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Letters, Petitions and Comments

Comments on NHTSA ADS Regulatory Barriers ANPRM

CVSA submitted comments to the National Highway Traffic Safety Administration’s (NHTSA) advance notice of proposed rulemaking (ANPRM) on regulatory barriers for vehicles with automated driver systems (ADS).

Comments on KRD Hours-of-Service Exemption Request

CVSA submitted comments to FMCSA on an exemption request from Kimble Recycling and Disposal (KRD) for an exemption from the short-haul hours-of-service requirement that drivers return to their work reporting location within 12 hours.

Comments to NHTSA on ICR on FARS

CVSA submitted comments to NHTSA’s request for comments on an information collection request (ICR) on the Fatality Analysis Reporting System (FARS), published on April 25, 2019.

Comments on NPRM to Update the Incorporation by Reference of the CVSA Level VI OOSC

CVSA submitted comments to FMCSA supporting the amendment of the hazardous materials safety permit regulations to update the incorporation by reference of CVSA’s “North American Standard Out-of-Service Criteria and Level VI Inspection Procedures and Out-of-Service Criteria for Commercial Highway Vehicles Transporting Transuranics and Highway Route Controlled Quantities of Radioactive Materials as Defined in 49 CFR Part 173.403.”

Comments on AAR and ASLRRA Hours-of-Service Exemption Request

CVSA submitted comments to FMCSA in opposition to a joint exemption request from AAR and ASLRRA for exemption from the 14-hour on-duty period, required 10 hours off-duty period, 30-minute rest break and the maximum of 60/70 hours on duty in a 7/8-day work week requirement.

Comments on ABA and IDFA Hours-of-Service Exemption Request

CVSA submitted comments to the FMCSA in opposition to a joint exemption request from the American Bakers Association (ABA) and the International Dairy Foods Association (IDFA) for exemption from various hours-of-service requirements.