How to ​Collect Comments

Gathering Comments

Our top goal over the final three weeks is to gather thousands of comments on the IRAP rule to show the administration that IRAPs don’t belong in the construction industry. We know we can mobilize voters on this issue and that’s going to get the administration’s attention. This won’t be as simple as signing a form letter though – every comment must be unique.  It might be a challenge, but we have tried and tested ways to help ironworkers write unique, personal messages to our government.

LOCAL UNIONS MUST COLLECT WRITTEN COMMENTS. DO NOT REFER MEMBERS TO THE DEPARTMENT OF LABOR WEBSITE. 

Written comments should be submitted to mbechtel@iwintl.org. Local unions should focus on in-person written comments and may supplement their direct outreach by linking to saveironworkerapprenticeships.org on digital platforms. 

Comments can only be submitted once so please make sure to follow the instructions below.

 

Before You Begin

The Department of Labor (DOL) will respond best to electronic submissions, not mailed letters. Our union will work together to collect two types of comments:

  1. Local Unions: Written Comments. The best comments will come from face-to-face outreach by political and apprenticeship coordinators at the local level. Ironworkers may type or hand write comments, but each comment should be unique and focus on the individual ironworker’s personal story.The best places for locals to gather these comments are:
    1. When members visit the hall.
    2. At scheduled comment banks.
    3. During worksite visits.
  2. The Iron Workers (IW) International: Direct Online Comments. Ironworkers who follow links and codes on our magazine, mail or our website will be able to submit comments through saveironworkerapprenticeships.org.  These semi-customized comments are convenient for ironworkers on the go and will be solicited and tracked by the International. Locals are welcome to boost this site on social media.

All comments must include the DOL identifier “RIN 1205-AB85” at the top of the page.

 

How to Gather Comments at the Hall

Most locals see a steady trickle of ironworkers come by the hall to be dispatched to jobs and pay dues. Locals should recruit everyone who walks through the door to write a comment.

Have a business agent or dispatcher on hand at the hall who is familiar with IRAP messaging and keep comment forms and a sign-in sheet handy.  Pull members aside, in groups if possible, and run through a shortened version of the comment bank host script explaining the issue and how to write a comment.  Have the members write the comment there (do not have them take a blank form to be returned later) and make sure they fill out the sign-in sheet completely.

Scan all comments and sign in sheets at the end of the day and email them to the data lead Mitchel Bechtel at mbechtel@iwintl.org.  Do not delay and stockpile comments; even small quantities should be submitted daily.

How to Organize a Comment Bank

A comment bank is a gathering of ironworkers in which a political coordinator educates the group about IRAPs, helps them write comments, then sends those comments to the IW International for submission. The top goal of locals fighting IRAPs is to schedule comment banks through the comment period.  

The political coordinator should be lead organizer of a comment bank.  Officers, apprenticeship coordinators and instructors should help with recruitment and lead by example by participating in the bank.  Recruit activists who have already commented to help run the banks.

Putting together an event like this might seem intimidating if you haven’t done it before, but this is a tried and tested program that has been done for years.  Break the process down to three steps: recruitment, conducting the bank, and reporting. 

Step One: Recruitment

  • Your first step is to make sure people attend the comment bank!  Schedule banks to coincide with membership meeting, apprenticeship class, retiree breakfast, union picnic or any other social event your union hosts, and always have banks scheduled on multiple dates.  
  • Not everyone comes to meetings or class.  You will have to recruit the majority of your local directly by phone. Contact the political department for a list of members who have not commented yet.  Use this script for reference.
  • If someone has already commented on the rule, invite them to write to their U.S. Senator instead. Comments can only be submitted once!

  Step Two: Conducting the Comment Bank

  • Welcome folks who arrive and have them fill out our provided attendance sheet completely.  Don’t act discouraged if less show up than you anticipated.  
  • Start by explaining the issue and what we are doing about it.  Your goal in this part is to make members understand the threat posed by construction IRAPs, get them comfortable with the idea of commenting to the government, and make sure they understand how to write a good comment. This script is a good place to start. Plan for 20 minutes to run through your script and answer questions.
  • Next, have folks write their comments.  The comment form here helps folks get the required identification filled in. Plan for this part to take 40 minutes.  Walk through the room while they are writing and help people who are having trouble. Read over each comment when it is almost done and make suggestions if necessary.  Make sure each finished comment includes the DOL identifier (RIN 1205-AB85), participant's name, date, the state they live in, and signature and collect them when they are done. Congratulate the commenter on a job well done and tell them they have helped the union.

Step Three: Reporting to the International 

  • This step is just as important as the first two. If comments don't reach the Department of Labor and we don't track who sent them, all this work is for nothing.
  • Scan the written comments and the attendance sheet, then send both documents by email to the IRAP Campaign Data Lead Mitchell Bechtel at mbechtel@iwintl.org. Include the date of the comment bank, the local it took place at, and the names of whoever led it or assisted in the body of the email.
  • Send this data to the lead immediately following the comment bank. Our system updates daily. Save the original copies.

 

How to Gather Comments at a Jobsite

Many ironworkers seldom come to the hall, but we can reach most of them at work.  Writing comments at the construction site is not as convenient as at the hall but planning and cooperation can help get the job done.

Step One: IRAP Education

  • Pick a worksite in your jurisdiction and schedule a date to collect comments. Provide the stewards with IRAP message guidance and make sure they understand the issue.  
  • Have the stewards talk to members about IRAPs during breaks and meetings over two days before comment collection.They should use a shorter version of the comment bank host script to develop their rap.The steward should inform members what day the business agent will collect their comments.

 Step Two: Comment Collection

  • On the scheduled day, the political coordinator or business agent should meet members in the parking lot before their shift.  
  • The BA or PC should have comment forms and a sign in sheet. They should have members fill out their comments on the spot before beginning work. Do not have them take home forms at this point. Make sure every ironworker that comments also fills out the sign-in sheet.

Step Three: Reporting to the International 

  • This step is just as important as the first two. If comments don't reach the Department of Labor and we don't track who sent them, all this work is for nothing.
  • Scan the written comments and the attendance sheet, then send both documents by email to the IRAP Campaign Data Lead Mitchell Bechtel at mbechtel@iwintl.org. Include the date of the worksite visit, the local that did it, and the names of whoever led it or assisted in the body of the email.
  • Send this data to the lead within 24 hours following the comment bank. Our system updates daily. Save the original copies.

 

Gathering Comments Resources

Comment Bank Recruitment Script


Protect Our Apprenticeships Sign-In Sheet


Comment Bank Host Script


Comment Form