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Antilock Brake Systems
TCA supports federal regulations to require that all new trucks and tractors manufactured after December 1999 be equipped with antilock braking systems (ABS) and that all new dollies and trailers manufactured after December, 2001 be equipped with ABS.
Prior to the dates that ABS would be mandated, TCA encourages all carriers to voluntarily equip an ever-increasing portion of their new vehicles with ABS. The voluntary phase-in period will provide the necessary time for manufacturers to engineer ABS for all vehicles and assure acceptable levels of durability, reliability, and maintainability.This time frame will also allow carriers to become familiar with ABS and establish mechanic and driver training systems that ensure safe and effective operation.
Adopted February 10, 1991
Applicability of Federal Motor Carrier Safety Regulations
The provisions of the Federal Motor Carrier Safety Regulations should be applicable to the operation of all commercial vehicles with a Gross Vehicle Weight Rating (GVWR) of 10,001 pounds or more; to the operation of all vehicles transporting hazardous materials in a quantity requiring placarding of the vehicle; and to the drivers of all such vehicles.Under provisions of the Commercial Motor Vehicle Safety Acts of 1982 and 1984, the applicability of these regulations should be extended to the operations of such vehicles and drivers operating in intrastate commerce and enforced through the Motor Carrier Safety Assistance Program (MCSAP).
Rather than proposing changes in the applicability of the Federal Motor Carrier Safety Regulations which would create a potential degradation of safety, FMCSA is urged to direct its attention to affording relief from paperwork burdens and any another specific requirements which do not demonstrably improve safety.
Brake Adjusting Responsibilities
Written policies should be developed by each motor carrier fleet delineating responsibility for performing brake adjustments. When drivers are held responsible for making brake adjustments, motor carriers should assure that those drivers are properly trained to do such work.
Drugs & Alcohol
TCA supports federal requirements for all interstate and intrastate truck drivers to undergo tests for drug and alcohol use, as follows:
A. Pre-Employment Testing
B. Testing for Reasonable Cause
C. Post-Accident Testing
D. Random Testing
TCA supports random roadside testing without the need for probable cause for drug or alcohol use conducted by the federal or state government to determine if random roadside testing is practical and effective. It also supports testing by police officials at roadblocks established to detect drivers of motor vehicles who are under the influence of alcohol.
E. Optional Testing
TCA would support the development of additional federal requirements for all interstate and intrastate truck driver drug and alcohol testing as follows:
A. Driver Training School Testing
B. National Drug Clearinghouse
C. National Driver Register
D. Alternative Specimens
Adopted March 3. 2013
TCA would not support implementation of federal drug and alcohol regulations that would:
Drivers who, as a result of testing, show evidence of drug use should be medically unqualified, and should be disqualified for a specified period of time. They should be retested and found free of drugs prior to being found qualified. If a driver tests positive for alcohol or drugs, an individual should be further evaluated to determine if a problem exists and the individual is disqualified.
Amended October 5, 2008
Electronic Logging Devices
TCA supports federal laws and regulations requiring the use of electronic logging devices (ELD) for documenting compliance with hours of service (HOS) rules. In developing such a law or regulation, TCA believes the following issues should be addressed:
Amended March 14, 2011
Laws, rules, regulations, orders, and standards relating to the safety of highway transportation of hazardous materials should be nationally uniform. There are certain areas where the federal government should have exclusive jurisdiction of regulations governing hazardous materials transportation. State governments should share concurrent jurisdiction with the federal government in regulating the routing of hazardous materials.
States or localities that believe federal standards are deficient should be encouraged to petition to revise such federal standards rather than acting unilaterally to regulate hazardous materials in transportation. There may be instances when a state or locality should be allowed to adopt or continue to enforce a law, rule, regulation, order, or standard until such time as the federal government adopts a rule, regulation, order, or standard covering the same subject matter, and when the state or local requirement:
All motor carriers should be required to register with the federal government as a prerequisite to transporting hazardous materials. There should be a federal requirement that motor carriers train, test, and certify drivers of hazardous materials vehicles, for safety and to forestall state and local requirements for testing and licensing of such drivers.
TCA supports the creation of a federal fund to address the needs of state and local personnel who respond to hazardous materials accidents and incidents. Fees established would be broad-based and funded by all carrier modes, manufacturers, and shippers of hazardous materials. The fees shall be reasonable and graduated to reflect the differing risks among hazardous materials. All monies collected from these fees would be used solely for the training and equipping of hazardous materials response personnel and would be specifically directed to replace state and local hazardous materials fees, permits, and registrations. State and/or local acceptance of Federal funds would preclude those jurisdictions from assessing like fees.
