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NASTC - National Association of Small Trucking Companies

COVID-19 Updates

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A Message From Jon Pertchik - CEO, TravelCenters of America

July 22, 2020

To our valued partners:

I want to thank you and your drivers for continuing to work so hard through the coronavirus pandemic. As the COVID-19 pandemic continues and we are seeing a possible second surge hit the country, our top priority remains the health and safety of our employees and customers.

TravelCenters of America continues to take proactive and appropriate steps to help minimize the spread of COVID-19, including enhanced cleaning measures and social distancing, always following guidance from the Centers for Disease Control (CDC).

The CDC (and now the White House) continues to advise that face coverings are an effective tool to combat the spread of COVID-19 in public settings. Employees at all our locations are required to wear a face mask or covering while working. As an additional measure to help minimize the spread of COVID-19, effective Wednesday, July 29, 2020, we will be joining Pilot/Flying J and Loves in requiring all customers (with the exception of those with medical conditions and children) to wear face masks or coverings while visiting our locations.

As an essential business, we have a responsibility to provide a safe experience at our sites and see this as a step everyone can take for their personal safety and for the safety others. Requiring face coverings at our travel centers nationwide is a further demonstration of our commitment to promoting a safe environment.

We ask that you help us communicate this important message to your drivers and let them know we want everyone to have peace of mind while visiting us. These are certainly challenging and stressful times and we appreciate your cooperation and understanding of our decisions. We have always taken pride in maintaining clean and safe operations and sites and we intend to continue to play a leadership role.

Throughout the pandemic, your professional drivers have worked tirelessly to ensure essential goods and services are delivered around the country. Our employees have worked tirelessly so our sites could remain open. Working together, we can help combat COVID-19.

We look forward to continuing to serve you as this situation evolves. Thank you, as always, for your continued support and loyalty.

- Jon Pertchik CEO, TravelCenters of America

P. J. Park
Vendor Relations, Maintenance & Credit Services Program Manager
800.264.8580

Fax: 615.451.0041


FMCSA COVID-19 Notice of Enforcement Discretion Determination

On July 6, 2020, the Federal Motor Carrier Safety Administration (FMCSA) published a Notice of Enforcement Discretion Determination on random controlled substance and alcohol testing.

For more details, visit the FMCSA Web Page:

https://www.fmcsa.dot.gov/emergency/notice-enforcement-discretion-determination-random-controlled-substance-and-alcohol

Nicole Gifford
Director of Drug & Alcohol
800.264.8580
Fax: 615.451.0048
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www.nastc.com


As Parts of the Nation's Economy Begins to Reopen NASTC Sends a Special Message of Thanks
to our Member Companies and Drivers

I want all Americans to join me in sending you a resounding THANK YOU for everything you're doing to help keep our country moving. Our nation is embroiled in a crisis and our trucking companies and their drivers are doing everything they can to keep America moving. There is no insignificant job in this effort and I just want you to know how important each of you are. From the driver delivering medical supplies and food to the shops keeping them running to the dispatchers and office workers that keep it all organized. The drivers that are delivering fuel, feed and fertilizer are working hard on the front end so we'll have food and grain to haul later and let's not forget the driver delivering the paper products that are flying off the shelves. Everyone is important. Many of you are running hard and others are standing ready to charge into the fray as the economy wakes us from a long spring nap. Things are slowly starting up again and they need us to bring them materials and move their products.

During this time, I know a lot of people are under a lot of stress; please be mindful of this in dealing with others. Let's focus on our mission to keep America moving and realize how important you are in this effort. Remember, the most important thing we haul is you!!! Nothing happens without all of you staying healthy and safe. Along with the waking economy comes more traffic and other obstacles for you to deal with to get to your destination safely. Please stay alert and safe; we need all of you!!

In closing, keeping this country moving in difficult times is not new to most of you. Keep up the great work!! Take care of yourself and your family and stay healthy and safe!!

God Bless You All!! God Bless America!!! KEEP ON TRUCKING!!!!

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com
  Buster Anderson
Executive Vice President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

U.S. Secretary of Transportation Elaine L. Chao Thanks America's Truckers

Dear Member,

I want to share this thank you video from Secretary of Transportation Elaine L. Chao to the trucking workforce. During these challenging times, the men and women working in the motor carrier industry are on the frontlines performing essential work. We sincerely appreciate all that they do.

https://www.youtube.com/watch?v=gdlMLITc4wM&feature=youtu.be

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

FMCSA to Distribution Protective Masks for Truck Drivers

The Federal Motor Carrier Safety Administration (FMCSA) is assisting in the distribution of one million protective masks to the nation's commercial truck drivers.

FMCSA has been working with states, industry stakeholders, and motor carriers to distribute one million protective face masks for truckers which were provided by the Federal Emergency Management Agency (FEMA).

Dates and times for the distribution of masks will be updated as they are established. Click the link below to find locations where the masks are being distributed:

https://www.fmcsa.dot.gov/masks

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

President Trump Thanks Truck Drivers

Today at 1:30 p.m. ET President Trump will be hosting an event on the South Lawn to thank truck drivers for their efforts during the COVID-19 crisis. Tune in to the White House YouTube channel to view the remarks live. The link is below:

https://www.youtube.com/watch?v=ff6XHUk_Qno&feature=youtu.be

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

Expanded Frequently Asked Questions for State Driver Licensing Agencies and Commercial Drivers Regarding Permissible Actions During the COVID-19 Emergency

Below you will find a link to the FMCSA website which contains an expanded list of frequently asked questions regarding permissible actions during the COVID-19 crisis:

https://www.fmcsa.dot.gov/emergency/expanded-frequently-asked-questions-state-driver-licensing-agencies-and-commercial

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

FMCSA EXTENSION AND EXPANSION OF EMERGENCY DECLARATION

The FMCSA has decided to expand the emergency declaration issued on March 13th. The link below will provide clarification on this extension and expansion:

https://www.fmcsa.dot.gov/emergency/expanded-emergency-declaration-under-49-cfr-ss-39023-no-2020-002-relating-covid-19

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

ALL DRIVERS and Their Families and those who support them THANK YOU!!!
YOU ARE MY HEROES

I want you and everyone who supports you to know how very proud I am of you. Once again, as the nation struggles, you have risen above everything to keep America moving and alive. Yes, without your brave actions to keep America moving in the face of this challenge we would certainly be helpless. Every load you deliver during this crisis is vital to not only the economy, but to our very existence. Of course, we know that this is what you do every day, crisis or not. Now however, America is watching closely. They are beginning to understand how vitally important you really are. The President of the United States routinely now includes you when thanking our frontline responders. He knows how much your effort means to this country in crisis.

While your valiant effort is being recognized, I just want to remind you that the most important part of every load you haul is you, the driver. It can't get there without you. Please take care of yourself!!! Make sure you stay safe and healthy. I think this may be a long race and it's important that you stay in the game.

America is watching as you charge into the face of our invisible enemy like a valiant knight aboard a mighty steed of iron. With you leading the way we will win this war. Keep up your good work and remember that I'm so very proud to help you in any way I can.

TAKE CARE - WE'RE ALL DEPENDING ON YOU - WE LOVE YOU.

Buster Anderson
Executive Vice President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

FMCSA Statement on State and Local Shelter in Place and
Other Restrictions on Movement Relating to COVID-19

The link below is from the FMCSA and will provide clarification on State and local shelter in place and other restrictions and how they apply to over the road trucking.

https://www.fmcsa.dot.gov/emergency/statement-state-and-local-shelter-place-and-other-restrictions-movement-relating-covid-19

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

CARES Act Paycheck Protection Program Important Highlights

The Small Business Administration (SBA) just released details and the application form for the new $350 billion in small business loans under the Paycheck Protection Program (PPP) enacted as part of the "CARES Act."  The application window will begin on April 3rd.  

Small businesses are eligible if they also meet program size standards. It is important for companies to reference the SBA's NAICS Code set to determine the specific employee threshold to qualify.

PAYCHECK PROTECTION PROGRAM (PPP) INFORMATION SHEET:
BORROWERS

The Paycheck Protection Program ("PPP") authorizes up to $349 billion in forgivable loans to small businesses to pay their employees during the COVID-19 crisis. All loan terms will be the same for everyone. 

The loan amounts will be forgiven as long as

  • The loan proceeds are used to cover payroll costs, and most mortgage interest, rent, and utility costs over the 8 week period after the loan is made; and 
  • Employee and compensation levels are maintained. 

Payroll costs are capped at $100,000 on an annualized basis for each employee. Due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs. 

Loan payments will be deferred for 6 months. 

When can I apply? 

  • Starting April 3, 2020, small businesses and sole proprietorships can apply for and receive loans to cover their payroll and other certain expenses through existing SBA lenders. 
  • Starting April 10, 2020, independent contractors and self-employed individuals can apply for and receive loans to cover their payroll and other certain expenses through existing SBA lenders. 
  • Other regulated lenders will be available to make these loans as soon as they are approved and enrolled in the program. 

