Jeremy Ferguson, President, SMART Transportation Division and Dennis Pierce, President, Brotherhood of Locomotive Engineers and Trainmen, Teamsters Rail Conference, on move announced by the nation’s largest railroads to further abuse shippers and gridlock the supply chain in order to extort a contract settlement from rail unions:

CLEVELAND — Late on Friday, September 9, the nation’s largest railroads began warning major shippers that they are declaring an embargo on certain types of new shipments five days in advance of the end of the federally mandated cooling-off period at 12:00 AM EDT September 16. They further advised that all rail shippers could be blocked from making any rail shipments well in advance of next Friday’s deadline for a lockout or strike. This completely unnecessary attack on rail shippers by these highly profitable Class I railroads is no more than corporate extortion.

Our Unions remain at the bargaining table and have given the rail carriers a proposal that we would be willing to submit to our members for ratification, but it is the rail carriers that refuse to reach an acceptable agreement. In fact, it was abundantly clear from our negotiations over the past few days that the railroads show no intentions of reaching an agreement with our Unions, but they cannot legally lock out our members until the end of the cooling-off period. Instead, they are locking out their customers beginning on Monday and further harming the supply chain in an effort to provoke congressional action.

The railroads are using shippers, consumers, and the supply chain of our nation as pawns in an effort to get our Unions to cave into their contract demands knowing that our members would never accept them. Our Unions will not cave into these scare tactics, and Congress must not cave into what can only be described as corporate terrorism.

Rather than gridlock the supply chain by denying shipments and potentially locking our members out next Friday, the railroads should work towards a fair settlement that our members, their employees, would ratify. For that to happen, we must make improvements to the working conditions that have been on the bargaining table since negotiations began. Penalizing engineers and conductors for getting sick or going to a doctor’s visit with termination must be stopped as part of this contract settlement. Let us repeat that, our members are being terminated for getting sick or for attending routine medical visits as we crawl our way out of a worldwide pandemic.

No working-class American should be treated with this level of harassment in the workplace for simply becoming ill or going to a routine medical visit. Sadly, the Presidential Emergency Board recommendation got it wrong on this issue. As we have said from the day that they were implemented, these policies are destroying the lives of our members, who are the backbone of the railroad industry.

These employment policies have forced thousands of employees out of the industry and make it all but impossible to recruit new workers. With understaffed operations, these railroads abuse their best customers by refusing to provide deliveries consistent with their legal obligations. These self-appointed titans of industry complain constantly about government regulation and interference — except now when it comes to breaking the backs of their employees. It’s time for the federal government to tell the CEO’s who are running the nation’s railroads into the ground that enough is enough. Congress should stay out of the rail dispute and tell the railroads to do what other business leaders do — sit down and bargain a contract that your employees will accept.

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The SMART Transportation Division is comprised of approximately 125,000 active and retired members of the former United Transportation Union, who work in a variety of crafts in the transportation industry.

The Brotherhood of Locomotive Engineers and Trainmen represents nearly 57,000 professional locomotive engineers and trainmen throughout the United States. The BLET is the founding member of the Rail Conference, International Brotherhood of Teamsters.

The following is a joint statement from SMART TD President Jeremy Ferguson and BLET President Dennis Pierce:

CLEVELAND, Ohio, August 27, 2022 — On Monday, August 22, the SMART TD and BLET, along with the other remaining United Rail Unions, met with the Rail Carriers via Zoom to determine if PEB 250’s recommendations could serve as a basis for a tentative agreement. In-person meetings were then held on Thursday and Friday in Chicago, Illinois. Unfortunately, the meetings did not result in any tentative agreement language that operating crafts would accept, or that could be presented to our members for ratification.

Although no tentative agreement was reached this week, SMART TD and BLET remain committed to negotiating over issues that are most important to our members, including wages, quality of life, and attendance as well as voluntary time off issues. In addition to those issues, we are seeking clarification on certain aspects of PEB 250’s recommendations concerning health and welfare.

We will continue to keep our members updated as the cooling-off period countdown clock to 12:01 a.m. (eastern time) on September 16th approaches. Our goal is and always has been to reach a voluntary agreement that is worthy of our membership’s consideration. As we approach the final stages of the steps of the Railway Labor Act, we appreciate our members’ continued support. We have made it abundantly clear to the Carriers that we are prepared and willing to exercise every legal option available to us, to achieve the compensation and working conditions that we and our families rightfully expect and deserve.

