Opinion for the Court filed by Senior Circuit Judge MacKINNON.
MacKINNON, Senior Circuit Judge:
Appellants United Transportation Union (the Union), T.E. Lloyd and Patrick Saunders challenged in district court the decisions of appellees Drew Lewis, Secretary of Transportation, and Robert W. Blanchard, Federal Railroad Administrator, (1) that use of metal hooks to open coupler knuckles during railroad humping operations does not violate section 2 of the Safety...
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