Intermodal Equipment Providers RuleIntermodal Equipment Providers Rule

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Presentation ObjectivesPresentation Objectives

To explain industry responsibilities under the To explain industry responsibilities under the

new intermodal equipment provider (IEP) rule.new intermodal equipment provider (IEP) rule.

To facilitate compliance and improve vehicle To facilitate compliance and improve vehicle

safety through better understanding of these safety through better understanding of these

requirements.requirements.

To explain how FMCSA will enforce the IEP rule.To explain how FMCSA will enforce the IEP rule.

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To ensure that IEPs, motor carriers, and To ensure that IEPs, motor carriers, and drivers drivers shareshare safety responsibility for safety responsibility for intermodal equipment (IME) operating on our intermodal equipment (IME) operating on our nation’s highways. nation’s highways.

Why FMCSA Issued the IEP RuleWhy FMCSA Issued the IEP Rule

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Who Is Affected by the IEP RuleWho Is Affected by the IEP Rule

IEPsIEPs

Drivers Drivers

Motor carriers operating as IEPsMotor carriers operating as IEPs

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Definitions Definitions

Interchange – Interchange – The act of providing intermodal equipment to a motor carrier (except The act of providing intermodal equipment to a motor carrier (except

for leasing). for leasing).

Intermodal Equipment – Intermodal Equipment – Intermodal container chassis and all other kinds of trailers, chassis, Intermodal container chassis and all other kinds of trailers, chassis,

and associated devices used to transport intermodal containers.and associated devices used to transport intermodal containers.

Intermodal Equipment Interchange Agreement Intermodal Equipment Interchange Agreement –– Written agreement between an IEP and a motor carrier establishing Written agreement between an IEP and a motor carrier establishing

their responsibilities and liabilities. their responsibilities and liabilities.

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What IEPs Must DoWhat IEPs Must Do

If you are an IEP, you must –If you are an IEP, you must – Register with FMCSA.Register with FMCSA. Mark your IMEMark your IME..

Establish and implement a systematic inspection, repair, Establish and implement a systematic inspection, repair, and maintenance (IRM) program.and maintenance (IRM) program.

Maintain inspection, repair, and maintenance records.Maintain inspection, repair, and maintenance records. Require and respond to driver inspections.Require and respond to driver inspections. Conduct periodic IME inspections.Conduct periodic IME inspections.

We will explain these requirements in the next few We will explain these requirements in the next few slides.slides.

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IEPs Must Register with FMCSAIEPs Must Register with FMCSA

Register by –Register by – Completing and filing Form Completing and filing Form

MCS-150C andMCS-150C and Obtaining a USDOT Obtaining a USDOT

Number.Number.

You must register by You must register by

December 17, 2009.December 17, 2009.

You must update your You must update your

registration every 2 years.registration every 2 years.

USDOT # USDOT #

Ending inEnding inRenew by Last Renew by Last

Day ofDay of

11 JanuaryJanuary

22 FebruaryFebruary

33 MarchMarch

44 AprilApril

55 MayMay

66 JuneJune

77 JulyJuly

88 AugustAugust

99 SeptemberSeptember

00 OctoberOctober

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IEPs Must “Mark” IMEIEPs Must “Mark” IME

Mark your IME by December 17, 2010. Mark your IME by December 17, 2010.

Four options for “marking” your IME:Four options for “marking” your IME:

1.1. Mark each IME unit, permanently.Mark each IME unit, permanently.

2.2. Mark each IME unit, using a label.Mark each IME unit, using a label.

3.3. Identify IME and IEP on an interchange agreement.Identify IME and IEP on an interchange agreement.

4.4. Identify IME and IEP on trailer document.Identify IME and IEP on trailer document.

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Options 1 and 2: Mark Each IME UnitOptions 1 and 2: Mark Each IME Unit

Trailer Co. USDOT 332211

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Option 3: Identify the IEP and IME in the Option 3: Identify the IEP and IME in the Interchange AgreementInterchange Agreement

Interchange Agreement must Interchange Agreement must ––

Identify you as the IEP.Identify you as the IEP.