Today, July 24, 2022, the United Rail Unions, who are bargaining as part of the Coordinated Bargaining Coalition and the Brotherhood of Maintenance of Way/SMART Mechanical Coalition, and the Carriers represented by the National Carriers Conference Committee (NCCC), began their presentations before Presidential Emergency Board (PEB) No. 250, which was appointed by President Biden on July 18, 2022.

The hearings are scheduled to continue through Thursday, July 28, with Friday reserved for facilitation meetings with the parties and the PEB. Following the hearings, the PEB will issue recommendations for settlement of the national agreement dispute. A second thirty-day cooling-off period will begin when those recommendations are issued, which should occur on or before August 15.

A summary of the proposals being advanced by the United Rail Unions can be found by reading this PDF, and a summary of the proposals being advanced by the NCCC can be found by reading this PDF.

The Unions’ proposals include a 5-year wage proposal seeking an increase of 31.2% when compounded, while the carriers are asking the PEB to recommend 17% compounded over 5 years.

On the issue of healthcare, the Unions are seeking status quo for employee cost sharing, and increases in autism and hearing benefits, which are long overdue. Despite our members being deemed “essential” and keeping the Nation’s rail system operating during the pandemic, the Carriers, just as they did during negotiations, have the audacity to ask the PEB to recommend massive healthcare concessions in both the form of drastic increases in employee costs and decreases in certain benefits, along with healthcare plan changes that only serve to further increase the record profits they are already reaping. In addition to wages and healthcare, the Unions are also seeking to create a national sick leave policy that would provide employees with 15 protected sick leave days and add three additional holidays, along with various craft-specific work rule proposals.

As we have previously communicated, the United Rail Unions remain unified in their efforts to secure the best contract possible for our members. We will show this week that the Unions’ proposals are supported by current economic data and are more than warranted when compared to our memberships’ contribution to the record profits of the rail carriers.

Additional information will be provided as developments warrant. We appreciate your continuing support.

Read this statement in PDF form.

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The unions comprising the Coordinated Bargaining Coalition are: the American Train Dispatchers Association (ATDA); the Brotherhood of Locomotive Engineers and Trainmen / Teamsters Rail Conference (BLET); the Brotherhood of Railroad Signalmen (BRS); the International Association of Machinists (IAM); the International Brotherhood of Boilermakers (IBB); the National Conference of Firemen & Oilers/SEIU (NCFO); the International Brotherhood of Electrical Workers (IBEW); the Transport Workers Union of America (TWU); the Transportation Communications Union / IAM (TCU), including TCU’s Brotherhood Railway Carmen Division (BRC); and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART–TD).

The Brotherhood of Maintenance of Way Employes Division and SMART Mechanical Unions are also bargaining as a coalition.

Collectively, these Unions represent approximately 115,000 railroad workers covered by the various organizations’ national agreements, and comprise 100% of the workforce who will be impacted by this round of negotiations.

The United Rail Unions issued the following statement June 2, 2022:

The rail unions who are bargaining as part of the Coordinated Bargaining Coalition (CBC) and the Brotherhood of Maintenance of Way/SMART Mechanical Coalition concluded their second week of compulsory joint National Mediation Board-mediated negotiations with the National Carriers’ Conference Committee (NCCC) yesterday.

These joint mediated negotiations, under the direction of the NMB board members themselves, resulted from the unions’ request to be released from mediation after more than two years of bargaining with the major U.S. Class I railroads.

In spite of the unions’ best efforts to negotiate a fair agreement, the NCCC and the rail carriers that it represents still refuse to make a comprehensive settlement proposal that our members would even remotely entertain. In fact, the carriers continue to advance proposals that insult the hard-working union members who have carried our nation through the pandemic.

Although all of the involved unions would prefer to reach a voluntary agreement, it has become quite clear at this point that the rail carriers will not bargain in good faith to that end. For that reason, all of the involved rail unions are again requesting that the NMB put forth a proffer of arbitration to move our contract dispute through the remaining steps of the Railway Labor Act.

Additional information will be provided as developments warrant. We appreciate your continuing support.

