Motor Carrier Evaluation Program Presented By Kriss Grisham
Motor Carrier Evaluation Program Presented By: Kriss Grisham Date: July 7, 2015 Contractors Transportation Management Association (CTMA) Conference
Table of Contents § DOE Motor Carrier Evaluation Program (MCEP) § Key Requirements, Policies, and DOE Order § MCEP Activities § FY 2015/FY 2016 Completed and Planned MCEP’s § Current Total MCEP Motor Carriers § MCEP Revision Status § MCEP Tier Process § Tier Process and Hierarchy § MCEP Approvals § Planned Rollout of MCEP Revision Motor Carrier Evaluation Program 2
DOE Motor Carrier Evaluation Program Objective is to provide and monitor metrics on the quality and capability of for-hire motor carriers, drivers, and vehicles available for transporting DOE radioactive materials and hazardous wastes. § Applies to carriers transporting HRCQ, TL Radioactive Materials, and any Hazardous Waste § Does not apply to carriers transporting non-hazardous materials § Provides requirements, roles and responsibilities, and processes to assure that motor carriers transporting radioactive materials and hazardous wastes are evaluated for: i. Safety ii. Financial Status iii. Security iv. Compliance with DOT regulations and DOE policies and practices Motor Carrier Evaluation Program 3
Key Requirements, Policies and Orders Policy Description 10 CFR Part 71 Packaging and Transportation of Radioactive Material 40 CFR Part 263 Standards Applicable to Transporters of Hazardous Waste 41 CFR Part 109 -40 Transportation and Traffic Management 48 CFR Subpart 9. 4 Federal Acquisition Regulation, Debarment, Suspension, and Ineligibility 49 CFR Parts 40 and 350 -399 Federal Motor Carrier Safety Regulations 49 CFR Parts 100 -180 Hazardous Materials Regulations DOE O 460. 2 A Departmental Materials Transportation and Packaging Management Motor Carrier Evaluation Program 4
MCEP Activities: FY 2015/FY 2016 Completed and Planned MCEP’s for FY 2016 is 15, which is 2 more than completed in FY 2015 Motor Carrier Evaluation Program 5
MCEP Activities: Current Total MCEP Motor Carriers In 2012 there were 49 total MCEP Carriers, primarily reduced to current level using ‘sunset’ provision Motor Carrier Evaluation Program 6
MCEP Activities: MCEP Revision Status February 2014 § § Issued Draft MCEP Management Plan for review Reviewed by TMC MCEP WG March – April 2014 § § § Received 380 review comments 257 comments resolved to date 123 GC comments incorporated, still being worked October 2015 § New target date to resolve all comments and issue revised MCEP § Tiered Approach and GC comments created an MCEP scope issue for some Program Offices within DOE/NNSA Revision Note Motor Carrier Evaluation Program 7
MCEP Tier Process Carrier Category Functions & Responsibilities Tier 1 § Carriers transporting materials requiring Definitions of Tiers § issuance of an FMCSA Hazardous Materials Safety Permit (HMSP) (49 CFR Part 385, Subpart E) or Carriers transporting commodities that require a Hazardous Materials Security Plan (49 CFR Part 172, Subpart I) DOE/NNSA-led onsite verification HQ for “National ” carriers Field/Site Offices for evaluation of “Local ” carriers Primary Entity Responsible for Conducting Evaluations § § § Minimum Required Evaluation § Onsite verification visit § Carriers monitored monthly using information obtained from the Federal Motor Carriers Safety Measurement System in addition to other available notification sources Carrier Monitoring Evaluation Criteria § § All Tier 2 Items All Tier 3 Items FMCSA HMSP Hazardous Materials Security Plan Motor Carrier Evaluation Program Tier 2 § Carriers transporting Type A or Type B § Class 7 materials not included in Tier 1 Carriers transporting TL quantities of lowlevel or mixed waste shipped as low specific activity (LSA) or surface contaminated object (SCO) § DOE/NNSA-led offsite verification § HQ for “National” carriers § Field/Site Offices for evaluation of Tier 3 § Carriers transporting MCEP-defined hazardous materials not included in Tier 1 or Tier 2 and which require an Environmental Protection Agency (EPA) Uniform Hazardous Waste Manifest § Contractor “due diligence” determination “Local” carriers § Offsite review (validation of records and § Carriers monitored monthly using § All Tier 3 Items § EPA number, if hazardous waste with § § § documents) information obtained from the Federal Motor Carriers Safety Measurement System in addition to other available notification sources Uniform Hazardous Waste Manifest § Enforcement History § Dun & Bradstreet Report documents) information obtained from the Federal Motor Carriers Safety Measurement System in addition to other available notification sources § Operating Authority Insurance Safety Rating, if applicable PHMSA Registration, if applicable Federal Motor Carriers Safety Measurement System status EPA number, if hazardous waste with Uniform Hazardous Waste Manifest 8
Tier Process and Hierarchy § Process is used to control and manage Motor Carrier evaluations § Hierarchy provides added value § Tier 1 carrier could execute work scope of lower tier, but not vice versa § Process implements a “sunset” provision § Carriers must stay competitive, get new/keep work scope or be placed on In -Active Status Motor Carrier Evaluation Program 9
MCEP Approvals § Approvals require sound justification § Tiered approach will help minimize/avoid costs by providing a graded approach to evaluations § Avoid conflicts of interest and impartiality § Developing MCEP Evaluator qualifications for local and national carriers § Per Order 460. 2 A, All DOE and NNSA sites are required to submit their local MCEP Carrier list and associated MCEP reports to the MCEP Program Manager Motor Carrier Evaluation Program 10
Planned Rollout of MCEP Revision § Stepped Approach to the MCEP revision rollout 1) Issue Revision 2) Develop MCEP Training Program a) 3) 4) 5) Qualify Additional MCEP Evaluators Establish Rollout Period Assist in Rollout Fully Implement New MCEP Plan Motor Carrier Evaluation Program 11
- Slides: 11