THE FEDERAL government has a goal to reduce truck traffic fatalities by 50% in the next 10 years, said Steve Barber, director of the Office of Enforcement and Compliance, Federal Motor Carrier Safety Administration (FMCSA), Washington DC. As part of reaching that goal, carriers can expect a 37% increase in regulation enforcement and 52% increase in enhanced penalties. State enforcement grants have been increased 50%.
"There are going to be more roadside inspections," Barber said. "We must join forces to reduce fatal crashes."
Barber discussed highway regulations at the National Tank Truck Carriers Safety Council Meeting April 19-20 in New Orleans, Louisiana. Also presenting information on the subject were Cliff Harvison, National Tank Truck Carriers president, Alexandria, Virginia; and Kip Hart, Hart Industries president, Middletown, Ohio.
Barber said the FMCSA will be assessing safety profiles of new companies as they apply for a Department of Transportation (DOT) registration. In addition, carrier records will be examined to determine company risk factors. The factors would be determined by a review of accident reports, out of service times, hazardous materials records, driver records, vehicle reports, and safety management systems.
He advised carriers to review their company profiles on file with DOT to determine accuracy. If discrepancies are discovered, DOT should be contacted. Carriers have the right to appeal safety ratings.
As for obtaining more information about driver records across the United States, Barber does not anticipate a countrywide system because of invasion of privacy laws. "I don't think we are going to be able to do that," he said.
However, it may be possible for states to communicate with each other to insure that commercial driver licenses aren't issued in multiple.
Regulation Proposals Harvison provided information about regulatory proposals that would affect the industry. Under consideration are changes that would affect inspection, testing, maintenance, and repair provisions for cargo tanks. DOT requested the American Society of Mechanical Engineers (ASME) to develop an international cargo tank design code. The new code, if implemented, would call for third-party inspection each time a tank is repaired or manufactured. NTTC and the Truck Trailer Manufacturers Association (TTMA) object to the concept because it would abdicate DOT's congressionally mandated duty to enforce DOT regulations. If the proposal is eventually approved, Harvison said NTTC would further challenge the issue in court.
Areas covered in the proposed code would be cargo tank design and materials, fabrication and inspection, and general requirements for components such as valves and vents. Affected parties would include manufacturers, repair shops, and users of specification tank trailers, intermodal tank containers, ton tanks, intermediate bulk containers, and others.
Another proposal being pushed by the Research and Special Programs Administration (RSPA) would require a retrofit for overturn protection devices for petroleum, acid, and stainless steel multi-compartment tank trailers. The MC300 series would have to meet the DOT400 series requirements. Harvison estimated the retrofit cost at $6,000 to $10,000 per trailer.
Another proposal on the table would require increased training and documentation for loading and unloading MC306/DOT406 tank trailers. Drivers would be the logical source to provide the documentation. The proposal is coming from the National Transportation Safety Board.
Lee Drury, safety director for fleet safety at Jack B Kelley Inc, Amarillo, Texas, said that inspectors from the Federal Drug Administration (FDA) are conducting surprise inspections where medical usage gas is being loaded. Harvison pointed out that FDA can regulate the trucking industry indirectly by imposing controls on the shipper, which in turn can pass the constrictions, if any, on to their carriers.
Harvison also noted that carriers with gross revenues of $18.5 million or more must pay an increased hazardous materials fee to DOT of $2,000. Smaller companies still pay $300.
Two issues related to drivers include fall protection devices that the Occupational Safety and Health Administration (OSHA) is considering. OSHA is looking at accidents happening at loading or unloading facilities. Ergonomics regulations, which include methods to ease the physical strain of certain jobs, are on a fast track. This issue will enhance the Clinton/Gore administration as a payback for organized labor support and is expected to receive a push for completion before the November presidential elections, Harvison said.
Equipment Inspections Beginning July 1, 2000, annual inspections on liquefied compressed gas cargo tanks must be performed by a registered inspector who visually inspects the delivery hose, delivery hose assembly, and piping system while the system is under test pressure.
Hart said inspectors will have to be DOT registered. He also pointed out that some testing methods are dangerous and recommended that compressed gas NOT be used for testing. He said testing at 10-15 psi or above could result in catastrophic accidents.
Product cannot be unloaded if the delivery hose or delivery hose assembly has damage to the hose cover that exposes the reinforcement. If wire braid enforcement has been kinked or flattened so as to permanently deform the wire braid, the product cannot be loaded or unloaded. Also restricting loading and unloading are hose soft spots when the hose is not under pressure, or bulging when the hose is under pressure. Also on the no loading or unloading list is damage that results in loose outer coverings.
Other loading and unloading preventions include damaged, slipping or excessively worn hose couplings; and loose or missing bolts or fastenings on bolted hose coupling assemblies.
Product also cannot be unloaded if there are defects in the piping system that include any external leak identifiable without the use of instruments; bolts that are loose, missing, or severely corroded; or manual stop valves that will not actuate.
Other considerations include rubber hose flexible connectors with any condition outlined above for hose assemblies. Stainless steel flexible connectors with damaged reinforcement braid are also on the list as prevention to loading and unloading. Product cannot be unloaded if internal self-closing stop valves fail to close or permit leakage through the valve detectable without the use of instruments. Also on the list are pipes or joints that are severely corroded.
Hart said that stainless steel flexible hose for both LP gas and anhydrous ammonia need to be examined in a common-sense inspection for wear and tear.
Hart discussed background on the HM-225A regulation that went into effect July 1, 1999. It imposes new requirements on operators of cargo tanks used to transport liquefied compressed gases and new procedures for unloading.
Before unloading, the cargo tank discharge system must be checked, including the delivery hose assembly and piping, Hart said. The requirement is designed to assure that the system is of sound quality, without obvious defects, and that connections are secure. The check must be done after the pressure in the discharge system has reached equilib- rium with the pressure in the cargo tank. After unloading, a visual examination must be made for defects to that portion of the hose and hose assembly that was deployed for the delivery.
Visual inspections of each delivery hose and delivery hose assembly are required each month for each cargo tank in service. The cargo tank piping system, including fusible elements, bolts, connections, valves and seals, must be visually inspected. All emergency discharge control devices designed to close the internal self-closing stop valve must be inspected to assure that all linkages to the valve operate as intended.
In addition, the internal self-closing stop valve must be checked for leakage.
For emergency discharge control equipment, the regulation specifies two types of emergency discharge control equipment: passive shut-down and remote control shut-down.
The passive shut-down equipment must halt the flow of product without human intervention within 20 seconds of an unintentional release caused by complete separation of a delivery hose.
The remote control shut-down equipment must close the internal self-closing stop valve and shut off the engine and auxiliary power upon activation by the person attending the unloading operation.