| Comment Number: | OL-10504023 |
| Received: | 3/8/2005 10:54:41 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:
General Comment: In its stated purpose of the NSPS, DOD repeats the fact that Congress authorized the Secretary of Defense and the Director of the Office of Personnel Management to establish a labor-management relations system and points to 5 U.S.C. 9902(m). However, again DOD fails to identify that Congress also said and the law assures the participation of, employee representatives in the development and implementation of the labor management relations system by requiring the Secretary of Defense and the Director of OPM to afford employee representatives and management the opportunity to have meaningful discussions concerning the development of the new system; this did not happen.