565, 570 (3d Cir.2008); South Bay Boston Mgmt., Inc. v. Unite Here, Local 26, 587 F.3d 35, 40 (1st Cir. 2009). On appeal, Doyle argues that the August 1 agreement did not waive his right to file suit challenging SEPTA’s compliance with the arbitration award. He also argues that the arbitration award itself entitled him to return to work as soon as he was re-qualified on the physical characteristics of the line on which he would be working. Addi the same federal-law principles that we would apply to interpret the collective bargaining agreement itself. Nonetheless, unions’ waivers of employees’ federal statutory rights are generally enforced under federal law only if “clear and unmistakable.” Wright v. Universal Mar. Serv. Corp., 525 U.S. 70, 80, 119 S.Ct. 391, 142 L.Ed.2d 361 (1998) (<HOLDING>). Without deciding whether that standard
holding employees under age discrimination in employment acts adea parallel retaliation provision includes former employees as long as the alleged discrimination is related to or arises out of the employment relationship holding that the word waiver is not required to waive a right even when a statute requires clear and unmistakable evidence of waiver holding that title vii provides the exclusive judicial remedy for claims of discrimination in federal employment holding that even if the standard for waiver is clear the standard was not met holding that clear and unmistakable standard applied to unionnegotiated waiver of employees statutory right to a judicial forum for claims of employment discrimination