View this release in PDF form.

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The unions comprising the Coordinated Bargaining Coalition are: the American Train Dispatchers Association (ATDA); the Brotherhood of Locomotive Engineers and Trainmen / Teamsters Rail Conference (BLET); the Brotherhood of Railroad Signalmen (BRS); the International Association of Machinists (IAM); the International Brotherhood of Boilermakers (IBB); the National Conference of Firemen & Oilers/SEIU (NCFO); the International Brotherhood of Electrical Workers (IBEW); the Transport Workers Union of America (TWU); the Transportation Communications Union / IAM (TCU), including TCU’s Brotherhood Railway Carmen Division (BRC); and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART–TD).

The Brotherhood of Maintenance of Way Employes Division (BMWED) and SMART Mechanical Division (SMART-MD) are also bargaining as a coalition.

Collectively, these unions represent approximately 140,000 railroad workers covered by the various organizations’ national agreements, and comprise 100% of the workforce who will be impacted by this round of negotiations.

While waiting for a response to our recent request to the National Mediation Board that a proffer of arbitration be issued by the Board to move our contract dispute to the next level, CBC unions participated in two additional days of mediated bargaining sessions with NCCC this week.

Once again, the nation’s class 1 rail carriers showed just how far removed they are from the realities that their employees and shippers are experiencing. Without regard for the beating that these rail carriers took in front of the Surface Transportation Board a week ago, and ignoring their continued record profit reports, the rail carriers continue to advance proposals at the bargaining table that they have previously been told are unacceptable to the CBC Unions and our members.

Due to the NCCC’s refusal to negotiate a fair agreement in good faith, all CBC Unions again request that the NMB proffer arbitration to the parties to stop the endless delays by the rail carriers.

As we advised in January and April, we had hoped that the involvement of the NMB would cause the industry to refocus on addressing the legitimate needs of the men and women whose labor generates their positive financial returns. That has not happened, and there is no indication that it will without allowing the remaining steps of the Railway Labor Act to play out to compel a favorable settlement.

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The unions comprising the Coordinated Bargaining Coalition are: the American Train Dispatchers Association (ATDA); the Brotherhood of Locomotive Engineers and Trainmen / Teamsters Rail Conference (BLET); the Brotherhood of Railroad Signalmen (BRS); the International Association of Machinists (IAM); the International Brotherhood of Boilermakers (IBB); the National Conference of Firemen & Oilers/SEIU (NCFO); the International Brotherhood of Electrical Workers (IBEW); the Transport Workers Union of America (TWU); the Transportation Communications Union / IAM (TCU), including TCU’s Brotherhood Railway Carmen Division (BRC); and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART–TD). Collectively, the CBC unions represent more than 105,000 railroad workers covered by the various organizations’ national agreements, and comprise over 80% of the workforce who will be impacted by this round of negotiations.

Follow this link for a pdf of this release.

The Coordinated Bargaining Coalition (CBC) released the following statement on January 24, 2022:

After more than two years of bargaining with the major U.S. Class 1 railroads, discussions completely stalled last week. Accordingly, pursuant to the terms and conditions of the Railway Labor Act, top leaders of 10 rail unions applied to the National Mediation Board (NMB) for the assignment of a federal mediator to assist in our negotiations.

The Carriers represented by the National Carriers’ Conference Committee (NCCC) simply are not bargaining in good faith. This development is very frustrating, as the Unions in the Coordinated Bargaining Coalition have been at the negotiating table since November 2019. Throughout that time, despite our best efforts, the carriers have not made a comprehensive settlement proposal that we believe our members would even remotely entertain. In fact, the Carriers’ latest proposal is worse than bad faith; it is insulting.

After carrying our nation through the pandemic, and as the carriers have posted record-breaking profit margins due to their implementation of so-called “Precision Scheduled Railroading” practices, our members have earned, and rightfully expect, a substantial contract settlement that recognizes the sacrifices they and their families make each day. Instead, the Carriers continue to push proposals that fail to even catch up to the cost of living. From the beginning of this round of negotiations, the CBC has adamantly refused to accept any type of concessionary agreement. Instead, the railroads continue to demand extreme changes to our members’ current benefits and attempt to unilaterally impose work rule changes that would further erode our members’ already-taxed standard of living.

