Tag Archives: minimum insurance

Uncovering new information on Trucking Minimum Liability Insurance Rates

Truck Safety, ,

After numerous phone calls and emails, I have finally been able to find someone who could give me a rough estimate of the premiums which a trucking company might be able to expect if the minimum liability gets increased from $750,000 to $4.2 million. In fact, two people–unbeknownst to each other–referred me to this man, who is the president of an independent insurance agency.

I spoke with him yesterday and explained to him the kind of information that I was looking for and why I was doing so.  I let him know that I have been trying to verify whether there was any truth to the “early estimates” which I have been reading about and that it was important to me to know whether what truckers and Congress were being told was accurate. Specifically, is it accurate that a current premium of $5,000/year could skyrocket to $20,000/year?

He then described to me the graduated system of premium rates–which I had previously heard of through John Lannen: https://annaleahmary.com/2015/06/the-future-of-trucking-who-pays-for-the-costs-of-safer-roads/ “John Lannen, executive director of the Truck Safety Coalition, has shared background information with us which he has gathered from numerous sources, presentations, and conversations regarding the economics of additional insurance coverage for motor carriers.  It turns out that the first million dollars’ worth of  trucking insurance is the most expensive and each incremental amount is cheaper. . . . ” (For more details, go here: https://annaleahmary.com/2015/06/trucking-minimum-liability-insurance-trucker-wages-a-facebook-conversation/ )”

After speaking with him, I immediately proceeded to email him and document what I had heard him tell me over the phone. I asked him to verify the accuracy of my description. Here is my email to him and his response to me:

Thank you again for taking the time to speak with me and answer my questions about trucking liability.
Please let me know if this is an accurate representation of your rough estimate of the impact of an increase in liability coverage upon trucking premiums:
1st million: $5,000/truck
2nd million: add $1,200
3rd million: add $900
each additional million: would continue to be a smaller increase
So, in this example, a trucker who currently pays $5,000 (and again, I am confused if this means that this $5,000 is for just his liability portion or his whole insurance bill) would pay something a little more than $7,100–like maybe $7,600.
To clarify: That estimate of a trucker’s premium would be for if the liability coverage was $4.2 million.
Would this be an accurate ROUGH estimate?
Marianne
His reply to me:

Marianne:   Thanks for your call and again my sincere regrets for your loss.   Yes, this is a very rough and best guess estimate based on what I see and hear. 

Best wishes in your pursuit. 

I also heard back from a trucker whom I have been in conversation with via email and facebook. Tilden Curl got me in contact with his insurance agent, who responded to the above information with his own estimate:

Hello Marianne and Tilden,

 My condolences, Marianne, for your loss. My heart is heavy for you as Tilden spoke of your story and inquiries to me yesterday. Admittedly my thoughts drifted to you & your daughters while I passed a number of tractor/trailers on the freeway just last night. . . 

Due to so many factors the variance of premiums is enormous. We have seen some at $1,800 all the way up to $9,000 annual.

Historically, since the current minimums were mandated back in early 1980s, a good average would be the $5,000 mark. It does tend to flow up and down with the economy, markets, catastrophic events, and such, but a good average is the $5K.

I can only speculate on what the premiums would be if federal mandate were to be elevated to a $1.5MM, $2MM, $3MM or even $4.2MM limits.

The numbers estimated in the other emails seem pretty low to me. I would think closer to:

1.5MM – $6,200 +/- annual

2MM – $7,000 – $7,500

3MM – $7,800 – $8,400

4.2MM – $8,600 – 9,300

Mark D. Johnson

HUB International Transportation Insurance Services, Inc.

Even if we go with the second estimate, $9,300, this is still only an increase of $4,300 from a current $5,000. Compare this to the “early estimate” of $20,000 or more, which is what is being told to truckers and would increase their premium by $15,000/year.

Thus, the estimates I have been given are at least $11,700/year less than what truckers are apparently being told. Big difference.

Furthermore, I am assuming, that Congress has been told that the rates will skyrocket and go up to $20,000. So the question is:  Did Congress vote upon the THUD Appropriations Bill — to take away funding from FMCSA which would allow them to continue the rulemaking on this vital matter (previously authorized by Congress) — based on INACCURATE information?

Read about that here:

My Crash Course on Underwriting for Trucking Minimum Liability Could Impact You

AnnaLeah and Mary, Truck Safety, , ,

In case you did not know it, the minimum level of liability insurance, which trucking companies are required to have, is $750,000 and has not increased in over 35 years. It has not kept up with inflation as Congress intended when it originally authorized the Secretary of Transportation to set that limit.

