On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to respond to FMCSA’s request for comments on the American Trucking Associations’ (ATA) petition for federal preemption of California’s Meal and Rest Break rules. TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those covered by FMCSA’s HOS regulations and California’s rules. For reasons discussed below, we urge FMCSA to reject ATA’s petition.
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.
Washington, DC — The Transportation Trades Department, AFL-CIO (TTD), is urging the Federal Motor Carrier Safety Administration (FMCSA) to follow established protocol and put science first by denying a petition by several trucking companies to use hair specimen in lieu of federally mandated urine in pre-employment drug tests.
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. 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.
Through this notice, FMCSA is seeking to define a “curbside bus operator” for the purpose of implementing section 32707 of MAP-21, which requires an annual safety fitness assessment of certain motor carriers of passengers that serve primarily urban areas with high passenger loads. The Agency has specifically identified curbside operators as the intended subject of that requirement, and proposes that these carriers should be defined as those that use 25% or more of their motorcoaches for operations involving pick-ups and drop-offs at curbside locations or parking lots.
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in support of the Notice of Proposed Rulemaking (NPRM) on Qualifications for Commercial Motor Vehicle (CMV) Drivers; Diabetes Standard. By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including those who are medically certified to operate a CMV. We therefore have a vested interest in this rulemaking. In addition to the comments that follow, we endorse those separately filed by TTD affiliates, the Amalgamated Transit Union (ATU) and the Sheet Metal, Air, Rail Transportation Union – Transportation Division (SMART-TD).
At the outset, we express support for FMCSA’s consideration of updating its existing standard that requires motor carriers to maintain a specified minimum level of financial responsibility to provide coverage for public liability and property damage resulting from a commercial bus accident. TTD and our affiliates have a long history of advocating for strengthening market entry standards to help ensure only upstanding motor carriers are granted operating authority. Just last week, TTD’s Executive Committee renewed the call for improving these standards, urging FMCSA to increase the current minimum level of financial responsibility.
ATLANTA, GA—The Transportation Trades Department, AFL-CIO (TTD) and its 32 affiliated unions waded into every major transportation policy debate in Washington and focused on expanding transportation investments, reforming safety policy, protecting workers’ rights, and rejecting job-killing trade policies. “2015 must be the year when we break the stalemate on funding our badly deteriorated transportation system […]
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