OOIDA concerned truck maintenance survey could lead to unnecessary regulations

December 28, 2018

Mark Schremmer

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The Owner-Operator Independent Drivers Association is opposed to FMCSA’s collection request regarding truck maintenance requirements, saying the proposal could lead to unnecessary rules and regulations that would place economic burdens on small-business truckers.

The Association filed formal comments to the FMCSA on Thursday, Dec. 27.

“OOIDA cautions against using the proposal as a basis for unnecessary maintenance regulations that would place economic burdens on small-business truckers, while doing nothing to improve highway safety,” OOIDA President Todd Spencer wrote in the comments. “Drivers and motor carriers are already required to perform daily and annual inspections to ensure their vehicles are operating safely.

“As emphasized in regulatory guidance, the lack of specificity regarding standard intervals for preventative maintenance allows flexibility for fleet and vehicle specific inspections. In short, implementing standardized interval or mileage requirements would not be a practical solution for the trucking industry.”

FMCSA posted the notice and request for comments on Nov. 27. According to FMCSA, the main goals of the collection request for truck and bus maintenance requirements would be to develop an operational definition of “systematic maintenance,” evaluate whether current regulations and the intervention process could be modified to improve compliance, and to gather information to assist in establishing minimum standards.

“The agency justifies the potential survey by stating that they utilize the Compliance, Safety and Accountability (CSA) enforcement program to prioritize and target interventions,” OOIDA wrote. “This is the same CSA program that is currently undergoing congressionally mandated revisions so that it meets more acceptable validation standards. In addition, motor carrier crashes, including fatal crashes, have actually increased since the inception of the CSA program in 2010. Thus, using the CSA program to target vehicle maintenance violations is not a productive approach.”

FMCSA’s notice cites a 2014 study by the John A. Volpe National Transportation Systems Center that said motor carriers targeted for interventions for vehicle maintenance issues had a 65 percent higher crash rate compared to the national average.

“However, the report does not explain how many, if any, of those targeted carriers that had crashes were actually a result of vehicle maintenance problems,” OOIDA wrote. “In fact, according to the FMCSA’s own Large Truck Crash Causation Study, the number of crashes involving large trucks where a vehicle maintenance issue was cited as a possible contributing factor was 2 percent, and none of which implied a vehicle causing the crash.”