expert witness header
spacer

CSA scores would be made public again under House bill rider

The House’s 2020 Department of Transportation funding bill, in addition to its policy riders on hours of service, would require the Federal Motor Carrier Safety Administration to make carriers’ scores within the Compliance, Safety, and Accountability program publicly available once again.

The bill, the annual Transportation, Housing and Urban Development (THUD) appropriations package, cleared the House’s Appropriations Committee on Tuesday, and it now heads to the full House for consideration.

Scores were pulled from public view in December 2015 by the FAST Act highway bill, due to concerns about the data’s efficacy and whether the system accurately portrayed carriers’ safety performance and safety risk.

Specifically, the FAST Act targeted the percentile rankings within the Safety Measurement System (SMS) and the underlying data used to calculate those rankings. The FAST Act bill required the National Academies of Science to study the system and denote any deficiencies. It also called for the NAS to issue recommendations for how FMCSA could reform the program to make it more accurate in its assessment of carrier safety.

In 2017, NAS issued a report recommending sweeping changes to CSA and the SMS.

FMCSA was scheduled to begin testing those recommendations via a pilot program late last year. The agency issued a 10 page report saying it planned to replace the existing CSA Safety Measurement System with a new scoring system. It also said it hoped to improve the quality of data used to score carriers, as well as make it easier for carriers to calculate their scores. The agency said it also might add an absolute scoring system, instead of relying solely on relative scores that compare carriers to their peers.

The House’s THUD appropriations package seemingly would require those reform efforts to continue, though it would require CSA scores to be made public within six months of the bill’s passage.

However, the legislation must still pass the full House and then the Senate — and likely a conference committee between the two chambers — before becoming law.

Excerpt taken from https://www.ccjdigital.com

Trucking Industry Struggles With Growing Driver Shortage

A tractor-trailer rolls along the highway in Miami last November. The trucking industry needs to hire almost 900,000 more drivers to meet rising demand, according to an industry analysis.

Joe Raedle/Getty Images

America needs more truck drivers. The trucking industry is facing a growing shortage of drivers that is pushing some retailers to delay nonessential shipments or pay high prices to get their goods delivered on time.

A report from the American Trucking Associations says more than 70 percent of goods consumed in the U.S. are moved by truck, but the industry needs to hire almost 900,000 more drivers to meet rising demand.

Derek Leathers, CEO of Omaha-based trucking company Werner Enterprises, tells Here & Now‘s Meghna Chakrabarti that truckers drive the American economy, but in recent years the industry has struggled to attract new drivers.

“Being a truck driver was something that carried a certain level of honor with it,” he says. “They were kind of the ‘knights of the road,’ and we lost that somewhere along the way, and I think often trucks are portrayed as sort of this negative reality on the road.”

The ATA report notes that the industry has struggled with a driver shortage for the past 15 years. During the Great Recession, freight volumes dropped, allowing the industry to meet demand with fewer drivers. But when volumes recovered in 2011, the driver shortage became a problem again.

According to an industry analysis by DAT Solutions, just one truck was available for every 12 loads needing to be shipped at the start of 2018, which is the lowest ratio since 2005.

“In addition to the sheer lack of drivers, fleets are also suffering from a lack of qualified drivers, which amplifies the effects of the shortage on carriers,” says ATA Chief Economist Bob Costello. “This means that even as the shortage numbers fluctuate, it remains a serious concern for our industry, for the supply chain and for the economy at large.”

An aging fleet of drivers is one of the main reasons for the driver shortage. The Bureau of Labor Statistics estimates that the average age of a commercial truck driver in the U.S. is 55 years old. The industry also heavily relies on male drivers — only 6 percent of commercial truck drivers are women, according to the ATA.

“Demographics are working against the industry,” Leathers says. “The trucking industry average age is about 10 years older than the average age across other comparable industries like manufacturing and construction. So as those retirements are taking place, we’re just not seeing the same level of new entrants into the industry.”

The industry has struggled to attract new drivers because the lifestyle of a trucker is less than ideal. Drivers are often forced to be on the road for extended periods of time, causing fatigue, and many suffer from undiagnosed sleep apnea.

The Trump administration implemented new safety regulations in December that require commercial truck drivers to use electronic logging devices to record their hours. But many truckers say the federal mandate does not provide the flexibility they need.

