ATA Regulatory Update

Transcription

1 ATA Regulatory Update January 25, 2018 Prepared for Minnesota Trucking Association Safety Conference 1

2 Topics Electronic Logging Devices Hours of Service Medical Certification/OSA Younger Drivers & Licensing Issues DOT Regulatory Reform Compliance, Safety, Accountability Preventability Program Recent Legislative Activity Automated Trucks 2

3 Electronic Logging Devices 3

4 ELD Implementation began on December 18 th CVSA Memo No OOS until April 1, 2018 FMCSA No CSA Points until April 1,

5 ELD Exemptions Exemptions TRALA, UPS Seven more (and counting) awaiting decision Livestock 90-day waiver January 18 date extended 30 days 5

6 Hours of Service 6

7 Hours of Service New Ag Exception Interpretation Split Sleeper Berth Pilot Study (WA State and VTTI) Sampling Study Design Timeline Rule Change? 7

8 Hours of Service FMCSA Newly Proposed Guidance on 2 issues: Use of CMV for Personal Conveyance (PC) Allows Laden Vehicles for PC, based on intent of move Transportation of Agricultural Commodities Laden/Unladen Vehicle loads beyond 150 AMR Meaning of Sources and Multiple Sources 8

9 Medical Certification / OSA 9

10 Medical Certification / OSA May 2018 Med Certification Integration Slowdown at AAMVA FMCSA resolution? Obstructive Sleep Apnea ANPRM Withdrawn Senators Schumer and Booker 10

11 Younger Drivers & Licensing Issues 11

12 Younger Drivers / Licensing Pilot Program Proposed 3 year program Study the feasibility, benefits, and safety impacts of allowing a covered driver to operate in interstate commerce Covered driver = Under 21, MOS to operate a CMV Reservists or National Guard 200 participants ELDS, OBMS, crashes, driving and inspection violations WHEEL Act (H.R. 3889) 12

13 Younger Drivers / Licensing CDL Knowledge Test Waiver July 2017 Military Domicile Rule October 2016 Includes CDL Skills Test Waiver extension to 1 year 13

14 Entry Level Driver Training (ELDT) Final Rule Issued December 2016 Establishes new minimum training standards Must complete a prescribed program of knowledge and skills instruction provided by an entity listed on FMCSA s Training Provider Registry. Incorporates performance-based concepts by requiring that driver-trainees demonstrate proficiency in both the BTW and theory portions of the curricula no minimum hours requirements. Compliance begins February

15 DOT Regulatory Reform 15

16 DOT Regulatory Reform ATA Priorities High Priority Flexible Split Sleeper Berth MVR to Verify MEC Expand short haul exception for CDL drivers 16

17 DOT Regulatory Reform ATA Priorities Medium Priority Limit Supporting Documents Clarify that FMCSRs are federally approve standards Allow out-of-state knowledge testing and CLP issuance Definition of a Tank Vehicle Allow EMR information required when hauling HazMat to be provided in electronic format 17

18 DOT Regulatory Reform ATA Priorities Needed but less urgent Only three years of employment history on application Self-reporting of violations 18

19 Compliance, Safety, Accountability 19

20 Compliance, Safety, Accountability (CSA) FAST Act Study By National Academies of Sciences Published June 2017 Reasonable, Defensible, Could Improve FMCSA requested comments to develop a Corrective Action Plan required by the FAST Act ATA provided comments to FMCSA Awaiting FMCSA publication of the Corrective Action Plan 20

21 Preventability Program 21

22 Preventability Program Accident Preventability Demonstration Program Program details published July Allows carriers to challenge certain accident scenarios as not preventable DUI; wrong direction; struck in rear; legally stopped; suicide by truck; animal strike; infrastructure failure/falling debris; falling cargo. DataQ non-preventable accidents sent to FMCSA Non-preventable accidents noted on CSA profile, score recalculated At least 24 month pilot program 22

23 Preventability Program Summary of Requests 625 Total from 321 carriers (crashes starting June 1 through October 2017) Closed: Determination Made - 19 Closed: Not Eligible - 89 In Review Pending Public Info Pending Requestor - 21 Submitted (not processed)

24 Recent Legislative Activity 24

25 Recent Legislative Activity Three Tuck Related Bills Signed into Law in Early January Jobs for our Heroes Act - streamlines the process by which active-duty military, reservists and veterans apply for their commercial driver's license No Human Trafficking on Our Roads Act, disqualifies individuals from operating a CMV for their lifetime if they used a CMV to commit a felony involving human trafficking Combating Human Trafficking on Our Roads Act - fights human trafficking by designating an official at the U.S. Department of Transportation to coordinate human trafficking prevention efforts across DOT, among other measures Stop Underrides Act of 2017 Introduced in the Senate in December Would strengthen rear guards and add new mandate for side and front underride guards Includes retrofit and maintenance requirements 25

26 Automated Trucks 26

27 ATA Automated Truck Policy Policy Positions for the following topic areas: Safety Freedom of Choice vs. Mandates Flow of Interstate Commerce Uniform State Laws Infrastructure Public Education Maintainability 27

28 ATA Automated Truck Policy Future work Federal Preemption or state option Cyber and Data Security ownership, access, security Liability Driver Licensing/Training Vehicle Marking and Roadside Enforcement Security Vehicle-to-Grid (V2G) Data Recording Maintenance & Inspection Validation Other Issues 28

29 Considerations for Automated Truck Deployment Technology is developing Flexibility for innovation Safety & Productivity What s the ROI? Different business models 29

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