| Comment Number: | EM-017677 |
| Received: | 3/13/2005 7:50:28 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
March 13, 2005 DoD NSPS Comments , DoD NSPS Comments: I write to express my concerns about changes to work rules in the Department of Defense (DoD). The proposed regulations, known as the National Security Personnel System (NSPS), were printed in the Federal Register on February 14, 2005. 1. If NSPS is made permanent in its present form, it should only apply to those entering federal service after its adoption. It is not fair to make such dramatic changes to the federal personnel management system for those federal employees who entered the service under the present system. Many of us entered federal service because we were willing to accept less pay for a degree a job security. Had the NSPS been in effect at time of our entry, many would have opted for employment in the private sector. Therefore, NSPS brings a breech of implied contract between the Government and its employees presently in career status. Accordingly, those presently in the federal government should be Grandfathered into the present system and not subject to NSPS in its present form. 2. The NSPS ?reforms? run roughshod over employee?s rights and supposedly grant management the ability to better ?manage? the workforce. I submit that management already has sufficient ability inherent in OPM regulations; therefore, NSPS is unnecessary. Management either lacks the guts, patience, or ability to use what?s presently in place. Management can already reduce non-performers in grade; reassign problem employees for cause; disapprove step increases of poor performers; and fire those few employees who consistently fail to perform. Management also has the authority to provide extra training and counseling to improve performance. But, these methods already in place take a little effort that many managers either don?t have the courage to exert, or they lack the expertise in personnel management, or they simply don?t care. It is an abomination to abrogate the rights of employees because managers fail to manage. Fix or train management; don?t breech the rights of employees because it?s the easy way out. 3. To strip the AFGE of it?s already weak regulatory ability to care for the workforce is not in keeping the philosophy of unions in the private sector. Therefore, it?s wrong! Few will argue the need for unions during the 1930?s to check unfair practices of management. In the auto industry, there was no regulation on working hours, child labor, care for injured employees during the relentless ?speed up? of assembly lines or other industrial accidents, no say whatsoever in company policy, and no right to representation. Pinkerton thugs and other assorted pugilists hired by management beat employees if they were seen associating with the fledging union. Conditions for employees were unspeakable. Recent history shows management abuses rampant in the U.S. Postal System. NSPS is a small harbinger of the possible return to these days, even in the Government. The idea of giving up union rights to NSPS is a huge step backward. Do not allow NSPS to become permanent with any denigration to employee rights under AFGE. I urge you to force DoD to rethink this proposal. We need work rules that preserve fairness, serve the American people, and respect the rights of Defense Department workers. Sincerely,