“The Motor Carrier Act of 1935 first directed the establishment of Federal rules and regulations for interstate motor carrier operations that govern “security for the protection of the public.” Over time, both Congress and the Federal government have taken numerous actions to address the levels of financial responsibility, most recently with the recent enactment of MAP-21. The current minimum levels of financial responsibility for commercial motor carriers were established by Congressional legislation in the early 1980’s. Recently, there has been interest in determining whether the current mandated levels continue to accomplish these goals and whether victims of truck- and bus-related crashes are adequately compensated.” p. xi  http://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Financial-Responsibility-Study.pdf

As one daughter of a truck crash victim has said, “That’s $750K for each incident, not each person injured or killed in a crash. So if several families or cars are involved all those injured and all the families of those killed must share the $750K if that is all the truck company has.”  http://trucksafety.org/dawn-kings-journey-2011/

In contrast, check out this DOT document which they prepared in order to determine the value of lost life and injury and its impact on rulemaking decisions:                                          VSL Guidance-2013-2 DOT value of life .

In the fall of 2014, the Federal Motor Carrier Safety Administration (FMCSA)  issued an advanced notice of proposed rulemaking  in order to study, among other things, the question of whether the minimum liability level should be increased in order to more adequately compensate for lost life and injury due to truck crashes.

  • The Federal Government has long required motor carriers to maintain certain levels of financial responsibility, either through insurance, a bond, or other financial security, as a means to protect the public in the event of a crash.  An April 2014 Report to Congress found that while catastrophic motor carrier crashes are rare, the costs for resulting severe and critical injuries can exceed $1 million; current insurance limits do not adequately cover these costs, which are primarily due to increases in medical expenses and other crash-related costs. – See more at: http://www.fmcsa.dot.gov/newsroom/fmcsa-seeks-comment-public-insurance-providers-motor-carriers-revising-minimum-levels#sthash.dQV1v0AQ.dpuf
  • From a study released in April 2014, FMCSA says that, “The legislative history of minimum insurance requirements for commercial motor vehicles (CMV) indicates that Congress recognized that crash costs would change over time and that DOT would periodically examine the levels and make adjustments as necessary. A variety of recent studies indicate that inflation has greatly increased medical claims costs and related expenses. In conclusion, FMCSA has determined that the current financial responsibility minimums are due for re-evaluation. The Agency has formed a rulemaking team to further evaluate the appropriate level of financial responsibility for the motor carrier industry and has placed this rulemaking among the Agency’s high priority rules. The FMCSA will continue to meet with the stakeholders, including impacted industries, safety advocacy groups, and private citizens, as it moves forward with developing a proposed rule.”  http://www.fmcsa.dot.gov/mission/policy/report-congress-examining-appropriateness-current-financial-responsibility-and

Unfortunately, despite the insistence of many that this increase is necessary, the trucking industry is lobbying against it–declaring it unnecessary–and, at present, has put a rider in the THUD appropriations bill now being voted on. If the bill passes with that rider intact, then FMCSA will no longer be funded to complete the rulemaking process which has already been authorized.

What is the truth in this matter–necessary or unnecessary? That is what I would like to know. And I think that truckers and lawmakers and the public need to know this as well. And that is why I set out on a quest recently to find the answer to that question.

The support for halting the rulemaking which is coming from the trucking industry includes the Independent Owner Operators, who in particular are being told that their premiums will skyrocket if the rule were to pass.  According to Jami Jones from OOIDA (Owner-Operator Independent Drivers Association),

“An increase such as the one Cartwright is proposing would cripple small-business-truckers. Currently, the national average cost for a small-business trucker insuring one truck is about $5,000 per year.

It’s virtually impossible to project what the cost would be if the minimum liability requirement were increased more than 500 percent.

For starters many insurance carriers may quit offering insurance because of the increased amount of financial resources they would have to have in place to even write the policies. Secondly, there is no straight-line increase that can be drawn. But early estimates place annual premiums at $20,000 or more for a one-truck owner-operator for a $4.2 million liability policy.” – See more at: http://www.landlinemag.com/Story.aspx?StoryId=25702#.VXoxp_lViko

In contrast, check out this opinion on the potential premium:

https://annaleahmary.com/2015/06/the-future-of-trucking-who-pays-for-the-costs-of-safer-roads/ “John Lannen, executive director of the Truck Safety Coalition, has shared background information with us which he has gathered from numerous sources, presentations, and conversations regarding the economics of additional insurance coverage for motor carriers.  It turns out that the first million dollars’ worth of  trucking insurance is the most expensive and each incremental amount is cheaper. . . . ” (For more details, go here: https://annaleahmary.com/2015/06/trucking-minimum-liability-insurance-trucker-wages-a-facebook-conversation/ )”

Additionally, I have been having online conversations with truckers and have not found any evidence to verify the validity of that $20,000 estimate. Many people in the industry pooh-pooh safety advocacy which they consider based merely on emotion. But do they hold themselves to the same standard and insist on FACTS?