Where can I apply? You can apply through any existing SBA lender or through any federally insured depository institution, federally insured credit union, and Farm Credit System institution that is participating. Other regulated lenders will be available to make these loans once they are approved and enrolled in the program. You should consult with your local lender as to whether it is participating. Visit www.sba.gov for a list of SBA lenders. 

Who can apply? All businesses - including nonprofits, veterans organizations, Tribal business concerns, sole proprietorships, self-employed individuals, and independent contractors - with 500 or fewer employees can apply. Businesses in certain industries can have more than 500 employees if they meet applicable SBA employee-based size standards for those industries.

For this program, the SBA's affiliation standards are waived for small businesses (1) in the hotel and food services industries; or (2) that are franchises in the SBA's Franchise Directory; or (3) that receive financial assistance from small business investment companies licensed by the SBA. Additional guidance may be released as appropriate.

What do I need to apply? You will need to complete the Paycheck Protection Program loan application and submit the application with the required documentation to an approved lender that is available to process your application by June 30, 2020.

What other documents will I need to include in my application? You will need to provide your lender with payroll documentation. 

Do I need to first look for other funds before applying to this program? No. We are waiving the usual SBA requirement that you try to obtain some or all of the loan funds from other sources (i.e., we are waiving the Credit Elsewhere requirement). 

How long will this program last? Although the program is open until June 30, 2020, we encourage you to apply as quickly as you can because there is a funding cap and lenders need time to process your loan. 

How many loans can I take out under this program? Only one. 

What can I use these loans for? You should use the proceeds from these loans on your: 

  • Payroll costs, including benefits; 
  • Interest on mortgage obligations, incurred before February 15, 2020; 
  • Rent, under lease agreements in force before February 15, 2020; and 
  • Utilities, for which service began before February 15, 2020. 

What counts as payroll costs? Payroll costs include: 

  • Salary, wages, commissions, or tips (capped at $100,000 on an annualized basis for each employee); 
  • Employee benefits including costs for vacation, parental, family, medical, or sick leave; allowance for separation or dismissal; payments required for the provisions of group health care benefits including insurance premiums; and payment of any retirement benefit; 
  • State and local taxes assessed on compensation; and 
  • For a sole proprietor or independent contractor: wages, commissions, income, or net earnings from self-employment, capped at $100,000 on an annualized basis for each employee. 

How large can my loan be? Loans can be for up to two months of your average monthly payroll costs from the last year plus an additional 25% of that amount. That amount is subject to a $10 million cap. If you are a seasonal or new business, you will use different applicable time periods for your calculation. Payroll costs will be capped at $100,000 annualized for each employee. 

How much of my loan will be forgiven? You will owe money when your loan is due if you use the loan amount for anything other than payroll costs, mortgage interest, rent, and utilities payments over the 8 weeks after getting the loan. Due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs. 

You will also owe money if you do not maintain your staff and payroll.

  • Number of Staff: Your loan forgiveness will be reduced if you decrease your full-time employee headcount. 
  • Level of Payroll: Your loan forgiveness will also be reduced if you decrease salaries and wages by more than 25% for any employee that made less than $100,000 annualized in 2019. 
  • Re-Hiring: You have until June 30, 2020 to restore your full-time employment and salary levels for any changes made between February 15, 2020 and April 26, 2020.

How can I request loan forgiveness? You can submit a request to the lender that is servicing the loan. The request will include documents that verify the number of full-time equivalent employees and pay rates, as well as the payments on eligible mortgage, lease, and utility obligations. You must certify that the documents are true and that you used the forgiveness amount to keep employees and make eligible mortgage interest, rent, and utility payments. The lender must make a decision on the forgiveness within 60 days. 

What is my interest rate? 0.50% fixed rate. 

When do I need to start paying interest on my loan? All payments are deferred for 6 months; however, interest will continue to accrue over this period. 

When is my loan due? In 2 years. 

Can I pay my loan earlier than 2 years? Yes. There are no prepayment penalties or fees.

Do I need to pledge any collateral for these loans? No. No collateral is required. 

Do I need to personally guarantee this loan? No. There is no personal guarantee requirement. ***However, if the proceeds are used for fraudulent purposes, the U.S. government will pursue criminal charges against you.*** 

What do I need to certify? As part of your application, you need to certify in good faith that: 

  • Current economic uncertainty makes the loan necessary to support your ongoing operations. 
  • The funds will be used to retain workers and maintain payroll or to make mortgage, lease, and utility payments. 
  • You have not and will not receive another loan under this program. 
  • You will provide to the lender documentation that verifies the number of full-time equivalent employees on payroll and the dollar amounts of payroll costs, covered mortgage interest payments, covered rent payments, and covered utilities for the eight weeks after getting this loan. 
  • Loan forgiveness will be provided for the sum of documented payroll costs, covered mortgage interest payments, covered rent payments, and covered utilities. Due to likely high subscription, it is anticipated that not more than 25% of the forgiven amount may be for non-payroll costs. 
  • All the information you provided in your application and in all supporting documents and forms is true and accurate. Knowingly making a false statement to get a loan under this program is punishable by law.
  • You acknowledge that the lender will calculate the eligible loan amount using the tax documents you submitted. You affirm that the tax documents are identical to those you submitted to the IRS. And you also understand, acknowledge, and agree that the lender can share the tax information with the SBA's authorized representatives, including authorized representatives of the SBA Office of Inspector General, for the purpose of compliance with SBA Loan Program Requirements and all SBA reviews.
David Owen
President
800.264.8580
Fax: 615.451.9916
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com

CARES Act Paycheck Protection Program

Below you will find a link to the U.S. Department of Treasury's website with information on the Paycheck Protection Program. Providing small businesses assistance with job retention and other expenses in response to COVID-19.

https://home.treasury.gov/policy-issues/top-priorities/cares-act/assistance-for-small-businesses

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

Curbside pickup available from 11am to 9pm outside of the main east building entrance. Credit cards are the only option for payment. The link below will take you to a menu, dial 563-284-6512 to order.

https://iowa80truckstop.com/pdf/Iowa_80_Kitchen_Menu.pdf

P. J. Park
Vendor Relations, Maintenance & Credit Services Program Manager
800.264.8580

Fax: 615.451.0041


GUIDANCE ON THE ESSENTIAL CRITICAL INFRASTRUCTURE WORKFORCE

Below you will find a link to the Department of Homeland Security's (DHS) website. This article comes from the DHS's "Cybersecurity and Infrastructure Security Agency" (CISA). This article goes into detail on the Critical Infrastructure workforce. Once you click the link below if you scroll down on the article you will find a list of links, the 9th link from the top is on Transportation and Logistics.

https://www.cisa.gov/publication/guidance-essential-critical-infrastructure-workforce#

David Owen
President
800.264.8580
Fax: 615.451.9916
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www.nastc.com

FMCSA COVID-19 Drug & Alcohol Testing Guidance

Please refer to the link below for a guidance document from the FMCSA that contains recommended actions for regulated employers unable to conduct alcohol and drug testing due to COVID-19.

https://www.fmcsa.dot.gov/emergency/fmcsa-covid-19-drug-alcohol-testing-guidance

Nicole Gifford
Director of Drug & Alcohol
800.264.8580
Fax: 615.451.0048
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www.nastc.com


COVID-19 Small Business Guidance & Loan Resources

In the link below you will find some resources from the U.S. Senate Small Business Committee and the U.S. Small Business Administration in response to the COVID-19 Crisis. This information includes how small business owners can apply for low-interest economic injury disaster loans in SBA's 7(a) program.

https://www.sba.gov/page/coronavirus-covid-19-small-business-guidance-loan-resources

David Owen
President
800.264.8580
Fax: 615.451.9916
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com

COVID-19 Information and Resources

The COVID-19 situation is ever evolving which means some of this information may not be relevant in a few days. Visit NASTC's COVID-19 updates page for the latest information. 


Three-Month Waiver in Response to the COVID-19 Emergency
For States and CLP Holders Operating Commercial Motor Vehicles

The FMCSA has allowed a temporary waiver from certain commercial learner's permit (CLP) regulations, for example the requirement that a CPL holder must be accompanied by a CDL holder in the passenger seat when a CPL holder is operating a motor vehicle. The temporary waiver also allows states to give a driving skills test to any non-domiciled CDL applicant, regardless of where the applicant received driver training. Please take a loot at the full waiver for the terms, conditions, and restrictions:

Click here for Full Waiver 


CARES Act Signed into Law

Last week, President Trump signed a massive $2.2 trillion economic assistance package, called the CARES Act. This package will help businesses, provide direct financial assistance to Americans, and add funding for the over-worked health care system. 

Click here to Read More


CDC Statement on Self-Quarantine Guidance
for Greater New York City Transportation and Delivery Workers

The CDC issued self-quarantine guidance for the greater New York City area does not apply to critical infrastructure workers. This includes critical transportation and delivery workers who are needed for New York residents to continue their daily lives.

