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Federal Chassis roadability rules: Are you ready? By Joe Palazzolo, Palazzolo & Associates One of the most far-reaching intermodal regulations in recent years will take effect in December 2009 — less than six months from now. The U. S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) issued these regulations on chassis “roadability” and they will have a significant impact on intermodal cost and operations because, among other things, they require: Registration by Intermodal Equipment Providers (IEP) with the FMCSA Written, driver-signed pre-trip reports on the condition of each chassis, as the chassis is delivered to an equipment provider, or their agent Copies of driver reports, available for FMCSA audit, to be accessible at every Intermodal Equipment Provider (IEP) Numbering of each chassis to conform to federal regulations, regardless of the current chassis numbering system Annual chassis inspections IEP repair and maintenance record-keeping systems These regulations could have an impact on intermodal operations, including terminal and rail ramp gate operations, maintenance and repair activities and back-office IT systems and bookkeeping. From an operational perspective, the process required in the regulations state that: A motor carrier’s driver must conduct a pre-trip inspection of an intermodal chassis, observing the condition of nine different equipment components (listed below) Based upon that inspection, the driver must prepare a signed, federal Driver Vehicle Inspection Report (DVIR), even when no problems are observed The DVIR must be presented to the IEP or its agent at the time the chassis is ingated at their facility Problems reported on the DVIR must be repaired by the IEP or its agent before the equipment is returned to service The written, driver-signed reports are defined in the regulations as Driver Vehicle Inspection Reports. This report must include the results of inspection of: King pin upper coupling device Rails or support frames Tie down bolsters Locking pins, clevises, clamps or hooks Sliders or sliding frame lock Wheels, rims, lugs, tires Lighting devices, lamps, markers and conspicuity marking material Air line connectors, hoses and couplers Brakes The stated purpose of the regulations is to provide greater safety and accountability for intermodal chassis repair costs. Since publication of the regulations, there has been considerable debate over their interpretation, but two things are certain: various industry interest groups have different interpretations of the meaning of the regulations and the clock is relentlessly ticking towards the December 17, 2009 compliance date. One of the debate points centers around the definition of Intermodal Equipment Provider “Agent.” According to the regulations, an IEP “Agent” is any party that receives an intermodal chassis into their facility on behalf of an IEP. Under this definition, a marine terminal or rail ramp facility that ingates a chassis on behalf of a steamship line (owning the chassis) or a chassis pool operator, would be an IEP “Agent.” As such, they would be required to receive and process the Driver Vehicle Inspection Report. However, some terminal operators indicate that this definition is too expansive, and while they receive chassis in the course of. their business, they are not agents of the equipment provider, in a legal sense. Another disagreement is over the nature of a written, signed DVIR. Some have argued that the written report must be a paper document, while others state that an electronic, paperless equivalent will be satisfactory. However, few industry participants disagree that there is potential for cost increases, and in these economically challenging times, they could be significant. Some parties have considered the addition of expensive pedestals at terminal gates to process the DVIRs, while others seek less capital-intensive solutions . The close proximity of a December compliance date has other industry members concerned about time-consuming construction (with its tedious design and permit process). The implementation of corresponding computer programming and testing of systems also typically demand long lead times. One issue not debated is the potential for operational chaos if different solutions are installed at different intermodal facilities across the nation in the absence of a national framework. Large intermodal operators could face a multitude of vendors and a variety of systems. TrucFlo (www.trucflo.com) has proposed a paperless, nationwide system to ensure that all intermodal providers — motor carriers and their drivers, IEPs and their agents, railroads, repair facilities and inland depots — will be in compliance with the regulations. In the TrucFlo system, drivers report their chassis inspection by making a simple password-protected cell phone call. No paper is required. Once filed, this electronic, digital form can be accessed by TrucFlo subscribers via the Internet or through electronic file transfers. Larger terminal and rail gate systems will want to integrate the TrucFlo file into their existing gate systems while smaller subscribers can access their data through an Internet connection. The FMCSA has recently indicated that electronic DVIRs are an acceptable form of compliance to the regulations. Available nationally, TrucFlo has begun registration of drivers and will soon begin processing low-cost subscriptions. Information is available at the TrucFlo Web site and by calling its toll-free phone number: 877-TRUCFLO (877-878-2356). References: Federal Motor Carrier Safety Regulation (FMCSR) 73 FR 76794; December 17, 2008. www.fmcsa.dot.gov/iep	In This Issue Up Front News, Trends & Analysis New Items The outlook is improving Supply Chain Federal chassis rules: Are you ready? Working with the public sector How will your company deal with Sarbanes-Oxley Features Gateway at a glance �Southern California Six case studies in green Ports & infrastructure Nowhere near a Peak Season this year Port Products Green port product review Commentary Sustainable: The new buzz word On the Horizon Expect to see more LNG fuel stations in the future Casualties
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Federal Chassis roadability rules: Are you ready?