Comment Number: OL-10501660
Received: 2/27/2005 2:19:36 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 7601: "(2) Except as otherwise provided in Sec. 9901.910(c), management has no obligation to bargain or consult over a change to a condition of employment unless the change is otherwise negotiable pursuant to these regulations and is foreseeable, substantial, and significant in terms of both impact and duration on the bargaining unit, or on those employees in that part of the bargaining unit affected by the change." Since DoD defines the standard in a non-precedential manner, then management has all the power and no oversight. "(e) If a management official involved in collective bargaining with an exclusive representative alleges that the duty to bargain in good faith does not extend to any matter, the exclusive representative may appeal the allegation to the Board in accordance with procedures established by the Board." Management can assert what they want, when and how they want. Since management also controls the NSLRB, then there is no appeal or oversight. "Sec. 9901.918 Multi-unit bargaining." SECDEF has "sole and exclusive authority" do follow any whim desired. There is no provision for oversight or correction from management mistakes.