Click here for full statement

Dana Campbell
Vice President of Operations
800.264.8580
Fax: 615.451.9916
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www.nastc.com


Collection Sites COVID-19 Preparedness

Please refer to the link below for information from Quest Diagnostics regarding their Patient Service Centers (PSC) COVID-19 preparedness. Make note that COVID-19 tests are not being conducted at any of their drug testing collection sites.

https://blog.employersolutions.com/covid-19/

Nicole Gifford
Director of Drug & Alcohol
800.264.8580
Fax: 615.451.0048
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www.nastc.com


Special Update - Regulatory and Legislative Update
March 24, 2020

Regulation and Enforcement

State-ordered shutdowns grow as the COVID-19 situation remains fluid
Over the past week, individual states have issued emergency orders to restrict individual and commercial activity to stem the spread of the novel coronavirus (COVID-19). These terms of these orders vary, but in general they require residents to stay at home except to get food, health care, care for someone else, or work in a job deemed to be essential. As of now, at least 14 states have officially adopted some type of emergency order restricting people from working outside their homes except in essential jobs:
  • California
  • Connecticut
  • Delaware
  • Illinois
  • Louisiana
  • Maryland
  • Massachusetts
  • Michigan
  • New Jersey
  • New York
  • Ohio
  • Pennsylvania
  • West Virginia
  • Wisconsin
These restrictions beg the question, of course, of what constitutes "essential." In general, states seem to be coalescing around a list published by the Department of Homeland Security at:
https://www.cisa.gov/publication/guidance-essential-critical-infrastructure-workforce

Not surprisingly, basically anything that supports transportation and logistics is covered. Indeed, the list of essential workers is fair extensive and potentially open to interpretation, but among the categories not covered are non-food retail and manufacturing that is not deemed to be critical. A definition of critical manufacturing is on the website.

The situation of course is very fluid. One organization that is monitoring the situation closely is the National Association of Manufacturers. NAM's COVID-19 resources are available at https://www.nam.org/covid-19-state-resources/.

FMCSA's expanded enforcement relief covers a broader share of freight
The Federal Motor Carrier Safety Administration on March 18 issued an expanded emergency declaration that adds to the categories of goods considered to be direct assistance in relief from the impacts of the novel coronavirus (COVID-19) pandemic. (For details on the original March 13 declaration, see the Special Report distributed on March 16; unless otherwise stated, the terms of that declaration remain in place.) The expanded emergency declaration, which still expires on April 12 unless lifted earlier or extended, also offers some flexibility on enforcement relief on loads that combine routine commercial transportation and qualifying transportation. Specifically, the expanded declaration grants emergency relief from the requirements of Parts 390 through 399 for transportation to meet immediate needs for:

  • Medical supplies and equipment related to the testing, diagnosis and treatment of COVID-19;

  • Supplies and equipment necessary for community safety, sanitation, and prevention of community transmission of COVID-19 such as masks, gloves, hand sanitizer, soap and disinfectants;

  • Food, paper products and other groceries for emergency restocking of distribution centers or stores;

  • Immediate precursor raw materials-such as paper, plastic or alcohol-that are required and to be used for the manufacture of items in categories (1), (2) or (3);

  • Fuel;

  • Equipment, supplies and persons necessary to establish and manage temporary housing, quarantine , and isolation facilities related to COVID-19;

  • Persons designated by Federal, State or local authorities for medical, isolation, or quarantine purposes and;

  • Persons necessary to provide other medical or emergency services, the supply of which may be affected by the COVID-19 response.

The original declaration stated that qualifying direct assistance did not include routine commercial deliveries, or transportation of mixed loads that include essential supplies, equipment and persons along with non-qualifying transportation. The March 18 declaration states that direct assistance "does not include routine commercial deliveries, including mixed loads with a nominal quantity of qualifying emergency relief added to obtain the benefits of this emergency declaration." What exactly is meant by "a nominal quantity of qualifying emergency relief" would appear to be a judgment call by a carrier subject to review by a roadside inspector or auditor.

Another gray area could be what constitutes an "immediate precursor raw material." We do know from a frequently asked question (FAQ) page related to the emergency declaration is that livestock counts because it is a precursor to food. Carriers may never receive definitive answers on how to interpret the scope of the relief, so they might have to rely on their best judgment and be prepared to justify those decisions to inspectors or auditors.

Resources:

David Owen
President
800.264.8580
Fax: 615.451.9916
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com

Dear Member,

As of last night at 8:00pm the Governor of Pennsylvania has ordered all non-life-sustaining businesses to close until further notice. However, we wanted to let you know that this will not apply to you. In the transportation sector this mandate only applies to the transportation of people, not goods. I have provided some links below to further clarify the situation:

Click here to see a copy of the mandate

Click here to see an article from the PA Governors Website

Click here for a chart that shows which businesses this mandate applies to (Transportation is on page 3)


David Owen
President
800.264.8580
Fax: 615.451.9916

This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com


Dear Member,

The President has declared a National Emergency due to the Coronavirus Disease 2019 (COVID19) outbreaks. In response to this the FMCSA is allowing exemptions on certain regulations until the termination of the emergency or 11 :59 P.M. (ET) on April 12, 2020, whichever comes sooner. Below you will find two links from the FMCSA website that go into more detail on this subject:

Click here to go directly to an Article from the FMCSA Website

Click here to go directly to the FMCSA National Emergency Declaration Letter

David Owen
President
800.264.8580
Fax: 615.451.9916

This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com


FMCSA CDL Waiver

FMCSA grants, until June 30, 2020, a waiver from certain regulations applicable to interstate and intrastate commercial driver's license (CDL) and commercial learner's permit (CLP) holders and to other interstate drivers operating commercial motor vehicles. For more information please click the link below:

https://www.fmcsa.dot.gov/emergency/fmcsa-cdl-waiver-32420

Angel Clark
Director of Safety & Compliance Services
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www.nastc.com
800.264.8580


DOT Guidance on Drug/Alcohol Testing Compliance During COVID-19 Crisis

Please see the below link that provides DOT Guidance on Compliance with DOT Drug and Alcohol Testing Regulations in regards to the COVID-19 virus.

https://www.transportation.gov/odapc/compliance-with-dot-drug-and-alcohol-testing-regulations

If you have any questions please feel free to reach out to me.

Nicole Gifford
Director of Drug & Alcohol
800.264.8580
Fax: 615.451.0048
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www.nastc.com


(UPDATED: 3.20.2020)

COVID-19 Response

We are open and ready to serve you.

We at TA and Petro Stopping Centers are doing the best we possibly can to continue to serve you as the COVID-19 situation evolves. Thank you for your patience and support as we navigate through COVID-19 together.

Our operational directives are made relying on guidance from the Centers for Disease Control and the World Health Organization.

The following are our best current updates regarding our services and amenities:
• All fuel lanes are open, with no fuel rationing.
• All TA Truck Service centers are open and RoadSquad 24-Hour Roadside Assistance is available.
• Our showers are open and you can still reserve showers through the app. Our employees continue to use the highest-quality chemicals when cleaning each shower.
• We are following individual state mandates regarding closures of full-service restaurant dining. Some states are implementing 50% occupancy caps while others are mandating full dining room closures. Updates by state can be found below. The buffets and soup and salad bars in our Iron Skillets and Country Prides are closed, as are some of our dining rooms. Currently, carry-out at all restaurants is still available. You may order online from Iron Skillet ahead of time. Depending on the applicable government mandate, we may have to bring the food out to you. Specific information will be available at the travel center.
• Our quick-service restaurants are open. However, you will not be permitted to eat in the dining areas due to mandates as stated above. Depending on the applicable government mandate, we may have to bring the food out to you. Specific information will be available at the travel center.
• We are increasing our cleaning frequency and continue to use best-in-class, food-safe cleaners to disinfect and sanitize common touch points within the restaurants and travel centers. These include showers, restrooms, registers, door knobs, tables, menus, chairs, booths, counters, and all dishes, utensils and cooking surfaces.
• We have closed our Fitness Centers and Driver Lounges until further notice.
• For customers that usually use a TA/Petro refillable mug, we ask that you discontinue their use at this time. Please use a disposable cup; you will still qualify for the refill price: just tell the cashier that you participate in the refillable mug program.
• Our employees have been advised to take care of themselves and be aware of best practices for preventive safety measures. This includes frequent hand washing and staying home when feeling ill.
• All truck parking including Reserve-It remain in effect. Thank you for continuing to allow us to serve you as we navigate through this unprecedented time together. The decisions we make are with your health and safety at top of mind. We will continue to provide updates on our COVID-19 response page.

Thank you for your continued service - we appreciate all you do to keep our economy moving.

TravelCenters of America and Petro Stopping Centers

Restaurant Regulations by State (last updated 3/20 at 8:00 a.m.)

*Please note that Dunkin' and Baskin-Robbins restaurants will only be doing to-go orders. There will be no dine-in options at these locations.

