BNSF Railway DOT FMCSA Roadability Requirements Review December

BNSF Railway DOT FMCSA Roadability Requirements Review December 9, 2009 0

FMCSA Roadability Requirements Rules Governing Intermodal Equipment l The intent is to improve vehicle safety l l 23% of Intermodal Equipment examined is deemed out of service compared to 14% of non-intermodal equipment Enforcement begins December 17, 2009 l l l Roadside inspections Inspection of M & R records and processes Roadability reviews 1

FMCSA Roadability Requirements Definitions l Intermodal Equipment (IME) l l Intermodal Equipment Provider (IEP) l l Any party that has contractual maintenance responsibility or any party that authorizes the interchange to a motor carrier pursuant to an interchange agreement, e. g. , Uniform Intermodal Interchange Agreement (UIIA) Facility Operator l l Intermodal container chassis and all other kinds of trailers, chassis and associated devices used to transport intermodal containers (dry closed van trailers, as well as flatbed trailers carrying intermodal containers, are excluded) Party operating premises where IEPs make IME available for interchange to motor carriers Global Intermodal Equipment Registry (GIER) l Data base for identification of individual IME and corresponding IEP 2

FMCSA Roadability Requirements Definitions (continued) l Driver Vehicle Inspection Report (DVIR) l l Report that IEP receives from Motor Carrier upon return of IME reflecting any roadability component defects as reported by the driver Roadability Component Defects (RCDs) l Any component that affects the safe operation of the equipment; specifically: l l l l l 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 connections, hoses and couplers Brakes 3

FMCSA Roadability Requirements Responsibilities l IEP (Section 390. 40) l l Identify its operations to FMCSA via Form MCS-150 C Mark IME with USDOT number (12/17/2010) l l l Systematically inspect, repair and maintain all IME intended for interchange with a motor carrier Periodically inspect IME l l FMCSA adopted GIER as an option to mark IME eliminating physical stenciling FHWA form can be used to meet the FMCSA requirement Maintain a system of inspection, repair and maintenance records Provide sufficient space for drivers to perform pre-trip inspection of IME Repair any equipment damage, defects or deficiencies identified as part of the pre-trip inspection, or replace the equipment, prior to the driver’s departure 4

FMCSA Roadability Requirements Responsibilities l IEP (continued) l l l Maintain a system of DVIRs submitted by Motor Carrier drivers Not permit any person to operate IME declared “out of service” until all repairs required have been satisfactorily completed Certify on the original DVIR that repair of reported damage, defects or deficiencies was made or that repair was unnecessary 5

FMCSA Roadability Requirements Responsibilities l Motor Carrier (Section 390. 42) l Perform pre-trip inspection of the following components and be satisfied they are in good working order before operating IME over the road l l l l l Service brake components visible to a driver without physically gong under the vehicle and trailer brake connections Lighting devices and reflectors Tires Coupling devices Rails or support frames Tie-down bolsters Locking pins, clevices, clamps or hooks Sliders or sliding frame lock Upon return of equipment to IEP, report any known damage, defects or deficiencies or that no damage, defects or deficiencies exist 6

FMCSA Roadability Requirements Responsibilities l Maintenance & Repair Vendor (as IEP agent) l Ensure individuals performing annual inspections are qualified as follows: l l l Understand the inspection criteria set forth in part 393 and appendix G of Section 396. 19 and can identify defective components; Are knowledgeable of and have mastered the methods, procedures, tools and equipment used when performing an inspection; and Are capable of performing an inspection by reason of experience, training, or both as follows: Ø Successfully completed a Federal- or State-sponsored training program or have a certificate from a State or Canadian Province that qualifies the individuals to perform commercial motor vehicle safety inspections, or 7

