1989

h^r / r —^

t.j-

ANNUAL REPORT

OF THE

GOVERNOR'S MOTOR CARRIER

TASK FORCE

FOR

SAFETY AND UNIFORMITY

® ®n®

MD

TD

8.1 :AR/ 1989

Submitted to

WILLIAM DONALD SCHAEFER, GOVERNOR

STATE OF MARYLAND

JANUARY, 1990

y.

V1 ^ t f V

!' William Donald Schaefer Governor

O. James Llghlhlzer Secretary Stephen G. Zentz Deputy Secretary

Maryland Department of Transportation

The Secretary's Office

April 19, 1993

Mr. Michael S. Miller Maryland State Law Library

Courts of Appeal Building 361 Rowe Boulevard Annapolis MD 21401-1697

Dear Mr. Miller:

Thank you for your recent letter regarding reports and studies relating to the Governor's

Motor Carrier Task Force for Safety and Uniformity.

Enclosed are copies of the reports noted on the attached list. We only have one copy of some of the reports; Mr. Mati Koiva, Chief of the State Highway Administration's Motor Carrier Division, will give you those reports directly. If you have any questions,

Mr. Koiva can be reached at (410) 787-7665.

Thank you again for your interest in the Task Force's documents.

Sincerely,

CT

Secretary

Enclosures

cc: Mr. Mati Koiva

My telephone number is (410)- 859-7600 TTY For the Deal: (410) 684-6919

Post Office Box 8755. Baltimore/Washington International Airport, Maryland 21240-0755

1989

ANNUAL REPORT

OF THE

GOVERNOR'S MOTOR CARRIER TASK FORCE

FOR

SAFETY AND UNIFORMITY

SUBMITTED TO

WILLIAM DONALD SCHAEFER

GOVERNOR

STATE OF MARYLAND

JANUARY 1990

EXECUTIVE SUMMARY

The Governor's Motor Carrier Task Force For Safety and Uniformity is the successor to the Governor's Task Force on Uniform Motor Carrier Procedures and the Truck Safety Task Force. The Task Force continues to study existing Maryland procedures for the taxation, registration and administrative regulation of heavy trucks and buses, and to develop procedures that are simpler and more uniform, while ensuring that safety is not compromised and commercial vehicles pay their fair share of highway user costs. The Task Force has representation from the elected and appointed state officials, motor carrier industry, labor, and citizens. The Secretary of Transportation serves as Chairman.

So as to provide even broader input from the motor carrier industry, an Industry Advisory Committee, composed of representatives of a variety of carriers and industry interests, has been established.

The following are the major issues on which the Task Force focused during calendar year 1989:

* Preventive Maintenance Program. The Maryland Preventive Maintenance (PM) program was enacted into law in 1988. Draft PM Regulations were developed and published and public meetings held to inform those registered vehicle owners covered by the program. The regulations were adopted with an effective date of January 8, 1990.

* The 10.000/26.000-pound Threshold. Proposed federal rulemaking changing the definition of trucks covered by the safety regulations from over 10,000 pounds to over 26,000 pounds was extensively reviewed. The Task Force position was to not support the raising of the threshold.

* commercial Driver's License (CDL). In preparing for administering the new CDL tests, a Maryland CDL manual was prepared and is now being distributed.

* capital Beltwav. A number of enforcement and traffic

control measures were examined during the past year for use on the Capital Beltway. Numerous recommendations have already been implemented that involved the cooperation and support of Virginia and local jurisdictions.

* Public Information. A cooperative program with Virginia,

"Drive To Survive Together", was undertaken to improve traffic safety on the Capital Beltway, with truck safety as

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a major component. A motor carrier element of the statewide "Drive to Survive" highway safety campaign has been developed and will be initiated early in 1990.

The Task Force has continued to make significant progress in improving safety programs and in bringing about greater uniformity in Maryland's motor carrier procedures and between the state's procedures and procedures adopted as national standards. It holds promise for continued benefits from implementing increasingly uniform procedures and resolving other motor carrier problems of interest/concern to the industry and the various state agencies.

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Membership of the Governor's Motor Carrier Task Force For Safety and Uniformity

CHAIRMAN Richard H. Trainer, Secretary

Maryland Department of Transportation P.O. Box 8755

BWI Airport MD 21240-0755 (301) 859-7397

MEMBERS

The Honorable Thomas Yeager Senator Legislative District 13 413 Main Street Laurel, MD 20707 498-3400

Mr. William L. Rohrbaugh President Maryland Bus Association Rohrbaugh's Charter Service, Inc. 33 95 Main Street Manchester, MD 21102 239-8000

MEMBERS

The Honorable Bruce Poole Delegate 24 Jonathan Street Hagerstown, MD 21740 739-6409

Mr. George A. Gallagher IV President Maryland Motor Truck Association, Inc. George Transfer, Inc. P.O. Box 3153 Parkton, MD 21120 329-4000 (appointed 9/16/89)

Ms. Rita Bontz President Independent Truckers and

Drivers Association 1109 Plover Drive Baltimore, MD 21227 242-0507

Mr. Donald M. Bowman D. M. Bowman, Inc. Route 2, Box 43 A-l williamsport, MD 21795 223-6900

Mr. Walter Thompson Executive Vice President Maryland Motor Truck Association, Inc. 3000 Washington Boulevard Baltimore, MD 21230 644-4600

Mr. Anthony Dell'Isola Fleet Specialist United States Fidelity &

Guaranty Company 100 Light Street Baltimore, MD 21202 625-5684

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Mr. George W. Woods President Teamsters Joint Council 319 West Howard Street Hagerstown, MD 21740 739-7550

Mr. Kenneth L. Pierson 3300 Glen Avenue Glenn Dale, MD 20769 390-6640

Mr. Claude M. Ligon Commissioner Public Service Commission American Building 231 E. Baltimore Street Baltimore, MD 21202 333-6094

Captain John Himmelmann Commander Truck Enforcement Division Maryland State Police 7777 Washington Boulevard Jessup, MD 20794 799-8822

Mr. Arthur E. Price Director Motor Vehicle Fuel Tax Div. Comptroller of the Treasury P. O. Box 1751 Treasury Building Annapolis, MD 21401 974-3131 (appointed 8/7/89)

Ms. Rebecca Hahn Windsor Hahn Transportation, Inc. P.O. Box 8 New Market MD 21774 865-5467 (term ended 9/26/89)

Dr. Harvey Clearwater Associate Professor Director, Safety Education Center

University of Maryland PERH College Park, MD 20742 454-2753

Mr. Marshall Rickert Administrator Motor Vehicle Administration 6601 Ritchie Highway Glen Burnie, MD 21062 768-7274

Capt. Richard Janney Commmander, Automotive Safety Enforcement

Division Maryland State Police 6601 Ritchie Highway Glen Burnie, MD 21062 768-1735

Dr. Katherine P. Parrel1 Assistant Secretary for Toxics, Environmental Science and Health Maryland Department of the Enivronment 2500 Broening Highway Dundalk, MD 21224 631-3774

The Honorable Ida G. Ruben Senator 11 Schindler Court Silver Spring, MD 20903 439-2332 (appointed 6/5/89)

Howard G. FitzGerald Director Motor Vehicle Fuel Tax Div. Comptroller of the Treasury P.O. Box 1751 Treasury Building Annapolis, MD 21401 974-3131 (retired June, 1989)