State                Rule

  • Alabama:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Arizona:

    Black Bear Diner in Kingman is available for to-go meals only.
  • Arkansas:

    Maximum occupancy rate must remain under 50 percent or 50 people. Expires March 31.
  • California:

    Wheeler Ridge - Maximum occupancy rate must remain under 50 percent. Barstow and Ontario - To go only
  • Colorado:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 15.
  • Connecticut:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Florida:

    Maximum occupancy rate must remain under 50 percent. All booths and tables must be at least six feet apart. Tampa only - No food sales between 10 p.m. and 6 a.m. including roller grill, fountain drinks, coffee and all self-serve items.
  • Illinois:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. People may not walk into the restaurant to pick up their orders. Food must be consumed outside of the building. Expires March 30.
  • Indiana:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Iowa:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 31.
  • Kentucky:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Louisiana:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Maryland:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Massachusetts:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 6.
  • Michigan:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 30.
  • Minnesota:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. People may go into the restaurant to pick up their orders as long as there are less than five people in the facility.
  • Missouri:

    Johnson County, Kansas City and Wyandotte County only - Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 31.
  • Montana:

    St. Charles County, Yellowstone County and Missoula County only - Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Nevada:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • New Hampshire:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 17..
  • New Jersey:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed only between 5 a.m.-8 p.m.
  • New Mexico:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 10.
  • New York:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • North Carolina:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • North Dakota:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Oklahoma:

    Oklahoma City - Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Ohio:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Oregon:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Pennsylvania:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Rhode Island:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • South Carolina:

    Columbia only - Maximum occupancy rate must remain under 50 percent. All booths and tables must be at least six feet apart. No more than six people can be at a table. A curfew is in place from 11 p.m. until 6 a.m.
  • Tennessee:

    Nashville only - Bars and restaurants are closed. Expires April 3.
  • Texas:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Utah:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Virginia:

    Maximum occupancy rate must remain under 10 total people. To go is encouraged.
  • Washington:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • West Viriginia:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Wisconsin:

    Maximum occupancy rate must remain under 50 percent or 50 total people. All booths and tables must be at least six feet apart.
  • Wyoming:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Cheyenne only - Customers may not enter restaurants. To go orders must be delivered to the guests' cars.

P. J. Park
Vendor Relations, Maintenance & Credit Services Program Manager
800.264.8580

Fax: 615.451.0041


Dear NASTC Insurance Services Client,

NASTC and NASTC Insurance Services will be working remotely due to current events of COVID-19:

All of our NASTC Insurance Services clients have access to our CSR 24 - Certificate system to process requested Certificates of Insurance on a daily basis, over the weekend or on Holidays.

In order to better serve you, please contact us to obtain your USER NAME

Contact us with any questions. Department email: This email address is being protected from spambots. You need JavaScript enabled to view it.


Go to: https://portal.csr24.com/mvc/2648580

USERNAME: User Name

PASSWORD: nastc

Click "Managing Certificate". • Issue a Certificate of Insurance/Proof of Insurance Click on the "DATE" of the Certificate: • "2019-2020" Certificate • "2020-2021" Certificate Click "Add Holder", enter the broker/carrier information and "Submit" in bottom corner to send.


Dear Member,

Due to the COVID-19 crisis and for the safety of our staff and community, NASTC, NASTC Insurance Services and NASTek National will begin operation remotely. We ask for your patience during this time as we try to provide you the same service in a remote fashion. We also thank all our drivers for their service to our country during this time and pray for the health and safety of everyone. Please visit our Contact page for direct lines and email addresses.

Dana Campbell
Vice President of Operations
800.264.8580
Fax: 615.451.9916
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com


To our valued fleet partners:

This is truly an unprecedented time for the nation and I want to let you know that we at TravelCenters of America are focused on doing all that we can to ensure the continuity of our business operations for you and your professional drivers. Our top priorities are the health and well-being of our employees, our customers and the general public.

Specifically, we are doing the following:

· Working with NATSO as well as our two primary competitors to ensure our travel centers are considered "Essential Services" under various state laws, so that they are not closed. Of course we recognize that your fleet and drivers are moving critical goods to consumers to help them stay healthy, comfortable and fed, which makes our centers "essential services".

·To the fullest extent possible we are keeping quick serve and full service restaurants open. In cases where we are forced to close them, we are ensuring take out options remain.

·Showers and bathroom facilities will remain open, subject to state law limitations.

·Convenience store facilities will remain open, subject to state law limitations.

·TV lounges and fitness facilities will be closed.

·Truck parking and reserve It, reserved parking for our loyal fleet customers, will remain in effect.

· We are maintaining appropriate and enhanced cleaning protocols with the best-in-class chemicals to ensure the safety of our customers, drivers and employees.

We feel an important obligation not just to you and your drivers, but to this Country to help make sure we continue to play a role in ensuring essentials make it to our fellow citizens. We feel proud, patriotic and humble.

In this fast-evolving situation, we have a highly-trained emergency response team closely monitoring updates by the minute and we will continue to operate under guidance from the Centers for Disease Control and the World Health Organization.

We've created a webpage for our customers to get daily status updates on our operations. Please visit:

https://www.ta-petro.com/newsroom/covid-19-response

This link contains the latest information on our COVID-19 response, including precautionary measures we are taking for the health and safety of everyone.

Thank you for your continuing support and let us know how we can be helpful.

Sincerely,
Jon Pertchik
CEO, TravelCenters of America

https://www.ta-petro.com/newsroom/covid-19-response


At NASTC, the health and well-being of our members, as well as your OTR drivers, are a top priority. We understand the concern and uncertainty you may be experiencing surrounding the coronavirus disease (COVID-19) and we are committed to being responsive to the needs of our members as the situation evolves.

As the FMCSA recognizes the critical role the trucking industry will play in keeping America supplied with food, medical supplies and equipment during this time, so does NASTC.

Therefore, the most important thing is to keep drivers healthy and on the road. We want to make sure you can be diagnosed and treated for illnesses that are NOT related to COVID-19. Currently the only way to confirm COVID-19 diagnosis is with an in-person test, therefore it would not be possible for HelpMD physicians to come to such a diagnosis over the phone, computer, or mobile app. NASTC'S partnership with HelpMD can be a very important and beneficial service we can provide for your company.

We are approaching the start of spring allergy season which can make you feel miserable. Common symptoms such as:
• Itchy and watery eyes
• Runny Nose
• Sneezing
• Nasal Congestion
• Swollen sinuses
• Sinus pressure in your face, teeth and head.

HelpMD, a leading telemedicine provider, is changing the way people seek and get medical advice, diagnosis and prescriptions. Keeping you from having to go to an urgent care facility, doctor's office or the ER with NON-CRITICAL illnesses. HelpMD can also treat illnesses such as:
• Pink Eye
• Urinary Tract Infection
• Nausea
• Diarrhea
• Rashes
• And many more
• Covers employee, spouse and dependents
• No co-pay
• Connect by phone, mobile app or computer
• 24/7 on demand access to a board-certified physician.
• Prescriptions are provided when deemed medically necessary

If you suspect you are infected with the virus that causes COVID-19, follow the steps (as detailed by the CDC) to help prevent the spread of the disease in your home and community.

A link to the CDC instructions has been provided below for your convenience.

https://www.cdc.gov/coronavirus/2019-nCoV/index.html

For more information about HelpMD please reach out to Debbie Lamberson.

Debbie Lamberson
Project Sales Manager
Direct Line: 615.989.9198
This email address is being protected from spambots. You need JavaScript enabled to view it.
www.nastc.com
800.264.8580


(UPDATED: 3.17.2020)

COVID-19 Response
We are open and ready to serve you.

Click here for a direct link to TA/PETRO's response on their website

We at TA and Petro Stopping Centers are doing the best we possibly can to continue to serve you as the COVID-19 situation evolves. Thank you for your patience and support as we navigate through COVID-19 together. Our operational directives are made relying on guidance from the Centers for Disease Control and the World Health Organization.

The following are our best current updates regarding our services and amenities:
• All fuel lanes are open.
• Our showers are open and you can still reserve showers through the app. Our employees continue to use the highest-quality chemicals when cleaning each shower.
• We are following individual state mandates regarding closures of full-service restaurant dining. Some states are implementing 50% occupancy caps while others are mandating full dining room closures. Updates by state can be found below. The buffets and soup and salad bars in our Iron Skillets and Country Prides are closed, as are some of our dining rooms. Currently, carry-out at all restaurants is still available. You may order online from Iron Skillet ahead of time. Depending on the applicable government mandate, we may have to bring the food out to you. Specific information will be available at the travel center.
• Our quick-service restaurants are open. However, you will not be permitted to eat in the dining areas due to mandates as stated above. Depending on the applicable government mandate, we may have to bring the food out to you. Specific information will be available at the travel center.
• We are increasing our cleaning frequency and continue to use best-in-class, food-safe cleaners to disinfect and sanitize common touch points within the restaurants and travel centers. These include showers, restrooms, registers, door knobs, tables, menus, chairs, booths, counters, and all dishes, utensils and cooking surfaces.
• We have closed our Fitness Centers and Driver Lounges until further notice.
• For customers that usually use a TA/Petro refillable mug, we ask that you discontinue their use at this time. Please use a disposable cup; you will still qualify for the refill price: just tell the cashier that you participate in the refillable mug program.
• Our employees have been advised to take care of themselves and be aware of best practices for preventive safety measures. This includes frequent hand washing and staying home when feeling ill. Thank you for continuing to allow us to serve you as we navigate through this unprecedented time together. The decisions we make are with your health and safety at top of mind. We will continue to provide updates on our COVID-19 response page.

