Harvest Newsletter
March 11, 2008 Vol 11, No 3
Your Business Is Under Attack
Under a proposed rule announced December 26, 2007, by the Federal Motor Carrier Safety Administration (FMCSA), individuals seeking new commercial driver's licenses (CDL) will be required to complete both classroom and behind-the-wheel training from an accredited educational program or institution.
Beginning three years from the effective date of the final rule, all applicants for a CDL would be required to provide a valid certificate from a truck driving program or institution accredited by the US Department of Education. For a Class A CDL, the proposed rule would require a minimum of 76 hours of classroom instruction and 44 hours of behind-the-wheel training.
This rule will severely impact the harvesting industry. It would require the harvester to hire employees 4 to 8 weeks earlier than normal and pay the tuition cost of the driving school, easily amounting to $8000 of additional cost for each employee hired. Many potential employees would not be available to attend truck driving school until late May or early June, making them unavailable to the harvester until mid-June.
You are urged to send your comments on the proposed rule. Instructions are available at www.regulations.gov docket number FMCSA-2007-27748. Public comments will be accepted until March 25, 2008. Please fax your comments today to 202-493-2251.
Talking points for your comments: Hiring employees 1 to 2 months earlier than normal. Cost of training increased by $8,000. Likely that trained drivers will leave seasonal harvesting work and seek full-time work for a trucking company. Harvest safety record is good and exposure is limited to under 20,000 miles driving and distances of 30 miles or less. This regulation could drive many harvesters out of business, limiting the availability of harvesters to bring in the wheat, corn and corn silage crops, seriously increasing the threat to the National Security of our food supply.
Unified Carrier Registration
If you operate a truck which has a gross vehicle weight of 10,001 pounds or more, or a bus or van with seating for 11 passengers or more in interstate commerce, there is a new federal law that applies to your business.
The Unified Carrier Registration (UCR) Program requires individuals and companies that operate commercial vehicles in interstate commerce to register their business with their home state (if the state is a participant state) and pay an annual fee based on the size of their fleet. All our client states are participant states except Florida. Florida harvesters will need to use Georgia as their base state.
Registration is accomplished on-line at the internet website: www.urc.in.gov. The registration form is a one page application. Submission of the application and appropriate fees--either on-line or by mail--completes registration for the carrier for one year.
When you register and pay your UCRA fees, the base state will let the Federal Motor Carrier Safety Administration (FMCSA) know, which will indicate to Safety and Fitness Electronic Records (SAFER) that you have complied with UCRA. Roadside enforcement will be able to access UCRA information through SAFER Query Central to determine if you are current with your UCRA obligations. No UCRA credential is required to be carried in vehicles.
Two problems with this whole deal:
First, you were supposed to register in 2007, so when you try to register, you will have to pay for 2007, then register for 2008 and pay again!
Second, the fleet size is determined by number of units, including trailers. It is currently my understanding that combine trailers, header trailers and crew trailers will not be counted as units unless you have a pro-rated license plate on the trailer. These trailers are implements of husbandry. In addition, any unit that is not taken out of state does not have to be counted.
Fees affecting most of you will be the following:
3 -5 units - $116.00 6 - 20 units - $231.00 21-200 units - $806.00
Do not put off this registration. It is so easy to check that roadside enforcement is planning on checking everybody. Law enforcement will be looking for your DOT number appropriately displayed on your truck door, then checking on your registration with their in-cruiser computer.
Safety School
Please make Safety School attendance a priority for your Spring schedule. Locations and times are listed below:
Saturday, April 5 – Lubbock, TX at 10:00 AM. Holiday Inn Park Plaza, 3201 S Loop 289 USCHI will have an additional session in the afternoon at the same location. Lunch provided
Tuesday, April 8 – Enid, OK at 2:00 PM. Location: St Gregory Roman Catholic Church, 1924 W. Willow.
Saturday, April 12 – Hutchinson, KS at 2:00 PM Location: CHI, Ltd auditorium, 114 W Sherman. Reception for Meadowbrook Company personnel after Safety School
Wednesday, April 16 – Marysville, KS at 1:00 PM Location: Wagon Wheel Restaurant, 703 Broadway
Thursday, April 24 – Wahpeton, ND at 10:00 AM Location: Tom Haugrud's Shop, 8205 182nd Ave SE. Heading down Main St to Smith Motor at Stop Light turn south onto Hwy 127, Go south to Mile Marker 20, then east 1 mile to dead end, turn south to reach the shop.
The Safety Training CD/Video will be worth the trip. We have just about wrapped up the production of the CD and you have my guarantee that it will be useful to your safety training program. And of course, the 'cool hat" promised in the last newsletter is ready for your head.
Please come, have some fun, learn our new approach to safety training, and get some cool stuff. Also help us celebrate the safety success of our loss free clients.
AGENDA
How to Hold an Employee Safety Meeting
Labor Issues--recruiting, compliance, H2A, Immigration Laws
How to Use the Safety CD
2 Professional Custom Harvesters - "How I do safety with my crew"
Update on DOT regulations, UCR and other upcoming trouble
Overview of Safety CD
Synopsis of CHAMP report - "Pricing to make a Profit"
Safety Awards
Loss Report
The following losses have been reported since February 1, 2008:
IV backed into CV in elevator line IV hit elevator door while entering dumping area Tractor Truck jack-knifed on icy road IV rear-ended CV Hail damage to truck Trailer overturned in field End gate opened and cargo lost during transit Tools stolen from service truck IV turning right, collision with CV IV hit something in road, damaged IV IV struck elevator door while exiting Lightning struck GPS on combine
Final Word
I need your help. We are seeing more collisions involving your truck turning right and hitting a vehicle passing you on the right side of your truck. When you swing out, they go around on the right side, even if your blinker is on. Give me some safety guidelines to reduce this claim occurrence
Please attend Safety School. If you are planning on attending and want to visit with Mike or Larry about your renewal, please call our office and let us know, so that we can have everything we need for your renewal with us.
As you plan your maintenance, don't forget to pack the wheel bearing of your camper trailers. And change the batteries in all your smoke detectors. And have all your fire extinguishers serviced. And treat your spouse to something special immediately. Be safe, be careful, live boldly.
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