TABLE OF CONTENTS

Executive Summary

Membership of the Governor's Motor Carrier Task Force for Safety and Uniformity

Table of Contents

Introduction

Vehicle Inspection and Maintenance

Public Information

Hazardous Materials

Training and Penalties

Related Safety Issues

Permitting

Capital Beltway and other Traffic Safety Management

Appendices

A - Summary of Task Force Meetings

B - Motor Carrier Industry Advisory Committee Membership List

C - Subcommittee Membership Lists

D - Commercial Motor Vehicle Definition

E - Commercial Driver Licensing Training Sources

F - Capital Beltway Safety Issues

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INTRODUCTION

On March 20, 1989, Governor William Donald Schaefer appointed the Governor's Motor Carrier Task Force for Safety and Uniformity as the successor to the Governor's Task Force on Uniform Motor Carrier Procedures and the Truck Safety Task Force. The new task force was asked to continue the work of the previous ones and to address new issues dealing with safety and procedural and regulatory issues. The task force met on April 21, June 7 August 1, and October 5. A summary of these meetings is included as Appendix A.

To provide broader input from the motor carrier industry, an Industry Advisory Committee (see Appendix B for list of members) was appointed by the Chairman of the Task Force.

The work of the task force was primarily done by the various functional subcommittees consisting of task force members and

0Jhfw ;Lnt®rest®d individuals (see Appendix C for list of members of the subcommittees). Therefore, this report is organized principally along the functions of the subcommittees.

VEHICLE INSPECTION AND MAINTENANCE SUBCOMMITTEE

The subcommittee provided oversight to the Preventive Maintenance (PM) Program activities and concerned itself with the need to undertake a continuous review of the safety impact of the Maryland Motor Carrier Safety Program.

Preventive Maintenance Program

The Preventive Maintenance Regulations were published on June 30, 1989 in the Maryland Registerr Volume 16, Issue 13, Part

Revisions were published in the November 3, 1989 edj-tKpn. Copies of the Marvland Register were provided to all individuals who attended the public meetings. The final notice adopting the regulations was printed in December making them effective January 8, 1990.

A PM brochure describing the program was developed and mailed to 100,337 registered owners of Class E trucks with a registered or operating gross vehicle weight of over 10,000 pounds; Class F tractors; Class G freight trailers or freight semi-trailers; and Class P passenger buses. Eight public meetings, as announced in the brochure, attended by approximately 2,500 individuals, were held in Cumberland, Laurel, Towson, Salisbury, Waldorf, Frederick, Linthicum, and Centreville during

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August and September.

During the month of November, seven regional workshops were held in Salisbury, Essex, Chestertown, Frederick, Annapolis, Cumberland, and Greenbelt for state and local governmental agencies. Approximately 150 individuals attended these meetings. All attendees received copies of the Marvland Register and the revisions.

Speakers regarding PM were provided to 50 workshops or conferences sponsored by other organizations.

Roadside Inspections

The number of inspections completed in FY 1989 increased approximately 25% above FY 1988 inspections. The percent of trucks placed out of service as a result of full driver/vehicle inspections increased from 51.8% in FY 1988 to 52.9% in FY 1989. The number of citations issued increased 49% in FY 1989. A summary of the roadside inspections for the three fiscal years is as follows:

Roadside Inspection Summary

FY 1987 FY 1988 FY 1989

Number of Roadside Inspections

Trucks 7,397 19,193 23,732 Buses 489 1 > 195 —,125 Total 7,886 20,388 25,467

Percent of Trucks *Out-of-service 56.4 51.8 52.9

Average Number *of Defects per Truck 5.25 4.4 4.55

Citations Issued 2,566 5,652 8,429

* Based on data obtained from full driver/vehicle inspections using CVSA/FHWA inspection criteria

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Random Vehicle Inspections

On March 28, 29 and 30, 1989, random vehicle inspections (CVSA level 1, full vehicle/driver inspections) were conducted on 1-70 at the West Friendship and New Market weigh stations from 7 am - 5 pm. Vehicles were selected for inspection on a random numerical basis to assure equal probability of selection.

Analysis of the random vehicle inspections indicates the following:

1. Of the 261 vehicles inspected, 120 vehicles (46%) were placed out of service.

2. Of the 261 drivers checked, 7 (3%) were placed out of service.

3. For^Maryland registered trucks inspected, 56 of the 110 (51-s) vehicles inspected were placed out of service.

Future random vehicle inspections will be conducted to determine if compliance is improved as a result of the Preventive Maintenance Program and other Maryland Motor Carrier Safety Program initiatives.

Post Accident Investigations

The Maryland State Police conducted a total of 94 in-depth investigations of serious accidents involving heavy trucks and buses during CY 1989. The results indicate that driver error was the cause and/or major contributing factor in 82% of those 94 accidents. The analysis further indicates that the truck or bus driver was at fault in 51% of the cases and the driver of the passenger car or light truck in 49%. Equipment related defects were the major cause and/or contributing factor in 18% of the 94 accidents.

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Heavy Truck Accident Trends

Heavy trucks (trucks of over 10,000 lbs. gross weight) were involved in 101 fatal and 1,920 serious injury accidents in 1988, slight increases over 1987. Fatal accident and serious injury accident data from 1983 to 1988 is as follows:

Year

5-Year

Heavv Trucks Average

1983 1984 1985 1986 1987 1983-87 1988

Accidents 95 94 112 109 100 102 101

Serious Injury Accidents 1,460 1,700 1,740 1,890 1,890 1,740 1,920

Definition of Heavy Truck

The Federal Highway Administration (FHWA) issued an advanced notice of the proposed rulemaking in early 1989 asking for comments on raising the definition of a heavy truck from over 10,000 pounds to over 26,000 pounds gross vehicle weight. Based on'vehicle out of service data and other considerations, the task force expressed a sense of opposing the increase of the weight threshold. The full MOOT response to FHWA is included as Appendix D.

Impact of Safety Program

The safety impact study will concentrate on a comparison of Maryland vehicles/drivers and out-of-state vehicles/drivers, and the impact of the program on accident reduction. The study will also attempt to ascertain the extent the number of road-side inspection and in-terminal activities should be increased in future years.

PUBLIC INFORMATION SUBCOMMITTEE

The Public Information Subcommittee emphasis during 1989 included a comprehensive Washington, D.C. Capital Beltway safety program. Its goal is to change aggressive driving behavior m

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all drivers and to foster mutual respect by all highway users.

The program, "Drive To Survive Together," is a cooperative program effort between Virginia and Maryland to improve traffic safety on the 64-mile beltway. Maryland's share is 41 of those miles.

Virginia and Maryland each provided $250,000 for the program and are attempting to raise matching funds and services from the business community. "Drive To Survive Together" initially began as a one-year campaign. With on-going enthusiasm based on improved beltway conditions and accident statistics, the campaign will continue with modifications made as needed to maintain highway safety.

In addition, a motor carrier element of the Maryland statewide "Drive To Survive" highway safety campaign has been developed. It includes TV, radio and print advertisement that will be included in a media campaign sponsored by Maryland Motor Truck Association early in 1990. Other major sponsors are being sought to bring this important safety message to the public.

