I need to amend a DB plan that covers members of a USW local. The plan has a provision (that I understand is common among USW plans) that provides for a "special pension" as well as a regular pension.

The special pension is a lump-sum equal to 13 weeks of vacation pay less an offset for vacation pay received for the year.

Does anyone know a reason why this "special pension" would not be subject to the QJ&SA rules?