Third Quarter 2010
www.cvsa.org
Intermodal Equipment –What Inspectors Should Know About Upcoming Marking Requirements By Capt. John E. Harrison, Georgia Dept. of Public Safety, CVSA Vehicle Committee Capt. John E. Harrison
FMCSA recently amended the intermodal chassis marking requirements [390.21(g)(4)] to provide for a fifth option in regards to identification of the Intermodal Equipment Provider (IEP). To provide a little background, on December 17, 2008 FMCSA published a final rule phasing in new regulatory requirements for IEPs. In that final rule the IEP’s were required to file a MCS150C and obtain a USDOT number by December 17, 2009. Furthermore, by December 17, 2010 the final rule outlined four marking options for identifying intermodal chassis: (1) mark the intermodal chassis equipment on the curbside with the IEP’s name and USDOT number; (2) place a label on the curbside of the intermodal chassis marked with the IEP’s name and USDOT number; or (3) identify the IEP’s USDOT number on an interchange agreement that accompanies the intermodal equipment; or (4) identify the IEP’s USDOT number on a document placed in a weather-tight holder attached to the frame of the intermodal chassis. Subsequently, on December 29, 2009 FMCSA granted a request of the
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Intermodal Association of North America (IANA) to provide for an electronic means to identify the IEP. That amendment provides for a fifth marking option under section 390.21(g)(4) by basically cross-referencing the intermodal equipment’s license plate number, license plate state, or the alpha numeric equipment number to the IEP’s USDOT number using a real-time internet connection or through telephonic access. This fifth marking option (or IEP identification method) will be accomplished by through a website that accesses an electronic database of intermodal equipment known as the Global Intermodal Equipment Registry (GIER) maintained by IANA. Based on discussions with industry officials, most IEPs will likely exercise this fifth option of marking (or identifying) their intermodal equipment, via the GIER system. This is due to the nature of how intermodal equipment is owned, interchanged, and pooled to together by various entities. For example, an intermodal chassis might be owned by a bank or leasing company and furnished to a
chassis pool operator; the chassis pool operator in turn may offer the equipment to various IEPs as needed. Consequently, the IEP responsible for a particular piece of equipment may change several times during a week or even multiple times during a given day. The intermodal industry has indicated that changing the physical markings on each chassis every time the IEP changes would be cost prohibitive. They believe that this electronic clearinghouse (GIER) provided for under this new fifth marking option will be the most accurate and effective means of identifying the IEP for all parties involved. According to IANA, the GIER website will be accessible by roadside inspectors at some point in late summer. Once accessibility is granted enforcement that has web access would be able to query the system using an online public query feature that would allow the single lookup of any specific intermodal chassis. The beta test site can be accessed at: www.gierregistry.com. Inspectors are encouraged to visit the GIER website to see a mockup of how this cross-reference intermodal database will work. FMCSA is also exploring various options for roadside inspectors to access the GIER database using current FMCSA technologies in a seamless manner, such as through the Query Central website and through ASPEN. In addition, CVSA has established a subcommittee of the Training Committee to assist enforcement with understanding the many nuances associated with identification of intermodal equipment, understanding the industry jargon and bringing clarity to portions of the regulations. The subcommittee is made up of CVSA, FMCSA and IANA representatives.