HAZARDOUS MATERIALS SUBCOMMITTEE

The Hazardous Materials Subcommittee has reviewed a number of issues relating to the transportation of hazardous materials during 1989. The intent of the deliberations was to review existing conditions and provide comment and recommendations to the full Task Force. Topics included in the deliberations included: 1) Training, 2) Placarding, 3) Safe Havens, and 4) Routing. The findings of the committee and its recommendations are presented below:

Training

Training is an integral part of the operations of all transportation related programs. Well trained workers are usually associated with good companies that have good safety records. The new Commercial Drivers License will require that drivers hauling hazardous materials have a minimum level of competency. This is expected to further improve the generally safe record of hazardous materials haulers.

One additional training responsibility may have been placed on shippers, carriers, and various government and emergency response personnel under the Occupational Safety and Health Administration (OSHA) regulations promulgated this past March. In those. Code of Federal Regulations (29 CFR 1910.120),

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requirements on the training of employees that may be first responders to an incident situation involving hazardous materials, are mandated. If it is assumed that any employee that comes upon the scene of an accident becomes a "First Responder" under the regulations, then it becomes an obligation of the employer to provide training to meet the OSHA regulations. The specific language of the OSHA regulations from the Federal Register - of March 6, 1989 page 9329 29 CFR 1910.120 (q)(6)(i) is as follows:

First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

(A) An understanding of what hazardous materials are, and the risks associated with them in an incident. (B) An understanding of the potential outcomes associated with an emergency created when hazardous materials are present. (C) The ability to recognize the presence of hazardous materials in an emergency. (D) The ability to identify the hazardous materials, if possible. (E) An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook. (F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.

Based on the above regulations, it would seem to be appropriate, if not mandatory, for employers that have their workers in jobs where incidents are likely to be discovered to be trained to the level specified above.

Recommendation:

The committee believes that all employers, both private sector and government, must be encouraged to contact the Maryland Occupational Safety and Health Office and examine the State and federal

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OSHA regulations to determine whether their employees need to be trained to the above stated competencies. The liability costs for injured employees that were not trained must be considered in the evaluation of need.

Placarding

Placards are the means by which shippers and carriers express to the public and emergency responders the type of hazard that may be encountered in an accident or spill involving the motor vehicle and its contents. It is recognized that the placards do not reveal all hazards that may be encountered because many shipments of less than 1,000 pounds do not require placarding. The U.S. Department of Transportation (DOT) regulations specifically excluded these smaller shipments from the requirements because it did not want to nullify the impact of the highly visible warning with a saturation exposure. Only those shipments with quantities posing a significant risk are required to be placarded. Materials such as explosives, poisons, some radioactive materials, and flammable solids that are dangerous when wet are required to be placarded regardless of the quantity being transported.

The U.S. DOT has requested comments on the need to revise the placarding requirements. Some issues that are being discussed concern the size of placards, shipment quantities requiring placarding, and the use of displays or messages that may negate the effectiveness of placards.

The committee discussed these and a number of other issues relating to the placarding question. The findings of the committee are presented below:

A). Size. Increased placard size would certainly enhance visibility and, therefore, enhance safety. There are, however, physical limitations. Since experience has shown the current size to be satisfactory in most instances and the impact on industry to switch to a larger size (which could be only marginally larger) would be significant, the committee reached a consensus that no changes in size should be supported.

B). Quantity Thresholds. The existing regulations, which require placarding at the 1,000 pound level, are considered adequate for the expression of potentially significant hazards. At the present threshold, hazardous materials in quantities of less than the equivalent of two 55 gallon drums would not be expected to present a risk to emergency responders any greater

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than the risk posed by the fuel carried in the vehicles "gas" tank(s). Thus, reducing the threshold would not produce an enhancement of hazard expression. Increases in the threshold would reduce the warning effects and should not be considered.

C). Confusing Displays. The Federal regulations state that "No person may affix or display any sign or other device on a transport vehicle, ...., that by its color, design, shape, or content could be confused with any placard prescribed in this subpart."(49 CFR 172.502(b)). Some displays have been identified by the U.S. DOT as being confusing and have been ruled to be prohibited. The present practice of using the placard holders on vehicles to display safety messages such as "drive safely" can in certain situations be confused with a warning message. Although the U.S. DOT has not ruled on the use of these messages, the committee recommends that the use of such messages be discouraged and that the U.S. DOT consider the promulgation of a rule that would phase out their use.

D). Multiple Hazards. Many substances pose multiple hazards. One of the more prominent substances in this category is methyl isocyanate (MIC). Prior to Bhopal, the U.S. DOT classified this substance as a flammable liquid without any reference to its poison by inhalation hazard. Since Bhopal, the U.S. DOT has added the requirement to express the secondary hazard on the shipping documents and more recently added a requirement to display a warning statement on the outside of the transport vehicle.

Recommendation:

The U.S. DOT should be encouraged to establish in regulations a requirement for transporters to express all hazards that a substance may have. These hazards should be expressed in all communication elements; marking, labelling, placarding, and shipping paper descriptions.

E). off Road Use. The committee reviewed the need for emergency responders to have the same access to emergency information (i.e. placarding) at off road sites as they have for vehicles on the road. Since some companies use road vehicles as on site storage areas for certain hazardous materials, it would seem to be an appropriate practice to retain any required placarding on vehicles used for off road storage.

The use of placards on off road storage containers as a means of frightening would be criminals was also

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discussed by the committee. The consensus was that the expression of a hazard that does not actually exist can impede the actions of an emergency response team and prevent the timely control of a situation or the rescue of an accident victim. Security, at the expense of safety for emergency responders, should not be allowed. Other security measures should be employed rather than the use of inappropriate placards.

Recommendation;

Since the scope of the Federal and State regulations apply only to commercial transporters, the committee recommends that State and local fire officials consider the establishment of reguirements to maintain placarding of vehicles used in off road storage. Additionally, the committee recommends that the use of placards be prohibited on off road storage vehicles and buildings that do not contain hazards indicated by the placards.

F). Applicability To Government Vehicles. The Federal hazardous materials transportation regulations were developed as an outgrowth of the rules of the Interstate Commerce Commission. The authority of that organization was limited to commercial enterprises. Although the management of the highway safety program is now with the U.S. DOT, their regulations still limit applicability to commercial operations.

Hazardous materials are no less of a problem in government operations than they are in commercial enterprises. In fact, the personnel in government could be argued to be less experienced than their counterparts in industry that may work with the materials or vehicles on a more consistent basis.

Recommendation;

The committee recommends that revisions to the statutes and regulations be considered to reguire the use of placarding on government vehicles. Until those actions are implemented, the committee urges government agencies to voluntarily comply with the current rules regarding hazard communication: marking, labelling, placarding, and shipping papers.

Safe Havens

Safe havens are defined by the National Fire Protection

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Association (NFPA) as locations where shipments of certain very hazardous explosive materials can be safely stored. The NFPA has established a set of specific criteria that it feels is necessary for the protection of the surrounding public. The criteria include such items as: berms, fencing, lighting, paving, fire extinguishers, availability of power units, and surveillance.

These criteria are far in excess of the needs for the safe storage of most other hazardous materials. For this reason, the committee feels that it is necessary to clearly distinguish the difference between "safe havens" and "secure parking areas".

