Mechanics' Dispatch Nicole Casey Mechanics' Dispatch Nicole Casey

TSAP Update

Concerns for airworthiness safety is a cornerstone subject with the International Brotherhood of Teamsters that we accept with the most importance. Not only are we protecting the livelihoods of our members and their families, the continued devotion to safety is also a real benefit to the flying public which we are proud to defend. 

Brothers and Sisters,

Concerns for airworthiness safety is a cornerstone subject with the International Brotherhood of Teamsters that we accept with the most importance. Not only are we protecting the livelihoods of our members and their families, the continued devotion to safety is also a real benefit to the flying public which we are proud to defend. 

Recently there have been some events within the TSAP process that have raised some serious concerns to the membership. By their actions, we question whether UAL leadership are as committed to the overall safety program as they have led us to believe. In more than one case, they have gone back on agreements made within the program with little or no reasonable explanation. The addition or threat of discipline in some cases has given us a very valid reason to pause the program while we work out our differences. 

The Teamsters will continue to protect the integrity of flight safety and commit to a mutual agreement among the parties. However, we will not be pushed or coerced into re-defining that agreement when it puts our members at risk or degrades the integrity of the program. 

The company was assured in a meeting yesterday that the Union would review the overall TSAP program and come back with recommendations on a plan moving forward. Soon after that meeting, a communication was sent through the Senior Vice President of Tech Ops to all technicians which undermines that plan. The current TSAP program is flawed but can be corrected if UAL is serious about its commitment to the safety of the aircraft and the employees. Attempts by UAL to “bargain from the floor” offer us some legitimate proof that the overall commitment may not be universally shared by all members of management. 

The Teamster leadership will continue to discuss the TSAP program and move in the direction that is right for our members. We will keep you informed to that end.

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UAL Mechanics Dispatch 8/14/24

Yesterday, Teamsters General President Sean M. O’Brien and General Secretary-Treasurer Fred Zuckerman visited United Airlines technicians represented by Teamsters Local 210 at Newark Liberty International Airport as bargaining continues with the company.

Yesterday, Teamsters General President Sean M. O’Brien and General Secretary-Treasurer Fred Zuckerman visited United Airlines technicians represented by Teamsters Local 210 at Newark Liberty International Airport as bargaining continues with the company.

“This is the first step towards what will be an historic contract for United Airlines Teamsters,” O’Brien said. “Thanks to the leadership of our negotiating committee and the solidarity of United Airlines Teamsters across the country, we are taking this fight right to the carrier’s doorstep and will not rest until we get the contract we deserve.” 

With over 900 on-site technicians, Newark hosts the third-largest cohort of United Airlines Teamsters nationwide. 

“It’s time to put United Airlines on notice — the Teamsters are standing together. We are not playing games,” said David Mahood, a United Airlines technician from Local 210 and a member of the United Airlines Teamsters National Negotiating Committee. “Our strength comes from our determination to win. By speaking with one voice, we will deliver the industry-leading contract United Airlines Teamsters have rightfully earned.”

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Teamsters Wrap Up First Bargaining Session in Chicago

The Teamsters made significant progress for a strong new contract as bargaining began with United Airlines in Chicago on August 8. Every proposal in the union’s opening non-economic offer was presented across the table to the company.

“This is my first bargaining session, and I’m looking forward to getting a record contract as smoothly and quickly as we can,” said Jimmy Sligar, a rank-and-file bargaining committee member from Teamsters Local 19 in Houston. “The union has a great committee, and we presented proposals to the company that are really strong.”

Teamsters Wrap Up First Bargaining Session in Chicago

The Teamsters made significant progress for a strong new contract as bargaining began with United Airlines in Chicago on August 8. Every proposal in the union’s opening non-economic offer was presented across the table to the company.

“This is my first bargaining session, and I’m looking forward to getting a record contract as smoothly and quickly as we can,” said Jimmy Sligar, a rank-and-file bargaining committee member from Teamsters Local 19 in Houston. “The union has a great committee, and we presented proposals to the company that are really strong.”

Tentative Agreement Won on Tool Insurance
In the first round of negotiations, the United Airlines Teamsters national committee secured its first tentative agreement as the company agreed to raise the cap on tool insurance from $10,000 to $25,000.

