October 26, 2004

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Headline News


Lead the Change Initiative Successfully

Good leaders don’t accept the status quo. When you need to convince your workforce to shift gears, remember these tips for moving forward:

• Give and early warning. Sudden changes can be disconcerting and stressful. Try not to surprise anyone with the need to do things differently. People will respond better if they have time to digest the news and prepare themselves for the new order.

• Communicate every step. Uncertainty creates an atmosphere of tension in a workforce, which increases resistance to any change effort. Explain the big picture but don’t neglect the details. Tell people what to expect on a day-by-day basis.

• Don’t criticize the past. Change may be necessary, but that doesn’t mean that everything old is negative. People may feel embarrassed or angry by the implication that their past actions and efforts were wrong-headed. Let them save face by keeping everyone’s attention focused on what worked well and what they can expect to work better in the future.

• Reward the extra effort. Learning new skills and adjusting to a new routine is work. Recognize people for the time and emotional energy they put into change. Praise, time off, and other rewards will help them feel well compensated for the additional effort.

• Don’t ignore the sadness. People will feel a sense of loss when they give up an established, comfortable way of doing things. Allow them to grieve for the old, and give them the time to accept and embrace the new before you consider your change efforts a success.

Adapted from “Reaching the commitment Stage of Change,” by Mary Pille, on the InterBusiness Issues website.

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PTDI Offers Free Evaluator Training

Who: Current PTDI Certification Committee and Educational Team Leaders Prospective PTDI Certification Committee and Educational Team Leaders

What: Free* Staff Development Opportunity: PTDI Evaluator Training for

• Current & Prospective PTDI Certification Committee Members
• Current & Prospective Educational/Evaluation Team Leaders (ETLs)
* You pay only for your travel to & from the training

When: Friday, November 19, 2004, 9:00 a.m. – 4:00 p.m.

Where: American Trucking Associations (ATA) Building (PTDI Office)
2200 Mill Rd., Alexandria, Virginia

Why: The effectiveness of course certification depends on consistency of the team’s and Certification Committee’s reviews and evaluations. Consistency relies on a thorough understanding of the curriculum and certification standards and how they are applied. This comes through training and experience.

Bringing together the Certification Committee and team leaders will help each group see what is expected from the other’s viewpoint, and will help bring about the consistency required.

Training is required to serve as a Certification Committee member or as an on-site school visit team member.

Qualifications of Certification Committee and Educational Team Leaders:

• Certification Committee members are members of the PTDI Board of Directors. The makeup of the seven-member Committee represents schools, insurance, carriers and the public. On-site team leaders are administrative or instructional personnel from schools with PTDI-certified courses.

• Are willing and able to thoroughly review and verify an institution’s course administration, curriculum, instructional personnel, training vehicles, instruction, student evaluation and testing, outcomes, and records. The on-site team is the eyes and ears of the Certification Committee, who then reviews the findings of the on-site team.

• Understand the curriculum and certification standards

• Objectively apply the curriculum and certification standards

• Volunteer their time and services to the certification process. Team leaders are reimbursed for travel expenses for on-site visits (Training is not covered.).

• Are willing to travel regionally or nationally and to participate in up to three on-site visits per year (Committee – for Committee face-to-face and conference call meetings)

• Represent institutions that are in good standing with PTDI

• Sign a code of conduct to ensure objectivity and confidentiality

• Participate in training as a Certification Committee or Team Leader.

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Amendment Would Raise Penalties for HOS and Other Violations

An amendment to legislation pending to reauthorize highway funding for the next six years would substantially increase fine for hours-of-service and out-of-service violations. The amendment would also hold managers responsible if they order or allow violations. Currently a conference committee is working on a compromise between the different version of the highway bill reauthorization the House and Senate both passed.

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Industry Petition on Safety Performance History of New Drivers Denied

In an October 15 letter sent by Federal Motor Carrier Safety Administration (FMCSA) Administrator Annette Sandberg to the American Trucking Associations (ATA) the agency denied their petition to reduce from 30 to 5 days the time frame that former employers have to respond to a request for driver background information. This 30-day time frame was mandated by the FMCSA per their March 30, 2004 Final Rule on the Safety Performance History of New Drivers (49 CFR §391.23(g)(1)). You will recall that on May 10, TCA had sent a letter expressing our support for the ATA filed petition to the agency as well.