A driver of hazardous materials vehicles should be considered qualified based on knowledge, training, and experience. There should not be a special age requirement for such drivers in less-than-truck-load service. Any experience requirement should be based on a time period. Reports of accidents involving such drivers should not require detailed background information about the driver on a routine basis. Such details should be requested by government as needed.
Efforts to control pollution resulting from hazardous wastes should not be detrimental to the trucking industry.
TCA supports regulations to encourage re-use and recycling of hazardous wastes generated by the trucking industry.
Criteria for placing hazardous materials vehicles out of service should be applicable only to motor vehicles that are subject to placarding, and only if there is a violation of hazardous materials requirements that would result in an imminently hazardous situation in the event of spill or leakage of the hazardous materials.
Amended June 21, 1995
Hours of Service
Highway safety is of the utmost importance to TCA. TCA supports hours of service regulations that are practical and effective and that promote operational flexibility. Motor carriers must not be subject to citations or penalties for violations of hours of service requirements that result from activities over which they have no control.
In addition, any DOT rulemaking proposal on hours of service should address the following facets of hours of service:
Amended October 25, 1998
Identification & Markings on Trucks
For safety purposes, there should be permanent identification on all vehicles operating in interstate and intrastate commerce. Identification for vehicles operating under authority of the Interstate Commerce Commission or of state commissions shall be in compliance with requirements of such commissions. Identification of other vehicles shall consist of the name, city, and state of the vehicle owner or long-term lessee. Size and location of such identification should be comparable to that required for authorized carriers.
Limiting Speeds on Trucks
The speed of all electronically governed class 7 and 8 trucks manufactured after 1992 should be governed at a maximum speed not to exceed 65 miles per hour.
Adopted March 4, 2012
On Board Technology
TCA supports the development, testing and use of cost-effective on-board technologies that improve vehicle safety, driver performance, productivity, vehicle maintenance, and management. TCA supports Federal Motor Vehicle Safety Standards for those technologies which have a proven significant safety benefit and a reasonable cost.
Adopted March 3, 2013
Civil penalties for violations other than record-keeping violations should be eliminated. The general criteria for determining if penalties should be imposed should be the same for employers and employees.
Vehicles should not be impounded. Vehicles should be placed out-of-service only because of imminently hazardous conditions.
Safe Use of Technology
TCA supports the safe use of technologies and encourages drivers and/or motor carriers to consider a range of policies and safeguards intended to reduce, minimize, and/or eliminate driver distractions that may be caused by the increased use of electronic technologies (e.g. global positioning systems, cellular phones, etc.) during the operation of all types of motor vehicles. TCA strongly encourages and recommends that manufacturers of these devices, vehicle manufacturers, policy makers, motor carriers, and organizations representing motor carriers and the motoring public promote and adopt awareness, training, and safety policies on the use of such technologies - unless required by current laws and regulations - during the operation of a motor vehicle on our nation’s highways.
Adopted March 8, 2009
A certificate of safety fitness should be required for all motor carriers, both private and for-hire.
Sale of Alcohol at Truckstops
In an effort to create a safer driver environment for truck drivers and independent contractors, the trucking industry recognizes its obligation to place drivers and independent contractors on the nation's highways. Inasmuch as the nation's truckstops are the home away from home of most truck drivers and independent contractors, it is imperative that truckstops likewise do not sell alcohol to ensure the safest possible working environment for the industry's drivers and independent contractors. Therefore, TCA supports all legal efforts to eliminate the sale of alcohol in any form at all of the nation's truckstops.
TCA supports the adoption of primary seat belt laws for all motor vehicles by all states. TCA supports state laws that permit the admissibility of seat belt usage or non-usage as evidence in litigation.
Adopted March 1, 2008
If FMCSA develops screening and testing standards for sleep disorders, the agency should do so only through rulemaking and not through the publication of regulatory guidance. The development of any future regulation on establishing objective standards for sleep disorder screening, testing and treatment should be focused on conditions that pose a substantially elevated crash risk based on sound data and analysis, be cost-beneficial, and promote effective treatments that minimize the impact to motor carriers and commercial vehicle operators.
Adopted March 3, 2013
TCA urges states to adopt a uniform speed limit for all vehicles at a maximum speed of 65 mph. TCA opposes the use of any mechanical or electrical devices which enable drivers to exceed the speed limit without being detected.
Amended October 5, 2008
Roadside inspections are more effective than state inspections conducted annually or semiannually because they focus on the condition of drivers and loads as well as the condition of vehicles and equipment.
Vehicles should be placed out of service only because of imminently hazardous conditions. Vehicles should not be impounded.