Multiple subcommittees were formed during the session in Chicago. One subcommittee will work to address issues around Article 18 on Union Security and Representation; Article 19 on Grievance Procedure; and Article 20 on Board of Arbitration.

“We are working more aggressively and transparently than ever before to make sure United Airlines hears directly from our members during every step of these negotiations,” said Clacy Griswold, Chairman of the United Airlines Teamsters National Negotiating Committee. “The majority of the union’s full committee is made up of rank-and-file technicians. All proposals we will put on the table and fight for are drawn from the members. Together, with a united front, we have the power to take this company on and win big.”

Safety Protocols Must Be Improved
The Teamsters are demanding that United Airlines make serious movement on every issue, including changes to Article 7K. The union is calling on the company to follow the guidelines of government agencies concerning shelter-in-place orders and other safety protocol during a natural disaster. The urgency of this issue was particularly apparent after United Airlines attempted to force Local 19 members to report to work during Hurricane Beryl in Houston.

“So far, United has failed to respond seriously to emergency response preparedness. If United Airlines thinks they can drag the issue out by being obstinate, they’re in for a rude awakening,” Griswold said. “Throughout this process, we will not back down from protecting the safety and health of our members.”

The Teamsters and United Airlines will resume negotiations in Denver August 20-22.

“It’s important for the 10,000 Teamsters technicians at United Airlines to know it’s a new day and we have a more militant and more organized approach to bargaining,” said Dexter Thomas, a Teamster on the bargaining committee and Recording Secretary of Local 19. “We have heard our members’ concerns, and we will fight to make significant gains for all members every single time we come to the table. It’s important for all Teamsters at United to get and stay involved in this campaign at their stations. In this battle for an historic agreement, solidarity will make all the difference.”

 

 

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TSAP program with United Airlines is suspended

A letter was sent to United Airlines and the FAA earlier today. This letter describes serious violations to the discipline language on the agreement by United Airlines.

Hello all,

A letter was sent to United Airlines and the FAA earlier today. This letter describes serious violations to the discipline language on the agreement by United Airlines.

Effective immediately the TSAP program with United Airlines is suspended until further notice.

Please follow the instructions for flight safety reports to the NASA Aviation Safety Reporting System using the fink below:

NASA Aviation Safety Reporting System

Fraternally,

Dave Saucedo
Airline Coordinator

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Teamsters, United Airlines Set Additional Dates for Bargaining

The United Airlines Teamsters National Negotiating Committee has set additional dates for bargaining – Sept. 16-17, Sept. 24-26, Oct. 7-9, Oct. 22-24, Nov. 5-7, Nov. 12-14, and Dec. 3-5. Bargaining locations will rotate between Chicago, Denver, Houston, and San Francisco.

The United Airlines Teamsters National Negotiating Committee has set additional dates for bargaining – Sept. 16-17, Sept. 24-26, Oct. 7-9, Oct. 22-24, Nov. 5-7, Nov. 12-14, and Dec. 3-5. Bargaining locations will rotate between Chicago, Denver, Houston, and San Francisco.

The Teamsters will begin bargaining with the company August 6-7 in Chicago and continue negotiations August 20-22 in Denver. For more information, download the Teamsters Airline Division App at https://l.ead.me/bf44s1 to stay informed and engaged.

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UAL Negotiations Update 7/17/24

Your Teamsters United Airlines National Negotiating Committee has set dates with the company to begin bargaining a new contract at the carrier. The Teamsters and the company will meet on August 5 and 6 in Chicago. The next round of bargaining will be held on August 20 and 22, at a location of the union's choosing (to be determined in the near future).

TEAMSTERS, UNITED AIRLINES SET DATES FOR BARGAINING

Your Teamsters United Airlines National Negotiating Committee has set dates with the company to begin bargaining a new contract at the carrier. The Teamsters and the company will meet on August 5 and 6 in Chicago. The next round of bargaining will be held on August 20 through 22, at a location of the union's choosing (to be determined in the near future).

Your bargaining committee is working diligently to secure the best contract possible for all members at the carrier. For more news and updates, download the United Airlines App at https://l.ead.me/bf44s1.

