PrePass Urges Caution on CMV Electronic Identifier System

Trucks on highway
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A new PrePass Safety Alliance whitepaper claims that a proposal to require that trucks have a unique electronic identifier system would not necessarily improve highway safety, and could allow inspectors to monitor the condition of commercial motor vehicles while they are in motion.

The controversial advance notice of proposed rulemaking, issued by the Federal Motor Carrier Safety Administration on Sept. 23, would if finalized require that every commercial motor vehicle operating in interstate commerce be equipped with a wireless electronic identification system that would help inspectors better target high-risk motor carriers.

The FMCSA proposal asks stakeholders through Nov. 22 to offer their thoughts on several critical questions — including privacy and security issues — on how the agency should proceed on myriad technology challenges. However, the agency said the identification system would be “key to efficient and productive safety regulatory oversight.”

PrePass is a nonprofit organization that provides bypass and electronic toll payment services to more than 105,000 motor carriers with an estimated 700,000 trucks. It has said that a simple identifier on a vehicle does not present a threat to bypass, but that the new mandate on data should be of concern to all stakeholders in the trucking industry.

The PrePass paper, “Understanding Electronic IDs for Trucks,” said there is no research or evidence that a unique electronic identification mandate would improve highway safety or reduce crashes.

“If unique electronic identification transmits data that identifies a violation, will the truck be required to pull over for an inspection?” is a question raised in the paper. “With inspection and parking facilities unable to accommodate current demand, where would these inspections take place? How would removing that many trucks from the road affect the supply chain and motor carriers?”

The paper said that the electronic identification system would enhance truck inspections, but once the government has that data, there would be no limitations on how it would be used. “FMCSA may be tempted to collect that transmitted data and directly use it in the Safety Management System ratings of carrier safety.”

The FMCSA proposal announcement noted that the agency is currently undertaking an operational test of Level VIII Electronic Inspections to enhance its current process for monitoring and enforcing motor carrier and driver safety compliance.

“The electronic inspections being examined as part of the operational test effort would enable FMCSA to assess on-the-road safety compliance while a commercial motor vehicle is still in motion, minimizing disruption to the motor carrier and therefore, supply chain, and doing so in a way that significantly reduces large trucks and bus emissions across the nation,” FMCSA said. “This effort would also enable FMCSA to collect more safety data about more carriers, with the goal of further reducing injuries and fatalities resulting from large truck and bus crashes.”

The whitepaper also suggested that there could be a large number of truck driver resignations if the proposal become mandate.

“A survey by Randall Reilly in June 2022 disclosed that 27% of truck drivers would leave the industry if a unique electronic identification mandate became law,” the paper said. “Professional drivers who are out on the road every day provide valuable guidance on a path forward to improved highway safety — without an intrusive government program.”

It notes that instead of requiring electronic identifiers, FMCSA should take three steps to improve safety:

  • Manage driver detention and delay at shipper facilities
  • Continue work on increasing and improving truck parking
  • Provide better oversight of driver training

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The alliance position maintains that the final rule should be limited to one piece of data, such as the vehicle identification number, said Bob Trent, vice president of communications for PrePass. “We produced the whitepaper to more fully illustrate just how far the scope of data included in the FMCSA’s ANPRM goes beyond what trucking industry and enforcement stakeholders agreed was necessary for UID,” Trent added.

The FMCSA proposal is the result of a petition requested by the Commercial Vehicle Safety Alliance, first in 2010 and again in 2015. CVSA argued that an electronic identification system would not only help inspectors target high-risk carriers but also help carriers with good ratings avoid numerous inspections.

“We have not as an organization specified the technology that we believe should be used to achieve the goal. We’re not technology experts in that sense,” Adrienne Gildea, CVSA’s deputy executive director, has said.