“Federal regulators simply don’t have a clue,” Todd Spencer, executive vice president of the Owner Operator Independent Drivers Association, a trade group, told NPR in December. “They don’t have a clue what truckers do, how they go about doing it, the environment that they live in, the schedules and things like that, the demands of the job.”

Leathers says his company has increased wages, so drivers can make up for lost time on the road. The median annual wage for heavy and tractor-trailer drivers was $41,340 in May 2016, according to the BLS.

“Pay in the industry’s come up considerably. Here at Werner our pay’s up 17 percent over the last couple of years,” Leathers says. “First-year entrants into the industry now make around $50,000 a year depending on what part of the business they go in. So it’s a good job. It pays well; you can build a family around it. It’s about getting that awareness out there.”

Excerpted from https://www.npr.org/2018/01/09/576752327/trucking-industry-struggles-with-growing-driver-shortage

 

ATA – New Survey Data Reveals Increases in Driver Compensation

UPDATED: New Survey Data Reveals Increases in Driver Compensation
Competitive Market Boosting Driver Pay and Benefit Packages

Arlington, Virginia — Today, the American Trucking Associations released data from its latest Driver Compensation Study, showing driver pay has climbed as rising demand for freight transportation services has increased competition for increasingly scarce drivers.

“This latest survey, which includes data from more than 100,000 drivers, shows that fleets are reacting to an increasingly tight market for drivers by boosting pay, improving benefit packages and offering other enticements to recruit and retain safe and experienced drivers,” said ATA Chief Economist Bob Costello.

According to this most recent study, the median salary for a truckload driver working a national, irregular route was over $53,000 – a $7,000 increase from ATA’s last survey, which covered annual pay for 2013, or an increase of 15%. A private fleet driver saw their pay rise to more than $86,000 from $73,000 or a gain of nearly 18%.

In addition to rising pay, Costello said fleets were offering generous signing bonuses and benefit packages to attract and keep drivers.

“Our survey told us that carriers are offering thousands of dollars in bonuses to attract new drivers,” Costello said. “And once drivers are in the door, fleets are offering benefits like paid leave, health insurance and 401(k)s to keep them.

“This data demonstrates that fleets are reacting to concerns about the driver shortage by raising pay and working to make the job more attractive,” he said. “I expect that trend to continue as demand for trucking services increases as our economy grows.”

Excerpted from: http://www.trucking.org/article/New-Survey-Data-Reveals-Increases-in-Driver-Compensation

 

 

Enforcing ELDs: A new way of life for trucking

Unknowns associated with the ELD mandate abound, but right now, enforcement issues are a top concern in the industry.

Roadside inspections

The electronic logging device (ELD) mandate is here, and there are still a lot of unknowns that go along with it. The industry is still waiting to see how the mandate will really impact capacity, rates, productivity, and, of course, the growing truck driver shortage.

However, since the mandate went into effect on Dec. 18, one of the larger known issues associated with it is enforcement officer training.

“The biggest problem we’ve seen at roadside is the training enforcement received is somewhat minimal if any,” Fred Fakkema, vice president of compliance for Zonar Systems, told Fleet Owner. “I think they’re still going through it. The issue today is when one of our legacy customers that are running AOBRDs (automatic onboard recording devices), which are grandfathered in until 2019, is being questioned as to why they don’t have an ELD and then are written up on the inspection report, if you will.”

Though enforcement officers are not putting truckers out of service for not having an ELD until April 1, they are still looking to see if drivers are indeed complying with the mandate. FMCSA has maintained that CSA points won’t go against the carrier right away, but officers are still making notes in their inspection reports.

According to Fakkema, who is a former 25-year veteran with the Washington State Patrol, the problem is that officers still don’t understand that grandfathered-in AOBRD truckers do not need to have an ELD – at least not until 2019.

“The driver needs to indicate to enforcement, ‘No, I’m not [using] an ELD; I’m [using] an AOBRD and I’m grandfathered in,’” he explained.

“Coming from the enforcement background, we know how important that first interaction is, how that should take place and what direction it will go if the driver accidentally says ‘ELD’ when he means ‘AOBRD,’” Fakkema added. “It’s really that communication piece on the roadside that’s so important.”

Holding out on ELDs

Through the month of December, Zonar saw a surge in ELD adoption rates, particularly among the smaller carriers trying to catch up with the mandate.