We anticipate that the involvement of the NMB will cause the industry to refocus on addressing the legitimate needs of the men and women whose labor generates their positive financial returns. In an effort to bring all affected members up to speed, the CBC’s latest proposal can be found at:

CBC bargaining proposal (SMART-TD)

Additional information will be provided as developments warrant. We appreciate your continuing support, and we look forward to working with the NMB to reach a settlement that we can be proud of.

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The unions comprising the Coordinated Bargaining Coalition are: the American Train Dispatchers Association (ATDA); the Brotherhood of Locomotive Engineers and Trainmen / Teamsters Rail Conference (BLET); the Brotherhood of Railroad Signalmen (BRS); the International Association of Machinists (IAM); the International Brotherhood of Boilermakers (IBB); the National Conference of Firemen & Oilers/SEIU (NCFO); the International Brotherhood of Electrical Workers (IBEW); the Transport Workers Union of America (TWU); the Transportation Communications Union / IAM (TCU), including TCU’s Brotherhood Railway Carmen Division (BRC); and the Transportation Division of the International Association of Sheet Metal, Air, Rail, and Transportation Workers (SMART–TD).
Collectively, the CBC unions represent more than 105,000 railroad workers covered by the various organizations’ national agreements, and comprise over 80% of the workforce who will be impacted by this round of negotiations.

Read this release in PDF form.

Washington, D.C. (Aug. 7, 2020) — On August 5, 2020, 12 rail unions whose members and their families are covered by the NRC/UTU Plan and the Railroad Employees National Health and Welfare Plan filed suit against the nation’s Class I railroad carriers in the United States District Court for the District of Columbia.
The suit asks the court to force the carriers to bargain in good faith with the unions over mandatory subjects of bargaining. The involved issues have been the subject of collective bargaining for decades and are in fact part of the carriers’ bargaining notices served on November 1, 2019, pursuant to Section 6 of the Railway Labor Act (RLA). At issue are carrier attempts to restrict access to certain medications and to forcibly reconfigure health care networks.
The unions are: the American Train Dispatchers Association; the Brotherhood of Locomotive Engineers and Trainmen; the Brotherhood of Maintenance of Way Employes; the Brotherhood of Railroad Signalmen; the International Association of Machinists and Aerospace Workers; the International Association of Sheet Metal, Air, Rail and Transportation Workers, Mechanical Division; the International Association of Sheet Metal, Air, Rail and Transportation Workers, Transportation Division; the International Brotherhood of Boilermakers; the International Brotherhood of Electrical Workers; the National Conference of Fireman & Oilers District, Local 32BJ, SEIU; the Transportation Communications Union/IAM; and the Transport Workers Union.
The rail carriers are: BNSF Railway Company; Kansas City Southern Railway Company; CSX Transportation; Grand Trunk Western Railroad Company; Norfolk Southern Railway Company; Soo Line Railway Company; and Union Pacific Railway Company. Also named in the suit is the National Railway Labor Conference (NRLC), whose National Carriers’ Conference Committee (NCCC) is the designated bargaining agent of the railroads.
The unions have asked the court to:

  • issue a declaratory judgment that the carriers are obligated to bargain in good faith with the unions on proposed health and welfare changes in accordance with the collective bargaining procedures outlined under the RLA;
  • issue a declaratory judgment that health and welfare plan design changes are a mandatory subject of collective bargaining pursuant to the RLA;
  • issue a declaratory judgment that the NRLC may not force plan design changes upon its employees without the agreement of the unions, to be achieved through the mandatory dispute resolution process of the RLA;
  • issue an order enjoining the NRLC from trying to force these health and welfare changes via arbitration rather than addressing them in collective bargaining; and
  • issue an order requiring the NRLC to engage in good faith negotiations with the unions over their proposed health and welfare changes through the RLA’s major dispute resolution procedures.