I am certainly motivated strongly by emotions to be in this quest for safer roads for the long haul. But I hope that I am basing my statements and my advocacy on facts and logical reasoning. In fact, I am not content to accept at face value statements by the trucking industry which influence both those whom they represent and also lawmakers who make decisions on truck safety legislation. I am, therefore, concerned about decisions being made on matters which impact victims of truck crashes and which quite possibly may be impacted by misinformed fears.

Because I feel so strongly about getting to the bottom of this question, I have spent many hours this week trying to find out what the new premiums will actually be for truckers if the minimum liability level is eventually raised. In order to educate myself on this topic, I have spoken or emailed with:

  • Todd Spencer, Executive Vice President of OOIDA–the Owner-Operator Independent Drivers Association (awaiting a response from him)
  • National Association of Insurance Commissioners (who explained to me that as liability limits go up, rates go down. He also told me that insurance companies are required by law to file their rate tables with the state and that I should be able to contact a state department of insurance and ask for that information. He said that the rate tables would list the options for liability limits and that each level would indicate a figure which would be a multiplier–to be multiplied by the trucker’s base rate in order to find out the new premium at higher levels. I have yet to get access to these tables.)
  • North Carolina Department of Insurance (still have to check with the Property and Casualty Division)
  • Numerous insurance agencies
  • Several truckers, including: https://annaleahmary.com/2015/06/trucking-minimum-liability-insurance-a-facebook-conversation-with-truckers-continues/

Many independent owner operators are concerned that they would bear the brunt of increases — being at a disadvantage to the larger self-insuring trucking companies. FMCSA’s rulemaking addresses this issue. http://www.landlinemag.com/Story.aspx?StoryID=28110#.VXozEPlViko

Along that line, please read this paper written by an independent owner operator:      Tilden Curl Paper on Trucker Insurance

Finally, I contacted FMCSA, to whom, on May 5, 2014, we originally presented our petition request for raising the minimum liability. At that time, they indicated that in order to get access to proprietary insurance information to determine estimated premiums they would have to initiate the rulemaking process–which they did in November 2014.

However, when I emailed FMCSA today to find out if they had gotten access to that proprietary information, they let me know that they did not yet have the information to estimate the increase in insurance premiums. In order to get that information, they have recently published a rulemaking entitled “Confidential Business Information,” which would “help encourage insurance companies to share some of their proprietary information” for use in the agency rulemaking process–without disclosing confidential information to the general public.

The evident lack of transparency really bothers me, especially with all of the rumors going around–rumors which are swaying decisions and actions that impact life & death matters.

Meanwhile, who pays the price for this issue being stuck in limbo? Some would claim that, “In the end, if minimum liability insurance is increased to $4.2 million, the only winners would be the trial lawyers and large motor carriers – with small-business trucking suffering an expensive, wildly burdensome and completely unnecessary mandate.” – See more at: http://www.landlinemag.com/Story.aspx?StoryId=25702#.VXo3XvlViko

Really? What about those who already bear the brunt of unexpected, unnecessary tragedy and untimely death? Aren’t they the ones that the insurance is intended to benefit?

 

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Trucking Minimum Liability Insurance & Trucker Wages. . .A Facebook Conversation

AnnaLeah and Mary, Truck Safety, ,

A Facebook Conversation on Trucking Minimum Liability Insurance AND Trucker Wages. . .

Truckers United Just got off the phone with my Congressman’s office. Have all of You made that call yet? Us Capitol switchboard; 202-202-3121
Higher liability insurance is not needed as only 1% of claims today exceed the current $750,000 minimum. Company Drivers, This affects you also!!!

