Policy

October 13, 2023 The Honorable David H. Boulter Acting Associate Administrator, Aviation Safety Federal Aviation Administration 1200 New Jersey Ave, SE Washington, DC 20590 RE:     Regulatory Definitions of On-Demand Operation, Supplemental Operation, and Scheduled Operation Docket No. FAA-2023-1857 Mr. Boulter: On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to […]

October 3, 2023 Dear Senator: On behalf of the undersigned American maritime labor organizations and the thousands of American licensed and unlicensed merchant mariners and longshore workers we represent we ask that you cosponsor and support S 2862, the American Farmers Feed the World Act of 2023. The enactment of this bipartisan legislation will feed […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Transportation Security Administration’s (TSA) notice of proposed rulemaking to require security vetting of certain public transportation, railroad, and over-the-road-bus (OTRB) employees. TTD consists of 37 affiliated unions that represent employees working across the transportation sector, including rail and public transit employees. We therefore have a vested interest in this rulemaking. Transportation labor has long been at the forefront of demanding the strongest federal measures to protect the transportation infrastructure and systems that have been terrorism targets. We believe that efforts to secure our transportation system must strike a balance. They should provide protection and security against the terrorist threat environment while also preserving the legitimate rights of employees. To that end, we encourage the TSA to conduct additional, proactive outreach to stakeholders, including transportation labor, as it finalizes this rulemaking.

September 25, 2023 Dear Representative: On behalf of the undersigned American maritime labor organizations and the thousands of American licensed and unlicensed merchant mariners and longshore workers we represent we ask that you cosponsor and support HR 4293, the American Farmers Feed the World Act of 2023. This enactment of this bipartisan legislation will feed […]

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) request for comment on an Information Collection Request (ICR) related to monthly reporting requirements on freight train length and tonnage by Class I railroads. Specifically, the proposed information collection would require Class I freight railroads to provide the FRA, on a monthly basis, with data regarding the total number of trains operated and the total number of cars in those trains, as well as the total trailing tonnage in specified train length categories. TTD consists of 37 affiliated unions representing the totality of rail labor, including both passenger and freight rail workers. We therefore have a vested interest in this ICR. Additionally, we endorse the comments of our affiliate, the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART-TD).

The length and weight of freight trains have dramatically increased in recent years due to the rail industry’s adoption of Precision Scheduled Railroading (PSR). A recent fact sheet from the Association of American Railroads (AAR) illustrates that maximum train length increased by roughly 40% between 2010 and 2022. Similarly, rail unions have reported trains operating in the western United States that are up to four and five miles long. Rail workers have long-standing safety concerns related to train length, including radio and End of Train (EOT) device communication issues; increased blocked crossings; additional in-train forces that make it difficult to keep trains intact; insufficient training for Very Long Trains (VLT) crews; and decreased maintenance standards. We therefore strongly support the FRA’s proposal to gather train length and tonnage data from Class I freight railroads.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice regarding the Canadian National (CN) Railway Company’s petition to extend its waiver of compliance from the provisions of §236.377, Approach locking; §236.378, Time locking; §236.379, Route locking; §236.380, Indication locking; and §236.281, Traffic locking, to extend the periodic testing schedules from at least once every two years to at least once every four years. TTD consists of 37 affiliated unions representing the totality of rail labor. For the reasons outlined below, we respectfully request that the FRA deny CN’s petition. Additionally, TTD endorses the comments of our affiliate, the Brotherhood of Railroad Signalmen (BRS).

In its petition, CN is requesting an extension of its initial waiver, first granted in 2012 and most recently extended in 2018, that allows for the verification and testing of signal locking systems controlled by microprocessor-based equipment through the use of alternative procedures every four years. As BRS notes in its comments, continuing to grant this request bypasses several safety checks that validate signal control systems. First, the alternative methods of verification currently in place under this waiver, using the Cyclic Redundancy Check (CRC)/Checksum/Universal Control Number (UNC), are not an adequate substitute for required field verification testing. These methods cannot reliably discover errors that would otherwise be identified through the required means of testing and verification as established under federal regulations.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice of proposed rulemaking concerning the certification of train dispatchers. TTD consists of 37 affiliated unions, including those representing train dispatchers, and we therefore have a vested interest in this rulemaking. We applaud the FRA for proposing this rule and strongly support the implementation of certification requirements for train dispatchers. We ask the FRA to consider the recommended changes to the proposed rule outlined below and urge the agency to expeditiously finalize this regulation. Additionally, we endorse the comments of our affiliates, the American Train Dispatchers Association (ATDA), the International Brotherhood of Electrical Workers (IBEW), and the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD).

Background on Congressional and FRA Action on Dispatcher Certification

Certification of certain rail crafts or classes of employees is not a new concept in the rail industry. In fact, the FRA has been discussing certification requirements for the past few decades. As the FRA notes in section III, paragraph 2 of the NPRM, Congress mandated in the Rail Safety Improvement Act of 1988 that anyone operating a train, including locomotive engineers, be certified. The FRA subsequently finalized the necessary regulations for locomotive engineers in 1991, over three decades ago, and those regulations are now contained in Part 240 of Title 49, Code of Federal Regulations.

On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to the Federal Railroad Administration’s (FRA) notice of proposed rulemaking governing the certification of rail signal employees. TTD consists of 37 affiliated unions, including those representing signal employees, and we therefore have a vested interest in this rulemaking. We applaud the FRA for proposing this rule and strongly support the implementation of certification requirements for signal employees. We respectfully ask the FRA to consider the recommended changes to the proposed rule outlined below and urge the agency to expeditiously finalize this regulation. Additionally, we endorse the comments of our affiliates, the Brotherhood of Railroad Signalmen (BRS), the International Brotherhood of Electrical Workers (IBEW), and the Transportation Division of the International Association of Sheet Metal, Air, Rail and Transportation Workers (SMART-TD).

Background on Congressional and FRA Action on Signal Employee Certification

Certification of certain rail crafts or classes of employees has been a topic of discussion within the FRA for several decades. As the FRA notes in section III, paragraph 2 of the NPRM, Congress mandated in the Rail Safety Improvement Act of 1988 that anyone operating a train, including locomotive engineers, be certified. The FRA subsequently finalized the necessary regulations for locomotive engineers in 1991, over three decades ago, and those regulations are now contained in Part 240 of Title 49, Code of Federal Regulations.

September 11, 2023  To Whom It May Concern:  We write regarding U.S. Customs and Border Protection’s (CBP’s) recent decision, HQ  H328718 (July 17, 2023), to request that this ruling be withdrawn and reconsidered. On behalf  of America’s seagoing unions, we believe it is important to have more clarity in the applicability  of the coastwise laws […]

August 16, 2023 Alan Shaw Norfolk Southern 1200 Peachtree St NE Atlanta, GA Mr. Shaw: On behalf of the Transportation Trades Department (TTD) of the AFL-CIO, we are writing to urge Norfolk Southern (NS) to swiftly join the Federal Railroad Administration (FRA)’s Confidential Close Call Reporting System, which enables workers to confidentially report “close call” […]