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United Airlines Teamsters Meet in Las Vegas to Prepare for Bargaining

(LAS VEGAS) – Members of the United Airlines Teamsters National Negotiating Committee convened in Las Vegas to review contract proposals submitted by rank-and-file technicians during the past few weeks. Teamsters at the world’s third-largest airline submitted thousands of proposals on what they want in the new collective bargaining agreement.

(LAS VEGAS) – Members of the United Airlines Teamsters National Negotiating Committee convened in Las Vegas to review contract proposals submitted by rank-and-file technicians during the past few weeks. Teamsters at the world’s third-largest airline submitted thousands of proposals on what they want in the new collective bargaining agreement.

 “The voices of rank-and-file technicians have been heard loud and clear, and now it’s time to secure the best contract possible at United Airlines,” said Chris Griswold, Director of the Teamsters Airline Division.

Members of the Teamsters negotiating committee diligently reviewed and consolidated all proposals as the union works to finalize and tackle workers’ biggest priorities. Initial bargaining will begin in August.

“The level of engagement we’ve seen in this contract campaign is unprecedented,” said Bob Fisher, Teamsters Airline Division Director-Below the Wing. “The Teamsters want all members at United Airlines connected to and participating in this campaign. Together we will make sure negotiations are transparent, aggressive, and ultimately successful for the entire membership.”

The committee will continue the process of reviewing more contract proposals next week.

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Teamsters to Host RLA Trainings for United Airlines Technicians

As we work to bargain the best possible contract at United Airlines, the Teamsters Union will host virtual informational training sessions at United Airlines Stations across the country with our Training and Grants Department. Rank-and-file aviation technicians will learn about the Railway Labor Act (RLA), including:

As we work to bargain the best possible contract at United Airlines, the Teamsters Union will host virtual informational training sessions at United Airlines Stations across the country with our Training and Grants Department. Rank-and-file aviation technicians will learn about the Railway Labor Act (RLA), including:

 – How the collective bargaining process works at United Airlines
– How and why bargaining union contracts in aviation is different from other industries
– The role of the federal government in aviation labor relations
– The ratification and enforcement of union contracts in the airline industry

See the training schedule below. Click on the time to save an invite to your calendar.

 

Teamsters Local 856 & 986: San Francisco
Thursday, July 11 — 5am, 2pm and 10pm

 

All rank-and-file technicians are strongly encouraged to attend these important trainings. For more information, contact Paul Trujillo at ptrujillo@teamster.org or Iliana Flores at iflores@teamster.org.

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United Airlines Bargaining Survey Credentials

All United Airlines Teamsters technicians should have received a text message with a unique link to fill out a bargaining survey on what you want in your new contract. If you need new credentials to fill out the survey, you must request them by Sunday, July 7, at 1pm EST. Here’s the contact information to receive new credentials:

All United Airlines Teamsters technicians should have received a text message with a unique link to fill out a bargaining survey on what you want in your new contract. If you need new credentials to fill out the survey, you must request them by Sunday, July 7, at 1pm EST. Here’s the contact information to receive new credentials:

 

Western Region (Including Teamsters SFO 856/986 Members):

Dave Saucedo, (425) 358-1006

dsaucedo@teamster.org  

 

Eastern Region:

Vinny Graziano, (201) 838-2014

vgraziano@teamster.org

 

Central Region:

Mike Moats, (216) 857-0763

mmoats@teamster.org

 

 

If you’re in the Southern Region (or if you don’t know your region), contact Bob Fisher, Teamsters Airline Division Director - Under the Wing, at (304) 261-3379 or at rfisher@teamster.org.

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Join Us for the United Airlines Contract Campaign Kickoff Call - June 18!

Teamsters General President Sean M. O’Brien, General Secretary-Treasurer Fred Zuckerman, and the Teamsters Airline Division will be hosting an important call with United Airlines technicians. During this call, We will outline our goals for negotiating a strong new Teamsters contract at United Airlines, focusing on critical issues including compensation, health care, safety, and progression. 

Join us for the United Airlines Contract Campaign Kickoff Call happening this Tuesday, June 18th!

Teamsters General President Sean M. O’Brien, General Secretary-Treasurer Fred Zuckerman, and the Teamsters Airline Division will be hosting an important call with United Airlines technicians. During this call, We will outline our goals for negotiating a strong new Teamsters contract at United Airlines, focusing on critical issues including compensation, health care, safety, and progression. 