FMCSA Roadability Requirements Responsibilities l Maintenance & Repair Vendor (as IEP agent) (continued) Ø ü ü l Have a combination of training or experience totaling at least 1 year. Such training or experience may consist of: Participation in a commercial motor vehicle manufacturer-sponsored training program designed to train students in commercial motor vehicle operation and maintenance; Experience as a mechanic or inspector in motor carrier or intermodal equipment maintenance program; Experience as a mechanic or inspector in commercial motor vehicle maintenance at a commercial garage, fleet leasing company, or similar facility; or Experience as a commercial motor vehicle inspector for a State, Provincial or Federal government Retain evidence of that individual’s qualifications as outlined above for the period during which that individual is performing annual motor vehicle inspections for the IEP and for one year thereafter 8

FMCSA Roadability Requirements Responsibilities l Maintenance & Repair Vendor (as IEP agent) (continued) l Ensure that each brake inspector is qualified as follows: l l l Understands the brake service or inspection task to be accomplished and can perform that task; and Is knowledgeable of and has mastered the methods, procedures, tools and equipment used when performing an assigned brake service or inspection task; and Is capable of performing the assigned brake service or inspection by reason of experience, training, or both as follows: Ø Has successfully completed an apprenticeship program sponsored by a State, a Canadian Province, a Federal agency or a labor union, or a training program approved by a State, Provincial or Federal agency, or has a certificate from a State or Canadian Province that qualifies the person to perform the assigned brake service or inspection task (including passage of Commercial Driver’s License air brake test in the case of a brake inspection); or 9

FMCSA Roadability Requirements Responsibilities l Maintenance & Repair Vendor (as IEP agent) (continued) Ø Ø l Has brake-related training or experience or a combination thereof totaling at least one year. Such training or experience may consist of: Participation in a training program sponsored by a brake or vehicle manufacturer or similar commercial training program designed to train students in brake maintenance or inspection similar to the assigned brake service or inspection tasks; or Experience performing brake maintenance or inspection similar to the assigned brake service or inspection task in a motor carrier or IEP maintenance program or; Experience performing brake maintenance or inspection similar to the assigned brake service or inspection task at a commercial garage, fleet leasing company, or similar facility Ensure no person is employed as a brake inspector unless the evidence of the inspector’s qualifications are maintained at the location where the brake inspector is employed 10

FMCSA Roadability Requirements Responsibilities l Maintenance & Repair Vendor l (as IEP agent) (continued) Maintain evidence of brake inspectors qualifications for the period during which the brake inspector is employed in that capacity and for one year thereafter l Evidence of brake inspector qualifications does not have to be maintained if brake inspector has passed the air brake knowledge and skills test for a Commercial Driver’s License 11

FMCSA Roadability Requirements Responsibilities l Facility Operator l The roadability regulations are not applicable to facility operators; however l l Out gate edits for IME on hold for RCDs must absolutely be adhered to IEPs will be dependent on facility operators to provide space for driver pre-trip inspection Checkpoint personnel will not complete DVIR on behalf of Motor Carrier drivers Will not establish manual processes for placing IME on hold or releasing IME from hold 12

FMCSA Roadability Requirements BNSF Process Facilitation l As a facility operator, BNSF will assist Motor Carriers and IEPs with DVIR information exchange, automatic bad order hold of IME reported to have RCDs and release of IME from hold after certification that repairs were made or repairs were unnecessary only if the following criteria is met: l l IEP is utilizing the Intermodal Association of North America (IANA) program for DVIR processing IEP has executed an agreement with the on-site M&R vendor for RCD repair When the above criteria is met: l l l IME is registered in GIER Drivers will be prompted at in gate for RCD declaration If RCDs are reported, equipment will be designated in BNSF’s system as on Hold for RCDs On-site M&R vendor will have access to BNSF’s system for visibility of IME on hold On-site M&R vendor will have access to BNSF’s system to release IME from hold Potential web tool development for IEP management of IME on hold and release from hold 13

BNSF Railway DOT FMCSA Roadability Requirements Review Q&A 14