The need for safe havens is limited to those transporters that deal in the interstate transportation of explosives. This is believed to be a relatively small segment of the trucking industry. The key factor relating to the need for safe havens is the reguirements of the regulations that one person be constantly in view of the vehicle. In order to meet this reguirement, transporters must have two drivers or persons accompanying the vehicle on overnight trips, or the company must hire a night watchman.

Parking a vehicle and relinguishing the responsibility and liability to a safe haven operator could have significant implications regarding insurance costs. Operational costs, which would reguire the availability of a 24 hour watchman, in addition to the construction costs, would seem to make the establishment of a commercially viable safe haven guestionable in view of the limited extent of the industry need. A government operation would seem to be impractical for the same economic reasons.

The establishment of safe or secure parking areas for hazardous materials vehicles would carry much of the same economic disincentives. The establishment of secure parking areas for these vehicles that are having mechanical or containment problems would be problematical. The usual response decision is determined by the specific circumstances of the situation. In most instances, the emergency responders prefer to deal with the situation where it exists. Moving a vehicle that is having problems would be expected to exacerbate the situation. If a vehicle must be moved, the choice would be to move it the shortest distance possible. Given these circumstances, the selection of sites for any of these "safe areas" would be extremely difficult.

Recommendation;

The establishment of contingency plans by the Local Emergency Planning Committees (LEPCs) for highway incidents must be part of their overall responsibilities. Should they identify a need for a dedicated safe parking area for distressed

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vehicles, they should be encouraged to work with State and local emergency response personnel in developing their plans.

Routing

Specific routing requirements for hazardous materials shipments are limited to certain high levels of radioactive materials known as Highway Route Controlled Quantities (HRCQ) and Class A and B explosives. General routing requirements for all hazardous materials shipments are also contained in 49 CFR 397.9. The text of those requirements is as follows:

Unless there is no practicable alternative, a motor vehicle which contains hazardous materials must be operated over routes which do not go through or near heavily populated areas, places where crowds are assembled, tunnels, narrow streets, or alleys. Operating convenience is not a basis for determining whether it is practicable to operate a motor vehicle in accordance with this paragraph.

The radioactive materials rules are contained in Title 49 of the Code of Federal Regulations (CFR) at part 177.825. They require that the shipments be made on "safe" routes and except for emergency or delivery situations shall be on "designated" routes. Designated routes include the federal interstate system and any routes designated by states as alternates. Specific route plans are to be developed for each HRCQ shipment and provided to the driver.

Since the initial construction of the Interstate system, many of the system's segments in and around urban centers have become heavily congested. The Baltimore and Capital Beltways are prime examples of this situation. Because of these changes in traffic use patterns, it could be argued that those segments of the Interstate system are not as safe as some of the more rural areas. If this premise is acceptable, then it could be reasoned that some consideration should be given to evaluating the risks of having hazardous materials shipments routed over the less risky segments. In order to conduct a comprehensive risk analysis that involves interstate routes, a nationally uniform procedure needs to be established. The U.S. DOT has such a document for HRCQs of radioactive materials, but has not extended it to cover other hazardous materials.

Maryland, in 1981, used the federal guidelines to establish alternate routes for HRCQ shipments. They included U.S. Route 301 and U.S. Route 40/48. On May 12, 1988, the U.S. DOT published new rules on designating routes for HRCQs of

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radioactive materials. In these rules at 49 CFR 177.825, alternate routes must be registered with the U.S. DOT. Maryland has not fully complied with the registration reguirements and the nreviously designated routes are now not authorized for those shipments. With the prohibition of HRCQ shipments through the Pennsylvania Turnpike tunnels, any shipments from the Maryland area to western states must be routed north or south on interstates 81,83,or 95 to Interstate routes 80 or 40 in northern Pennsylvania or Tennessee.

Routing reguirements for Explosives A and B shipments are presented in 49 CFR 397.9. Those regulations reguire a written route plan similar to those for HRCQs.

The absence of any other routing regulations has placed the burden of selecting routes on the shippers and carriers. Except for the specific guidance that applies only to HRCQ shipments routing procedures are undefined. It is in this area where the U.S. DOT is beginning to consider whether specific procedures need to be developed.

In an Advance Notice of Proposed Rule Making in the Federal Reaister of April 7, 1988, the U.S. DOT called for comments on this issue. Factors such as the identification of which elements are significant, how they should be weighted, and how thev should be evaluated were opened for discussion. Comments cost factors were also sought. Possibly of primary significance was the question of what roles industry, local, state, and federal agencies should take in the process.

Legislative involvement in the selection of routes was not considered by the committee to be appropriate. The process of objectively and scientifically examining all of the elements that qo into a risk assessment of alternative routes requires the consideration of many issues beyond those that can be dealt with in a political forum.

Recommendations:

1. Maryland should encourage the U.S. DOT to develop nationally uniform procedures for evaluating the risks of routing various hazardous materials.

2. Maryland Department of Transportation should establish a designated unit to serve as the focus of highway routing issues.

3. An advisory body for the routing unit should be established to provide input into the development and use of any routing procedures. The advisory body should have representatives from police, fire, emergency response, health, environment, and industry

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organizations.

4. The routing unit should be provided with authority to administer all routing programs in the State and be given the authority to resolve any disputes that may develop among local jurisdictions. The unit would likewise need to yield to federal authority in interstate disputes.

5. Routing restrictions should be applied to only those transported substances that pose a "significant risk", as defined by the U.S. DOT, to the public. The committee recommends that the "significant" risk substances include only those materials that pose a poison by inhalation, explosive, or significant radiological (Highway Route Controlled Quantities) hazard. National uniformity in the selection of substances subject to routing restrictions is essential.

6. Industry should be encouraged to voluntarily establish routing procedures for all their hazardous materials shipments to minimize risks to the public. Time of day considerations should be weighed in their planning to avoid the higher risks associated with rush hour travel.

TRAINING AND PENALTIES SUBCOMMITTEE

The subcommittee addressed several issues regarding truck driver training, licensing and penalties in 1989. The sub- committee looked at training opportunities for Maryland truck drivers that would enable them to successfully pass the commercial driver's examination in order to maintain their ability to operate commercial vehicles. The subcommittee found sufficient opportunities in place for such training and was apprised of the fact that many other opportunities are being developed in the state to serve this need.

Some of the training organizations that are available in Maryland are included in Appendix E. The quality of material and training opportunities available appears, at present, to be adequate; however, the needs of the Maryland driver cannot be adequately assessed at this time. Some experience after January 1, 1990 with the success and/or failure rate of the Maryland truck drivers, will help to determine any additional needs that need to be put in place to assist the Maryland commercial driver in obtaining the required commercial driverxs license.

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The Maryland Commercial Driverxs License Program has been effectively developed administratively by the Motor Vehic e Administration. The Administration appears to be ready to implement Maryland^ Commercial Drivers License Program commencing January 1, 1990. The CDL program resulted from the 1986 Federal Safety Act, that requires the states to establish classified driverxs licenses, stricter more efficient testing nrocedures and stricter standards of behavior for operators of commercial motor vehicles. Under this le9islat^°n' motor vehicles are defined as trucks in excess of 26,000 pounds, buses carrying more than 15 passengers and transportation 0

hazardous materials requiring placarding regardless of the nature of the vehicle used. This important truck safety legislation will have far reaching impact on commercial truck transportation in the United States.