Thank you for your continued service - we appreciate all you do to keep our economy moving.

Restaurant Regulations by State (last updated 3/17 at 2:30 p.m.)

*Please note that Dunkin' and Baskin-Robbins restaurants will only be doing to-go orders. There will be no dine-in options at these locations.

State

Rule

  • California:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Colorado:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 15.
  • Connecticut:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Florida:

    Maximum occupancy rate must remain under 50 percent. All booths and tables must be at least six feet apart.
  • Illinois:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. People may not walk into the restaurant to pick up their orders. Food must be consumed outside of the building. Expires March 30.
  • Indiana:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 31.
  • Iowa:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 31.
  • Kentucky:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Louisiana:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Maryland:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Massachusetts:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires April 6.
  • Michigan:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 30.
  • Minnesota:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed. People may go into the restaurant to pick up their orders as long as there are less than five people in the facility.
  • Missouri:

    Johnson County, Kansas City and Wyandotte County only - Dine-in areas are closed. Drive-thru, to go and delivery is allowed. Expires March 31.
  • Montana:

    Yellowstone County and Missoula County only - Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • New Jersey:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed only between 5 a.m.-8 p.m.
  • New Mexico:

    Maximum occupancy and seating capacity rate must remain under 50 percent. All booths and tables must be at least six feet apart.
  • New York:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • North Carolina:

    Effective after 5 p.m. today: Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Ohio:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Oregon:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Pennsylvania:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Rhode Island:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • South Carolina:

    Columbia only - Maximum occupancy rate must remain under 50 percent. All booths and tables must be at least six feet apart. No more than six people can be at a table.
  • Texas:

    Harris County and Dallas County only - Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Virginia:

    Maximum occupancy rate must remain under 10 total people. To go is encouraged.
  • Washington:

    Dine-in areas are closed. Drive-thru, to go and delivery is allowed.
  • Wisconsin:

    Maximum occupancy rate must remain under 50 percent or 50 total people. All booths and tables must be at least six feet apart.

P. J. Park
Vendor Relations, Maintenance & Credit Services Program Manager
800.264.8580

Fax: 615.451.0041

Article Deficiencies for Small Carriers

NASTC News


Mandated Speed Limiters

The entire idea of governed trucks came about in mega-fleets to save money on fuel. This was long before automatic transmissions, cruise control, and other technologies that assisted drivers to get into and maintain speed in the “sweet spot.” However, it was soon apparent that true professional drivers could maximize mileage without such a device and rookies just couldn’t. Large companies began to lose their best, safest, and oldest drivers because they detested governed trucks. This has much to do with ever increasing DRIVER TURNOVER in large companies. Another inconvenient truth: ALMOST ALL FULL-TRUCKLOAD COMPANIES WITH OVER 500 POWER UNITS HAVE DRIVER TURNOVER RATES IN EXCESS OF 100%! NASTC has made the case for three decades that this represents the biggest safety issue in trucking, not speed, not fatigue, not hours of service violations, but DRIVER TURNOVER! No wonder large carriers think there’s a driver shortage. No wonder they want 18-year-olds to drive commercial vehicles. No wonder they want small carriers with single-digit turnover rates to be regulated away.


Hair sample testing in the
“Mandatory Guidelines for Federal Workplace Drug Testing Programs”

October 28, 2020

Substance Abuse and Mental Health Services Administration
Center for Substance Abuse Prevention
Division of Workplace Programs
5600 Fishers Lane, Room 16N02
Rockville, MD 20857

RE: Document No. SAMHSA-2020-0001-0002

To whom it may concern:

The National Association of Small Trucking Companies (NASTC), which represents more than 13,500 small-business commercial motor carriers, is pleased to respond to the Substance Abuse and Mental Health Services Administration (SAMHSA) notice requesting comment regarding inclusion of hair sample testing in the “Mandatory Guidelines for Federal Workplace Drug Testing Programs” (Document No. SAMHSA-2020-0001-0002).

NASTC is a member-based association whose member companies range from one or a few power units to more than 100 power units; however, our members average 12 power units. These companies mainly operate in the long-haul, over-the-road, full-truckload, for-hire sector of interstate trucking. NASTC’s members come from the largest segment of America’s long-haul trucking — small motor carrier businesses. Thus, they are more representative of the vast majority of our nation’s commercial motor carriers, the almost 440,000 carriers with fewer than 100 power units, in contrast to the 1,441 megafleet carriers. Moreover, NASTC administers drug and alcohol testing programs for approximately 4,500 member motor carriers of all sizes. This experience since 1991 provides NASTC with keen insight regarding this important subject.

We appreciate SAMHSA’s mission “to maintain the integrity and ensure the quality of federal drug-free workplace programs by a commitment to identify and mandate the use of the most accurate, reliable drug tests and testing methods available.” We commend SAMHSA for its adherence to high standards and its deliberative approach. In NASTC’s view and based on our extensive experience, we contend that in long-haul trucking, urine specimens provide the best means of ensuring integrity and quality through the most accurate and reliable testing methods.

We acknowledge that a sizable share of the 1,441 largest motor carriers have incorporated hair testing for drug use into their drug testing programs. That is a business decision they have made on their own. The large carriers’ intent here is plain: Making hair testing not merely an alternative to or supplement to urine drug testing of commercial truck drivers, but to replace such testing with hair testing.

Their criticism of the proposed guidance as not clearing the way for hair testing at full speed ahead seems to have less to do with the science and performance of certain drug testing methods and more to do with saddling their numerous small competitors with additional compliance costs. As this notification states, urine drug testing will cost a little less than hair testing when the costs of recontouring the infrastructure to use hair are included. That hard cost remains a mystery in that the entire protocol will change. Training, collection, certification, and the duties of a medical review officer will have to be reconstructed based on FMCSA’s regulations. Also, as pointed out above, in many cases there will have to be dual systems run. This has the potential to undo all the good work the industry has done now for almost 30 years, especially with small carriers who make up 99.9 percent of those regulated. This isn’t just a bad idea – it’s a horrible and short-sighted regulatory mistake!

The economic case for forcing small motor carriers to switch drug testing methods falls flat on its face. There is no reason to put the government’s thumb on the scales for economic and competitive outcomes desired by and disproportionately favorable to the relative handful of the largest motor carriers 1. We recognize that economic considerations 1 may be of less concern than scientific ones to SAMHSA; however, it is important that this agency be aware of the broader picture.

In 1991, when testing for drugs was first required for all carriers regardless of size, the positive rate for drug usage for the general population exceeded 15 percent while the positive rate for professional truck drivers was 9.5 percent. Today, the positive rate for drivers in the long-haul niche has hovered just above or just below 1 percent for the past three years. This is a regulatory area where the policies as implemented have been extremely effective. Also, over the years as our industry’s positive rate has declined, so have the numbers for large truck-car fatalities fallen almost as a direct correlation. See the graphic below.

1 Ivan Espinoza-Madrigal & Larry Willis, “Hair drug testing is not accurate, we shouldn't rely on1 Ivan Espinoza-Madrigal & Larry Willis, “Hair drug testing is not accurate, we shouldn't rely onit,” The Hill, September 25, 2017 (https://thehill.com/opinion/healthcare/352235-hair-drugtesting-is-not-accurate-lets-stop-relying-on-them)

The drug testing methods presently employed have achieved this remarkable reductionThe drug testing methods presently employed have achieved this remarkable reductionin commercial driver drug usage and corresponding improvements in highway safety.Therefore, a high bar should be required for supplementing — and certainly for displacing — theexisting, successful drug testing method. And the burden of proof for making a change resideswith the special interests advocating such dramatic change.

Megacarriers’ opinions notwithstanding, hair testing would not improve on urine testingfor detecting drug usage by commercial drivers. The reason is because 2 drug screening servesthe purpose of determining the condition of a driver at the time the driver is behind the wheel.This is generally shorter-term or immediate, rather than a week up to 90 days earlier.

In the trucking sector, random drug tests of 50 percent of drivers must occur while adriver is on duty. Thus, while hair testing may detect past drug usage by a driver, it does notindicate the status of the driver’s drug usage during a period when the truck driver will have justbeen behind the steering wheel. Nor would hair tests be feasible in postaccident or for-causescreening situations for the same reasons. Notably, law enforcement will not perform roadsidedrug tests. A delay in collecting specimens from drivers at the time of a reportable accident hasimplications regarding determining contemporaneous drug usage, chain of custody ofspecimens, potential for fraud, and accuracy with respect to the facts at time of accident.

