Thursday, September 19, 2013

All we ask... Just Do What's Right

September 19, 2013

Mr. Michael E. Sprayberry, P.E.
State Administrator for Maintenance Contracting
Florida Department of Transportation

Dear Mr. Sprayberry,

Thank you for your response to our email of August 26th. We trust you are the individual responsible for negotiating, letting and managing the movable bridge Contractual Services Agreements with ICA and ISS in Districts 1&7 and again please ask you for copies of the completed Agreements in force between yourselves and the above parties in the above districts. We would also appreciate an update on the current stage of negotiations, the expected date for signing the new Agreements and the vendors under consideration.

May we also ask that, while assigning all operation and management responsibilities and not retaining authority to direct employment or sub-contractor employment policies, your department does not overlook blatant exploitation nor ignore profiteering when brought to your attention.  We remain confident that equity is a fundamental principle embraced by our government, one that cannot be dismissed by the adroit crafting of contractual clauses and will remain the touchstone prevailing throughout our discussions and your negotiations.

Thank you for your concern and voicing your opinion on the McNamara-O’Hara Service Contract Act (SCA). We are bridge tenders not lawyers and are certainly not qualified to argue the appropriateness of the SCA in this instance. We do have reasonable confidence in the verbal opinion received from the Employment Standards Administration’s Wage and Hour Division (WHD). This obviously bears further scrutiny.

Your Contractual Service Agreement contains your right to audit (3H) and we ask you to use that right to uncover the details of the wage theft we suffer under our employment by ISS. Please discover and disclose the poisonous pie chart of misappropriation that has us living on the edge, while enriching middlemen empowered and emboldened by a lack of accountability.  This is the untenable situation we ask you to prevent in the future, both your department and we operators will benefit from the next Agreement specifying:

1). All contract employees to be retained under a “for cause” (not the current silence-instilling “at will”) relationship. This simple protection solves the previously disclosed conflict of interest. It opens the floodgates of direct reporting to your inspectors yielding a clearer picture of bridge condition with suggestions for safer, more efficient operations.

2). Operators to be indemnified against personal liability stemming from actions, errors or omissions incurred while performing our job. ICA indemnifies you, why not us?

3). Operators to be paid “no less than prevailing local wages and benefits” stopping the temptation for contractors and their sub-contractors to exploit us. While not formally enforceable, it’s the spirit of the Davis-Bacon Act we ask you to respect.

Your audit will prove the need for adding these protections to your next Agreement. They are in your power and best interest to give. They are demanded by fair play. We thank you for your consideration and look forward to your positive response.

The Organizing Committee

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