Earlier this month the American Trucking Association provided its thoughts on FMCSA’s proposed rulemaking addressing missing Federal Motor Vehicle Safety Standards certification labels for commercial motor vehicles operated by U.S.–domiciled motor carriers.
The American Trucking Associations adamantly opposes the implementation of this proposed Commercial Vehicle Certification Label rule for several reasons:
- There is no safety benefit to implement this “mattress tag” rule, only unnecessary administrative compliance costs. As the report of the Independent Review Team, titled, Blueprint for Safety Leadership: Aligning Enforcement and Risk” date July 15, 2014 strongly recommended that “FMCSA needs to better align compliance and enforcement processes with the safety risks that cause crashes.”
- FMCSA fails to recognize that operational efficiencies for drivers, carriers, and vehicles will be significantly reduced as a result of this proposal. For example, trailer and chassis interchanges and interlining would be affected, roadside inspection time would increase, driver on duty time due to additional pre and post inspection checks and back-office compliance costs would increase.
- FMCSA fails to understand that no matter what the NHTSA rule says, no certification label is permanent.
- Several commercial vehicle manufacturers are no longer in business, having gone bankrupt, been sold, or just closed their doors, making the ability to obtain a lost or defaced certification letter impossible.
- And lastly, the NTSB recommendations were the result of a bus crash that the Board attributed to the driver’s failure, not the equipment, let alone the standards 2 to which it was manufactured. The recommendations have nothing to do with trucking operations.
