| Comment Number: | OL-10506369 |
| Received: | 3/11/2005 2:20:24 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:
Congress rejected the Defense Secretary's request for authority to waive all provisions of title 5, chapter 71, concerning labor management relations. 5USC 9902(b)(3)(D) and (d)(2). 70 Fed. Reg. 7601, 9901.917(d)(1) sets no limit to the Secretary's authority to prescribe matters by reg. or policy. 70 Fed. Reg. 7597, 9901.910(a)(2) gives management the right "to take whatever actions may be necessary to carry out the Dept.'s mission." I have seen a lot of things done in the name of carrying out the mission and they weren't all legal or ethical, but they thought they could get away with it. I agree some parts of the system need an overhaul and 9/11 was the perfect opportunity to discover those areas. Let us negotiate in the areas that need the work and leave the others alone. The Labor-management system is the checks and balances system that this country was founded on. 70 Fed. Reg.7596, 9901.907(a)(1). I am a title 32 employee and we have as our appeal system for adverse actions the Adjutant General. That system does not work well. A dispute resolution board picked by the Secretary is not independent.