“A lot of them assumed that with CVSA’s announcement of the April 1 out-of-service criteria that we could wait until April, then they found out that that’s actually not the case,” Fakkema explained. “I think there’s a few of them that were hoping something would happen right before the deadline. They were hoping for a say and that hasn’t come to fruition.”

Though adoption rates were on the rise nearing the Dec. 18 deadline, many smaller carriers and owner-operators are still deciding to hold out until “hard enforcement” begins in April, according to Fakkema. It’s a trend others within the industry are seeing as well.

Kevin Hill, president and founder of CarrierLists, said that even a month before the mandate became law, two out of three smaller fleets had yet to install electronic devices. Among the smaller carriers he surveyed in the last two months, ELD adoption rates jumped to around 75%. However, adoption since has been flat, he noted.

“I think some of them are going to try to hold out,” Hill explained. “I think a lot of them had equipment on back order. I expect that once we get well into January, it will start rising again once they get their devices from back order.”

Hill pointed out that he believes many of those small fleets and owner-operators will indeed wait until April 1.

“Say 5% or 10% wait and still don’t have ELDs. If you take 5% of the trucks off the market, especially with capacity as it is right now, there will be exponential results on that,” he said.

According to DAT Solutions’ data for the week ending Dec. 30, van load-to-truck ratio was up 22% to 12.3 from 10.1 the previous week, and reefer load-to-truck ratio was up 33% to 23.7 from 17.8 the previous week. DAT analyst Mark Montague said those load-to-truck ratios are at record highs.

Because of the activity in the market and strong economic growth, Hill explained driver time is going to become much more valuable as we head further into 2018. That means the shippers who are inefficient loading or unloading and have chronic detention problems will see their costs rise more than their competitors in 2018, he said.

Hill also projects inefficient shippers will have two choices going forward: Pay higher-than-market rates, or invest capital to become more efficient in their production and shipping departments.

In addition, DAT’s Montague stressed that with load-to-truck ratios setting record highs, it is imperative shippers make their operations more driver friendly.

“I’ve been in drop lots where a driver has to spend a half hour hunting down his trailer,” Montague told Fleet Owner. “So there are a number of things shippers can do to make it more friendly for truck drivers and minimize their time spent at the facilities.”

For instance, Montague emphasized the need for solid communication between the receiving gate and the dock to minimize loading and unloading times. He also suggested shippers make their facilities more available to drivers taking their mandated breaks.

ELDs and the driver shortage

There has also been a lot of discussion about drivers leaving the industry because of the ELD mandate. However, as Montague pointed out, market rates are so strong right now that it’s “hard to envision a meaningful exodus of owner-operators in the industry.”

For those who haven’t yet installed an ELD, Montague noted that he believes there will be a lot of pressure to comply with the mandate before April 1.

“I think if the guys get a ticket, they are going to be convinced they are going to need to go out and get an ELD,” he explained. “If it gets back to the company the owner-operators drive for, that’s not going to sit well with the company because eventually it will impact the company’s insurance rates.”

Montague added that particularly knowledgeable shippers are pretty well-educated on the mandate at this point and that they have been requiring their carriers and brokers to hire drivers with ELDs.

“If you find out your load was delayed because the driver didn’t have an ELD and was stopped, that’s definitely going to be a huge negative,” he said.

As for training drivers and making them more comfortable with the idea of using an ELD, Fakkema suggests fleet managers leverage drivers who have already embraced the technology to help mentor more reluctant drivers.

“It’s hard to push something from the top down in any culture and in any business,” he explained. “It really has to come from the bottom up. If you have drivers who understand the technology, how it works, and how it benefits the driver and have those individuals work with the other drivers to really create that mind-set for others, that it is a good thing and not necessarily a bad thing.”

Fakkema further stressed that education is key for drivers when interacting with enforcement officers.

“That initial contact – when it’s just the driver and it’s just the enforcement person on the side of the road – I don’t think there’s enough focus placed on how that transaction takes place,” he noted. “That’s the important piece. That’s where it all happens.”

Excerpted from https://www.fleetowner.com/regulations/enforcing-elds-new-way-life-trucking

Positive Drug Tests in the Driver Workforce Hit 10-year High

Positive Drug Test Heat Map of United States
@AaronHuffCCJ

Newly released data show that trucking and other safety-sensitive workforces have the highest drug-positive test rates in a decade. The positivity increases are driven primarily by cocaine, methamphetamine and marijuana.

