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PMAA Regulatory Report - April 17, 2014

SUBJECT: U.S. DOT Motor Carrier Regulations
ISSUE: Ten Most Cited Violations at Roadside Inspections
PMAA CONTACT: Mark S. Morgan, Regulatory Counsel - mmorgan@pmaa.org
DATE: April 17, 2014

NEW DOT DATA REVEALS THE TOP 10 MOST COMMON VIOLATIONS AT ROADSIDE INSPECTIONS:

New data released by the U.S. DOT’s Federal Motor Carrier Safety Administration (FMCSA) reveals the 10 most frequently cited violations of federal hazardous material transportation regulations issued at routine roadside truck inspections. The data covers more than 154,000 roadside inspections performed in 2012 by the FMCSA. During this period roadside inspectors found more than 35,000 violations of federal regulations. The most common violation was failure to have a copy of the carriers U.S. DOT HAZMAT registration certificate in the cab of the vehicle. All petroleum marketers operating a placarded vehicle must register with the U.S. DOT and pay an annual fee in return for a HAZMAT operating certificate. A current copy of the HAZMAT certificate must be kept on file at the marketers principle place of business. A copy of the certificate must also be kept in the cab of all placarded vehicles. Three of the top ten violations involved shipping papers. For example, it is a violation of U.S. DOT regulations to carry shipping papers in a clipboard with a metal cover unless the metal cover clearly states that shipping documents are kept inside (ex. “SHIPPING PAPERS CONTAINED INSIDE”). In addition, four of the top ten violations involved placard violations. These violations issued for missing, obscured or damaged hazardous material placards. The following is the top 10 federal HAZMAT transportation violations issued in 2012:
 

 

Regulation

Violation Description

# of inspections

# of violations

% of total violations

1

49 CFR 107.620

No copy of US DOT hazardous materials registration number

2,822

2,823

8.14%

2

49 CFR 177.834

Package not secure in vehicle

2,603

2,669

7.69%

3

49 CFR 172.516

Placard damaged, deteriorated, or obscured

2,119

2,419

6.97%

4

49 CFR 172.504

Vehicle not placarded as required

1,901

2,044

5.89%

5

49 CFR 177.817

No shipping papers (Carrier)

1,754

1,780

5.13%

6

49 CFR 177.817

Shipping paper accessibility

1,641

1,646

4.74%

7

49 CFR 172.602

Emergency response information missing

1,540

1,547

4.46%

8

49 CFR 172.502

Failure to provide carrier required placards

1,450

1,519

4.38%

9

49 CFR 172.200

Offering a hazardous material without preparing a shipping paper. (None at all)

1,009

1,032

2.97%

10

49 CFR 177.823

No placards/markings when required

912

1,005

2.90%

Marketers should audit their procedures to ensure that these regulatory requirements are being followed.
 
 

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