  • Marianne Waldron Karth Please take the time to read what I have to say about liability insurance–after losing 2 daughters, In Memory of AnnaLeah 1995 to 2013 and Mary Lydia Karth 1999 to 2013 AnnaLeah (17) and Mary (13), in a truck crash. …See More

    Like · Reply · Remove Preview · 2 · 1 hr
  • Truckers United Marianne Waldron Karth, First and foremost, I am Deeply sorry for your loss! I Will take time to better understand your point of view as it is valid! At a glance I noticed that the cost of inflation is part of the reasoning behind the desired liability increase. The FMCSA has also raised certain fines due to inflationary increases. I suppose this would be fine if freight rates kept up with inflation. They have not as there are those who are paying little more today than they were in the 80’s. There are novice Drivers on the road today earning pennies more a mile than I did when I started driving in 89. I have a paycheck stub of an experienced co Driver who in 1978 earned .23.5 cpm. Accounting for inflation, that would be about .80cpm today. 50cpm is very hard to come by today. We have novice Drivers earning .25cpm today. We have mega companies paying their lease Drivers .90cpm + a meager fuel surcharge. The megas cost of operation last year averaged $1.64 a mile. These guys are self insured and they want insurance premiums to go up because it will affect them positively as it strains the rest of us. When I spoke to my Congressman’s office I tried to make them aware that our cost of doing business keep going up up up while our income has been stagnant for 25yrs or more.I think that OOIDA has suggested that a catastrophic fund could and should be set up to handle the the instances that exceed the current minimum. Mamm, I AM sympathetic to your concerns. I am also aware that we Drivers are having to work within a punitive system trying to force safe behavior instead of devising a system that pays Drivers to Be Safe. I do believe that there is an answer to be found if WE Work Together. Maybe I should have said “Higher liability insurance is not needed. We should consider creating a catastrophic fund to address the 1% of claims that exceed the current minimum”. I do appreciate your contacting me.
    Like · Reply · 20 mins
    • Marianne Waldron Karth Thank you for taking time to respond. I don’t think that it is an either/or situation. I am also advocating for improvement in truck driver compensation. I hope to promote sitting-down-together to discuss WIN/WIN solutions. Who profits and who pays the price for the status quo? https://annaleahmary.com/…/driver-sees-wages-synonymous…/

      “Driver sees wages synonymous with trucking safety”
      What is the answer to making sure that truck…
      ANNALEAHMARY.COM
      Like · Remove Preview · 5 mins
    • Marianne Waldron Karth Many “truck safety issues” are social and public health problems and they should be addressed as such so that individuals (Victims & their Loved Ones and Truck Drivers) do not pay the heavy price or bear the entire burden for resolving these issues.
      Truckers United Tilden Curl had written an article that I am vaguely familiar with as it’s been almost a year since I first touched on it. This article pertains to the megas ability to self insure and how that affects freight rates. Tilden and I spoke last Friday but I haven’t had a chance to download the article for review. Once done, I would be happy to share it with you. I only remember that Tilden’s approach made sense to me at the time. Tiden, Allen Smith and I are OOIDA members. Speaking for myself, I don’t believe that OOIDA is the enemy here. We, the membership, are pennies fighting against Dollars that will do whatever it takes to increase their profits. Yes, this is America and that is their right, but at what cost to those like you and me? I only desire that reasonable steps be taken to protect all. Thank you Marianne Waldron Karth
      *     *     *     *     *     *     *     *    *     *     *     *     *     *     *     *     *     *     *     *     *     *     *
      Apparently OOIDA says , “…protect the legislation halting FMCSA’s rush to raise insurance requirements.” – See more at: http://www.landlinemag.com/Story.aspx?StoryID=29127#.VW5Vas9Viko
      But this has not been a “rush;” it has been discussed and studied for some time now:  http://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Financial-Responsibility-Requirements-Report-Enclosure-FINAL-April%202014.pdf

Had it up to here with the impact of political battles on the safety of travelers on the road!

AnnaLeah and Mary, Truck Safety, , , ,

Maybe its’s just me–and my frustrated opinion–but I have had it up to here with the impact of political battles on the safety of travelers on the road.

Just one example is the HOS (Hours of Service) Rules which have been debated forever and a day. Back & forth, back & forth–until what are we left with but an unenforceable mess of regulations and little accountability for truck drivers who are too often driving fatigued, under pressure to drive too many hours to make a living.

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Then there is the provision which ties the hands of DOT to increase minimum insurance levels (not done for 35 years)–though they have already issued a lengthy report saying that it is necessary.