The lone issue in ATA’s petition involved §391.23(g)(1) of the rule that mandates a 30-day response time for the prior motor carrier to respond to the previous employer with the requested information on a prospective employee. ATA felt that this 30-day period was far too long, and petitioned the agency to reduce this time frame to 5 days. However, an excerpt from the Administrator’s letter denying the request reads as follows: “When previous employers have significant safety information about a former employee driver, it may take them some time to review the information properly and communicate this information to the prospective employer. A 5-day window in these situations is simply not practical. Many motor carriers are small businesses that cannot afford the administrative staff to process requests of this kind rapidly… A 5-day turnaround time would impose a disproportionate and unjustifiable economic burden on such carriers.”

Click here for a copy of the FMCSA denial letter. For further information or questions on this issue, please contact Rich Clemente at TCA (703) 838-8847 or email: rclemente@truckload.org.

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TCA Attends FMCSA Comprehensive Safety Analysis 2010 Listening Session

On October 19, Rich Clemente, TCA’s Director of Safety attended the fifth of six of the Federal Motor Carrier Safety Administration's (FMCSAs) “Comprehensive Safety Analysis 2010 Listening Sessions” that was held in Falls Church, Virginia. This series of six public listening sessions have been scheduled by the agency to solicit input on ways they can improve the process of monitoring and assessing the safety of the nation’s motor carriers and ensuring their compliance with federal regulations -- primarily through their Compliance Reviews (CRs) and SafeStat initiatives. One remaining Listening Session is scheduled for October 26 in Springfield, Massachusetts.

This fifth session was very well attended by a number of truck (and bus) company and industry trade Association representatives, and other industry professionals. Department of Transportation (DOT) Secretary Norman Mineta and FMCSA Administrator Annette Sandberg were in attendance for the Listening Session as well.

The day was broken up into a number of individual breakout sessions, which were facilitated by representatives from Touchstone Consulting who are working with the agency on this initiative. The format for the breakout sessions was to solicit input and feedback from the attendees on the agency's "three-pronged" view of their CR process:

1) the current state;
2) the case for change; and
3) the future state.

The feedback from the participants on the FMCSA's CR and current SafeStat processes was considerable, however, the “key” discussion points centered around some of the following issues:

1) the purpose of the CR;
2) agency resources for doing CR's (as currently only 2% of the trucking companies with operating authority receive a CR/year);
3) data and data quality issues;
4) training and education; and
5) drivers, the driver's history and the driver shortage issue.

Please note that all of the feedback and comments from this and all of the other five Listening Sessions will eventually be posted on the agency's Docket Management Website: http://dms.dot.gov -- approximately 60 days after each session has been completed. The Docket Number is 18898 for accessing this information.

Administrator Sandberg spoke briefly prior to the breakout sessions regarding the Agency’s reasoning for scheduling the sessions, and she was subsequently questioned about a few regulatory and legislative issues as well. When questioned about this "Compliance Review" initiative being targeted for a year 2010 completion, she said that while this is true, there would be a number of proposals and rulings along the way issued by their agency for "tweaking" aspects of the current CR (and SafeStat processes).

TCA will keep you posted on this issue. Please call or email Rich Clemente at (703) 838-8847 or rclemente@truckload.org if you would like to discuss this matter further, or if you would like to receive handout materials from the session.

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FMCSA Issues Proposed Changes to Motor Carrier Safety, Haz Mat and Other Enforcement Proceedings

The Federal Motor Carrier Safety Administration (FMCSA) issued a Supplemental Notice of Proposed Rulemaking (SNPRM) in the October 20, Federal Register, proposing to amend its rules of practice for motor carrier safety, hazardous materials (HM), and other enforcement proceedings. According to the agency, these rules would increase the efficiency of the procedures, enhance due process and the awareness of the public and regulated community, and accommodate recent programmatic changes. The rules would apply to all motor carriers, other business entities, and individuals involved in motor carrier safety and hazardous materials administrative actions and proceedings with the Agency. Industry comments must be filed with the FMCSA on or before December 6, 2004.