Event Details:

Date: Tuesday, June 18Time: 4:30 PM ET / 3:30 PM CT / 2:30 PM MT / 1:30 PM PTHow to Register: click here.

We look forward to your participation and to working together to secure a strong contract for United Airlines technicians. 

In Solidarity, 

The Teamsters Airline Division

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Special Contract Proposal Meetings 

Please join us for special contract proposal meetings at Local 856 on the Thursday, June 27 and 7:30 a.m., 11 a.m or 3 p.m.  These meetings will summarize the process the SFO committee went through gathering contract proposals and where we stand today. Everyone will have an opportunity to provide feedback and present additional proposals.  

United Airlines Teamsters SFO
Special Contract Proposal Meetings
 

Thursday, June 27, 2024

7:30 a.m.

-&-

11:00 a.m.

-&-

3:00 p.m. 

Teamsters Local 856

453 San Mateo Ave.

San Bruno, CA

Please join us for special contract proposal meetings at Local 856 on the above date and times.  These meetings will summarize the process the SFO committee went through gathering contract proposals and where we stand today. Everyone will have an opportunity to provide feedback and present additional proposals.  

 

Submit Additional Proposals

Please click the link below to access our contract proposal form. You may complete the form and bring it to one of the above meetings, or return it to Business Agent Javier Lectora or Business Agent Mark DesAngles. 

 

2024 United Airlines Contract Proposal Form

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UAL Mechanics Safety Dispatch

The FAA has recently begun Compliance Action interviews of our members who have been involved in alleged Non-Sole Source, Regulatory Non-Compliance issues. These interviews are a result of an FAA Inspector finding a Regulatory Non-Compliance instance not associated with the TSAP program. Finding a violation outside of the TSAP program is known as Non-Sole Source.

Brothers and Sisters,

The FAA has recently begun Compliance Action interviews of our members who have been involved in alleged Non-Sole Source, Regulatory Non-Compliance issues. These interviews are a result of an FAA Inspector finding a Regulatory Non-Compliance instance not associated with the TSAP program. Finding a violation outside of the TSAP program is known as Non-Sole Source. Compliance Action interviews generally result in an administrative letter being placed in your file, these letters are not Legal Enforcement letters, they are administrative and will stay in your file for two years. They are instructive in nature and are designed to identify and correct Regulatory Non-Compliance issues without taking Legal Enforcement Action against your license. I am attaching the brochure that you will receive from the FAA should you be notified of a Compliance Action interview. It explains your rights and the interview process. A Compliance Action interview does not preclude you from accessing the TSAP program. Upon notification of an interview, you should immediately file a TSAP if you have not already done so. Contact your Business Agent or Shop Steward and advise them of the time, date, and any specifics the FAA provides regarding the interview. Always ask the FAA if you can have a Shop Steward present as a witness during the interview and take detailed notes. We suggest that you cooperate fully during the interview. If the FAA indicates that the investigation will result in Legal Enforcement, notify your Business Agent immediately, and set up a meeting with our License Protection Attorney. 

Your safety on the job is paramount. We want you to return home from your shift the same way you came in. We want you to protect your license by following the paperwork. If you do make a mistake or find a hazard or paperwork issue, please file a TSAP as soon as you become aware and let your Shop Steward or Business agent know. 

Fraternally,

Chris Moore

Safety Coordinator, Airline Division

International Brotherhood of Teamsters



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Continued RLA Section 6 Contract Negotiations

As described in our last update, we’ve reached out to the company to secure new meeting dates for negotiations. At this point, they have not provided any dates that they are available. This refusal by the company to meet to resume negotiations is unacceptable, and we are reminding the company that Section 2, First of the Railway Labor Act requires the company to meet with us in order to make and maintain agreements. If the company continues to refuse to meet with us in the near future, the Teamsters are prepared to take all legal options, including but not limited to engaging in self-help, to compel the company to comply with its obligation to bargain in good faith. We will keep you updated as new developments occur.

April 23, 2024

Re: Continued RLA Section 6 Contract Negotiations

Dear Brothers and Sisters,

As described in our last update, we’ve reached out to the company to secure new meeting dates for negotiations. At this point, they have not provided any dates that they are available. This refusal by the company to meet to resume negotiations is unacceptable, and we are reminding the company that Section 2, First of the Railway Labor Act requires the company to meet with us in order to make and maintain agreements. If the company continues to refuse to meet with us in the near future, the Teamsters are prepared to take all legal options, including but not limited to engaging in self-help, to compel the company to comply with its obligation to bargain in good faith. We will keep you updated as new developments occur.

