Coalition proposes chassis ID system
A coalition of organizations representing different segments of the intermodal industry said a current system for identifying container chassis should be retained and a national registry of chassis owners should be developed.
The group made its comments in response to regulations being proposed by the Federal Motor Carrier Safety Administration under the 2005 law called the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users. SAFETEA-LU requires intermodal equipment be matched to an intermodal equipment provider through a unique identifying number.
The coalition said the FMCSA has initially proposed that all intermodal chassis and trailer equipment be stenciled or otherwise marked with the equivalent of a USDOT number, as is done with self-propelled commercial motor vehicles.
The coalition suggests, instead, that existing identification numbers on chassis be used to match the equipment with the appropriate equipment provider. Chassis are marked with a unique, 10-digit alphanumeric identifier that is used for inventory tracking, terminal gate transactions, as well as maintenance and repair recordkeeping.
The coalition making the recommendation includes the American Association of Port Authorities, Association of American Railroads, Institute of International Container Lessors, Intermodal Association of North America, Ocean Carrier Equipment Management Association, National Association of Waterfront Employers, and United States Maritime Alliance Ltd.
The group said every ocean carrier, railroad, chassis lessor, equipment pool or other entity that is likely to be identified as an intermodal equipment provider under the proposed rules, maintains a fleet file listing all chassis or “trailing equipment” under its ownership and/or control by the existing alphanumeric chassis ID number.
Using those numbers rather than renumbering all chassis is not only cost effective, but could avoid other problems, the group argues.
“Capturing and marking the estimated 850,000 chassis in service in the United States with yet another ID number would in all likelihood, cause confusion as to the controlling party of the equipment versus achieving the desired result of the proposed rules, which is to better identify the entity that has responsibility for a particular piece of equipment. From an operational perspective, it is a process that could take as much as two years to complete, with an estimated cost of tens of millions of dollars,” they write in a submission to the FMCSA.
Instead, they propose development and maintenance of a Web-based equipment registry that would be accessible to federal, state and local enforcement authorities and would eliminate the need for the FMCSA to modify its Motor Carrier Management Information System (MCMIS) to accommodate the new requirements.
“Equipment providers would submit to the database the ID numbers already marked on those chassis for which they are responsible for the inspection, maintenance and repair. The database would be searchable by either intermodal equipment provider or by the chassis alphanumeric identifier and would be administered by an independent third party,” the coalition said.
A copy of the comments is posted on the AAPA Web site at http://aapa.files.cms-plus.com/PDFs/Final%20Supplemental%20Comments%205-21-07.pdf .