A Notice of Proposed Rulemaking (NPRM) was issued by the then Federal Highway Administration (FHWA) back in early 1996 which proposed the first comprehensive rewrite of the FHWA’s rules of practice for motor carrier administrative proceedings since 1985 – which was intended at that time to be a “forerunner” of the agency’s “zero-base” review of the Federal Motor Carrier Safety Regulations (FMCSRs). One part of this proposal was to entirely eliminate the rules of practice contained in Part 386, and replace them with “new” rules of practice in new part 363 of the FMCSRs. The goal of that prior proposal was to improve the then existing rules of procedure for motor carrier enforcement proceedings.

In the October 20 SNPRM, the agency only proposes changes to part 386, Rules of practice for motor carrier, broker, freight forwarder, driver and HM proceedings, including the agency’s occasional enforcement of the HM regulations on shippers. Most of the SNPRM proposed changes are technical in nature to eliminate inconsistencies or increase the efficiencies of the procedures. However, a few notable proposed changes include:

1) a proposed changing of the time frame within which respondents must reply to the notice of claim -- current §386.14 provides 15 days from the date of service of the notice of claim for the respondent to reply which is proposed to be changed to 30 days; and

2) in §386.16 the agency is proposing to provide an informal oral hearing as a new adjudication option.

A section-by-section summary of all of the other proposed changes can be found in a copy of the actual October 20 Register notice which can be downloaded by clicking here for a PDF and here for an HTML. If you have any questions on this issue, contact Rich Clemente at (703) 838-8847 or email: rclemente@truckload.org.

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FMCSA Releases Official Statement on Congressional HOS Action

FMCSA Administrator Annette Sandberg issued the following statement on October 5 regarding the recent Congressional action on the hours of service (HOS) rules. “The FMCSA recognizes the intent of the Congress in adopting the HOS provision as part of the highway reauthorization extension (H.R. 5183) passed September 30 to avoid widespread disruption within the motor carrier industry and to enhance effective enforcement of the HOS requirements. We believe the new rule, announced in April 2003, significantly advances commercial vehicle safety by extending drivers’ required off-duty time from 8 to 10 hours, shortening on-duty time from 15 to 14 hours, and preventing extension of the workday. The rule increases each driver’s opportunity to get sufficient rest. This improves drivers’ “physical condition” an important boost to highway safety. FMCSA remains committed to rules that address the safety challenge of a diverse industry through clear, enforceable, science-based steps. Accordingly, we have accelerated the September 1, 2004 Advance Notice of Proposed Rulemaking, describing the agency’s request for information on the costs and benefits associated with Electronic On-Board Recorders. Also, the agency has contracted for literature reviews on the effect of hours of service regulations on driver health. This will provide the information necessary for revising the HOS rule. The action by Congress means the new hours of service stay in effect and will be enforced until September 30, 2005, or until such earlier time as FMCSA issues a revised rule addressing the concerns of the U.S. Court of Appeals for the District of Columbia Circuit stated in Public Citizen et. al v. FMCSA.”

Regarding the status of the U.S. Court of Appeals pending decision on the HOS case, on October 8, the Court granted the “interveners” recent motion to withdraw our prior motion (in light of the legislative extension of the current rules) and also dismissed as “moot” the motions of the would-be amici (including CVSA, OOIDA, and NITL) to participate. As further developments warrant, we will keep you posted, for questions on this issue, please contact Rich Clemente at (703) 838-8847 or email: rclemente@truckload.org.

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USDA Announces New Voluntary Agricultural Security Guidelines

The U.S. Department of Agriculture (USDA) recently released the new, voluntary security guidelines for haulers of food and agricultural products. The new “Guide for Security Practices in Transporting Agricultural and Food Commodities” and the accompanying “Agricultural and Food Transporters Conference (AFTC) Resources Directory for Security Practices in the Transportation of Agricultural and Food Commodities” were recently released during the AFTC education session at ATA’s Management Conference and Exhibition in Las Vegas. This guide is designed to enhance security measures practiced by the nation’s approximately 27,000 commercial transporters of agricultural and food-related products across the nation each year.