To be clear, we are prepared, as we’ve reported over the entirety of last year, to present our contract opener to the company. We will meet anytime, anywhere to bargain an Agreement that you can be proud of, and we will use every legal resource at our disposal to achieve that end.

In solidarity,

Vinny Graziano

Teamsters Airline Division

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Safety Reminder

The explosive growth at United resulted in the addition of over two thousand technicians in a brief period of time. This scenario has resulted in many of our new technicians being thrust into situations that put them in the unenviable position of having to perform tasks that they are unfamiliar with and with no experienced technicians to guide them. As dedicated technicians, you provide a safe and on-time product and the expanded fleet and workload have put a strain on all of you. For that reason, I am asking that we all take a step back and look at how we perform our work. It is our responsibility to make sure that we are following the policies and procedures. Read and follow the paperwork! Never sign for work that you have not performed without first verifying that the job has been completed properly. Make sure to follow the LOTO procedures on every job. Ensure that you have adequate manpower when moving aircraft. When using equipment around the aircraft please follow established company procedures and make sure to use the proper PPE.

4/22/24

Brothers and Sisters,

The explosive growth at United resulted in the addition of over two thousand technicians in a brief period of time. This scenario has resulted in many of our new technicians being thrust into situations that put them in the unenviable position of having to perform tasks that they are unfamiliar with and with no experienced technicians to guide them. As dedicated technicians, you provide a safe and on-time product and the expanded fleet and workload have put a strain on all of you. For that reason, I am asking that we all take a step back and look at how we perform our work. It is our responsibility to make sure that we are following the policies and procedures. Read and follow the paperwork! Never sign for work that you have not performed without first verifying that the job has been completed properly. Make sure to follow the LOTO procedures on every job. Ensure that you have adequate manpower when moving aircraft. When using equipment around the aircraft please follow established company procedures and make sure to use the proper PPE. 

If you run into complications that will impact your ability to perform your job safely, or impact ETR, whether it is parts, process or equipment advise your lead or supervisor immediately and work toward a solution. 

Your safety on the job is paramount. We want you to return home from your shift the same way you came in. We want you to protect your license by following the paperwork. If you do make a mistake or find a hazard or paperwork issue, please file a TSAP as soon as you become aware and let your Shop Steward or Business agent know. 

Fraternally, 

Chris Moore

Safety Coordinator, Airline Division

 

 

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Negotiations Update

The members have spoken and the offer from the company was rejected. We will reach out to the company to secure dates for future bargaining. Further details will be shared when dates are secured. Thank you for your participation in this ratification process.

Negotiation Committee Members:

Mitch Hunt - DEN
Dave Mahood - EWR
Blake Silverstein - IAD
Dexter Thomas - IAH
Scott Stoddart - LAX
Mike Blomquist - MCO
Mike Pecoraro - ORD
Joseph Prisco - SFO
John Laurin - SFO

Dear Brothers and Sisters,

The members have spoken and the offer from the company was rejected. We will reach out to the company to secure dates for future bargaining. Further details will be shared when dates are secured. Thank you for your participation in this ratification process.

In solidarity, 

Vinny Graziano
Teamsters Airline Division

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Tentative Agreement Vote Tally

A conference call has been set up for April 17 at 10 a.m. Pacific Time to listen to the vote tally. United Airlines Teamsters are encouraged to call in. Dial-in information is listed below:

A conference call has been set up for April 17 at 10 a.m. Pacific Time to listen to the vote tally. United Airlines Teamsters are encouraged to call in. Dial-in information is listed below:

 DIAL-IN NUMBER- 844-291-6355

ACCESS CODE – 920959

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Foreign Repair Testing Comments

The International Brotherhood of Teamsters (IBT) is pleased to provide comments to the Federal Aviation Administration’s (FAA) Notice of Proposed Rulemaking (NPRM) entitled Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside of the United States. The Teamsters are proud to represent tens of thousands of members in the aviation industry who ensure, and rely on, the safety of aircraft and of our National Airspace System. This includes pilots and flight attendants for whom planes are their workplaces, and demand that aircraft be maintained safely, regardless of where the maintenance is performed. Important to this rulemaking, this also includes the world’s most highly skilled maintenance technicians, who maintain aircraft across the nation and whose work is increasingly threatened by carriers’ outsourcing schemes which place profit above safety.