The only instance of the four types of drug screening in which hair testing may besuitable is preemployment screening. Even then, this method would typically need to besupplemented with urine testing so as to provide more recent drug usage readings, due to therebeing 5 days before drugs consumed appear in hair. Thus, a dual system of both urine and hairtests would be required.

As the notice recounts, controlled substances may be detected in hair due tocontamination from environmental exposure or cosmetic hair treatments, and how variationoccurs in connection with hair color. A recent journal item sums up the challenges with drugtesting by hair as “someone could be exposed to a drug without having ingested it and thereforetest positive as well as the fact that the drugs bond with some hair types better than others,which cause inaccuracies about when a drug might have been taken.”3 Another journal articleconfirms how with hair treatments, “drugs may be lost from the hair matrix or, under conditionsof environmental contamination, be more easily incorporated into the hair matrix.”4 This studyfound that damaged hair decreases drug concentration by 40-60 percent. Other “researchsuggests that there isn’t that strong [a] link between cannabis consumption and chemicaldeposits in the hair after all,” calling into question the efficacy of hair drug testing.5

2 Eric Miller, “HHS Issues Proposed Hair Testing Guidelines,” Transport Topics, September 8,2 Eric Miller, “HHS Issues Proposed Hair Testing Guidelines,” Transport Topics, September 8,2020 (https://www.ttnews.com/articles/hhs-issues-proposed-hair-testing-guidelines)

3 Jenna Bouley, “Issues with Hair-Follicle Drug Testing,” Richmond Journal of Law andTechnology, August 13, 2018 (https://jolt.richmond.edu/2018/08/13/issues-with-hair-follicledrug-testing/)

4 C. Jurado , P. Kintz, M. Menéndez, & M. Repetto, “Influence of the cosmetic treatment of hairon drug testing,” International Journal of Legal Medicine, 1997;110(3):159-63 (https://pubmed.ncbi.nlm.nih.gov/9228567/)

5 “Update on Hair Follicle Drug Tests Effectiveness,” Euro Pharm Forum, August 10, 2017
(https://www.europharmforum.org/2017-update-on-hair-drug-test-efficacy/)

To the extent these confounding factors have a disparate adverse impact on racial andTo the extent these confounding factors have a disparate adverse impact on racial andethnic minorities, it would be advisable to err on the side of caution with regard to hair testing inthe trucking sector. It is clear that, for small- and medium-sized motor carriers, the legalexposure caused by false positives from hair tests would skyrocket, especially with respect tohair test results jeopardizing minority truck drivers’ livelihoods.

In 2020, the entire country has gained a view of the problems arising from false positivesand false negatives in COVID screening tests. In similar fashion, hair testing for drugs wouldlikely produce many more false readings for drug use. In order to confirm the initial falsepositivereading, further testing, perhaps a screening of a urine sample, would be required. Inother words, a dual system, with all the added costs and ramifications, would be layered ontothe trucking industry. That is ludicrous. The proliferation of false positives and false negativesfrom hair tests would dramatically increase legal liability exposure for motor carriers, brokers,shippers, and every part of the trucking industry.

Simply put, an unwise testing shift would do unnecessary harm to small businesses,truckers, and others involved in the business.

In NASTC-managed carriers’ drug and alcohol screening programs since 1991, workingwith NIDA-certified laboratories, about 100 urine tests are performed per day. Results areproduced within 24 hours on the initial test, and on average one out of every 100 drugscreenings yields a positive reading for drug usage. For the one out of 100 positive drug testsusing urine samples, these “laboratory positives” are dealt with according to our protocols,which enable timely verification through direct interactions between a medical review officer, thedriver, the drivers’ doctor and/or pharmacy. This ensures due process, balance, accountability,and fairness.

A positive drug test result for a commercial truck driver constitutes a one-strike-andyou’re-out standard. A single positive drug test effectively bars that driver from continuing towork in the trucking industry. The federal Drug and Alcohol Clearinghouse in effect precludessomeone whose record has a positive drug test from ever driving a commercial vehicle again.Thus, it is important both to ensure a clean truck-driving workforce on our highways and to beabsolutely certain that the driver in question is not a victim of false positives that would close offhis or her livelihood if positive drug test results are erroneous. Also, false negatives potentiallycreate increased liability for a company owner.

While hair testing may yield more positive drug tests than do urine tests because certaindrugs remain detectable in hair much longer than in urine, those results do not indicatecorresponding risks to the driving public. The drug might have been lawfully consumed orresponsibly dispensed and used, and pose no danger when a driver is on duty driving. Forinstance, a truck driver who lives in a state where marijuana is legal may use this drug when offduty, or he or she was legitimately prescribed an opioid weeks or months before in connectionwith medical treatment under a physician’s care. Again, the concern with regard to truck driverdrug usage is a driver’s condition at the time he or she is driving. Is there evidence that thedriver’s usage affected his or her ability to operate a vehicle safely while on duty? In this light,hair testing for drugs seems of less benefit where professional drivers are concerned.

While hair testing for drug use may be useful in some industries and for applicationssuch as legal and criminal justice purposes, its utility in the trucking industry, and perhaps inother transportation sectors, strikes us as less beneficial and less practical. In any event, hairbaseddrug testing in trucking would leave us either sole use of another method of testing inmost circumstances or serve as a supplement to urine or saliva tests — a dual system, entirelyneedlessly.

In conclusion, NASTC appreciates the opportunity to comment on this matter.

Sincerely,

david owen
David Owen

A downloadable PDF of this article can be found here


Article Deficiencies for Small Carriers

To whom it may concern:

NASTC was asked to chronicle all and any deficiencies that we felt were worrisome for small carriers in the current regulatory environment. This request was made by staffers for Senator Deb Fischer. We passed this request to Henry Seaton, ASECTT, Rick Gobbell, Jeff Davis, Fleet Safety Services LLC, Joe Rajkovacz, Western States Trucking Association, Mark Andrews, and others. The enclosed package is that compilation and taken in its entirety, it would seem that we, as a group, feel as if we’re the smartest people in the room and that FMCSA, the Motor Carrier Safety Advisory Committee, CVSA, and all of the Safety groups (PATT, CRASH, MADD, Public Citizen, etal) haven’t a clue with their faulty rationales reflected in the HOS, CSA, and actions proposed and/or implemented by the agency or mandated by Congress. We appear on the face of this submission to be a total contrarian group opposed to everything. Nothing could be further from the truth.

This package comes across this way because of one simple fact:

99% of the “for-hire” carriers are not in the policy making loop and all policy, regs, and laws are greatly influenced, written, or submitted by the 1% of “for-hire” carriers who have for decades promoted the erroneous factoid that owner-operators and small carriers are unsafe with the corollary that large mega-carriers who spend millions, are inherently safer. This myth has been drummed into the safety establishment for almost 50 years resulting in the huge disconnect between safety and compliance, the inexcusable lacking of CSA and SMS methodology, and the illogical shortcomings of the HOS. All symptomatic of the mind set and faulty premises regarding big trucks and safety.

No longer should we quietly accept Draconian demands that come down from inside the belt-way with regs, guidance, mandates, and laws that reek of regulation without representation. Strictures that are passed primarily to harass the small, weak, and unrepresented at the competitive whim of monopolistic, mega fleets.

  • Take a look at the make-up of the Motor Carrier Safety Advisory Committee. With the exception of Todd Spencer, no one represents small truckers and 6 members come from so-called safety groups (people who have had relatives die in a large truck accident), four or five from enforcement, with the remainder being unions, the insurance community, and big trucking.
  • Where does CVSA get its authority, funding, and unbridled power? It’s an ad-hoc, non-elected, non-appointed entity funded by the tax payers with little or no accountability.
  • When will someone hold the agency, Virginia Tech University, or the so-called Academy of Scientists accountable for their constant rubber-stamping of anything the agency wants to prove from one of its “studies”. Over and over the lack of sound science has been pointed out and results have been predictably unsupportable. Some of the more recent absurdities include the finding that CSA is “salvageable” with a larger and broader set of data, that lacking conclusive cost/benefit analysis a simple contribution of “expert opinion” will suffice, and the absolute refusal to look at Werner’s safety numbers vis-a-vis, the use of ELD’s prior to a mandate, and then, from their own study claiming the mandate would save 17 lives, a number far below any logical statistical standard deviation.

There are many more examples that were fortunately thwarted before passage, such as mandated speed limiters, increased insurance minimums, the sleep apnea debacle, the certified medical examiners registry, the unending attack on the owner/operator business model, and the idea that non-rated carriers should be treated as somehow deficient just because the agency couldn’t get around to rating them. Some really smart guy even made the comment that these “dastardly small carriers just weren’t having enough accidents to be measured.”

All of this said, NASTC would like to be on record (as we’ve stated many times) that we need to seriously consider the desk-top audit biennial rating for all carriers and the fixing of HOS as far as flexibility is concerned, as top priorities, consider driver turn-over as a serious safety issue, and for goodness sake put some equity small vs. large in the entire policy-making and enforcement rationale. Over time, many of the problems cited will be diminished to a workable level.