The Task Force is providing sufficient copies of the highly touted video AAA Foundation for Traffic Safety presentation, "Sharing the Road With Big Trucks", to the professional driving schools in Maryland. The Maryland Motor Vehicle Administration Driver Improvement Program is being reviewed further to insure that the commercial vehicle driver is getting adequate consideration and information from its courses. This will made part of an ongoing process of the Motor Vehicle Administrationxs review and quality control procedures m i Driver Improvement Program.

The subcommittee is recommending to the task force that it endorse the more extensive use of defensive driving courses by the trucking industry.

The subcommittee reviewed and has endorsed the updated fine schedules for commercial vehicle drivers submitted by the Maryland State Police. This new fine schedule was adopted by under Margaret Kostritsky, Chief Clerk, District Court. Publications of the new fine schedule will be incorporated in next printing on July 1, 1990 of the District Courts official fine and point assessment pamphlet.

On Capital Beltway safety issues, this subcommittee realizes that the undertaking of or recommendation of any programs to affect commercial drivers'attitudes which may be unfit or unsafe for the Capital Beltway, requires extensive review and identification of attitudes presently held by thesf., , c ^ drivers and further cataloging of these negative attitudes and behavior patterns, the review of this issue by this subcommittee would require a lot of in-depth studying and additional resources to accomplish. This might be a major singular topic to invol the committee and the task force in 1990.

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RELATED SAFETY ISSUES SUBCOMMITTEE

The Subcommittee on Related Safety Issues met twice during the year and decided to monitor the many Federal Motor Carrier Safety Regulations rulemakings to keep the committee advised on the status of ongoing dockets that would impact on Maryland's truck and bus safety regulatory program. These rulemakings include:

Docket MC-89-4 Emergency Warning Devices Docket MC-89-5 Redefinition of Commercial Motor Vehicle Docket MC-89-6 Motor Vehicle Marking Docket MC-88-14 Commercial Driver's License Standards Docket MC-114 Recision of the Commercial Zone

Exemption Docket MC-116 Controlled Substances Testing Docket MC-128 Blood Alcohol Concentration Level for

Commercial Vehicle Drivers Docket 89-17 Safe Entry and Exit Requirements for

Commercial Vehicles Docket 89-18 Reflecting Surfaces

The Subcommittee also decided to review developing issues which have not yet reached the rulemaking stage. These include:

o The hazards associated with alternative fuels for commercial vehicles.

o Opportunities for improving commercial vehicle accident data.

o Need for increased roadside rest facilities for commercial vehicles.

The Subcommittee plans to continue to monitor Federal developments in the motor carrier safety regulatory field as reflected in rulemakings by the Federal Highway Administration, the National Highway Traffic Safety Administration and the Office of Hazardous Materials of the Research and Special Programs Administration, and such other emerging commercial vehicle safety issues as are identified.

At this time, the Subcommittee recommends continued efforts to identify and fund additional or enlarged roadside rest facilities for commercial vehicles within the State to allow parking for commercial vehicles in order that fatigued drivers may get appropriate rest and meet hours of service limitations.

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PERMITTING SUBCOMMITTEE

The Permitting Subcommittee met twice during 1989.

Trucking in Maryland: A Handbook was revised and reviewed by the subcommittee. Several parts of the handbook were revised to reflect 1989 legislation and revisions to motor carrier regulations.

The subcommittee undertook a detailed review of the New England Oversize/Overweight Agreement and the Multi-State Oversize/Overweight Trip Permit Agreement. In addition, the subcommittee is also reviewing the International Temporary Permit Aareement for fuel tax and International Registration Plan temporary permits. The purpose of these agreements 15 to enable a motor carrier to obtain the required permits for member states by contacting one state.

The Minnesota Department of Transportation conducted a survey in 1989 on behalf of American Association of State Highway Transportation Officials to obtain opinions and data on oversize/overweight issues and status on implementation of the National Governor's Association consensus agenda. The subcommittee provided comments in response to that survey.

The Federal Highway Administration contracted with a consultant in late 1989 to study alternatives for simplifying oversize/overweight permitting procedures. The subcommittee will monitor the progress of that study.

The subcommittee remains interested in establishing a motor carrier telephone information service as a step to improving services. The decision was made previously to incorporate that service into the Motor Carrier Services Section of Motor Vehicle Administration. Three additional positions are needed to implement that service.

The Subcommittee will continue to pursue these and other issues in 1990 to provide efficient services.

CAPITAL BELTWAY AND

OTHER TRAFFIC SAFETY AND MANAGEMENT ISSUES

The Final Report of the Truck Safety Task Force dated January 1, 1989, included a section on various traffic safety issues that were raised subsequent to a series of truck accidents

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involving hazardous materials on the Capital Beltway. The great majority of the suggestions made have been acted on and the results are shown in Appendix F. In addition, MDOT issued a report entitled Beltway Safety in 1989 at the reguest of the Maryland General Assembly.

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A-1

Summary of Task Force Meetings January - December, 1989

April 21st

Secretary Trainer welcomed everyone to the new task force, officially called the Governor's Motor Carrier Task Force for Safety and Uniformity, and announced the new subcommittee assignments. There was a presentation on the effect on the Department of the International Registration plan and the fuel tax. There was also a discussion of the results of the just concluded 1989 General Assembly session. Major items which passed included the Commercial Drivers License, the covered load bill, and guarterly proration of registration. Other items which failed included action on increased inspections, weight tolerances, 53 foot trailers, fuel tax, and trailer length-size restrictions.

June 7th

Additional appointments to the Task Force and Advisory Committee were announced. Status reports from each subcommittee were given and of particular interest were the scheduled publication of the Preventive Maintenance regulations and the time-table for the motor carrier portion of the Drive to Survive campaign. There was a thorough discussion of the proposed federal rulemaking on changing the definition of trucks covered from 10,001 to 26,001 pounds. The Task Force endorsed the recommendation to not change to the higher threshold and to keep trucks of 10,001 pounds subject to the inspection and enforcement reguirements.

August 1st

Copies of the new Preventive Maintenance brochure were passed out for review by the task force members. The group was briefed on the mailing to be made to the registered owners affected by the PM program and on the upcoming public meetings to explain the program. Also discussed were the arrangements being made for Maryland to co-host the Mid-Atlantic Workshop and the feasibility study of the use of photo-radar as an enforcement tool on the Capital Beltway.

A-2

October 5th

The group was informed on the results of the PM public hearings. Approximately 2,500 people attended the eight meetings and planning is underway to conduct seven more meetings throughout the state with state, local, and other governmental agencies to explain the PM program reguirements to them. The Drive to Survive Together ads, which are to air over the next month, were previewed. The results of the Mid-Atlantic Workshop were discussed with the consensus of those who attended that too much of the agenda was taken by federal government speakers. The issue of Maryland's weight law being in conflict with federal law was reviewed and the two areas of conflict are the tolerance for agricultural and forest products and for sealed seagoing containers.

