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NTTC asks for clarity on rear guard labels

June 13, 2022
Tanker operators’ difficulties replacing unreadable labels could lead to ‘unjustified violations’ of regulations, association says in letter to FMCSA
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National Tank Truck Carriers recently sent a letter to the Federal Motor Carrier Safety Administration (FMCSA) expressing its concerns regarding the rear guard labels that are required in CFR 393.86(a)(6).

Due to time and harsh environments, labels on rear trailer guards can become damaged or unreadable. However, NTTC members have expressed concern about their inability to secure replacement labels from original manufacturers leading to unpreventable and unjustified violations of this federal regulation, the association said.

“It is no secret that the trucking industry faces a critical shortage, with less drivers available to deliver the essential commodities required by industry and the traveling public,” Ryan Streblow, NTTC president and CEO, said in the letter. “By addressing 49 CFR 393.86(a)(6), it will help alleviate concerns that trailers may fail inspections if they do not have these labels affixed as required.”

To help avoid this issue, NTTC says it hopes FMCSA will issue a proposed rulemaking that ensures regulatory clarity for the country’s tank truck owners and operators.

Furthermore, NTTC asserted its belief that rear impact guards are critical for the safe operation of tank trucks, and wholeheartedly supports their inclusion of items needed for routine inspection.

Peer associations such as the Commercial Vehicle Safety Alliance and American Trucking Associations have similarly commented to FMCSA about CFR 393.86(a)(6), in alignment with NTTC’s position, the association added.

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