| Comment Number: | OL-10503383 |
| Received: | 3/5/2005 10:02:42 AM |
| 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:
All Sections-The use of the words flexible and comtemporary in context with the scare phrase- The attacks of September 11... is a ruse; not a reason for NSPS.The meanings of neither word has anything to do with stripping workers of their workplace democracy- as is the case in this proposed regulation. These regulations makes no case for the radical removal of rights balanced by any particular national security concern.When you cut to the chase through all the rehortical wordsmithing, gobbledegook power words like essential management flexibilities...what does that really mean? Total management rights? A Trust me management with no system of checks and balances to protect workers from abuses? Do we ignore thirty years of experiences with abusive federal managers who have had thousands of federal courts and impartial arbitrators rule against them ordering millions of dollars of judgements in favor of abused federal workers? Are all the managers going to be replaced and brand new, well-trained, fair and objective managers going to implement NSPS? CSRA has had a requirement since 1978 for federal managers to fairly and objectively rate every federal employee on their actual performance. To date, that hasn't ever happened. Now a worker's perfromance will be the determining factor in all aspects of conditions of employment and we are supposed to believe these same managers who have been required to accurately measure employees performance will now do it fairly and objectively in a system that has absolutely no meaningful system to challenge the supervisor's appraisal? Congress intended to preserve employee rights balanced by the unique security needs of the DOD when it passed PL108-136. This regulation makes a mockery of Congressional intent, eg.- This proposal negates any collective bargaining at the whim of the Secretary. If a local collective bargaining agreement can be reached and signed, the Secretary can the very next day issue a directive that superceeds the agreement and null and voids the agreement reached between the parties that both sides agreed made sense at that activity. The Secretary does not have to justify any personnel directive or issuances after this regulation becomes final. DOD said it wanted to incorporate the best practices of the private sector into NSPS. This regulation does the opposite. At one of the largest private sector employers (Northrop Grumman Ships Systems) the employer wants more employee empowerment, more employee input into everyday work evolution, less management direction, more self directed work teams. NGSS wants more than the employees' arms and legs, they want the employees' ideas on how to work smarter, more efficiently, & with less down time. They come to the bargaining table with their employees and negotiate a win-win personnel system with their employees. They don't take away employees' workplace democracy; they work with the workers to make meaningful changes. It isn't- my way or the highway- as this proposed regulation is. Collective bargaining has been the most successful redistribution of wealth to workers in the history of the nation and created a middle class from poverty. NSPS is a direct threat to all collective bargaining. If you want to see the real intent and the blueprint for NSPS- visit the Right Wing "think tank", the Heritage Foundation website and call up an article titled Taking Charge of Federal Personnel written January 10, 2001, by George Nesterczuk (the principle consultant hired by DOD and sitting at the table in all discussions held with employee representatives over NSPS), Donald Devine and Robert Moffit. This was well before 9-11...The attacks of 9-11 wasn't the reason for NSPS, merely the opportunity.