And don’t forget the increase in truck length (Double 33s). . . do we really want to share the road with them & will the drivers be trained to handle them?

http://www.roadscholar.com/content/2016-transportation-housing-and-urban-development-appropriations-bill

It seems to me that those who have crafted & approved the anti-safety provisions in the FY2016 THUD Appropriations Bill have either had the wool pulled over their eyes or care very little for the human lives that are ended on a daily basis–whose blood is spilled on the highways of our country.

https://annaleahmary.com/2014/07/truck-safety-needs-bipartisan-support-protecting-its-citizens-is-one-of-the-basic-purposes-of-government/

There has got to be a better way to move this mountain! It’s a matter of life & death.

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Thanks, Phil & WNCN, for shedding light on truck crashes. It can happen to anyone at anytime.

AnnaLeah and Mary, Truck Safety, , ,

http://www.wncn.com/story/29036149/mother-who-lost-2-daughters-raises-concerns-about-bigger-trucks

Preventable, though-unforeseen, inconceivable, unimaginable, irrevocable. . . all these words describe too many truck crash tragedies year after year–as a result of numerous factors which have been argued over too many times.

WNCN: News, Weather, Raleigh, Durham, Fayetteville

Ask Congress to strip the FY2016 THUD bill of all the ANTI-SAFETY Provisions. Send an email tonight.

Truck Safety, , , ,

We have learned that Congressman David Price (D-NC), Ranking Member of the House THUD Appropriations Subcommittee, is going to be offering an amendment during Wednesday morning’s House Committee on Appropriations markup to strip the FY2016 THUD bill of all of the anti-safety provisions from the bill.  Please make as many calls or emails as you can to House Appropriations Committee Members before Wednesday morning and ask them to:

“Vote Yes on the Price (NC) Amendment”.  Choose SAFETY: we all travel the roads of this country.

 CONTACT INFORMATION for members of the House Committee on Appropriations is listed below.

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Special Interest Riders in the FY2016 THUD Bill Include:

 FedEx Double 33’ tractor trailers on federal and local roads (House THUD bill Sec. 125).  The anti-safety, pro-industry plan will overturn state laws and bulldoze states to accept trucks that are at least 84 feet long on federal, state and local roads.

  • If truck lengths are increased from 28 to 33 feet, the laws of 39 states (AL, AK, AR, CA, CO, CT, DE, GA, HI, IL, KS, KY, LA, ME, MD, MI, MN, MS, MO, NE, NH, NJ, NM, NY, NC, ND, OH, OK, PA, RI, SC, SD, TN, TX, VT, VA, WA, WV, WI) which currently prohibit longer trailers may be overturned.  States where double 33s are prohibited and states where they are not running will be pressured to allow these longer trucks on their roads which are not equipped to accommodate them.
  • Longer double-trailer trucks will make passing even more dangerous than it already is. A double-trailer truck using 33-foot trailers would be at least 84 feet long, the height of an 8-story office building, and a triple-trailer truck would be at least 120 feet long, equivalent to a 12-story building. These longer trucks would dwarf the size of an average car and are the equivalent of 5 to 8 passenger cars in length

 

Special interest weight and length exemptions for specific states including Idaho and Kansas (House THUD bill Secs. 124 and 126) or specific industries. The provision would allow Idaho to operate trucks up to 129,000 pounds and Kansas to operate trucks potentially more than 100 feet long.

  • By overwhelming margins in numerous public opinion polls over the last 20 years, the American public consistently and convincingly rejects sharing the road with bigger, heavier and longer trucks. The most recent poll in January 2015 by Harper Polling revealed that 76% of respondents oppose longer and heavier trucks on the highways and 79% are very or somewhat convinced that heavier and longer trucks will lead to more braking problems and longer stopping distances, causing an increase in the number of crashes involving trucks.
  • Special interest truck size and weight exemptions are essentially “earmarks” for states and “unfunded mandates” imposed on all American taxpayers who bear the cost of federally-financed infrastructure damage and repairs.

 

Extension and expansion of the  “Collins Amendment” tucked into the 2015 overall federal spending bill last December that dramatically increases the working and driving hours of truck drivers up to 82 hours a week and takes away their “weekend” off, resulting in more tired truckers and jeopardizing safety (House THUD bill Sec. 132).

  • A provision added to the Omnibus spending bill (Pub. L. 113-235) in December 2014 rolled back important safety reforms to hours of service (HOS) rules which were implemented by the DOT in July 2013 after a lengthy rulemaking process which considered 21,000 formal public comments, thorough and compelling scientific research, extensive stakeholder input, as well as three lawsuits.
  • This major change will significantly increase working and driving hours for truck drivers, from 70 hours to 84 hours. Essentially, this provision takes away the two-night off “weekend” for truck drivers.
  • With this provision, the HOS rule reverts to the Bush Administration rule in effect when a 2006 survey of truck drivers found an alarming 65% of truck drivers reported they had often or sometimes felt drowsy while driving and nearly half admitted to falling asleep while driving in the previous year.

