FMCSA waiver addresses intermodal chassis with expired annual inspections

Posted June 5, 2020

The Federal Motor Carrier Safety Administration (FMCSA) grants a waiver to allow for the operation of intermodal chassis with annual inspection decals or similar documentation that show an expiration date of March 31, 2020, or later.

The Intermodal Association of North America (IANA) requested the waiver from FMCSA on behalf of intermodal equipment providers (IEPs) and motor carriers operating intermodal chassis.

The movement of intermodal equipment has been disrupted by COVID-19, according to IANA. Large numbers of intermodal chassis, both loaded and unloaded, are parked at locations other than the intermodal equipment providers’ maintenance facilities where the mandatory annual inspection is performed. Many of the annual inspections on these units have expired or are due to expire, and the units’ current locations leave stakeholders with no practical means of arranging the annual inspection in order to return the chassis to revenue service.

Terms of the waiver

This waiver is effective June 1, 2020, and expires either on September 1, 2020, and is limited to the operation of intermodal chassis included in IANA’s Global Intermodal Equipment Registry (GIER). GIER is a database that includes more than 700,000 chassis and provides an electronic means of identifying the responsible IEP with specific pieces of intermodal equipment to facilitate compliance with FMCSA’s safety rules. Approximately 90 percent of the chassis in North America are managed in GIER.

Other terms of the waiver include:

• Intermodal equipment providers and motor carriers may operate intermodal chassis:
  • With expired inspection decals provided the decal expired on or after March 31, 2020; and
  • Until they can be returned to an IEP facility where the annual inspection can be performed by a qualified individual, not to exceed three months from the date of the waiver.
• All the parties involved continue to comply with §396.12 prohibiting IEPs from offering unsafe chassis for transportation, and carriers being coerced into accepting such chassis.
• Motor carriers and their drivers continue to be responsible for reporting chassis defects to the IEPs, and IEPs continue to accept responsibility for addressing the defect reports.
• Motor carriers must ensure that their drivers conduct a pretrip/predispatch inspection as required by §392.7 prior to using a chassis with an expired annual inspection decal to ensure there are no visible defects or deficiencies likely to cause a mechanical breakdown while on public roads.

FMCSA reserves the right to revoke this waiver for IANA’s intermodal equipment provider members’ failure to comply with the terms and conditions of this waiver.

This article was written by Kathy Close of J. J. Keller & Associates, Inc.