The chief executives of the 12 unions issued the following statement concerning the lawsuit:
The railroads’ attempt to evade their legal obligation to bargain on these issues of great importance to our members has left us with no choice but to enforce these legal rights in court. If implemented without successfully negotiated application, the carriers’ proposals could be extremely harmful to our members and their families. Even more outrageous, the process they are attempting to impose would allow rail carriers to reduce employees’ access to medicines and doctors in the middle of a pandemic. When they should be rewarding the contributions of their essential employees with hazard pay, the rail carriers instead attempt to reduce medical benefits when they are needed most. Events like these are why railroad managers were labeled as “Robber Barons” over a century ago; their actions today are proof positive that the label still applies. Unfortunately for working class Americans, this is the way of many corporations across the country in Donald Trump’s America; essential employees are treated as expendable employees. We will not stand idly by while management attacks the core legal rights our members enjoy.
Updates will be provided as developments warrant.
Read this release in PDF form.
Read the case filing. (PDF)

The SMART-Transportation Division has reached out to the chairman of the National Carriers’ Conference Committee (NCCC) seeking answers as to what the rail industry’s response would be to the spread of the COVID-19 respiratory illness, especially when considering the strict attendance policies of carriers.

This is the first of what will be a number of outreach efforts by the union to transportation stakeholders to protect the health and jobs of SMART-TD members as the illness, commonly known as the coronavirus, spreads.

At present, the Centers of Disease Control and Prevention (CDC) and other reputable sources report 158 patients being treated in 17 states for the disease, which starts out with respiratory symptoms such as coughing, sneezing, shortness of breath and/or fever. In order to prevent the virus’s spread, CDC has recommended that affected workers remain at home.

“As we have discussed on numerous occasions, this philosophy is incongruent with many of the rail carriers’ current attendance policies, which can be described as unforgiving, at best, for employees who miss work due to illness,” SMART-TD President Jeremy Ferguson wrote to the NCCC’s Brendan Branon.

Ferguson said that the communications efforts of the NRC/UTU Health and Welfare Plan Governing Committee in conjunction with the Railroad Employees’ National Health and Welfare Plan to inform, educate and help protect members from coronavirus could have a positive impact in stopping the spread of the virus among transportation workers.

However, he asked Branon to map out a more detailed response in cooperation with the governing committee to answer questions about the industry’s response to the virus going forward:

Do the carriers plan to adopt the CDC’s guidelines, specifically, the CDC’s Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19), as published on the CDC.gov website?

If the answer is yes, do the carriers plan to relax their current attendance policies for employees who miss work accordingly?

If the answer is no, then what are the carriers’ alternative plans or suggestions?

Do the carriers plan to relax their current attendance policies for employees who miss work as a result of a family member, or someone who resides in the same household, contracting coronavirus or showing such symptoms?

Do the carriers plan to relax their current attendance policies for employees who miss work because they determine that they should be tested for coronavirus?

What steps are the carriers taking, if any, to sanitize the workplace (including but not limited to equipment, company provided transportation and away-from-home lodging facilities, and other common areas such as offices and crew staging areas)?

COVID-19 is easily spread through respiratory droplets produced when an infected person coughs or sneezes, the CDC said. It also may be possible that a person can get COVID-19 by touching a surface or object that has the virus on it and then touching their own mouth, nose, or possibly their eyes, but this is not thought to be the main way the virus spreads, CDC said.

Additional outreach is planned by SMART-TD to the federal Department of Transportation, federal Health and Human Services Department, Federal Railroad Administration and the Association of American Railroads.

Read President Ferguson’s letter here.

NORTH OLMSTED, Ohio — The team negotiating the next National Rail Contract which will affect more than 40,000 SMART Transportation Division members has been finalized by the union’s leadership.
The team will be led by TD President Jeremy Ferguson with the assistance of Vice Presidents Brent Leonard; John J. Whitaker III; Chadrick Adams; Jamie C. Modesitt; Joe M. Lopez and David B. Wier Jr.
Also part of the team are five General Chairpersons, Mike LaPresta (BNSF); Gary Crest (Union Pacific); Roger Crawford (Illinois Central); Thomas Gholson (Norfolk Southern) and Christopher Bartz (yardmasters).
“We are prepared to do whatever it takes to get the most out of this round of national contract talks,” President Ferguson said. “It will be a challenging process and it could be quite contentious at times. However, we on the negotiating team are confident that as we work through the process we can achieve a positive result.”
The opening meeting of negotiations is scheduled for February 26 and 27 in Washington, D.C., with talks occurring in Cleveland, Omaha, Washington, D.C. and Chicago, as the year progresses.
SMART-TD is part of a Coordinated Bargaining Coalition that consists of it and nine other unions representing rail labor. Carriers BNSF, CSX, Kansas City Southern, Canadian National, Norfolk Southern, Soo Line, Union Pacific and numerous smaller railroads are represented by the National Carriers’ Conference Committee (NCCC) during negotiations.
In related news, CSXT will not be part of national bargaining, except for health and welfare issues. For the wages and rules portion, SMART-TD and CSX have agreed to begin bargaining locally on behalf of trainmen starting Jan. 21, 2020.
A joint meeting for the negotiating parties regarding facilitated bargaining is scheduled in Jacksonville, Fla., on January 22 and 23.
Additional meeting dates for these negotiations are currently under discussion, and a tentative schedule will be set in the near future. Neither the SMART-TD nor CSX have exchanged any proposals, and an agenda for the subjects to be discussed during these contract talks, which are separate from the National Rail Contract negotiations, has yet to be finalized.