 

A prohibition on rulemaking going on right now at the U.S. Department of Transportation to determine whether or not motor carriers have sufficient insurance coverage, which has not been reviewed and revised since 1985. (House THUD bill Sec. 134) The bill will STOP progress on this needed & already-too-long-delayed increase.

  • Congress gave the DOT Secretary and FMCSA the authority to review the insurance level.  The rule making process, which includes public comments, should be respected and followed.
  • Minimum levels of insurance for trucks, currently set at $750,000, have not been increased in over 35 years and are woefully insufficient.
  • The underinsured segments of the industry are effectively subsidized by American taxpayers through unreimbursed social welfare programs including Medicaid and Social Security.
  • If all of the industry were required to absorb more of the losses they cause, significant changes in the industry would occur, resulting in safer highways for all.

According to Michael R. Lemov, Car Safety Wars, p. 31, “Today, the U.S. DOT uses a figure of $9.2 million per lost life (2013) which includes value for both economic costs and other costs including value for pain and suffering.” Compare this to the $750,000 current trucking minimum liability insurance.

https://annaleahmary.com/2014/12/good-news-fmcsa-announces-first-step-toward-increasing-minimum-liability-for-trucker-insurance/

Urge Members of the House Appropriations Committee:

Stand Up For Safety –Vote YES on the Price (NC) Amendment!

 

To Contact the Members of the House Committee on Appropriations:

  1.  Hal Rogers (R-KY) at 202-225-4601 or through email at: shannon.rickett@mail.house.gov
  2. Rodney Frelinghuysen (R-NJ) at 202-225-5034 or through email at: kathleen.hazlett@mail.house.gov
  3. Robert Aderholt (R-AL) at 202-225-4876 or through email at: mark.dawson@mail.house.gov
  4. Kay Granger (R-TX) at 202-225-5071 or through email at: shannon.meade@mail.house.gov
  5. Mike Simpson (R-ID) at 202-225-5531 or through email at: nathan.greene@mail.house.gov
  6. John Culberson (R-TX) at 202-225-2571 or through email at: catherine.knowles@mail.house.gov
  7. Ander Crenshaw (R-FL) at 202-225-2501 or through email at: erica.striebel@mail.house.gov
  8. John Carter (R-TX) at 202-225-3864 or through email at: steve.gilleland@mail.house.gov
  9. Ken Calvert (R-CA) at 202-225-1986 or through email at: Ian.Foley@mail.house.gov
  10. Tom Cole (R-OK) at 202-225-6165 or through email at: maria.bowie@mail.house.gov
  11. Mario Diaz-Balart (R-FL) at 202-225-4211 or through email at: miguel.mendoza@mail.house.gov
  12. Charlie Dent (R-PA) at 202-225-6411 or through email at: drew.kent@mail.house.gov
  13. Tom Graves (R-GA) at 202-225-5211 or through email at: jason.murphy2@mail.house.gov
  14. Kevin Yoder (R-KS) at 202-225-2865 or through email at: patrick.carroll@mail.house.gov
  15. Steve Womack (R-AR) at 202-225-4301 or through email at: Adrielle.Churchill@mail.house.gov
  16. Jeff Fortenberry (R-NE) at 202-225-4806 or through email at: alan.feyerherm@mail.house.gov
  17. Tom Rooney (R-FL) at 202-225-5792 or through email at: jessica.moore@mail.house.gov
  18. Chuck Fleischmann (R-TN) at 202-225-3271 or through email at: alek.vey@mail.house.gov
  19. Jaime Herrera Beutler (R-WA) at 202-225-3536 or through email at: chad.ramey@mail.house.gov
  20. David Joyce (R-OH) at 202-225-5731 or through email at: john.miceli@mail.house.gov
  21. David Valadao (R-CA) at 202-225-4695 or through email at: Kristina.Dunklin@mail.house.gov
  22. Andy Harris (R-MD) at 202-225-5311 or through email at: john.dutton@mail.house.gov
  23. Martha Roby (R-AL) at 202-225-2901 or through email at: Andrew.Ashley@mail.house.gov
  24. Mark Amodei (R-NV) at 202-225-6155 or through email at: Kyle.Thomas@mail.house.gov
  25. Chris Stewart (R-UT) at 202-225-9730 or through email at: cam.madsen@mail.house.gov
  26. David Jolly (R-FL) at 202-225-5961 or through email at: Jenifer.Nawrocki@mail.house.gov
  27. Scott Rigell (R-VA) at 202-225-4215 or through email at: John.Thomas@mail.house.gov
  28. Evan Jenkins (R-WV) at 202-225-3452 or through email at: Brian.Barnard@mail.house.gov
  29. David Young (R-IA) at 202-225-5476 or through email at: Tara.Morgan@mail.house.gov
  30. Steven Palazzo (R-MS) at 202-225-5772 or through email at: Patrick.Large@mail.house.gov
  31. Nita Lowey (D-NY) at 202-225-6506 or through email at: drew.jacoby@mail.house.gov
  32. Marcy Kaptur (D-OH) at 202-225-4146 or through email at: mike.berman@mail.house.gov
  33. Pete Visclosky (D-IN) at 202-225-2461 or through email at: kevin.spicer@mail.house.gov
  34. José Serrano (D-NY) at 202-225-4361 or through email at: matthew.alpert@mail.house.gov
  35. Rosa DeLauro (D-CT) at 202-225-3661 or through email at: Eric.anthony@mail.house.gov
  36. David Price (D-NC) at 202-225-1784 or through email at: kate.roetzer@mail.house.gov
  37. Lucille Roybal-Allard (D-CA) at 202-225-1766 or through email at: victor.castillo@mail.house.gov
  38. Sam Farr (D-CA) at 202-225-2861 or through email at: debbie.merrill@mail.house.gov
  39. Chaka Fattah (D-PA) at 202-225-4001 or through email at: elizabeth.king@mail.house.gov
  40. Sanford Bishop (D-GA) at 202-225-3631 or through email at: jonathan.halpern@mail.house.gov
  41. Barbara Lee (D-CA) at 202-225-2661 or through email at: colin.foard@mail.house.gov
  42. Mike Honda (D-CA) at 202-225-2631 or through email at: eric.werwa@mail.house.gov
  43. Betty McCollum (D-MN) at 202-225-6631 or through email at: Jennifer.Holcomb@mail.house.gov
  44. Steve Israel (D-NY) at 202-225-3335 or through email at: Mark.Snyder@mail.house.gov
  45. Tim Ryan (D-OH) at 202-225-5261 or through email at: ryan.keating@mail.house.gov
  46. Dutch Ruppersberger (D-MD) at 202-225-3061 or through email at: Deborah.Haynie@mail.house.gov
  47. Debbie Wasserman Schultz (D-FL) at 202-225-7931 or through email at: coby.dolan@mail.house.gov
  48. Henry Cuellar (D-TX) at 202-225-1640 or through email at: megan.swearingen@mail.house.gov
  49. Chellie Pingree (D-ME) at 202-225-6116 or through email at: Joe.Marro@mail.house.gov
  50. Mike Quigley (D-IL) at 202-225-4061 or through email at: joseph.bushong@mail.house.gov
  51. Derek Kilmer (D-WA) at 202-225-5916 or through email at: Kevin.Warnke@mail.house.gov 

Same Old, Same Old: Trucking Safety Debates Impact Spending Bill

Truck Safety, , , ,

When the trucking industry uses the appropriations bill process to sway votes, what do you think is their primary motivation: Safety or Profit?

See what you think:

“Foxx said Republicans are conducting an end run around the normal legislative process by including the trucking provisions in his agency’s funding bill.

What’s happening is the appropriations process is now being used to create policy, which, when it comes to safety, that’s a real problem because it leaves us without a process with which we can articulate the concerns we have, he said. You can expect us to be very vocal about these issues, and my hope is that folks won’t only reconsider the merits of some of the issues, but also some of the processes that some of these issues are dealt with, because there’s a much better process available.

The trucking industry offered a starkly different perspective, saying the provisions that are included in the THUD bill have been on Congress’s agenda for a long time.

These issues have been debated for years, American Trucking Association spokesman Sean McNally told The Hill on Wednesday morning, noting that lawmakers will be holding a hearing on the appropriations bill in the afternoon.

They’re the same issues we’ve been talking about for years, and now we’re going to talk about them again, he said.

McNally added the appropriations bill is fair game for the trucking provisions because it is a piece of legislation that is moving through Congress.

We obviously take a different view of the safety ramifications of these provisions, he said, describing the changes as a number of things we believe will increase output and safety.”  http://thehill.com/policy/transportation/240453-gop-spending-bill-reignites-trucking-debate

Sounds good, but just exactly how will their actions increase SAFETY? That is what I want to know.