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Maryland Motor Carrier Industry Advisory Committee to the

Governor's Motor Carrier Task Force for Safety and Uniformity

CHAIRMAN J. Sean Callahan

Preston Trucking Co., Inc. 151 Easton Boulevard

Preston, Maryland 21655 (800) 551-7737 or 1-673-7151

MEMBERS D. L. Albert! Albert! Van & Storage, Inc. 18930 Gaithersburg- Laytonsville Rd. Gaithersburg, Md. 20879-4196 840-2100

Chris Balodemas Director of Traffic, Transportation

and Fleet Maintenance Giant Food, Inc. 6000 Sheriff Road Landover, Md. 20785 341-4875

Rita Bontz, President Independent Truckers

and Drivers Association 1109 Plover Drive Baltimore, Md. 21227 242-0507

Donald M. Bowman D. M. Bowman, Inc. Route 2, Box 43 A-l Williamsport, Md. 21795 223-6900

Theodore E. Brooks, Sr. 5513 Dolores Avenue Baltimore, Md. 21227 247-1836

Edward Gallagher IV President Maryland Motor Truck Association George Transfer, Inc. P. 0. Box 3153 Parkton, Md. 21120 329-4000

MEMBERS Eugene Higgins Joseph J. Hock Trucking, Inc. 5501 Belle Grove Road Baltimore, Md. 21225 789-4400

Ty Pruitt Ty Pruitt Trucking 539 N. Dean Street Baltimore, MD 21205 732-5020

H. Glenn Miller Genstar Stone Products Co. Executive Plaza IV 11350 McCormick Road Hunt Valley, Md. 21031 628-4000

John C. Miller Maryland Farm Bureau 8930 Liberty Road Randallstown, Md. 21113 922-3426

Thomas March Greyhound Lines, Inc. 1110 New York Avenue, N.W. Washington, D. C. 20005 202-289-5133

Ray Poussard Public Affairs United Parcel Service 316 Pennsylvania Avenue Washington, D. C. 20003

Peter Ramaley S & A Distribution Services 900 S. Eutaw Street Baltimore, Md. 21230 685-2200

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Edwin F. Hale, President Port East Transfer, Inc. Pulaski Hwy & 68th Street Baltimore, Md. 21237 342-1500

Rebecca Hahn Windsor Hahn Transportation, Inc P.O. Box 8 New Market MD 21774 865-5467

Bill Rohrbaugh, President Rohrbaugh's Charter Service 3395 Main Street Manchester, Md. 21102 239-8000

Gordon Westkamp Baltimore Tank Lines P. O. Box 1028 Glen Burnie, Maryland 21061 760-5500

Bill Orner President Western Maryland Trucker

Association R.D.I Box 209 Grantsville, MD 21536 895-5436 (office) 895-5710 (home)

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Vehicle Inspection and Maintenance Subcommittee

CHAIRMAN Clyde E. Pyers

Director, Office of Transportation Planning Maryland Department of Transportation

P.O. Box 8755 MS 135 BWI Airport, MD 21240

859-7333

MEMBERS MEMBERS

Captain Richard Janney Automotive Safety Enforcement Division

Maryland State Police 6601 Ritchie Highway Glen Burnie, MD 21062

Bruce Diehl Motor Vehicle Administration 6601 Ritchie Highway Glen Burnie, MD 21062

Edward Gallagher IV George Transfer, Inc. p. O. Box 3153 Parkton, MD 21120

Carl R. Harbaugh MDOT/OTP P.O. Box 8755 BWI Airport, MD 21240-0755

Frank Maule Department 801 Giant Food, Inc. P. O. Box 1804 Washington, DC 20013

Claude M. Ligon, Commissioner Public Service Commission American Building 231 E. Baltimore St. Baltimore, MD 21202

Richard Page Public Service Commission American Building 231 E. Baltimore St. Baltimore, MD 21202

Dr. Harvey Clearwater Associate Professor Director, Safety Education Center

University of Maryland PERH College Park, MD 20742

Murray Zepp Maryland Motor Truck Assoc. 3000 Washington Boulevard Baltimore MD 212 30

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PM Regulations Working Group

Mr. Eugene Higgins Joseph J. Hock Trucking, Inc. 5501 Belle Grove Road Baltimore, Maryland 21225 789-4400

Ms. Rita Bontz, President Independent Truckers and

Drivers Association 1109 Plover Drive Baltimore, Maryland 21227 242-0507

Mr. Murray Zepp Maryland Motor Truck Association, Inc. 3000 Washington Boulevard Baltimore, Maryland 21230 644-4600

Mr. Dave Gaulden Preston Trucking Co. 151 Easton Blvd. Preston, MD 21655 673-7151

Mr. Louis F. Sturn LFS Coach, Inc. 2200 Ridge Road Baltimore, MD 21207 298-3334

Mr. V. Fred Storm Monumental Motor Tours, Inc. 3319 Pulaski Hwy. Baltimore, MD 21224 675-8000

Capt. Richard Janney Commmander Automotive Safety Enforcement Division Maryland State Police 6601 Ritchie Highway Glen Burnie, Maryland 21062 768-9175

Lt. Bob Kirk Maryland State Police 1401 Bel Air Road Bel Air MD 21014 879-2101

Mr. Richard Page Public Service Commission American Building 231 E. Baltimore Street Baltimore, MD 21202 333-6060

Mr. Andrew C. Phillips Public Service Commission American Building 231 E. Baltimore Street Baltimore, MD 21202 333-6013

Mr. W. Drew Stabler Agriculture 4401 Brookeville Road Brookeville, MD 20833 774-9290

Mr. Frank Maule Department 801 Giant Food, Inc. Post Office Box 1804 Washington, D.C. 20013 995-4717

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Dr. Harvey Clearwater Associate Professor Director, Safety Education

Center University of Maryland PERH College Park, MD 20742 454-2753

Mr. Clyde Pyers Director Office of Transp. Planning MDOT, M.S. 135 P.O. Box 8755 BWI Airport, MD 21240-0755 859-7333

Mr. Mati Koiva Office of Transp. Planning MDOT, M.S. 135 P.O. Box 8755 BWI Airport, MD 21240-0755 859-7333

Ms. Diane Ratcliff Manager, Statewide Programs Mass Transit Administration 300 W. Lexington Street Baltimore, MD 21201-3415 333-2993

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Related Safety Issues Subcommittee

CHAIRMAN Kenneth L. Pierson

3300 Glen Avenue Glenn Dale, MD 20769

390-6640

MEMBERS Cpl. M. (Buddy) Bell Maryland State Police S.T.E.U. 777 Washington Blvd. Jessup MD 20794 799-0146

Rita Bontz President Independent Truckers and

Drivers Association 1109 Plover Drive Baltimore, MD 21227 242-0507

James Latchaw 14201 Gaines Avenue Rockville, MD 20853 871-7067

Frank Maule Department 801 Giant Food, Inc. Post Office Box 1804 Washington, D.C. 20013 341-3165

Mike Zezeski Office of Traffic 7491 Connelley Drive Hanover, MD 21076 787-5860

MEMBERS Andrew R. Hricko General Counsel Insurance Institute for

Highway Safety Suite 800 1005 N. Glebe Road Arlington VA 22201 (703)247-1500

Richard Page Public Service Commission American Building 231 E. Baltimore Street Baltimore, MD 21202 333-6063

Joseph Colden Motor Vehicle Administration 6601 Ritchie Highway Glen Burnie, MD 21062 787-2971