The International Brotherhood of Teamsters

Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside of the United States

[Docket No. FAA-2012-1058 Notice No. 24-05]

Federal Aviation Administration

U.S. Department of Transportation

April 5, 2024

Prepared by:

Cole Scandaglia, Senior Legislative

Representative and Policy Advisor

 

The International Brotherhood of Teamsters (IBT) is pleased to provide comments to the Federal Aviation Administration’s (FAA) Notice of Proposed Rulemaking (NPRM) entitled Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside of the United States. The Teamsters are proud to represent tens of thousands of members in the aviation industry who ensure, and rely on, the safety of aircraft and of our National Airspace System. This includes pilots and flight attendants for whom planes are their workplaces, and demand that aircraft be maintained safely, regardless of where the maintenance is performed. Important to this rulemaking, this also includes the world’s most highly skilled maintenance technicians, who maintain aircraft across the nation and whose work is increasingly threatened by carriers’ outsourcing schemes which place profit above safety.

 

Through this NPRM, the FAA proposes to require certificated repair stations located outside the territory of the United States whose employees perform safety-sensitive maintenance functions on certain air carrier aircraft to obtain and implement a drug and alcohol testing program. The Teamsters support this rulemaking in the strongest possible terms and urge the expeditious adoption of a final rulemaking.

 

Currently, employees of part 145 repair stations located outside the territory of the United States and who perform safety-sensitive maintenance functions on part 121 air carrier aircraft are not subject to the Department of Transportation’s drug and alcohol testing program. This deficiency is one of a number of safety oversight requirements that only attach to maintenance performed domestically. In total, the amount of heavy maintenance being performed at foreign stations has increased dramatically over the last 30 years as has FAA’s certification of foreign stations, which now stands at above 900 facilities.

 

The Teamsters have long argued for a single level of safety, and that the current “two-tiered’ system of regulation is inappropriate and fundamentally unsafe. Further, the ability of air carriers to evade regulatory responsibilities and the attendant costs of those responsibilities has undoubtedly played a role in the continued outsourcing of heavy maintenance. Thankfully, Congress has agreed, mandating the FAA promulgate rulemaking requiring drug and alcohol testing programs for these part 145 employees – in 2012 via section 308 of the FAA Modernization and Reform Act, and again in 2016 via section 2112 of the FAA Extension, Safety, and Security Act of 2016, when FAA failed to act following the 2012 directive. We have been deeply disappointed with the failure of the FAA to respond to original the Congressional mandate for over a decade.

 

However, with the publication of this NPRM, FAA is finally taking steps towards satisfying both Congressional intent and the interests of our members. We strongly commend the agency, the Department, and the Biden Administration for finally acting to better ensure safety in our skies and at our workplaces.

 

Application of Part 40

As FAA discusses, 49 USC 44733(d) requires covered employees to be “subject to an alcohol and controlled substances testing program determined acceptable by the Administrator and consistent with the applicable laws of the country in which the repair station is located”. Through this NPRM, FAA has correctly defined an “acceptable” testing program by simply applying existing part 120 and part 40 standards, stating that the agency “has long held that the standards… are acceptable drug and alcohol testing programs for the aforementioned safety-sensitive functions”. The Teamsters agree. It would be inappropriate and inconsistent with Congressional intent to only apply these sections in part, given the wide and consistent application of the regulations to DOT-regulated safety sensitive aviation workers, and transportation workers more broadly. Further, the Teamsters would strongly oppose the creation of a patchwork system in which foreign entities could be invited to propose “equivalent” testing programs to satisfy the statutory requirement. DOT’s reliance on existing part 40 standards to address the use of alcohol and controlled substances for domestic covered employees clearly necessitates an identical application for any further employees entered into its testing programs. The FAA should maintain this determination and application in its final rule.

