| Comment Number: | OL-10510401 |
| Received: | 3/16/2005 9:23:47 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:
9901.341 For the case of Nuclear Engineers like myself, a pay-for-performance system will compromise nuclear safety, which is our primary focus. In many cases, the knowledge that comes from experience gives long-time employees insight to make better decisions that relate to safety. In many cases, these decisions are at odds with cost and expediency. In a pay-for-performance system, long-time employees will lose all advantage of that experience, since performance will be the sole measure of their value, and safety is extremely difficult to quantify. 9901.405-409 While some managers are excellent communicators and facilitators, others are untrained and very poor personnel managers. Impementation of NSPS will making working for a poor manager untenable. Favoritism will become rampant. I expect that managers will not recieve the training that they need to become effective personnel managers, and even if they did, many nuclear managers were selected for their positions based on criteria other that their management skills. General: NSPS does not establish a system to challenge managers ratings. We currently have an established system of labor unions to assist when a challenge to managers becomes necessary. Under NSPS, instead of being able to address unfair labor practices in-house, many of these issues will have to be addressed in the court system. This will be very inefficient and expensive, both for employees and for the employer. As I understand it, here in the northwest, the organization that is to mediate in labor relations was disbanded last year, leaving no effective method outside the courts to deal with unfair labor practices. General: NSPS will overall have the effect of devaluing experienced employees in favor of the younger aggressive employee. In the long run, a loss of experience will result, since younger employees tend to be more transient. Senior employees will leave when younger employees that are the favorites of management recieve higher pay. Employee turnover will dramatically increase, and in the long run, our very ability to do nuclear work will be compromised, since experience is what nuclear safety at shipyards is built on.