Policy

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Canadian National Railway’s (CN) petition for a waiver of compliance from the “hands-on” component of periodic refresher training required by 49 CFR 232.203(b)(8). By way of background, TTD consists of 37 affiliate unions, including the totality of rail labor[1]. We endorse the comments of our affiliates, the Transport Workers Union of America (TWU) and the Sheet Metal, Air, Rail and Transportation Workers (SMART), that are also posted in this docket.

As discussed below, TTD opposes CN’s resubmitted waiver request and urges the FRA to reject the request because it jeopardizes the safety of rail labor employees and the public.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) proposed rule regarding Risk Reduction Programs (RRP). TTD consists of 37 affiliate unions representing the totality of rail labor and its 105,000 workers across the country. Our affiliated unions represent workers who perform every task on trains and railroad tracks and at rail yards and shops. These workers are vital to keeping our railroad system successfully operating every day.[1]

The NPRM, issued in response to a petition filed by the Association of American Railroads (AAR), seeks views on whether to retain, remove or modify the application of 49 CFR 271. 3(c) in the development of risk reduction programs, to contractors and their employees who perform a significant portion of a railroad’s operations. Currently, pursuant to final FRA rules issued on February 18, 2020 (49 CFR 271) contractors and their employees, providing “ongoing services involving significant aspects of the railroads operations” (e.g. maintenance of locomotives and rail car, dispatching, switching, flagging etc.) are covered under the development and implementation of the mandated risk reduction plans. (see 49 CFR 271.221 and 3(c)). As justification, the AAR asserts that none of the seven Class 1 freight railroads utilize such contractors, and therefore requests that the existent requirements under 49 CFR 271 be removed, notwithstanding that even if true, such arrangements could arise in the future.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the PHMSA’s request for information (RFI) regarding electronic hazard communication. By way of background, TTD consists of 37 affiliate unions, including freight rail workers, first responders, and dispatchers who interact with hazardous materials on a daily basis.

In the RFI, PHMSA seeks input regarding the potential use of electronic communication as an alternative to current, physical documentation requirements for hazard communication (e.g. shipping papers, train consists, dangerous goods manifests, notifications to the pilot in command, and emergency response information, as well as associated administrative documentation including DOT Special Permits, approvals, and registrations) concerning transportation of hazardous materials.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Aviation Administration’s (FAA) request for comment on the Installation and Operation of Flightdeck Installed Physical Secondary Barriers on Transport Category Airplanes in Part 121 Service. TTD consists of 37 unions in all modes of transportation, including those that represent flight, cabin crew, and ground personnel at airlines throughout the United States. TTD, along with its affiliate unions, has long fought for so-called secondary barriers or Installed Physical Secondary Barriers (IPSB) on transport category aircraft. While we are pleased the FAA finally has initiated a Notice of Proposed Rulemaking (NPRM), the FAA should take further actions related to the scope of the rulemaking, compliance timeline, and application to foreign air carriers, among other important steps.

Good morning. Thank you, Chairman DeFazio and Ranking Member Graves for inviting me to testify before the committee today. It is truly an honor to be asked to testify at Chairman DeFazio’s final full committee hearing. The Chairman has a proud and historic legacy of fighting for sound transportation policy, new investments in a modern transportation system and infrastructure that create good union jobs, and the strongest transportation and construction worker protections in our laws and regulations.

I speak today on behalf of 37 unions who collectively represent millions of frontline workers across every mode and every sector of America’s transportation network.

On behalf of workers across the airline industry, we are writing to encourage you to support the bipartisan Global Aircraft Maintenance Safety Improvement Act (H.R. 7321) when it comes up for a vote on the House floor. This legislation removes incentives for airlines to offshore maintenance jobs by closing safety loopholes which allow US-aircraft to be repaired on lower safety standards at FAA-certified facilities abroad.

The Honorable Pete Buttigieg Secretary U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Secretary Buttigieg: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am writing to express deep concern about the U.S. Department of Transportation’s (DOT) approach toward the deployment of poorly regulated and potentially disruptive new technologies […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the Federal Transit Administration’s (FTA) proposed changes regarding National Transit Database (NTD) safety and security reporting. TTD consists of 37 affiliate unions and their workers, including transit operators, maintenance workers, and other operations personnel. TTD endorses the comments by our affiliates, the Amalgamated Transit Union (ATU) and the Transport Workers Union of America (TWU), which are also filed in this docket.[1] In particular, as stated by ATU, implementation of data collection must capture both physical and other forms of assault.

The proposed changes would incorporate the updated definition of “assault on a transit worker” for the purposes of NTD reporting. The Bipartisan Infrastructure Law amended 49 U.S.C. 5302(1) to define “assault on a transit worker” as a “circumstance in which an individual knowingly, without lawful authority or permission, and with intent to endanger the safety of any individual, or with a reckless disregard for the safety of human life, interferes with, disables, or incapacitates a transit worker while the transit worker is performing the duties of the transit worker.”