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The Complete Guide to FMCSA, NHTSA & Other Regulations for Truck Manufacturers

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FMCSA Regulations for Truck Manufacturers

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    The Federal Motor Carrier Safety Administration (FMCSA) is a department within the Department of Transportation. Formerly, it was a part of the Federal Highway Administration. Established on January 1, 2000, FMCSA’s mission is “to prevent commercial motor vehicle-related fatalities and injuries.” As such, the FMCSA implements a variety of regulations and standards pertaining to motor carriers (truck and bus companies).

    However, the FMCSA isn’t the only regulatory body that issues and enforces regulations impacting the trucking and transport industry. The National Highway Traffic Safety Administration, part of the Department of Transportation, issues regulations for all types of motor vehicles, while the Environmental Protection Agency issues regulations on emissions as well as other standards to address the environmental impact of motor vehicles and the Occupational Safety and Health Administration provides regulatory oversight on workplace safety, including the use and operation of motor vehicles in the workplace.

    FMCSA Regulations for Truck Manufacturers

    We’ve created this guide to provide an overview of FMCSA, NHTSA, and other regulations for truck manufacturers, including the regulations manufacturers need to know, regulations impacting drivers and operators, and more.

    In this guide, we’ll discuss:

    Who Must Comply with FMCSA Regulations?

    While most FMCSA regulations relate to the operation of commercial vehicles, truck manufacturers should be aware of FMCSA regulations and how these regulatory requirements may apply to the manufacturing process. Anyone operating the following types of commercial vehicles in interstate commerce must comply with FMCSA regulations: FMCSA Regulations

    • Vehicles with a gross vehicle weight rating or gross combination weight rating of 10,001 lb (4,537 kg) or more, whichever is greater
    • Vehicles designed for or used in transporting 9 to 15 passengers for compensation, including the driver
    • Vehicles designed for or used in transporting 16 or more passengers, including the driver
    • Vehicles of any size designed for or used in transporting hazardous materials per the Hazardous Materials Transportation Act (49 U.S.C. 5101 et seq.)

    Note that vehicles designed for or used for transporting hazardous materials are required to be placarded under the Hazardous Materials Regulations (49 CFR chapter I, subchapter C).

    Per these criteria, vehicles such as taxis and other vehicles with a similar capacity are not subject to FMCSA regulations. Additionally, the number of passengers a vehicle is designed for always trumps the number of passengers a vehicle is actually carrying. In other words, a bus carrying seven passengers across state lines but designed to hold up to 20 passengers is subject to FMCSA regulations.

    As a general rule, when a vehicle crosses state lines, even if the trip will be completed in the original state, those vehicles are subject to federal regulations (the FMCSA) rather than individual state regulations. On the other hand, vehicles and operators that engage only in intrastate commerce are subject to applicable state and local regulations, not necessarily to the FMCSA, although all states are required to have motor vehicle carrier regulations that are practically identical to the FMCSA’s. That said, states may have different definitions, registration and oversight procedures.

    It’s also worth noting that for passenger transportation, even companies that have through-ticketing agreements with other carriers are considered to be interstate carriers, and thus they’re subject to FMCSA regulations as well – even when the company itself engages only in intrastrate transit. However, there are a number of circumstances that would exempt certain vehicles and operators from being subject to FMCSA regulations. This article provides an excellent overview of these exemptions for passenger motor carriers.

    An Overview of FMCSA Regulations for Truck Manufacturers

    Anyone operating any of the types of vehicles described above must comply with applicable safety regulations issued by the U.S. Department of Transportation (DOT) related to:

    • Alcohol and controlled substances testing for any persons required to have a CDL (commercial driver’s license)
    • Appropriate driver qualifications, including medical exams
    • Regulations applicable to operating commercial vehicles
    • Parts and accessories required for safe operation
    • Hours of service
    • Regulations pertaining to inspection, repairs, and maintenance

    FMCSA Regulations

    The FMCSA has created a system known as BASICs (Behavior Analysis and Safety Improvement Categories) designed to assess the safety and performance of drivers and carriers, which includes:

    • Unsafe Driving
    • Hours-of-Service (HOS) Compliance
    • Driver Fitness
    • Controlled Substances/Alcohol
    • Vehicle Maintenance
    • Hazardous Materials Compliance
    • Crash Indicator

    Most of these regulations relate to drivers and operators, who are facing some regulatory changes in the coming years. The Electronic Logging Device (ELD) mandate is one newer regulation receiving mixed reactions among industry associations and operators. Fleets were required to implement universal ELDs into their business models by December 2017, while fleets that were already using electronic logging technology have until December 2019 to comply with all published requirements.

    ELDs are synchronized with a truck’s engine and aim to improve driver and highway safety by automatically logging hours of service (HOS), which guidelines restrict to 60 to 70 hours on duty over 7 to 8 consecutive days. These electronic tracking systems replace the paper logging methodology employed by many drivers. Drivers are also required to:

    • Carry an instruction manual on operating the ELD
    • An instructional sheet outlining the step-by-step process for transferring HOS records (which is used during roadside inspections)
    • An instructional sheet outlining procedures for handling and reporting on ELD malfunctions
    • Paper logs on HOS for the previous 8 days

    While drivers are required to have these items in possession, it’s the carrier’s responsibility to provide all of these materials to their operators when the ELDs are purchased. In addition to tracking hours, many ELDs also offer GPS capability, direct communication between carriers and owner/operators, and even provide some document organization functionality.

