New Jersey Motor Truck Association "Roadability" Regulations East Brunswick, New Jersey December 1, 2009 Tom

1. New Jersey Motor Truck Association "Roadability" Regulations East Brunswick, New Jersey December 1, 2009 Tom Malloy Vice President Intermodal Association of North America

2. Roadability RegulationsTime Line for Implementation • 6/17/2009  Final Rule became effective • 12/17/2009  Establish systematic inspection, repair and maintenance programs, and recordkeeping system, submit MCS 150 C • 12/17/2010  All chassis to be marked with U.S. DOT identification number and full implementation of Federal Rules 1

3. Roadability RegulationsIEP Requirements (390.40) • Identify its operations to the FMCSA by filing Form MCS 150C ( each operator will be assigned a unique U.S. DOT number) • Mark its IME with the U.S. DOT number (four five options to mark equipment) • Stencil • Label • On Interchange Agreement • In a Document Compartment • GIER 2

4. Roadability RegulationsIEP Requirements (390.40) cont. • Ensure IME intended for interchange with motor carrier is in safe and proper operating condition • Systematically inspect, repair and maintain all equipment intended for interchange with a motor carrier • Maintain a system of driver vehicle inspection reports submitted to the IEP • Maintain a system of inspection, repair and maintenance records 3

5. Roadability RegulationsIEP Requirements (390.40) cont. • Periodically inspect equipment intended for interchange • At terminal facilities where IME is made available for interchange provide sufficient space for drivers to perform pre-trip inspections • At terminal facilities when IME is made available for interchange, develop and implement procedures to repair damage, defects or deficiencies identified at pre-trip inspection 4

6. Roadability RegulationsDriver & Motor Carrier Requirements (390.42) • … the driver accepting equipment must inspect equipment components listed in§ 392.7(b)   • A driver or motor carrier must report to the IEP, or its designated agent, any known damage, defects, or deficiencies in the intermodal equipment at the time the equipment is returned to the provider or the provider’s designated agent. 5

7. Roadability RegulationsDriver & Motor Carrier Requirements (390.42) cont. • If no damage, defects, or deficiencies are discovered by the driver, the report shall so indicate. The report must include, at a minimum, the items in § 396.11(a)(2) of this chapter. 6

8. Roadability RegulationsDriver Requirements (392.7) • …shall deem to have confirmed the following components were in good working order when the driver accepted the equipment: • Service brake components (readily visible) and trailer brake connections • Lighting devices and reflectors • Tires • Coupling devices • Rails or support frames • Tie down bolsters • Locking pins, clevises, clamps, or hooks • Sliders or sliding frame lock 7

9. Roadability RegulationsDriver Vehicle Inspection Reports (396.11(a) (2)) • Intermodal equipment providers. Every IEP must have a process to receive driver reports of defects or deficiencies equipment operated. The driver must report on at least the following parts and accessories: • Kingpin upper coupling device ― Sliders or sliding frame lock • Rails or support frames ― Wheels, rims, lugs, tires • Tie down bolsters ― Lighting devices, lamps, • Air line connections, markers, and conspicuity hoses, and couplers marking material • Locking pins, clevises, ― Brakes clamps, or hooks 8

10. Roadability RegulationsProcedures for IEP to Accept Reports (396.12(b)) • Report Content 1) Name of the motor carrier 2) Motor carrier’s USDOT number 3) IEP’s USDOT number 4) Date and time the report was submitted 4) All damage, defects, or deficiencies reported 5) If no defect or deficiency, the report shall so indicate • 6) The signature of the driver who prepared the report. 9

11. Roadability RegulationsDriver Vehicle Inspection Reports (396.12(c)) • Corrective action 1) Each IEP, or its agent must repair the reported damage, defects, or deficiencies that are likely to affect the safety of operation of the vehicle. 2) Each IEP or its agent must certify on the original DVIR that the reported damage, defects, or deficiencies have been repaired, or that repair is unnecessary, before the vehicle is operated again. 10

12. GIER Approval • November 10, 2009/ November 13, 2009 • FMCSA will amend final rule to Create a fifth option for marking IME under 390.21. • Identification system to match IME to responsible IME 11

13. GIER Solution • An industry-sponsored virtual, technology solution to meet FMCSA regulations requiring identification of intermodal equipment and the IEP responsible for maintenance and repair of that equipment. • A central database where all intermodal equipment subject to the regulations and in use throughout US are registered utilizing the current alphanumeric equipment ID number. • A web portal to determine ownership and operating control of intermodal equipment. • Accessibility defined for all industry stakeholders including FMCSA and state and local enforcement personnel. 12

14. GIER – Equipment Assessment • 96 IEPs (UIIA, Safer System, U.S. DOT) • 785,854 known equipment universe • 72 IEPs with DOT # - 75% as of 12/01/09 • 24 IEPs without DOT # 13

15. GIER – “Early Adopter” Program • 412,652 total equipment • 52.5 % known equipment universe 14

16. www.gierregistry.com

17. Driver Vehicle Inspection Report(DVIR)

18. IANA DVIR – Reporting Items • Rail facility operator will transmit to IANA the following information collected at in-gate from drivers for all subscriber IEPs: • Date/Time of Gate Transaction 396.12 (b)(3) • Chassis ID Number 396.12 (b)(2) • Motor Carrier SCAC Code 396.12 (b)(1) • Driver’s License Number/ 396.12 (b)(5) License State 15

19. IANA DVIR – Reporting Items (cont.) • Two digit code assigned to each item • 00 will be utilized to designate no defects. 396.12 (b)(4) 396.11 (a)(2) “parts & accessories” 01 – Coupling 06 – Wheel 02 – Frame 07 – Lights 03 – Bolster 08 – Air Line 04 – Fastener 09 – Brakes 05 – Slider 00 – No defects • Location of Interchange – Not required by regulations 16

20. IANA DVIR – Information Transaction • Information transmitted electronically to IANA via 322 transaction set. Frequency of transmission of data to IANA to be determined. • IANA to Confirm Receipt of 322 via EDI 997. • IANA Assigns unique DVIR number. 17

21. DVIR SCHEMATIC Facility Process Motor Carrier Gate DVIR 396.11 Flow (AGS/Manned) J1 J2 TIR/EIR 18

22. DVIR SCHEMATIC Facility Gate (AGS/Manned) RR Facility Operator (Data Capture) EDI EDI 997 322 IANA IIS UIIA – Motor Carrier DOT # IDD– Driver First Name, Last Name & Pin (e-sig) GIER– IEP DOT # 19

23. DVIR SCHEMATIC IANA IIS UIIA – Motor Carrier DOT # IDD– Driver First Name, Last Name & Pin (e-sig) GIER – IEP DOT # EDI 322 IEP DVIR Report 396.12 20

24. DVIR SCHEMATIC Facility Process Motor Carrier Gate DVIR 396.11 Flow /Manned) ( AGS Port J1 RR Facility J2 Operator TIR / EIR (Data Capture) Container Yard EDI EDI 997 322 Depot IANA IIS M&R UIIA - Motor Carrier DOT # Vendors IDD - Driver First Name, Last Name & Pin (e-sig) GIER - IEP DOT # EDI 997 EDI 322 = Current Flow = Future Flow IEP 21 DVIR Report 396.12 15

25. Web site: www.intermodal.org Thank you.