Anthony Dell'Isola Fleet Specialist United States Fidelity &

Guaranty Company 100 Light Street Baltimore, MD 21202 625-5684

Houston D. Wedlock Safety Coordinator Preston Trucking Company 151 Blades Lane Baltimore, MD 21061 636-3000

Carl R. Harbaugh MDOT/OTP P.O. Box 8755 BWI Airport, MD 21240-0755 859-7364

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Hazardous Materials Subcommittee

CHAIRPERSON Dr. Katherine P. Farrell

Asst. Sec. for Toxics, Environmental Science & Health Maryland Department of the Environment

2500 Broening Highway Baltimore, MD 21224

(301) 631-3775

MEMBERS

George Harman Program Administrator Toxics Registries & Analysis Prog. 2500 Broening Highway Baltimore, MD 21224 631-3794

William P.- Rupert Chief, Haz. Mat. Trans. Division Md. Dept of the Environment 2500 Broening Highway Baltimore, MD 21201 631-3791

Max Drauschak Preston Trucking Co. 151 Easton Boulevard Preston, MD 21655 673-7151

Peter B. Ramaley Inland Leidy 900 S. Eutaw Street Baltimore, MD 21230 685-2200

Michael Zezeski State Highway Administration 7491 Connelley Drive Hanover, MD 21076 859-7482

Kevin McNiel Fleet Transit, Inc. 3225 Tate Street Baltimore MD 21226 355-7910 1-800-848-9393

MEMBERS

Lt. Lonnie Fulton Md. Transportation Authority P. O. Box 19691 2200 S. Clinton Street Baltimore, MD 21225 522-9409

Murray Zepp Maryland Motor Truck Association 3000 Washington Boulevard Baltimore MD 21230 644-4600

Allen Ward Office of Fire Marshall 6776 Reisterstown Road Suite 314 Baltimore, MD 21215 836-4844

Capt. Richard Janney Automotive Safety Enforcement Division

Maryland State Police 6601 Ritchie Highway Glen Burnie, MD 21062 768-1735

Lt. Kenneth Harry Truck Enforcement Division Maryland State Police 7777 Washington Boulevard Jessup, MD 20794

James Henry Md. Port Administration P.O. Box 3908 Baltimore MD 21222 633-1057

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MEMBERS

Joseph L. Muscaro Haz. Mat. Program Manager U.S. DOT Federal Highway Administration 31 Hopkins Plaza, Rm. 1615 Baltimore MD 21201 962-4571

Mati Koiva Md. DOT BWI Airport P.O. Box 8755 Baltimore MD 21240 859-7362

MEMBERS

Paul M. Bomgardner Haz. Mat. Specialist Safety Department American Trucking Association 2200 Mill Road Alexandria VA 22314-4677 (703) 838-1849

C-7

Training and Penalties Subcommittee

CHAIRMAN Melvin Holmes

Associate Administrator Driver Services

Motor Vehicle Administration 6601 Ritchie Highway

Glen Burnie, MD 21062

MEMBERS MEMBERS

Dr. Harvey Clearwater Associate Professor Director, Safety Education Center

University of Maryland PERH College Park, MD 20742

William L. Rohrbaugh President Maryland Bus Association Rohrbaugh's Charter Service,

Inc. 3395 Main Street Manchester, MD 21102

Capt. Richard Janney Commander Automotive Safety Enforcement Division

Maryland State Police 6601 Ritchie Highway Glen Burnie, MD 21062

Senator Thomas Yeager Legislative District 13 413 Main Street Laurel, MD 20707

Rita Bontz President Independent Truckers and Drivers Association

1109 Plover Drive Baltimore, MD 21227

Murray Zepp Maryland Motor Truck Assn. 3000 Washington Boulevard Baltimore, MD 21230

Capt. John Himmelmann Commander Truck Enforcement Division Maryland State Police 7777 Washington Boulevard Jessup, MD 20794

Delegate Jean Roesser 10830 Fox Hunt Lane Potomac, MD 20854

Ronald Lipps Office of Transportation Planning, MDOT BWI Airport, MD 21240-0755

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Permitting Subcommittee

CHAIRMAN Mati Koiva

Maryland Department of Transportation Office of Transportation Planning, MDOT

P.O.Box 8755 BWI Airport, MD 21240-0755

MEMBERS

Rita Bontz, President Independent Truckers and Drivers Association

1109 Plover Drive Baltimore, MD 21227

Capt. John Himmelmann, Commander Truck Enforcement Division Maryland State Police 7777 Washington Boulevard Jessup, MD 20794

Capt. Richard Janney, Commander Automotive Safety Enforcement Division

Maryland State Police 6601 Ritchie Highway Glen Burnie, MD 21062

Ed Hechmer, Chief Toll Facilities Police Baltimore Harbor Tunnel P. O. Box 3432 Baltimore, MD 21225

Steve Adkins MDOT/OTP P.O. Box 8755 BWI Airport, MD 21240-0755

MEMBERS

Patricia Shreeve State Highway Administration 707 N. Calvert St. Baltimore, MD 21202

Mr. Arthur E. Price, Director Motor Vehicle Fuel Tax Div. Comptroller of the Treasury P. O. Box 1751 L. L. Goldstein Building Annapolis, MD 21401

John Cahill State Highway Administration 707 N. Calvert Street Room #410 Baltimore, MD 21202

Rose Byron State Highway Administration 707 N. Calvert Street Room #112 Baltimore, MD 21202

Marshall Rickert Administrator Motor Vehicle Administration 6601 Ritchie Highway Glen Burnie, MD 21062

Joseph Colden Motor Vehicle Administration 6601 Ritchie Highway Glen Burnie, MD 21062

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C-9

Public Information Subcommi'ttee

CHAIRPERSON Hannah Romney-Whitney

Director, Public Affairs Maryland Department of Transportation

P.O. Box 8755 BWI Airport, Maryland 21240-0755

(301)859-7300

MEMBERS

Murray Zepp Maryland Motor Truck Association 3000 Washington Boulevard Baltimore, Maryland 21230 644-4600

MEMBERS

Rita Bontz President Independent Truckers and

Drivers Association 1109 Plover Drive Baltimore, Maryland 21227 242-0507

Mati Koiva MDOT/OTP P.O. Box 1755 BWI Airport, MD 21240- 0755 859-7362

Kenneth L. Pierson 300 Glen Avenue Glenn Dale, Maryland 20769 390-6640

Ken Holter MDOT/OTP P.O. Box 8755 BWI Airport, MD 21240-0755 859-7605

Lt. Johnny L. Hughes Maryland State Police 1201 Reisterstown Road Pikesville, MD 21208-3899 653-4343

Richard Page Public Service Commission American Building 231 E. Baltimore Street Baltimore, Maryland 21202 333-6060

4/18/89

D-1

Maryland Department ofTransportatmn

William Donald Schaefer Governor

The Secretary's Office Richard H. Trainor Secretary

June 16, 1989 ■

Chief Counsel .Federal Highway Administration Room #4232 400 Seventh St. S.W. Washington, DC 20590

RE: FHWA Docket No. MC-89-5 Commercial Motor Vehicle Definition

'To Whom It May Concern:

We have reviewed the advanced notice of proposed rulemaking regarding the 10,001 pound vs. the 26,001 pound gross vehicle weight rating (GVWR) threshold for commercial motor vehicle definition and offer the following comments.