Identify the IME.Identify the IME.

Stay on board the power unit.Stay on board the power unit.

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Option 4: Identify the IEP and IME on Option 4: Identify the IEP and IME on Trailer DocumentationTrailer Documentation

Trailer Documentation must Trailer Documentation must ––

Identify you as the IEP.Identify you as the IEP.

Identify the IME.Identify the IME.

Stay on board the IME unit in a weatherproof Stay on board the IME unit in a weatherproof container affixed to the frame.container affixed to the frame.

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IEPs Must Establish an IRM ProgramIEPs Must Establish an IRM Program

Required Inspection, Repair, and Maintenance Required Inspection, Repair, and Maintenance (IRM) program elements (IRM) program elements ––

Performing regular IME inspections.Performing regular IME inspections.

Repairing the problems you find.Repairing the problems you find.

Maintaining IME between inspections.Maintaining IME between inspections.

Creating a recordkeeping system for the program.Creating a recordkeeping system for the program.

Preventative maintenance is key to safety!Preventative maintenance is key to safety!

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IEPs Must Maintain IEPs Must Maintain IRM Program RecordsIRM Program Records

Your IRM recordkeeping and record retention Your IRM recordkeeping and record retention program must indicate –program must indicate –

Which IME units were inspected.Which IME units were inspected.

Inspection date.Inspection date.

Name of the person doing the inspection.Name of the person doing the inspection.

Description of what was checked.Description of what was checked.

List of problems found.List of problems found.

Dates of repair. Dates of repair.

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IEPs Must Require and Respond to IEPs Must Require and Respond to Driver InspectionsDriver Inspections

To meet our requirements, you must –To meet our requirements, you must –

Require each driver to complete a pre-trip inspection.Require each driver to complete a pre-trip inspection.

Provide a location and space for drivers to conduct Provide a location and space for drivers to conduct these inspections.these inspections.

Quickly repair defects drivers find during pre-trip Quickly repair defects drivers find during pre-trip inspections.inspections.

Require each driver to complete a Driver Vehicle Require each driver to complete a Driver Vehicle Inspection Report (DVIR).Inspection Report (DVIR).

Keep repair documentation and DVIRs.Keep repair documentation and DVIRs.

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IEPs Must Conduct Periodic InspectionsIEPs Must Conduct Periodic Inspections

A qualified inspector must inspect all of your A qualified inspector must inspect all of your

IME, at least, once every 12 months.IME, at least, once every 12 months.

You must keep the inspection report or You must keep the inspection report or

inspection sticker with the IME.inspection sticker with the IME.

The person who performed the inspection The person who performed the inspection

must sign the inspection report.must sign the inspection report.

Other Requirements for IEPsOther Requirements for IEPs

Have procedures in place and provide sufficient Have procedures in place and provide sufficient

space for drivers to perform a pre-trip inspection space for drivers to perform a pre-trip inspection

of tendered IME.of tendered IME. Develop and implement procedures to repair any Develop and implement procedures to repair any

equipment damage, defects, or deficiencies or equipment damage, defects, or deficiencies or

replace the equipment prior to the driver’s replace the equipment prior to the driver’s

departure.departure. Refrain from placing imminently hazardous IME Refrain from placing imminently hazardous IME

in service on our nation’s highways.in service on our nation’s highways.

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Summary of IEP Record Retention Summary of IEP Record Retention RequirementsRequirements

Type of RecordType of Record Keep it for How Long?Keep it for How Long?

Pre-trip Inspection ReportsPre-trip Inspection Reports 3 months3 months

DVIRsDVIRs 3 months3 months

Pre-trip Inspection and DVIR Pre-trip Inspection and DVIR

Repair DocumentationRepair Documentation12 months12 months

IRM Program RecordsIRM Program Records 12 months12 months

Roadside Inspection ReportsRoadside Inspection Reports 12 months12 months

Periodic Inspection ReportsPeriodic Inspection Reports 14 months14 months

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What Drivers Must DoWhat Drivers Must Do

Before a trip Before a trip –– Perform pre-trip inspections.Perform pre-trip inspections.

