| Comment Number: | OL-10508447 |
| Received: | 3/15/2005 8:43:52 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:
In your Myths and Facts document, you state, 'The implementation of the NSPS labor relations system will not eliminate unions or bargaining units. Employees will still be able to be represented by labor organizations and to bargain collectively. The proposed rules enable the Department to act expeditiously in carrying out its mission by limiting the situations that are subject to bargaining, and speeding up the bargaining process.' True, the Union will not be eliminated, but management no will no longer have to interact on the same scale as today. The major effects will be in the area of impact bargaining on changes to working conditions and loss of independent 3rd party review for grievances and adverse actions. Also, by adding personal conduct to performance ratings, the Department is hoping to take the wind out of Union officials who take aggressive action against agencies when employee rights are violated.