 

Exemptions and Waivers to Drug and Alcohol Program Requirements

Under Section 120.9 the FAA proposes to create an exemption process by which a entity can request an exemption if they demonstrate that “specific requirements of the subpart are inconsistent with the laws of the country where the repair station is located” and provide “a description of the alternative means that will be used to achieve the objectives of the provision that is the subject of the waiver or, if applicable, a justification of why it would be impossible to achieve the objectives of the provision in any way”.

In the event the rule includes an exemption process, the Teamsters strongly support a narrowly tailored process and commend the FAA for proposing such a mechanism. The provision of exemptions predicated on other factors like revenue or workforce size would be clearly inappropriate in the pursuit of one level of safety across maintenance providers and contradict Congressional intent.

 

In the NPRM, FAA requires the submission of six elements which must be included in a waiver request, including:

(1) Information about your organization, including your name and mailing address and, if you wish, other contact information such as a fax number, telephone number, or email address;

(2) The specific section or sections of this part from which you seek a waiver;

(3) The reasons why granting the waiver would not adversely affect the prevention of accidents and injuries resulting from the use of prohibited drugs or the misuse of alcohol by employees;

(4) A copy of the law that is inconsistent with the provision(s) of this part from which a waiver is sought;

(5) An explanation of how the law is inconsistent with the provision(s) of this part from which a waiver is sought, and;

(6) A description of the alternative means that will be used to achieve the objectives of the provision that is the subject of the waiver or, if applicable, a justification of why it would be impossible to achieve the objectives of the provision in any way.

Taken together, these elements provide an adequately high bar for the granting of an exemption request. In particular, we urge FAA to adopt a negative presumption under element #3 – all exemption requests should be considered under the assumption that a waiver will adversely affect accidents and injuries unless categorically proven otherwise.

 

In regard to element #4 and #5, we urge the FAA to adopt a narrow interpretation of “inconsistency” and require that the provider cite laws that would explicitly be inconsistent with the rule’s mandate. The FAA must not determine inconsistency based on speculative interpretations of laws with hypothetical or tangential relevance – the provider must prove that the law, in plain reading, prohibits the implementation of a section(s) of the final rule. In implementing element #6, the FAA should consider alternative measures where appropriate which uphold the core requirements of the rule. If the FAA believes that countries’ laws on indirect but adjacent issues such as data privacy are inconsistent, the Teamsters encourage the FAA to mandate tailored requirements which still retain Part 40 compliant random drug and alcohol testing regimes while identifying means of compliance to deal with specific attendant issues.

 

In reviewing comments filed to the docket before the filing deadline, we observe that several commenters suggest that national laws which prohibit drug consumption are adequate substitutes for the testing requirement in this rule, and facilities in those nations should be exempted under 120.9. Given that the DOT testing panel also covers substances which are also illicit in the United States, as well as substances which are illicit barring a legitimate prescription, it is unclear why these commenters believe this presents an inconsistency, and FAA should not view them as such.

 

Impact on International Agreements

In the discussion of the NPRM, FAA notes that opposing commenters to the ANPRM argued that the FAA does not have the authority to promulgate the rule and cannot impose regulations on persons outside the territory of the U.S. where those regulations conflict with the laws of sovereign nations. We believe that FAA has satisfied this concern via the proposed exemption process.

 

FAA also notes that commenters opposed unilateral application of drug and alcohol testing regulations pointed to the Bilateral Aviation Safety Agreements (BASA) that the U.S. is a party to and expressed that the rulemaking violates components of existing BASAs. FAA acknowledges that “to the extent that BASA provisions concerning notice and consultation are applicable to the proposed regulations, the FAA intends to follow those provision” and critically that “commenters have not identified any specific BASAs that are in conflict with the statutory requirements this proposed rule would implement, nor is FAA aware of any at this time”.

 

We strongly agree with the FAA and commend its conclusion in this regard. Opponents of this proposal have long lodged empty complaints of impacts on international agreements in the hope of derailing efforts to conduct random drug and alcohol testing and foreign providers, while failing provide convincing evidence of any such conflicts. There has been no evidence presented which demonstrates that our international obligations are inherently in conflict with this proposal, and FAA should not permit these concerns to impact its rulemaking.

 

Part 121 Directly Employed

FAA states that “in addition, the FAA is considering how best to deter drug and alcohol misuse for any aircraft mechanic working on a part 121 aircraft regardless of how that mechanic is employed. Therefore, the FAA seeks comments as to whether the testing requirements in this proposed rule should be extended to foreign aircraft mechanics working directly for part 121 carriers”.