Sincerely,

david owen
David Owen

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Alice in Wonderland-style Truck “Safety” Regs

Alice in Wonderland-style Truck “Safety” Regs

An interesting Blog from James Edwards, NASTC's Washington Contact.   A Line of Sight - Sunday, March 04, 2012 By James R. Edwards Jr., Contributing Editor             The so-called Compliance Safety Accountability program out of the U.S. Department of Transportation makes Alice’s experiences in Wonderland look reasonable.  CSA amounts to a bureaucratic end run around the legally required rulemaking requirements, an arbitrary and subjective way to re-regulate a deregulated industry, and a disruption to the supply chain in ways that will have substantial effects on consumers and the shipping public.             A little background:  CSA uses roadside inspection data to rank commercial motor carriers in seven “BASIC” safety categories.  BASICs include things like “vehicle maintenance,” “driver fitness,” and “unsafe driving.”  A creation of the Federal Motor Carrier Safety Administration, CSA ranks the truck companies against each other in each of the BASICs (five of which are publicized on the Internet).             CSA’s Safety Measurement System assigns scores in each BASIC to a carrier.  Rated carriers are then compared against their “peers” within each BASIC.  A percentile ranking in a category supposedly shows where a carrier stacks up against other motor carriers.  But it’s an ever-changing set of peers. FMCSA sets an arbitrary percentile level for each BASIC that some refer to as “limbo bars.”  Carriers whose BASIC score crosses the limbo bar gets branded on the CSA website with an “alert” — a golden triangle with an exclamation mark. The agency created CSA to replace its precursor, SafeStat.  No doubt SafeStat wasn’t perfect.  But SafeStat scores remained unpublicized.  They gave agency officers an internal tool for determining what interventions were appropriate for certain carriers that might have some challenging safety area.  If CSA were only a newer, internal tool for the agency to do its job, that would be tolerable.  But the FMCSA has put CSA scores out there in public.  The agency has even been pushing shippers and brokers to rely on CSA scores in choosing freight haulers. But CSA has real problems.  And it’s causing turmoil in the industry.  Perfectly safe carriers are losing business with established clients because of CSA-spurred fears.  How CSA got here reveals a lot about this imperfect system and its harmful consequences. First, CSA was rolled out never having followed legal requirements designed to protect against rogue rulemaking.  FMCSA developed CSA itself, without any clear statutory authority from Congress to do so.  The agency claims it can do this under its general authority.  CSA was field-tested in a handful of states, where indications were that it improved upon SafeStat, but had problems.  The University of Michigan produced a study at FMCSA’s request assessing CSA.  The study apparently never underwent any kind of peer review and was never published in any reputable academic journal.  Instead, FMCSA kept the UM study secret until just a few months ago — releasing it only after CSA had been made public and in use.  The study essentially concluded that CSA was better than SafeStat. In December 2010, FMCSA moved forward with what was then called Comprehensive Safety Analysis 2010, putting CSA ratings on the Internet and promoting them as new and improved and ready for the shipping public’s usage. FMCSA never afforded industry or the public the due process required by the Administrative Procedure Act.  In order to make such a substantial change in regulation, the APA lays out requirements, such as giving notice of proposed rulemaking, seeking public comment, etc.  Federal laws, including the Paperwork Reduction Act and the Regulatory Flexibility Act, require agencies to take into account the regulatory impact of its proposed rules on private industry, especially small businesses (which make up most of the trucking sector).  The Data Quality Act requires peer review, which CSA lacks.  In FMCSA’s case, the agency is constrained to follow the National Transportation Policy, which is set in law.  NTP requires the agencies of DOT to ensure that every rule and regulation balances safety, efficiency and competition.  In CSA’s case, none of this ever occurred. Second, CSA’s arbitrary nature and foundation of sand really appear when you look into the facts.  The agency only has enough roadside inspection data to rate 92,000 of the 770,000 federally regulated motor carriers in even one BASIC.  More than half of the 12 percent of the industry that’s rated is over the agency’s arbitrary trigger level that saddles a carrier with an “alert” in at least one CSA BASIC. In many instances, what data CSA uses has little, if anything, to do with actual safety.  For example, the “driver fitness” BASIC only rates 3.5 percent of the industry.  Most points in this category are assigned for drivers not having their medical cards on them at an inspection, not for driving with some disqualifying medical condition.  One carrier crossed the limbo bar because of a driver operating his vehicle with a suspended driver’s license.  His license was suspended for failure to pay child support. In the “vehicle maintenance” BASIC, more than half of the CSA points come from trailer lights burning out, brake adjustments and tire tread depth.  None of these factors has a proven correlation with safe vehicle operation.  In the “unsafe driver” BASIC, most CSA points accrue from truck drivers getting speed warnings and tickets.  Geographic bias tilts the playing field, though, because about half of such speed-related citations are issued in just five Midwestern states.  Their “probable cause” state laws mean police there must issue some citation in order to conduct roadside inspections.  Thus, Indiana wrote more than 53 percent of all the speed warnings truckers received in 2011 for allegedly driving 1-5 miles per hour over the speed limit.  Much of what comprises the “fatigued driver” BASIC is really logbook, paperwork violations — “form and manner” errors — where drivers didn’t strictly comply with the hours-of-service diktats that only a bureaucrat could love. And consider that when inspectors find nothing to mark down a driver or truck for, most inspectors refuse to issue a clean report.  Thus, the data that constitute CSA scores are virtually always negative with little positive data to give balance.  Further, because CSA ratings use subjective, faulty methods and incomplete, biased data, carriers that pass FMCSA’s safety fitness audits, which are objective, with flying colors may well have BASICs in which they are under “alert.”  And the subjective nature of the system makes it where carrier BASIC scores can swing wildly.  One carrier reportedly saw its “unsafe driving” BASIC whipsaw from 47 percent to 89 percent the same day.  Also, even if a carrier fires a driver who’s a safety risk, such actions won’t reflect in its CSA scores for many months. In other words, fit and safe carriers don’t control their own destiny under CSA.  They can watch their BASICs flitter all over the place but have no effective or fair recourse to get their scores settled in the safe zone.  That’s because CSA grades carrier safety like Dancing With the Stars grades dancers.  No matter how well everyone may dance, at the end of the night, somebody’s going home.  Only in the case of misbranded motor carriers, it means the arbitrary destruction of businesses, jobs, and freight capacity. Salt in the wounds that CSA is inflicting comes from reality checks that the FMCSA ignores.  On the objective criteria of accidents per million miles and accidents per power unit (tractor that pulls the trailer), Wells Fargo scrutinized CSA.  This objective assessor found little or no connection between a carrier’s CSA BASICs for “unsafe driving,” “fatigued driving” or “driver fitness” and accidents per million miles driven or accidents per power unit.  Wells Fargo concluded that CSA scores are “misleading.”   More salt-grinding comes from the absolute fact that accidents and deaths involving commercial motor vehicles keep falling to historic lows.  DOT’s own data show that, objectively looking at safety, the number of accidents and fatalities per million miles driven have steadily dipped to record levels. Also, FMCSA’s advisory committee found fault with CSA.  Its members couldn’t say with any confidence that CSA scores relate to carrier crash probability.  This group determined that the agency needs more data to make sure SMS methodology employs science instead of intuition or experts’ opinions. Third, CSA is hurting the industry.  Trucking companies are getting tarred by an unproven, subjective system at a time the industry has achieved some of the safest records ever.  Ultimately, what hurts trucking and shipping hurts consumers, because so much of our economy relies on the distribution system of shippers, brokers, carriers, logistics partners, expediters, and truckers.  Trucks play a central role in getting groceries to your local grocery shelves, medicine to your pharmacy, furniture to your department store, etc. A survey of shippers by Morgan Stanley found 55 percent of shippers saying they won’t use a carrier with even one CSA “alert.”  The FMCSA website now states that carriers not rated or with an “alert” might be considered a safety risk.  This despite the fact the agency is well aware of CSA’s shortcomings and the concerns industry has raised. The Department of Defense has begun relying on CSA, and long-time, safe carriers are losing business hauling goods for DOD.  As a number of shippers and brokers, including large retailers, factor CSA into their carrier selection, they are opening themselves up to legal liability.  Shippers and brokers that use CSA as part of their own, ad hoc selection criteria now face vicarious liability and negligent selection lawsuits.  In other words, rather than keeping the onus on the agency to be the sole determiner of carrier fitness, the shipping public exposes itself to liability lawsuits under state law.  It should be enough for the shipping public to compete carriers on rates, routes and services.  Safety should not become a competitive matter in this picture.  It becoming such subjects the shipping public to liability. This scenario with CSA is much like consumers being forced to do their own inspections of jet airplanes, pilots and air carriers to determine if they are safe enough to fly on, rather than have confidence in the Federal Aviation Administration’s determination that an airline is a fit air carrier. In conclusion, as CSA blackballs perfectly safe and fit motor carriers, thousands of companies, especially small businesses, lose business from a frightened shipping public.  This risks loss of jobs at trucking companies and brokerages.  The loss of capacity will lead to higher freight rates.  Competition suffers.  All this pushes consumer prices higher.  It could force a tenth of all truck drivers out of the driver pool, at a time when the trucking industry is hiring.  Meanwhile, plaintiffs’ lawyers smell blood and launch new rounds of liability suits.             This isn’t a situation that ends pretty.  While Congress looks at transportation reauthorization, it should block FMCSA from publicizing CSA scores.  It should require FMCSA to fulfill its legal requirements of putting CSA through the complete rulemaking process.  Further, Congress should require the agency to use only objective measures to assess carrier safety, making absolutely demonstrable correlation of any safety measurement with carrier accidents and fatalities per million miles driven the only acceptable standard.  It should force FMCSA to own up to its responsibility as the sole determiner of carrier safety fitness.  And Congress should give federal preemption to protect anyone in the industry who relies on the agency’s carrier fitness determination for carrier selection.  That would save jobs, promote the economy and restore certainty to the shipping and trucking community.

