| Comment Number: | OL-10503402 |
| Received: | 3/5/2005 11:35:10 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:
Under Section 7117 of the Federal Labor Service Labor Management Statute, a compelling need must exist to make changes with out bargaining being completed first. Under 9901. 916 in contrast, this concept of law is omitted, and the "Board" is unfettered in ruling on the negotiability of an issue. The "Board" should be required to use a reasonable standard in making this decision and it should be stated. There is no standard stated and that is a standard by its self, that standard being "there is no standard".