 

While we understand that the coverage of the rule for foreign aircraft mechanics working directly for part 121 carriers is not Congressionally directed, we encourage the FAA to adopt the testing requirement for these mechanics. From the Teamsters perspective, we note that in June of 2023, United Airlines, whose technicians we represent, opened its first foreign maintenance hangar at Rio de Janeiro International Airport in Brazil, where it directly employs mechanics. In part, the facility has absorbed maintenance work previously being performed by part 145 contract facilities in China. It is our understanding that other part 121 carriers have or are considering similar operations.

 

Given that the rule intends to eliminate an aviation maintenance ecosystem in which the ability to uphold single level of safety is predicated on the geographic location of the maintenance facility, it holds logically that all aircraft mechanics working on part 121 aircraft should be captured by this rulemaking. In the event that FAA does not adopt this requirement, the rule may create a perverse incentive to simply move maintenance from a contracted part 145 facility to an in-house facility where the airline can evade the regulatory costs associated with compliance.

 

Alternatives

The FAA proposes two alternatives to the NPRM. First, maintaining status quo, and second that the FAA would work through the International Civil Aviation Organization to create an international standard for drug and alcohol testing of maintenance personnel at repair stations. The FAA correctly identifies that both alternatives violate the Congressional mandate. The Teamsters concur, and strongly oppose both alternative proposals.

 

Conclusion

The Teamsters applaud the FAA, DOT, and the Biden Administration in the strongest terms for the publication of this long overdue and historic rulemaking. Encompassing the recommended changes discussed above, we urge the FAA to move expeditiously to promulgate a final rule which will promote a single level of safety in aviation maintenance and remove incentives to outsource maintenance rooted in the cost savings of regulatory avoidance. We look forward to working with the FAA on implementation, and on other matters impacting Teamsters Airline Division members.

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Mechanics' Dispatch Nicole Casey Mechanics' Dispatch Nicole Casey

Ratification Update

Instructions on how to vote electronically, including Voting Credentials, on the above-referenced Tentative Agreement will be mailed to members today, Wednesday, March 27, 2024.  

 Please post the attached “Notice of Referendum” at the Local Union Hall, on all worksite bulletin boards, and any other appropriate places.

BallotPoint Election Services has been contracted to administer this election.

Brothers and Sisters,

Below is the notice of referendum on the TA. 

MEMORANDUM

TO: Local Unions 19, 25, 104, 210, 455, 769, 781, 856, 964, and 986

FROM: Robert Fisher, Interim Director

Teamsters Airline Division 

DATE: March 27, 2024

 

RE: United Airlines Technicians and Related Tentative Agreement

 

Instructions on how to vote electronically, including Voting Credentials, on the above-referenced Tentative Agreement will be mailed to members today, Wednesday, March 27, 2024.  

 Please post the attached “Notice of Referendum” at the Local Union Hall, on all worksite bulletin boards, and any other appropriate places.

BallotPoint Election Services has been contracted to administer this election.

NEW or REPLACEMENT VOTING CREDENTIAL:

Beginning 11:00 A.M. (Eastern Time) on Monday, April 8, 2024, BallotPoint will open the “United Airlines Technicians and Related Re-Credentialing System” for the Locals to request new or re-credential voting credentials and instructions for individual members.  The Local will handle any requests from members, confirm that the individual is an eligible voter, and credential them using the “United Airlines Re-credentialing System”.  

Requests for new or replacement voting credentials and instructions will be accepted using the web platform through Tuesday, April 16, 2024.

 

To be counted, members must vote by 11:00 A.M. (Eastern Time) on Wednesday, April 17, 2024.  Electronic ballots will be tallied by BallotPoint on Wednesday, April 17, 2024, at 1:00 P.M. (Eastern Time).

 

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Teamsters 856/986 SFO Members:


If you do not receive your voting credentials by Monday, April 8, 8 a.m., Pacific Time, please contact the following:

Local 856 Members -- (Last Name A-LED)
Contact Marta Pacheco at 650 266 7704 or MPacheco@ibt856.org

Local 986 Members -- (Last Name LEE-Z)
Contact Adriana Sanchez at adriana@teamsters986.org

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