Comment Number: OL-10503990
Received: 3/8/2005 10:01:42 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:

Subpart G Adverse Actions, Sections 9901.701 thru 9901.810; Due process and fairness demand that the independent body reviewing a major suspension as termination be allowed to alter the proposed penalty if they deem it to be unreasonable. The current standards approved by the courts to guide such bodies should continue to be used. Subpart I Labor Management Relations, Sections 9901.901 thru 9901.929; The labor management law that has governed the employees' right to organize and engage in collective bargaining has worked since 1978. There is no compelling reason to take away most of the collective bargaining rights or grievance rights. DoD should not create a company dominated dispute board. Any dispute board must be jointly selected by management and the Union.