    ELD manufacturers are responsible for ensuring that their devices meet the required technical specifications and also for registering their devices with the FMCSA. ELDs may also include portable ELDs and even mobile phones, provided that they meet the technical specifications and are registered. The FMCSA provides a helpful checklist that outlines these specifications and provides guidance for carriers and operators on selecting an appropriate ELD.

    Speed limiters are another possible change currently in consideration. This proposed mandate would require manufacturers to equip new trucks with speed limiting capabilities that would limit the maximum speed of the vehicle to 65 miles per hour. The debate has been heated surrounding the possible introduction of this requirement, although many industry associations have rallied around a proposed 65 mph limit. Due to recent cutbacks on federal regulation, this proposal is currently stalled.

    NHTSA Regulations Impacting Truck Manufacturers

    The National Highway Traffic Safety Administration (NHTSA) issues standards particularly related to the manufacture of motor vehicles and motor vehicle equipment. Specifically, NHTSA issues regulations on highway safety and motor vehicle safety. NHTSA and FMCSA often work collaboratively, issuing joint proposals such as the proposed speed limiter mandate discussed above. Specifically, NHTSA implements and enforces the National Traffic and Motor Vehicle Safety Act of 1966, as amended, 49 U.S.C. Chapter 301 (the Vehicle Safety Act), as well as other laws related to motor vehicle safety. It is the federal agency that issues and enforces all federal motor vehicle safety standards (FMVSS).

    NHTSA Regulations

    NHTSA regulations are the regulatory standards most directly related to the manufacture of heavy-duty vehicles and parts, and there are myriad regulations targeting specific safety guidelines and rules. For new manufacturers, the NHTSA publishes a guidebook with comprehensive information on procedural requirements, VINs, federal motor vehicle safety standards, and more.

    The NHTSA regularly issues publications on proposed rules, requests for commentary, and final rules. For example, Federal Motor Vehicle Safety Standards; Air Brake Systems is a rule that amends the previous Federal motor vehicle safety standard on air brake systems to improve the stopping distance performance for truck tractors. Specifically, 49 CFR Part 571 requires most new heavy truck tractors to achieve a stopping distance of 30% less than required by previous standards. These trucks are required to stop within 250 feet when loaded to their maximum gross vehicle weight rating (GVWR) from a speed of 60 miles per hour (with the exception of a few very heavy severe service tractors, which have a requirement of 310 feet). All heavy truck tractors must stop within 235 feet when loaded to their LLVW, or lightly loaded vehicle weight.

    Another example is a 2012 proposal to establish a new Federal Motor Vehicle Safety Standard No. 136, which would require electronic stability control (ESC) systems on truck tractors and on buses with a gross vehicle weight rating of more than 26,000 pounds (11,793 kilograms). These systems, when used in truck trailers and large buses, can reduce untripped rollovers and mitigate conditions that lead to a loss of control through automatic computer-controlled braking and a reduction in engine torque output.

    As federal regulations are often complex and the specific guidelines often difficult to navigate, there are a few resources that aim to demystify the regulatory landscape for truck and trailer manufacturers. The Truck Trailer Manufacturers Association, for instance, maintains a list of important federal regulations including:

    • 49 CFR Transportation
    • 49 CFR 571-121 Air Brakes
    • 49 CFR 571.108 Lighting
    • 49 CFR 571.223 Rear Impact Guard
    • 49 CFR 571.224 Rear Impact Protection
    • 49 CFR 567 Certification

    The entirety of Part 571 can be viewed via the Electronic Code of Federal Regulations (ECFR). Part 567, which covers certification, is also viewable via ECFR.

    Requirements for Data Plates

    Truck and trailer manufacturers must equip all vehicles with appropriate data plates. First, there are a number of steps required:

    • Obtain a World Manufacturing Identifier (WMI) from the Society of Automotive Engineers (SAE). This number becomes part of the VIN for all vehicles you manufacture and is used to identify your company as the vehicle’s manufacturer.
    • Register with NHTSA. Manufacturers generate their own VINs using NHTSA’s VIN formula. The content requirements are described in detail in Part 565.15.
    • VINs are then submitted to NHTSA with a letter of introduction.
    • Individual states also have their own registration requirements and regulations, so manufacturers should be aware of and follow all state requirements in addition to federal requirements.
    • VIN labels are affixed to every vehicle manufactured with the following self-certification statement: “This vehicle conforms to all applicable US FMVSS in effect on the date of manufacture shown above.”