The data also show the four common opioids that the U.S. DOT added last year in urine testing — hydrocodone, hydromorphone, oxymorphone, and oxycodone — have a higher positivity rate than the two opioids that were previously being tested — codeine and morphine.

The following data is a summary of a recent report compiled from 10 million U.S. drug tests conducted by Quest Diagnostics, a large medical lab. Many of Quest Diagnostics’ clients have safety-sensitive workforces that have federally required drug testing, including pilots, bus and truck drivers.

Cocaine

In the federally-mandated, safety-sensitive workforce, for which only urine testing is permitted, cocaine positivity increased by eleven percent (0.28 percent in 2016 versus 0.31 percent in 2017). This is the third consecutive year of increases in this workforce segment.

A new pattern emerged in this year’s analysis, with cocaine positivity in urine testing increasing significantly in certain states among the general U.S. workforce. Double-digit year-over-year increases in at least four of the five past years were seen in the states of Nebraska (91 percent), Idaho (88 percent), Washington (31 percent), Nevada (25 percent), Maryland (22 percent), and Wisconsin (13 percent).

Methamphetamine

Urine Testing

In the general U.S. Workforce between 2013 and 2017, methamphetamine positivity rates increased 167 percent in the East North Central division of the Midwest; 160 percent in the East South Central division of the South; 150 percent in the Middle Atlantic division of the Northeast; and 140 percent in the South Atlantic division of the South.

The percentage increase in these four U.S. Census divisions ranged between nine percent and 25 percent between 2016 and 2017.

Quest Diagnostics has created this map that shows positivity by state and compared to the national average.

Marijuana

Overall, marijuana positivity continued its five-year upward trajectory in urine testing for both the general U.S. workforce and the federally-mandated, safety-sensitive workforce. Marijuana positivity increased four percent in the general U.S. workforce (2.5 percent in 2016 versus 2.6 percent in 2017) and nearly eight percent in the safety-sensitive workforce (0.78 percent versus 0.84 percent).

Increases in positivity rates for marijuana were most striking in states that have enacted recreational use statues since 2016. The increases in marijuana positivity for safety-sensitive workers increased by 39 percent in Nevada, 20 percent in California, and 11 percent in Massachusetts.

“These increases are similar to the increases we observed after recreational marijuana use statues were passed in Washington and Colorado,” said Barry Sample, PhD, senior director, science and technology, Quest Diagnostics.

Prescription opiates

Nationally, the prescription opiate positivity rate dropped by double digits on a national basis for the general U.S. workforce in urine drug testing. The rate declined 17 percent between 2016 and 2017 (0.47 percent versus 0.39 percent).

Prescription Pills

The Trucking Alliance says hair sample tests will better screen for opioid use among truck driver applicants.

Prescription opiate testing for safety-sensitive transportation workers covered under U.S. Department of Transportation (DOT) rules went into effect in January 2018. Based on four months of data in 2018, Sample says the positivity rate for hydrocodone, hydromorphone, oxymorphone, and oxycodone are “certainly higher by large multiple” compared to the positivity rate for codeine and morphine.

The additional four prescription opiates being tested are not more impairing nor more addicting than morphine, he says. Quest Diagnostics and other laboratories refer positive test results to a medical review officer (MRO). The MRO will then determine if the driver has a valid prescription for the drugs and has the ability to issue a safety concern letter to the employer.

Combined testing

Many trucking companies are conducting hair follicle testing in addition to the DOT-mandated urine test. Based on Quest Diagnostics data, Sample says hair testing gives higher positivity rates.

Hair tests detect patterns of repetitive drug use, he says. It is the most effective test for detecting cocaine use, says Sample, who has a Ph.D. in pharmacology and is a board-certified toxicologist.

In other industries, oral fluid tests are also commonly used. Sample says the drug positivity rate for marijuana use is higher in oral fluid testing compared to hair or urine tests.

“There is value in having more than one testing specimen at your disposal,” he says. The advantages of hair and oral fluid testing is they are observed collections.

Excerpt taken from https://www.ccjdigital.com

CVSA Prepares for December 2017 ELD Implementation; Announces April 1, 2018, Effective Date for Out-of-Service Criteria Related to ELD Rule

The Commercial Vehicle Safety Alliance (CVSA) will begin enforcing the electronic logging device (ELD) mandate requirements on Dec. 18, 2017. The out-of-service criteria (OOSC) associated with the ELD mandate will go into effect on April 1, 2018.

