Intermodal chassis safety rule partially delayed

I work for a motor carrier that specializes in intermodal drayage around Puget Sound. We have about 60 power units and a sizable fleet of superchassis. But we do move a lot of terminal provided chassis. These new regulations, though badly needed, are a joke and a bad one at that.

Points to consider…

The terminal operators all say that no defective chassis should ever leave the terminal. We have been told by the terminal operators that when our drivers find defective chassis that they’re to be fixed immediately or we get another chassis. If that’s the way it’s suppose to work there won’t ever be a DVIR that lists a defect but we still have to submit them. We will be submitting hundreds of DVIR’s every day that shows no defects. Why are we being forced to do this?

OCEMA’s online system, that the IEP’s want motor carriers to submit DVIR’s through (www dot chassis dot com) , says "it only takes about a minute per DVIR", but when we have 300 DVIR's in a day it means over five hours of extra work. Why do we have to hire more help?

Equipment providers are not providing the paper DVIR’s to motor carriers. They expect us to provide them. We’re helping them comply with the regulations. They should at least supply us the paperwork to do it with.

Why can’t the terminal operator just hand the DVIR’s to the equipment provider? Nine times out of ten the equipment provider has a presence at the terminal operators location.

Drivers are not mechanics and they can’t be expected to certify that everything about every chassis is in good working order 100% of the time. But with these new regulations it’s conceivable that when a part on the chassis fails and causes an injury on the road, the motor carrier will be held legally responsible and the equipment provider will just point to the regulations and blame us. Before these regulations we'd share in the blame with the equipment owner. Now? I don't think so.

Equipment providers are expecting motor carriers to submit all DVIR's online and they want out-gated DVIR's to be submitted prior to in-gate. We have a handful of trucks that do nothing but move chassis and containers between terminals. They can do upwards of 12 in a day. 6 trucks at 12 a day means 144 DVIR's, all of which we won't see until the following day. And they want out-gated DVIR's prior to in-gate? Are we now required to hand a bag full of quarters to our drivers so they can find pay phones in order to call their dispatcher so the dispatcher can enter the DVIR’s on line?

These regulations were created specifically to make sure that container chassis provided by the equipment providers are legally roadable. Why is the motor carrier having to jump through hoops to help them comply with the regulations? It's because that process by which the DVIR's get back to the equipment provider wasn't included in the regulations and the equipment providers have come up with a way to shift that burden back to us.

 

Well said!

I never did like the idea, of putting my name, on a piece of paper, stating that I was operating a piece of equipment that was faulty. That, and the fact that I have to give out, my license number.