to concur with the separate comments submitted by the Transport Workers Union, a TTD member union.

Read More

Federal Transit Administration Must Prioritize Workers in the Transition to a Clean Transit Future

By Admin

Dear Administrator Fernandez, On behalf of the Transportation Trades Department, AFL-CIO (TTD), I urge you to ensure that the transformative investments in Zero-Emission Buses (ZEBs) included in the Infrastructure Investment and Jobs Act (IIJA) promote good union jobs among the incumbent and future workforces who will be tasked with maintaining the next generation of transit […]

Read More

TTD Urges DOT to Launch Bold Strategic Plan to Ensure Safety and Provide Good-Paying Union Jobs

By Admin

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 comment on its 2022-2026 Strategic Plan. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including workers directly affected by the DOT’s policies and programs.[1] We must be clear that the goals outlined by the DOT for the 2022-2026 Strategic Plan—creating good jobs, improving equity and environmental outcomes, and making the DOT more effective and accountable to the American people—can, and will, only be successfully achieved when the voice of working people is integral to the formulation and implementation of those policies.

While these comments aim to be comprehensive, we also recognize that they may not be fully inclusive in representing the needs and positions of transportation labor. We therefore strongly urge your full consideration of individual comments filed by our affiliated unions, and encourage further ongoing dialogue with those who represent working people to ensure the 2022-2026 Strategic Plan gives due consideration to the needs of all working people.

Read More

TTD Urges FTA to Protect Transit Workers

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD) and our 33 affiliated unions, we thank you for taking this important step to begin examining the serious safety issues facing transit workers across this country every single day.

TTD’s affiliated unions collectively represent most transit workers in this country, including rail transit, bus, roadway, construction, and maintenance workers[1]. Most of these workers interface directly with the public, and all are exposed to the risks of assault. We have long-called for both legislative and regulatory solutions to increase worker safety, including putting a stop to the scourge of assaults on transit workers.

Read More

FTA Must Prioritize Action on Worker Safety Issues

By Admin

August 16, 2021   Nuria Fernandez Federal Transit Administration East Building 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Transit Safety Concerns Docket No. FTA-2021-0011 On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Transit Administration’s (FTA) Request for Information on Transit Safety Concerns. TTD consists […]

Read More

TTD Opposes UP Brake Inspection Waiver

By Admin

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 petition for waiver of compliance from Union Pacific Railroad Company. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including employees who operate trains and carmen who perform brake inspections. We therefore have a vested interest in this policy.

Read More

Hands-On Training is Essential for Rail Safety

By Admin

Mr. Karl Alexy Associate Administrator for Railroad Safety & Chief Safety Officer Federal Railroad Administration 1200 New Jersey Avenue SE Washington DC, 20590 RE: UP Waiver of Compliance, Simulator Training Docket No. FRA-2021-0042 On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) request for […]

Read More

TTD Calls for A Pro-Worker, Pro-Safety Regulatory Agenda

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Department of Transportation’s request for comment on its notice entitled Notification of Regulatory Review. TTD consists of 33 affiliate unions representing workers in all modes of transportation. We therefore have a vested interest in this policy.

Read More

TTD Requests Extension of Comment Deadline on Brake Inspection Waiver Petition

By Admin

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FRA’s request for comment on the Petition for Waiver of Compliance submitted by Union Pacific Railroad Company. TTD consists of 33 affiliate unions representing workers in all modes of transportation, including rail workers who conduct pre-departure inspections, service, and operate trains. We therefore have a vested interest in this policy.

Read More