The Federal Motor Carrier Safety Administration’s (FMCSA) congressionally mandated ELD compliance deadline is still set for Dec. 18, 2017. On that date, inspectors and roadside enforcement personnel will begin documenting violations on roadside inspection reports and, at the jurisdiction’s discretion, will issue citations to commercial motor vehicle drivers operating vehicles without a compliant ELD. Beginning April 1, 2018, inspectors will start placing commercial motor vehicle drivers out of service if their vehicle is not equipped with the required device. Please note, a motor carrier may continue to use a grandfathered automatic onboard recording device (AOBRD) no later than Dec. 16, 2019. The AOBRD must meet the requirements of 49 C.F.R. 395.15.

This announcement does not impact enforcement of the OOSC for other hours-of-service violations.

CVSA supports moving forward with the compliance date as specified in the rule. However, setting an April 1, 2018, effective date for applying the ELD OOSC will provide the motor carrier industry, shippers and the roadside enforcement community with time to adjust to the new requirement before vehicles are placed out of service for ELD violations.

CVSA member jurisdictions have used this phased-in approach in the past when implementing a significant change in regulatory requirements. The CVSA Board of Directors, in consultation with FMCSA and the motor carrier industry, agreed that the phased-in approach to implementation of the ELD requirements outlined in the North American Standard Out-of-Service Criteria will help promote a smoother transition to the new ELD requirement.

A letter was sent to FMCSA notifying the agency of CVSA’s commitment to implementing the new requirement, as scheduled, on Dec. 18, 2017, and noting the April 1, 2018, effective date for applying the ELD OOSC.

For more information about the ELD rule, visit FMCSA’s ELD implementation website.

Excerpt from: http://cvsa.org/news-entry/2017-eld-implementation/

FMCSA Formally Withdraws Sleep Apnea Screening Rule

A rulemaking meant to establish criteria and processes for instituting sleep apnea screening requirements for truck operators will officially be withdrawn on Monday, according to a notice issued Friday by the Federal Motor Carrier Safety Administration.

A sleep apnea rule would give clarity to medical examiners, carrier employers and drivers themselves about what conditions or combination of conditions would prompt a driver to be referred for an in-lab apnea test, as well as treatment protocol. Currently, medical examiners have the discretion to determine which drivers are referred for apnea testing. Absent a rule, such a system will remain in place. Industry-wide, the system has prompted questions and concerns, particularly since sleep apnea referrals can carry expensive out-of-pocket costs for fleets, drivers or both.

The rule’s official withdrawal comes two weeks after the agency hinted in an annual regulatory update that the rule was on the chopping block. There was some confusion then, given that the report said the rule had been withdrawn on an unspecified date in June. However, no official notice had been published in the U.S. Federal Register, which is required to formally rescind a rule.

Friday’s notice, however, validates the U.S. DOT’s July update to its regulatory calendar.

The agency worked on the sleep apnea rule persistently in 2016, including the publication of a so-called pre-rule, listening sessions held around the country and apnea-focused meetings by two of its prominent advisory committees. However, the agency did not gather enough data to warrant a rulemaking, it said in the July regulatory update.

In the notice published Friday, FMCSA says the current protocol in place for apnea screening is sufficient. That protocol, spelled out in a bulletin issued in January 2015 by FMCSA, puts the onus on drivers’ medical examiners, encouraging them to refer drivers for apnea testing if they “believe the driver’s respiratory condition is in any way likely to interfere with the driver’s ability to safely control and drive a commercial motor vehicle.”

FMCSA’s published pre-rule, known as an advanced notice of proposed rulemaking, last March sought industry input for guidance on developing a rule. The agency also sought input from its advisory committees last year, including the MRB and the Motor Carrier Safety Advisory Committee, whose members include trucking industry stakeholders. The groups recommended that FMCSA in its sleep apnea rule require drivers who have a Body Mass Index of 40 or higher be automatically referred for apnea testing.

The groups also recommended that truckers with a BMI of 33 or higher, and who meet other qualifiers (like being male and older than 42), be referred for apnea testing, too. See the full list of apnea screening criteria recommended by the FMCSA committees at this link. Truckers referred for apnea testing, under the MCSAC/MRB recommendations, would receive a temporary certification pending their test results.

