Wednesday, June 24, 2015

Driver's Meeting Recap

Hello Everyone,

As most of you know, on June 24th we had a drivers meeting.  Andy started the meeting talking about trailers and rates.  He brought up that trailers are still moving but many of the dealers had ordered stock late last year so there is not some of the panic buying going on this year like went on last year.  He also addressed the rate cut that the manufacturers had put on us.  None of us liked it but, if we didn’t accept it,  the manufacturers would simply give the trailers to the transporters who did and there would literally be no trailers right now. 
Tom addressing the drivers at the Hernandez Event Center
Tom addressing the drivers
The bulk of the meeting was spent on Compliance.  As everyone is probably aware, we have some issues in this area and they never seem to get any better.  Tom spent about an hour and three-quarters up front going through our current scores, answering questions and explaining what will happen.  Probably the biggest question asked was about logging back.  It is true that if your truck has a GVWR under 10,000 pounds FMCSR does not require to log back.  It is also true that Synergy RV Transport is allowed to be more restrictive than FMCSR but not more lenient.  This is one of those areas that we are being more restrictive.  We will not have two classes of people at Synergy; EVERY TOWABLE DRIVER SHALL LOG BACK.  The reality is almost everybody already is and the few that aren’t will find out, very soon,  that we are serious about people following the rules. 
FMCSRs require that drivers log all commercial movement. This includes:
  • All time and miles that the driver is under load,
  • All time and miles that the driver is returning from a delivery either to his or her home or the terminal, and
  • All time spent driving from home or elsewhere to the terminal with the intent of picking up a unit or dispatching.
Although we have to conform in all areas, we have significant problems in two areas Driver Fitness and Hours of Service. In driver fitness the problems are pretty simple:
  •  not having the medical card with you, or
  • the GVWR of your trailer and truck adds up to more than 26,000 pounds if you don't have a CDL. 
The problems with hours of service are many.  I already addressed logging back to Goshen or to home.  If you call dispatch and get a load prior to leaving your home, you are required to log from home to Goshen.  The absolute biggest problems are:
  • the log not being current to the last change of duty status,
  • not having the previous seven days with you,
  • not having a supporting document for every log,
  • driving past eleven hours, fourteen hours or driving and being on duty more than eight consecutive hours without a thirty minute break off duty  (line 1) break.   
There are many more but those are the first we need to correct.

The other area where we seem to have some problems is getting drivers to send in their DOT inspections.  All DOT inspections shall be sent in within twenty-four hours or at the beginning of the next normal working day, regardless of whether you passed or not.  To be honest we will know anyway, save yourself some hassle and send them in.

I have taken over dealing with the log violations, our goal is not to create a lot discord. Actually quite the opposite; our goal  to correct training deficiencies or mis-conceptions that may exist.  Then if there are a few people who just refuse to comply we will deal with them one on one.


Tom Gibson

Monday, June 8, 2015

Window Tint Regulations Decoded

The issue of window tint seems to come up almost daily in the RV Transport industry. As is to be expected, the Federal Motor Carrier Safety Regulation governing this is pretty clear, but not the easiest to understand.

The Regulation Says...

The regulation that governs window tint is "§ 393.60: Glazing in specified openings." Specifically, § 393.60 (d) states:
Coloring or tinting of windshields and windows. Coloring or tinting of windshields and the windows to the immediate right and left of the driver is allowed, provided the parallel luminous transmittance through the colored or tinted glazing is not less than 70 percent of the light at normal incidence in those portions of the windshield or windows which are marked as having a parallel luminous transmittance of not less than 70 percent. The transmittance restriction does not apply to other windows on the commercial motor vehicle.
 The guidance from the FMCSA on this section confirms that, indeed, windows may be tinted:
Question 1: May windshields and side windows be tinted? 
Guidance: Yes, as long as the light transmission is not restricted to less than 70 percent of normal (refer to the American Standards Association publication Z26.1-1966 and Z26.1a-1969).
However, this is VERY misleading.

The Regulation Means...

 Notice that the regulation never addresses what level of tint can be added to the front side windows and the windshield. The regulation never addresses how dark the tint can be, only that 70% of light must pass through the window when measuring "parallel luminous transmittance."

 What is Parallel Luminous Transmittance?

Luminous Transmittance is simply a measurement of how much of the light on one side of the glass makes it to the other side. If a window were made of perfectly clear glass (which, by the way, does not exist.....any glass blocks some of the light), then the VLT would measure 100%.

If we measure standard, untinted safety glass, the results are somewhat surprising. Standard safety glass (usually tempered glass on the side windows, laminated safety glass on the windshield) blocks 20% to 25% of the glass with no additional tint whatsoever. 
Adding even a small amount of tint will almost always push the VLT below the federal legal limits.
Even if the tint is barely noticeable, the violation becomes even more severe.

How is VLT measured?

Visible light transparency can be measured in a number of ways, but the most popular choice (by both Synergy RV Transport and by law enforcement) is by a tint meter. The tint meter simply provides light on one side of the glass and measures how much of the light goes through the window.
For law enforcement it is an easy read. They place this on the window, and if it reads less than 70 (as it will with any tinted glass), they write the ticket. 

But it is legal in my state!

Like most regulations involving passenger vehicles, tint laws can vary wildly by state. Some states mandate 70% or greater VLT, while some states allow almost black tint to be passed through. Some states even govern the color of the tint that can be used.
The good news for us is we do not have to know the laws of every state because, as commercial drivers operating commercial motor vehicles, we only need to comply with federal regulations. The bad news is the federal regulation leaves precisely zero grey area.....tint on the windshield or front side windows is non-compliant. Although the regulation allows tinting, almost any level of tint is going to push a window under the 70% mark and make it non-compliant.

How can this affect me?

If the commercial motor vehicle you are driving has tint that reduces the VLT of the windshield or the front side windows, to below 70%, you can be cited. This citation comes with CSA points that are on your record for three years as well as a fine of up to in excess of $400. Moreover, since law enforcement personnel have a well-earned reputation for disliking window tint, you increase your chances of getting a closer look from an inspector. Finally, if your visibility is called into question in an accident investigation, the accident could be considered more your fault.

Sources: FMCSR Part 393.60 (Regulation and Guidance)

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