Comment Number: OL-10512220
Received: 3/16/2005 11:53:51 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:

Agency: Department of Commerce, National Processing Center Docket ID: NSPS-2005-001 RIN #: 3206-Ak76 Subpart I -- Labor-Management Relations Section 9901.904 Coverage Part (b)(5) Under this new personnel system the Department or the Secretary determines who can belong to a labor organization instead of federal law stating who can belong and who can not belong. Under Sec 9901.912(a) the Authority will determine the appropriateness of any unit. So this gives the freedom to the Authority to determine that any unit is inappropriate to belong to a labor organization just because the Department has railroaded this system through Congress. The Department now has the ability to classify the position differently than before, remove employee's with out proper rights to MSPB appeals, decide different pay structure than the rest of the federal governement, and now decide who if anyone can belong to a labor organization. Not one thing under this new personnel systems protects employee rights to choose, appeal, belong, pay, or job series which is protected now under current federal laws. Please don't be fooled into thinking that the wording in this personnel system does not give the 'sole, exclusive, and unreviewable discretion' to the Secretary will not be pushed to fullest extent possible. Employee's should have right to belong to a labor organization without fear from that the Secretary will reclassify them under this new system and then they will no longer have the choice or the freedom to do so.