| Comment Number: | OL-10501634 |
| Received: | 2/27/2005 1:55:21 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:
Comments concerning - Federal Register: February 14, 2005 (Volume 70, Number 29) Proposed Rules: FR Document 05-2582/NSPS (National Security Personnel System) Page 7571: "Because of the complicated and confusing criteria, front- line managers and supervisors are often reluctant to hold discussions with employees concerning everyday workplace issues, which can affect work unit effectiveness and efficiency and inhibit communication and problem solving." This is blatantly false or management does not know that within the law, what it says goes. The failure to communicate is the fault of management and employees should not be punished by this for managements' failures. Besides, if management did not get input from employees (who really are the ones that know how things work), managers are so far removed from the work, they could not get their job done. "... the union has no institutional right to represent the employee or attend meetings related to the resolution of the employee's issues. This change strikes an appropriate balance between the union's institutional rights and employee privacy and, with regard to complaint processes other than negotiated grievance procedures." This is a grave loss of protection for employees. The "appropriateness" of this is only that DoD and management no longer have to deal with those pesky union representative. "Further, this change ensures that investigations involving criminal matters are not affected by unnecessary delay, harm to the integrity of the investigation, or issues of confidentiality." Confidentiality is a false flag and is used to justify a further erosion of employess rights. "Under these regulations, disclosure of information is not required if adequate alternative means exist for obtaining the requested information, or if proper discussion, understanding, or negotiation of a particular subject within the scope of collective bargaining is possible without recourse to the information. This change also relieves management of the unnecessary administrative burden of producing information that can readily be obtained some other way and recognizes technological advances in information access and sharing." This section guts any right of discovery by interested parties. If "alternative means" is FOIA (Freedom of Information Act), then there is no discovery at all. Management can hide documents for what ever motivation they wish. "Unfair Labor Practices" This provides for voiding current local CBAs (Collective Bargaining Agreements) and supercedes local influence. Another term for this is "union busting."