After the trip After the trip –– Complete DVIRs.Complete DVIRs.

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Drivers Must Perform IME Pre-trip Drivers Must Perform IME Pre-trip InspectionsInspections

Check these parts during the pre-trip inspection:Check these parts during the pre-trip inspection:

Service brakes and Service brakes and trailer brake connections trailer brake connections

Rails and support Rails and support framesframes

Lighting devices and Lighting devices and reflectorsreflectors

Tie down bolstersTie down bolsters

TiresTires Locking pins, clevises, Locking pins, clevises,

clamps, and hooksclamps, and hooks

Coupling devicesCoupling devices Sliders or sliding Sliders or sliding

frame lockframe lock

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Drivers Must Complete a DVIRDrivers Must Complete a DVIR

Check these parts during the driver vehicle inspection Check these parts during the driver vehicle inspection –– King pin upper coupling device.King pin upper coupling device.

Rails or support frames.Rails or support frames.

Tie down bolsters.Tie down bolsters.

Locking pins, clevises, clamps, or hooks.Locking pins, clevises, clamps, or hooks.

Sliders or sliding frame lock.Sliders or sliding frame lock.

Lighting devices, lamps, markers, and conspicuity marking material.Lighting devices, lamps, markers, and conspicuity marking material.

Wheels, rims, lugs, and tires.Wheels, rims, lugs, and tires.

Air line connections, hoses, and couplers.Air line connections, hoses, and couplers.

Brakes.Brakes.

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FMCSA Roadability ReviewsFMCSA Roadability Reviews

In a roadability review, FMCSA investigators In a roadability review, FMCSA investigators

will – will –

Review the IEP’s compliance with 49 CFR parts Review the IEP’s compliance with 49 CFR parts 390, 393, and 396.390, 393, and 396.

There will be no safety rating issuedThere will be no safety rating issuedas a result of a roadability review.as a result of a roadability review.

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Selecting IEPs for Roadability Reviews Selecting IEPs for Roadability Reviews

We will use SafeStat to target IEPs.We will use SafeStat to target IEPs. Evaluate violations of 49 CFR parts 390, 393, and Evaluate violations of 49 CFR parts 390, 393, and

396. 396.

There are other reasons to initiate a review.There are other reasons to initiate a review. Non-frivolous complaint. Non-frivolous complaint. Pattern of recordable accidents.Pattern of recordable accidents. IEP request.IEP request. Higher-than-average OOS.Higher-than-average OOS. FMCSA discretion.FMCSA discretion.

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Consequences of Roadability ReviewsConsequences of Roadability Reviews

We will We will notnot issue safety ratings. We issue safety ratings. We maymay ––

Cite the IEP for violations.Cite the IEP for violations.

Issue a civil penalty to the IEP for violations.Issue a civil penalty to the IEP for violations.

Place a specific IME unit or all units OOS.Place a specific IME unit or all units OOS.

Prohibit the IEP from interchanging equipment from Prohibit the IEP from interchanging equipment from one or moreone or more of its locations. of its locations.

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Knowledge Check – Knowledge Check – What Have You Learned?What Have You Learned?

What is an IEP?What is an IEP?

What must an IEP do under the new IEP rule?What must an IEP do under the new IEP rule?

What must a driver do under the new IEP What must a driver do under the new IEP rule?rule?

What can happen after a roadability review? What can happen after a roadability review?

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FMCSA Information Line1-800-832-5660

General questions, registration using Form MCS-150C, USDOT Numbers, and the status of USDOT Numbers.

FMCSA Data Qs Systemhttps://dataqs.fmcsa.dot.gov

Questions or concerns about safety records.

DOT Safety Violation Hotline1-888-DOT-SAFT

http://nccdb.fmcsa.dot.govReport safety violations.

QuestionsQuestions

[NAME][NAME]

[TITLE][TITLE]

[CONTACT INFORMATION, INCLUDING[CONTACT INFORMATION, INCLUDING

PHONE NUMBER AND E-MAIL ADDRESS]PHONE NUMBER AND E-MAIL ADDRESS]

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