APA Advisory - Safety Audits for APA HOS Waiver Holders

August 16, 2021

TO:               

SUBJECT:  FMCSA to Conduct Safety Audit of APA HOS / ELD Exemption Holders

The U.S. Federal Motor Carrier Safety Administration (FMCSA) is notifying participants on APA’s Hours of Service (HOS) and limited Electronic Logging Device (ELD) exemptions to complete an “Information Request for Investigation”.  Each APA member company participating in our exemptions will receive a letter from FMCSA formally notifying you that the Agency will investigate your operations to determine the level of safety within your transportation operations.

The initial safety compliance review will be conducted on-line by you accessing the FMCSA’s Safety Measurement System (SMS) and logging into your company’s profile. The Agency will specify a deadline, approximately five (5) days for you to you complete the information requested and upload specified documents, including:

  • Accident Register
  • Driver List
  • Equipment List
  • MCS-90 Proof of Insurance
  • Questionnaire

APA’s Vice President and Transportation Committee Chairman, Steve Pelkey, alerted us to this initial Information Request for Investigation late Friday afternoon. Steve has reviewed the documents that FMCSA is requesting to be uploaded and believes they are pretty straightforward. He recommends that prior to submitting the documents, be certain that you have an accurate list of drivers, list of motorized and non-motorized equipment, and any accident reporting documentation.

Once you have submitted the information, we anticipate that FMCSA may follow up and request additional information on several drivers and/ or request maintenance records for a couple of vehicles.

We believe the Agency is primarily concerned about a company’s SMS rating, however, because the APA’s exemption renewal was only granted for one year, we suspect the new leadership is looking deeper to justify industry-related exemptions rather than rubber stamping exemptions issued by the previous Administration.

It is critical that all APA exemption participants who receive the Request for Investigation respond accurately and in a timely manner as the APA must file for renewal of the HOS and ELD exemptions for the 2022 Fourth of July season. Our ability to successfully renew the exemptions depends upon APA participants cooperating and successfully passing the safety audit.

If you have any questions or need assistance, please contact APA Executive Director, Julie Heckman at (240) 401-4513 or Vice President, Steve Pelkey at (603) 731-2000.

Advisory #2021-18

 

 

 

 

 

 

 

 

 

 

The U.S. Federal Motor Carrier Safety Administration (FMCSA) is notifying participants on APA’s Hours of Service (HOS) and limited Electronic Logging Device (ELD) exemptions to complete an “Information Request for Investigation”.  Each APA member company participating in our exemptions will receive a letter from FMCSA formally notifying you that the Agency will investigate your operations to determine the level of safety within your transportation operations.

 

The initial safety compliance review will be conducted on-line by you accessing the FMCSA’s Safety Measurement System (SMS) and logging into your company’s profile. The Agency will specify a deadline, approximately five (5) days for you to you complete the information requested and upload specified documents, including:

 

  • Accident Register
  • Driver List
  • Equipment List
  • MCS-90 Proof of Insurance
  • Questionnaire

 

APA’s Vice President and Transportation Committee Chairman, Steve Pelkey, alerted us to this initial Information Request for Investigation late Friday afternoon. Steve has reviewed the documents that FMCSA is requesting to be uploaded and believes they are pretty straightforward. He recommends that prior to submitting the documents, be certain that you have an accurate list of drivers, list of motorized and non-motorized equipment, and any accident reporting documentation.

Once you have submitted the information, we anticipate that FMCSA may follow up and request additional information on several drivers and/ or request maintenance records for a couple of vehicles.

We believe the Agency is primarily concerned about a company’s SMS rating, however, because the APA’s exemption renewal was only granted for one year, we suspect the new leadership is looking deeper to justify industry-related exemptions rather than rubber stamping exemptions issued by the previous Administration.

It is critical that all APA exemption participants who receive the Request for Investigation respond accurately and in a timely manner as the APA must file for renewal of the HOS and ELD exemptions for the 2022 Fourth of July season. Our ability to successfully renew the exemptions depends upon APA participants cooperating and successfully passing the safety audit.

If you have any questions or need assistance, please contact APA Executive Director, Julie Heckman at (240) 401-4513 or Vice President, Steve Pelkey at (603) 731-2000.