FMCSA to Begin Making Crash Preventability Determinations

FMCSA handed the trucking industry a significant victory this week when they announced a planned demonstration project to begin making preventability determinations on crashes meeting certain criteria and incorporating them into motor carriers’ CSA Safety Measurement System records. The announcement comes in response to comments by ATA on the Federal Motor Carrier Safety Administration’s 2015 Crash Weighting Study.

Motor carriers will be able to submit preventability challenges beginning August 1, 2017, for crashes the agency feels are more likely to have been unavoidable. That includes crashes in which the commercial motor vehicle was struck: in the rear; while parked; by a motorist driving under the influence; or by a motorist driving the wrong way. Motor carriers can also challenge the preventability of certain single-vehicle crashes including: animal strikes; suicide by truck; infrastructure failures; or trucks struck by falling objects.

If, after reviewing the evidence provided by the motor carrier, FMCSA finds the crash to be not preventable, it will be appropriately labeled on a carrier’s CSA profile and their Crash Indicator Behavioral Analysis Safety Improvement Category (BASIC) score will be re-calculated with the crash omitted. FMCSA will display this new score to logged-in motor carriers and law enforcement alongside the traditional Crash Indicator score which includes all crashes.

FMCSA will use the data from the demonstration project to determine whether removing non-preventable crashes improves the accuracy of the Crash Indicator BASIC. The program will last at least one year. 

Budweiser Delivers First Shipment Using Autonomous Truck

Excerpted from Truckinginfo.com

If you’re in Colorado Springs, you might buy a can of beer that was shipped by a self-driving truck.

Otto and Budweiser announced Tuesday that they have reached a major milestone on the road to autonomous trucking with the completion of the world’s first shipment using a self-driving truck.

Otto, which is now owned by Uber, teamed up with Anheuser-Busch to haul 51,744 cans of Budweiser from Fort Collins, through downtown Denver, to Colorado Springs. By using cameras, radar, and lidar sensors mounted on the vehicle to “see” the road, Otto’s system controlled the acceleration, braking, and steering of the truck to carry the beer exit-to-exit without any human intervention.

Walter Martin, a professional truck driver since 2007, monitored the 120-mile journey down I-25 on October 20 from the sleeper berth in the back. Otto says the project had full support from the State of Colorado.

“We are always looking for new innovations and technology,” explained Anheuser Busch’s James Sembrot in a video posted by Otto. “Otto’s trucks are the next area of transportation innovation.”

The driver is still involved in picking up the load, making sure the freight is secured in the trailer. Once the truck is on the Interstate, he flips a switch and the truck drives itself down the road.

As HDT’s Rolf Lockwood reported earlier this year, Otto hardware and software is tuned for the consistent patterns and easy-to-predict road conditions of highway driving. Sensors are installed high atop the truck, which offers an unobstructed view of the road ahead. With highways making up only 5% of U.S. roads, Otto says this allows a tight testing focus on a specific set of trucking routes critical for the American economy.

http://www.truckinginfo.com/news/story/2016/10/otto-budweiser-announce-first-shipment-using-autonomous-truck.aspx?utm_campaign=Breaking-News-20161025&utm_source=Email&utm_medium=Enewsletter&btm_ea=cGhpbEBhbmFseXNpcy1pbmMuY29t

DVIR Elimination if No Defects Found

Yesterday, the Federal Motor Carrier Safety Administration eliminated the regulation requiring commercial vehicle drivers to submit and retain Driver-Vehicle Inspection Reports when the driver has neither discovered nor been made aware of any vehicle defects.
The FMCSA found that the time saved by eliminating the paperwork required by the DVIR rule will relieve the trucking industry of 46.7 million working hours and save $1.7 billion per year. In addition, the FMSCA stated that eliminating the DVIR rule would not have any negative safety impacts because other regulations still require drivers to conduct pre-trip inspections.
The elimination of the DVIR requirement takes effect immediately, but is not eliminated for passenger-carrying commercial motor vehicles, such as busses.


Expert Witnesses | Services | Computer Based Test Systems | Reference Information | FMCSR | Site Map

©2001-2024 Analysis, Inc., All Rights Reserved.

Colorado Web Development by Flexiss,LLC