The new AFTC/USDA Security Guide contains security checklists for commercial transporters of agricultural commodities and food products and their drivers. The accompanying AFTC Resources Directory contains a new vulnerability and threat assessment tool and a security-planning guide for commercial transporters of agricultural commodities and foodstuffs. “These guidelines are practical, flexible and proactive,” according to Deputy Secretary of Agriculture James Moseley. Fletcher Hall, AFTC Executive Director added, “This is the first set of guidelines that that USDA has done that have been voluntary, and it has been a partnership between the private sector and the government.” Information for obtaining the guide can be found by clicking here, and for further questions about these guidelines, contact Fletcher Hall at (703) 838-7999 or by email at: fhall@trucking.org.

On another related issue, the Food and Drug Administration has yet to issue a final rule on the one remaining section (Section 306 - Recordkeeeping) of the Bioterrorism Act of 2002. This section of the Act covers the establishment and maintenance of records to allow for the identification of immediate previous sources and immediate subsequent recipients of food to assist the agency track food implicated in future emergencies. By way of reminder, the other three “key” sections of the Act – Administrative Detention (Section 303); Registration of Food Facilities (Section 305) and Prior Notice of Imported Food Shipments (Section 307) have already been issued in final rule form. TCA will keep you posted on further developments with the food security regulations as they occur.

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2004 Emergency Response Guidebook Now Available

The Research and Special Programs Administration (RSPA) recently announced that the 2004 Emergency Response Guidebooks (ERGs) have been published and are now available to the industry. The ERG 2004 was jointly developed by the U.S. Department of Transportation, Transport Canada, and the Secretariat of Communications and Transportation of Mexico for use by firefighters, police and other emergency services personnel who may be the first to arrive at the scene of a hazardous materials transportation incident. The guide is primarily used to aid first responders in:

1) quickly identifying the specific or generic classification of the material(s) involved in the incident; and
2) protecting themselves and the general public during this initial response phase of the incident.

The ERG is updated every 3 to 4 years to accommodate new products and technology, and the next version is scheduled for 2008.

A brief summary of the changes to the 2004 ERG follows. As for General Information various sections have been expanded and/or revised including:

1) What is a Toxic Inhalation Hazard?
2) Isolation and Evacuation Distances;
3) Who to Call for Assistance;
4) Hazard Classification System;
5) Table of Placards and Initial Response Guide to Use On-Scene;
6) Rail Car and Road Trailer Identification Charts;
7) Hazard Identification Codes Displayed on Some Intermodal Containers;
8) Introduction to the Table of Initial Isolation and Protective Action Distances;
9) Criminal/Terrorist Use of Chemical/Biological/Radiological Agents;
10) Glossary; and
11) Emergency Response Telephone Numbers.

Other significant changes include an Index List of Dangerous Goods in Order of ID Number and a Table of Initial Isolation and Protective Action Distances, and the Table of Water-Reactive Materials Which Produce Toxic Gases.

To obtain a copy of the 2004 ERG click here. This website also contains a number of other ERG related information documents for download including:

1) the ERG State Coordinators List;
2) DOD and Federal Agencies Point of Contact for the 2004 ERG; and
3) a Summary of the Changes from the 2000 version of the ERG.

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Reminder - Customs and Border Protection Changes Take Place on Nov. 15

Effective November 15, 2004, U.S. Customs and Border Protection (CBP) is initiating changes to the current system at 40 ports with two consecutive implementation dates on December 15, 2004 and January 14, 2005 for the remaining ports. Customs requires pre-notification on all freight coming into the U.S, if they do not receive pre-notification, the truck will be refused entry into the U.S and the process will have to re-start. Repeat non-compliance occurrences will result in fines to carriers. Pre-notification must be faxed to the border one hour before arrival, one half hour for BRASS.

CBP offers four (4) clearance programs for freight entering or transiting in the U.S.:

• Pre-Arrival Processing System (PAPS)
• QP / WP (an in-bond processing program that allows US Customs Brokers to process and send information on in-bond shipments to CBP
• Border Release Advance Screening and Selectivity (BRASS)
• Customs Automated Forms Entry System (CAFES)

Please refer to www.cbp.gov for complete details on the clearance programs and implementation dates.

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