EOBR’s: THE END OF BIPARTISAN REGULATIONS

EOBR’s: THE END OF BIPARTISAN REGULATIONS

Electronic onboard recording devices are an expensive, intrusive, and mostly unnecessary regulatory device that FMCSA wants to mandate on all commercial vehicles. Their argument is that this mandate will somehow improve SAFETY, i.e., a reduction of crashes, injuries, and fatalities in large truck crashes in the U. S. This argument continues in the face of the decade-long Werner experiment with EOBR’s that seemed to have a negative impact on crashes, injuries, and fatalities, rather than a positive one. EOBR’s started out in Western Europe years ago as a simple tachograph that helped government collect road taxes from truckers. Its original idea certainly had nothing to do with SAFETY, but much to do with money. That hasn’t changed much on this side of the Atlantic with this mandate. Money is the ultimate motivator behind mandated EOBR’s. Where is the money? Global Position Satellites (GPS) entered the trucking industry some twenty five years ago with Qualcomm leading the parade. The boxes were around $3,300.00 per unit and the monthly fee ran around $60.00 to $90.00 per power unit per month. Larger companies flocked to this technology primarily to mitigate the logistical nightmare created by extremely high driver turnover rates and the fact that a certain percentage of their drivers could not be trusted to tell the truth about their respective locations. There were certainly other benefits for GPS tracking that included ease of communication between driver and dispatch, fewer check calls, the ability for one dispatcher to handle more trucks, loads, and drivers, fuel tax calculations, asset management, and to use as a valuable marketing tool to sophisticated shippers who wanted to track their shipments. The down-side to this technology was that good drivers resented the implication that they could not be trusted and that “Big Brother” was always tracking their movements.   In the early years, I think it’s fair to say that GPS technology had a negative effect on many companies’ already huge driver turnover problems. Besides that, for small companies and independent owner-operators, it was too expensive and thus, not an option. Regulators and auditors love GPS because it saves them time and money at audits. Technology has since advanced the practicality for GPS usage and pricing is now available for less than half of the early Qualcomm pricing. Turning existing GPS systems into EOBR’s will once again increase drastically the cost per truck to include electronic logs. And basically, mandated EOBR’s will not be a major additional financial cost for the mega-fleets but for small fleets and independent contractors, it will be a significant burden and in most cases, with little or no return on investment. Speaking of money, how will the states, counties, and municipalities finance the cost of equipping all of their cruisers with the capability of pulling log data from trucks into the appropriate government system and transmitting that from the roadside? Speaking of money, if the EOBR becomes dysfunctional, is the truck then “out-of-service” on the side of the road? Speaking of money, how does FMCSA intend to train sheriff deputies, highway patrolmen, and any others who are being asked to make determinations and interpretations of federal regulations on the side of the road? Is there to be any standardization of procedures or interpretations or will we continue to see widespread confusion on inspections that lead to hundreds of mistakes made road side that immediately affect the safety status of companies and drivers without due process, probable cause, or any functioning appeal process? The cry for mandated EOBR’s is based on a false premise that all trucking companies and all drivers push the hours of service rules and cheat on their logs. If this premise were true, why are only 2.9% of companies audited given an UNSATISFACTORY rating? In 2011 there were 10,964 audits and 323 unsatisfactory ratings issued. FMCSA’s original plan was to mandate EOBR’s for only companies with extreme and chronic log falsification tendencies, the so called “BAD ACTORS.” This was however, devised prior to CSA which brands 35% of all carriers in the database as having “Driver Fatigue” issues and/or “unsafe driving issues” all of the time. The true figure is closer to 3-4% which would identify mandated EOBR’s as an over kill solution to a negligible problem. This is in fact the case. Mandated EOBR’s is merely a compliance tool that will have little positive effect on safety numbers at a huge cost to everyone from the driver down to the consumer. Who benefits from mandated EOBR’s? The mega fleets will benefit most. Since most of them already have the technology in their trucks, the cost for EOBR’s will be minimal. Once EOBR’s are mandated for everyone, they’ll be able to retain more drivers because leaving one company with EOBR’s for another company without them, will not be an option any longer. The brunt of the added costs will fall on their competitors, the small companies and independent contractors. This is the sole reason why The American Trucking Association who is politically and financially dominated by the mega-fleets, supports a proposal that is ultimately detrimental to competition and detrimental to 95% of the trucking companies in America, the small fleets and independent contractors. This also is the primary reason why OOIDA, NASTC, and The National Federation of Independent Businesses are the only three organizations that have publically opposed mandated EOBR’s. OOIDA is to be applauded for bringing FMCSA to court challenging the mandated use of EOBR’s. Though there were many logical disqualifying reasons, the court did not look past the driver harassment issue and set aside FMCSA’s attempt to mandate. The agency has promised to address the court’s issue with driver harassment with a re-worded mandate. I just don’t see how they can legitimately satisfy this one issue without a bureaucratic and litigious nightmare and, speaking of money, do we form a “driver harassment board” within the agency to determine whose harassment to kick? In many respects, this ends up being an additional, disingenuous tax on American consumers, much like cap and trade. Worse than that, it is the bunny hill to the slippery slope that will allow our central government to track, tax, and control all motor vehicles in the country. This issue is much larger than anyone at present believes. I’m still convinced that the only way to eliminate all truck-related fatalities is to eliminate trucks. NOTE of CLARIFICATION: Nothing in the above should be construed as an argument against the implementation of EOBR’s in a fleet of trucks as a management tool. Our entire argument is against mandated EOBR’s for all companies. This is not an appropriate function of government or the agency nor will it positively impact safety numbers. This is one of those issues that is best left to the market place for implementation as a means to compete, not an expensive fiat misplaced on the vast majority of carriers who have no business use for the technology. David Owen President, NASTC This email address is being protected from spambots. You need JavaScript enabled to view it. 800.264.8580 615.451.0042 Fax

The Best Americans I Know

The Best Americans I Know!

The following letter was widely published in the days following 9/11. We’ve had many requests for copies of this letter over the years so we thought we’d share it with you again. In many ways, our world will never be the same since the shocking attack by terrorists on our people on September 11th.  At first we watched with disbelief as the events of the day unfolded, horrified by what we saw but still somewhat detached, as if somehow it were not quite real.  It just couldn’t be real; this couldn’t be happening to us.  As the brutal reality of the day began to settle upon us, the weight was overwhelming.  How could we bear this?  We prayed.  We cried.  We became angry.  We were overcome by a collective sadness that I have never seen in my lifetime and hope to never see again.  We listened to our leaders and waited for action.  Our nation prepares for war while we prepare our souls to endure the pain of war.  We try to carry on with our lives.  It is not easy but we must do it.  We must not give up.  Our leaders have asked us to go back to work and work hard, for it is hard work that made us the great nation we are.  Back to work we go, continuing to build the strongest nation in the history of mankind into a better, stronger nation still. If hard work is the measure of a good American then I would like to salute the best Americans I know, the American Trucker.  While many of us tried to make sense of the terrible events of September 11th, the trucks kept rolling.  Delivering the things we need to continue with our lives, our food and clothing, the raw materials to keep our factories working, and the building materials we need to continue to build our nation.  Let’s don’t forget the medical supplies and emergency relief supplies that had to be delivered to the affected areas by trucks or the gasoline that we just can’t seem to live without.  Ask yourself this one question, “What kind of shape would this country be in if the trucks took a week off?” Thankfully they did not stop.  Because even though the vast majority of the country doesn’t seem to think highly of trucks or truckers, the truckers know how important the job they do is to America.  Can you imagine what life without them would be like? So while many of us gathered with our families and co-workers to watch endless hours of news and try to figure out what to do next, the trucks kept rolling.  Dealing with the same emotions with which we all struggled, drivers set it aside, climbed back up into their trucks and kept America moving.  They know how important it is.  I know how important it is.  I wish all Americans realized how important it is.  Atlas may hold up the world, but America rests on eighteen wheels and the square shoulders of the Best Americans I know, America’s Truckers. I salute you all, Buster Anderson Vice President, NASTC P.S.   Thanks for doing your part to keep America moving.

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