Maryland adopts all Federal Motor Carrier Safety Regulations (FMCSR's) by reference according to Maryland law. Maryland is currently implementing its own preventive maintenance (PM) program which reguires. that all commercia1! motor vehicles must be inspected, repaired, and maintained every 12 months or every 25 000 miles, whichever occurs first.- For the PM program, the threshold for trucks is 10,001 pounds. Roadside inspection is one method which will be used to enforce the PM requirement.. If the threshold were increased to 26,001 pounds, trucks between 10 001 and 26,'000 pounds would not be subject to random roadside inspections and would require "probable cause", to be stopped for inspection. Such a situation would mean that trucks between 10,001 pounds and 26,000 pounds would be subject to a lower level of'enforcement than those over 26,000 pounds. In order to achieve uniform enforcement of the Maryland PM law, we favor retention of the threshold at 10,001 pounds GVWR.

. Many vehicles in the 10,001 to 26,000 pound category operated under the commercial zone exemption repealed by Congress and FHWA in 1988. Some of these motor carriers now complain of additional paperwork burden especially the requirement to conduct vehicle inspections by the driver and to prepare records of,such .

' inspections. These carriers maintain that such frequent daili' inspections are unnecessary since the vehicles travel only short distances each day. To alleviate this situation, perhaps the inspection of the vehicle by the driver could be based on a . combination of time and mileage, e.g. if miles traveled per day

is less than. 250,, inspection by drivers would be required after

ocQ_7333 My telephone number Is (301)- —.

TTY For The Deaf (301) 859-7227 Post Ollice Box 0755, Baltimore/Washington International Airport, Maryland 21240-0755

D-2

traveling 250 miles. However, our enforcement people point out. that changing the daily inspections to a time/mxleage criteria •would make enforcement more difficult.

- Xn an attempt to assess the level-of maintenance of the

10 001 to 26,000 pound vehicle category, Maryland recently conducted random roadside inspections of vehicles and their drivers in this weight range with the following results.

No. 0f No. COS* Percentage (X)

Date Inspections Inspections 00S

21 54 13 4.5

March, 1989 39 May, 1989 29

I'M . 8^ I? -|z TOTALS 152 TOTALS

* COS - Out of service.,, _ , * > *" * ■, .

. %. v • •

•i' Maryland also recently conducted a random inspection of all buses and heavy trucks-with the following results.

No. of No. COS Percentage (%)

Date Inspections Inspections 00S

March, 1989 261 , ^ 120 . A6 , ■

Maryland roadside",inspection results of all buses and trucks since January 1, 1988 are. as follows: - •

No. 0f No. COS Percentage (7o)

Inspections Inspections OOS

27,543 15,184

Date

CY 1988 -• -- _ cno

Qtr.end 3/31/89 5,068 2,509

April, 1989 1>648 888 —ijx TOTALS 34,259 TB73BT

Although the out of service rate for the 10,001 to 26,000 pound vehicles is lower than the rate for all vehicles, we consider the 42% rate unacceptable.

We are concerned that exempting a whole class of yeh^c^!| ^°mo£

FMCSR's will send the "wrong" safety message to owners and drivers ot such vehicles. According to U.S. Department of Transportation fatal accident records for 1987, the following is a comparison of fatalities per 100 million vehicle miles traveled:

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D-3

* s'.e for tSioks Slween'lo!p01UMd 26,000 pounds, and; * 2.4 for all vehicles :

A1 though the fatal accident "t-fo-the 10 00^ to Z^OOO pounc^ ^

continuing nationally to reduce no T^rooertv losses. We believe

tha ^ ret a in ing the'? 0^0 01 ^1^00 pound vehicles in the overall safety program will enhance hrghway safety.

We appreciate the dilemma the current situation P^cs to the g

if ?hf tffldA^K^

the

could be provided an additional incentive assistance grant for

complying with FMCSR s. 1 '•>. '■ > :

So^eL^litoug^LrunantSous, Jhe above comments reflect the

maj ority Motor Truck

s.

■ .^iriont'MrTtaySV PoLsLd of United Parcel Service.has asked us to provide you his comments which are attached.

Enclosed is a WordPerfect 5.0 floppy disk of this letter as. requested. . •

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D-4

We hope these comments are helpful to you and look forward to our continued mutual efforts to improve highway safety.

CEP:si Enclosures

cc: Secretary Richard H. Trainor Deputy Secretary Steve Zentz Walter Thompson, MMTA Harry Filling, BGScE Russ Fiste, CVSA Ray Poussard, UPS ,

Sincerely

Clyde E. Pyers Director Office of Transportation Planning

/ .

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D-5

Comments received from Mr. Rayne G. Poussard, United Parcel Service re; FHWA Docket No. MC-89-5

' Please know that it is my opinion that MCSAP was intended at the outset for larger vehicles of the- 26,000 GVW variety; and for vjhicle safety requirements rules governing these vehicles ought to remain - the same at that threshold. Vehicles under 26,001 GVW were never thought to'; be over the road variety, rather always returning to facility from local runs.

Our own entire fleet 80,000 vehicles are inspected through a _ rigid PMI schedule regardless of weight, size.-

As to driver qualifications, I can't emphasize the importance of regulating driver qualifications at the 10,000 GVW threshold. ^ Drivers cause accidents all too often, not equipment. I realize CDL, drua testing, IRP," etc. are 26,000 GVW, but as to driver qualifications, the 10,000 GVW ought to be retained without exception.

Question 1 of CVSA (see attached): /Yes to intra/inter. Question 2, clearly NO. _ .

As a matter of fact, if Question 2 can't be^two part _ classification such as 10,000 GVW for driver qualification, and 26^000 GVW for equipment, then it must be 10,000 GVW for driver •regulation threshold. . .

I hope I haven't muddied up the waters for you. With kindest. . best wishes, I remain.' " .

' -.y * ■ .

Signed: Ray Poussard

I

E-1

COMMERCIAL DRIVER LICENSING TRAINING SOURCES

Cecil Community College* 97 N. Leslie Road Northeast, Maryland 21901

Dundalk Community College* 7200 Sollers Point Road B Baltimore, Maryland 21222

University of Maryland * College Park, Maryland

Diesel Institute * 5600 Columbia Park Road Cheverly, Maryland 20785

National Training System, Inc. * P.O. Box 2719 Laurel, Maryland 20708

Neilson Associates Transportation Safety Program 10101 Dubarry Street Glen Dale, Maryland 20769

Transportation Safety Consultants, Inc. 10740 Lyndale Avenue South Bloomington, MN 55420

SPA (Safe Performance Associates) 3250 U.S. Highway 19, North Clearwater, Florida 34618

W.C. Porter * Drive - Rite 95 Acquhart Road Glen Burnie, Maryland 21061

American Roadcraft Testing and Training Services 15200 - A Shady Grove Road Suite 536 Rockville, Maryland 20850

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American Trucking Association 2200 Mill Road Alexandria, Virginia 22314

Commercial Testing and Training Service 101 Spruce Road Seaford, Delaware 19973

National Training Systems Institute Publications, Inc.

1235 Woodrow Street, NE Salem, Oregon 97303

* Driver Testing Facility

APPENDIX F

Capital Beltway Safety Issues

F-1

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