    Each VIN contains important information about the vehicle including:

    • The manufacturer
    • Type of motor vehicle
    • Attributes of the vehicle
    • A check digit
    • Vehicle model year
    • Plant of manufacture
    • Number sequentially assigned during the manufacturing process (for high-volume manufacturers)

    There are some differences in the VIN based on whether the manufacturer is a high-volume manufacturer or a low-volume manufacturer. As noted in Part 565.15: “If a manufacturer is a low-volume manufacturer, the third, fourth, and fifth characters of the fourth section (positions 12, 13, and 14), combined with the three characters of the first section (positions 1, 2, and 3), shall uniquely identify the manufacturer and type of the motor vehicle and the sixth, seventh, and eighth characters of the fourth section (positions 15, 16, and 17) shall represent the number sequentially assigned by the manufacturer in the production process.”

    The attributes of the vehicle that a VIN includes vary based on the type of vehicle. For trucks, these attributes include:

    • Make
    • Model or line
    • Series
    • Gross vehicle weight rating
    • Engine type
    • Brake system
    • Cab type
    • Chassis

    For trailers, the attributes contained in the VIN include:

    • Make
    • Type of trailer
    • Body type
    • Length
    • Axle configuration

    Gross vehicle weight ratings are coded by class, consisting of classes A through H and classes 3 through 8, each class representing a gross vehicle weight rating range.

    There are also requirements specifying the location and readability of the VIN. Per Part 565.23: “The VIN of each vehicle shall appear clearly and indelibly upon either a part of the vehicle, other than the glazing, that is not designed to be removed except for repair or upon a separate plate or label that is permanently affixed to such a part.” For passenger cars, multipurpose passenger vehicles, and trucks with a GVWR of 4536 kg or less, the regulations stipulate that the VIN must be located inside the passenger compartment. Additionally, “It shall be readable, without moving any part of the vehicle, through the vehicle glazing under daylight lighting conditions by an observer having 20/20 vision (Snellen) whose eye-point is located outside the vehicle adjacent to the left windshield pillar. Each character in the VIN subject to this paragraph shall have a minimum height of 4 mm.”

    VINs consist of 17 characters, yet these characters convey a substantial amount of crucial information required for reporting and other purposes. But some manufacturers must also comply with guidelines that require Convention for Safe Containers (CSC) Plates. CSC is an international standard that aims to ensure the safety of shipping containers. CSC Plates provide additional information related to safety including:

    • Verification that the container passed specific tests
    • Verification that the container met minimum standards for capacity, weight, and resistance to shipping forces
    • A four-digit code identifying the container owner and the container’s intended use

    In addition to VIN plates and CSC plates, data plates are used for a variety of purposes in the transportation industry including:

    • Asset management and traceability
    • Dolly and chassis identification plates
    • Inspection and maintenance schematics

    Because data plates contain essential information for safety, asset tracking, and other purposes, truck manufacturers must install data plates with the durability to withstand the harsh conditions trucks and trailers often operate in, while remaining readable despite frequent abrasion and exposure to UV and harsh weather elements. For this reason, Metalphoto® photosensitive anodized aluminum is often the material of choice.

    OSHA, EPA, and Other Regulations Truck Manufacturers Should Know

    The Environmental Protection Agency (EPA) issued new greenhouse gas emissions and fuel economy standards in 2016, for which it worked closely with NHTSA to ensure that both agencies’ standards were harmonized. The Phase 2 Final Rule includes medium- and heavy-duty engines and vehicles covering “model years 2018-2027 for certain trailers and model years 2021-2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks.” However, as of October 2017, these new standards are being considered for possible repeal.

    OSHA and EPA Regulations

    Heavy-duty trucks have been facing increasingly tightening regulations on emissions since 2004. As standards become more stringent, the gap between newly manufactured trucks (which are required to meet the newest standards) and older models widens. As truck manufacturers work to comply with these stricter regulations, the cost of tractors and trailers tends to rise, creating a burden on trucking companies. However, the EPA argued that trucking companies could recoup these added costs over two years through savings produced by better fuel efficiency.

    At the time the new rule was issued, the EPA estimated that vehicles (gliders and trailers) using engines manufactured prior to 2002 produced 20 to 40% higher emissions compared to vehicles with newly manufactured engines. Additionally, the standards issued in 2016 created a loophole which would enable companies to install an outdated engine into a newer truck body in order to circumvent these requirements – a recognized problem that both engine manufacturers and environmental agencies encouraged closing.

    OSHA’s regulations focus on the operation of motor vehicles in the workplace and not to vehicles operated on public roads. In general, the Department of Transportation (DOT) has jurisdiction when a motor vehicle is operated on public highways, and other federal agencies preempt OSHA’s jurisdiction in situations covered by regulations set forth by other federal agencies. OSHA’s standards cover circumstances such as loading and unloading, hazardous waste transport, the use of mechanical means to secure trucks or trailers to loading docks, and other circumstances that arise in the workplace pertaining to worker safety.

    Additional Resources on Regulations and Standards for Truck Manufacturers

    For more information on regulations, standards, and guidelines impacting truck manufacturers and the transportation and logistics industry visit the following resources:

    The trucking industry is multi-faceted, and there are myriad regulations impacting drivers, carriers, and manufacturers. While making sense of the regulatory landscape can be challenging given the multiple regulatory agencies involved in issuing and enforcing standards and regulations, having a firm grasp on the current requirements is essential for all manufacturers.

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