On November 20, SMART Transportation Division (SMART-TD) General Chairpersons served on railroads represented by the National Carriers’ Conference Committee (NCCC) the SMART-TD’s intended amendments to agreements affecting rates of pay, rules and working conditions.

Such notices are required by Section 6 of the Railway Labor Act to reopen agreements. With this notice to the NCCC, and the NCCC’s earlier notice, the parties are set to begin the next round of bargaining.

While the national rail contract between the SMART-TD and railroads represented by the NCCC becomes amendable on January 1, 2020, the existing contract will remain in force until it is amended and ratified by SMART-TD members under the craft autonomy provisions of the SMART Constitution’s Article Twenty-One B (21B).

During this round of national contract negotiations with the SMART-TD, the NCCC will be the chief bargaining representative for matters pertaining to rates of pay, rules, and working conditions on behalf of BNSF, CSX, Kansas City Southern, Canadian National, Norfolk Southern, Soo Line, Union Pacific and numerous smaller railroads. Other railroads, including Amtrak, negotiate individually with the SMART-TD.
More than 40,000 SMART-TD members are affected by these national contract talks with the NCCC, and the resulting agreements frequently set patterns for other negotiated rail agreements.

SMART-TD President Jeremy R. Ferguson will lead the SMART-TD negotiating team. Members of the negotiating team will be selected early next month.

As noted in a press release on November 1, 2019, the SMART-TD will be joining with nine (9) other rail labor organizations who are participating in coordinated bargaining in this round of national negotiations.
Major elements of the SMART-TD’s Section 6 notices include:

  • Complete and permanent elimination of existing service scale (entry rates of pay);
  • A series of general wage increases, effective Jan. 1, 2020, and every six months thereafter;
  • Cost of living adjustments;
  • Shift- and weekend-differential pay;
  • Paid sick leave for all crafts, without censure or discipline;
  • Technology pay for daily required utilization of all in-cab and handheld reporting devices;
  • Additional rest opportunities and ability to miss work for family needs, quality of life, and doctor visits;
  • Additional training pay for all crafts, including compensation for qualification, re-qualification, and familiarization trips;
  • Carriers to give first-employment consideration to qualified conductors furloughed from other railroads;
  • Furloughed employees called back to work will be guaranteed a minimum of 60 days of work and pay;
  • Increased meal allowances;
  • Restrictions on transferring, consolidating, combining or centralizing yardmaster assignments;
  • Establishment of a formula for yardmaster extra boards; and
  • Enhanced benefits under the NRC/UTU Health and Welfare Plan and the Railroad Employees’ National Health and Welfare Plan (GA-23000).

SMART-TD Section 6 notices were developed beginning with recommendations offered by SMART-TD members. A committee of general chairpersons from the Association of General Chairpersons, District No. 1, reviewed and fine-tuned those suggestions, which were then approved by the entire Association of General Chairpersons, District 1.

To view the SMART-TD Section 6 notice, click here:
https://static.smart-union.org/worksite/PDFs/Agreements/2019+National+Rail+Contract/112019+–+Section+6+Notice.pdf

To view the carriers’ Section 6 notice, click here:
https://static.smart-union.org/worksite/PDFs/Agreements/2019+National+Rail+Contract/110119+–+NCCC+Section+6+Notice+-+SMART+TD.pdf