The Truck Safety game 001

Be a part of our team to promote safety & save lives

AnnaLeah and Mary, Truck Safety, , , , , ,

We appreciate all of the people who signed the  AnnaLeah & Mary Stand Up For Truck Safety Petition. Together with over 11,000 people, we helped to send a strong message to the Department of Transportation: Changes are needed in truck safety issues in order to stop the senseless, preventable deaths which occur year after year on the roads of our country.

Please act now to be a part of our team to continue our push for change. The most important thing which you can do is to stay connected with us by signing up to be on our Mailing List (get our newsletter and other important updates).  As we continue to make inroads in truck safety issues, your participation is vital.  We would like to be able to let you know when there is a way for you to help make a difference. You can multiply our safety advocacy efforts.

Newscast from our trip to DC to deliver the petitions to DOT:

To read more about the impact of our petition and what we want to continue to do, read more here: https://annaleahmary.com/how-you-can-help/

Other ways you can be involved:

1. Follow us on Twitter: https://twitter.com/MaryandAnnaLeah

2. Sign up for email notification of new posts on our website.  You only need to provide your email address. You can be confident that we will use it only to send you notification of our posts. Click on the SUBSCRIBE button on the bottom right column of our website.

3. When you read our posts, take advantage of the opportunity to share it by clicking on the social media icons at the bottom of each post.

4. Subscribe to the Truck Safety Coalition’s Email List to receive their “Action Alerts” and other News Updates. Click here:  http://trucksafety.org/karth-family-and-truck-safety-coalitions-next-steps/

5. Like the Truck Safety Coalition’s Facebook Page:  https://www.facebook.com/trucksafetycoalition

6. Follow the Truck Safety Coalition on Twitter: https://twitter.com/TruckSafetyOrg?lang=en

For those of you who have lost a loved one yourself in a truck crash, please consider sharing a photo and story with us on our Truck Crash Victim Photo Memorial Page. Not only will this allow us to help you preserve your loved one’s memory, but it will also serve as a reminder of the countless lives which have been touched by preventable truck crashes. Send your information to us here: photos@annaleahmary.com .

On behalf of the family of AnnaLeah & Mary Lydia Karth, whose loss we feel so deeply,
Jerry and Marianne Karth

Picture 275AnnaLeah writing

Red Herrings & Rabbit Trails; Profit vs Safety

Truck Safety,

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Let me make this very simple. It has become very apparent to me–after losing my daughters in a truck crash–that those who oppose positive changes which will improve safety on the roads [i.e, cause less people to be injured or killed as victims of a truck crash] tend to use red herrings & rabbit trails to divert the attention from the really vital issues.

Examples. . .

  • Regarding the Hours of Service 34-Hour Restart rules requiring two consecutive sleep periods between 1 and 5 a.m… they claim that their concern is for people on the roads. According to Senator Deb Fischer, “In addition, serious concerns were raised about the rule’s perverse impact on safety because, in effect, it pushed drivers onto the roads during workers, students, and families’ morning commutes.”  http://www.ttnews.com/articles/basetemplate.aspx?storyid=37567&t=Sen-Deb-Fischer-to-Offer-FMCSA-Reform-Legislation
  • But look at what industry representatives were writing about back in January 2013— before the change in the HOS even took place:”Associations such as NASSTRAC are gearing up for another busy year. Several key legislative matters, including the most recent Hours-of-Service rules and concerns over tolling policies, are still being decided.‘One critical issue that may have a negative impact on transportation and supply chain strategies is the Federal Motor Carrier Safety Administration’s (FMCSA) decision to revise the current hours-of-service rules for commercial truck drivers, which were adopted in December 2011,’ Everett says.The new rules—which require full compliance by July 1, 2013—retain the current 11-hour daily driving limit, but require drivers to take at least one half-hour break during eight hours. They also change the restart provisions, and mandate that a driver must have two consecutive rest periods from 1 a.m. to 5 a.m. before resuming driving.‘This change could reduce capacity by as much as seven to nine percent, according to some truckload carriers,‘ Everett says.”  http://www.inboundlogistics.com/cms/article/transportation-advocacy-shippers-stand-up-for-their-rights/
  • Take note of the industry perspective reflected here:”‘Legislators are currently considering and implementing laws and regulations that many transportation experts fear will significantly erode productivity—particularly in trucking—and could increase the delivered cost of goods by up to 15 percent annually,’ adds Brian Everett, executive director of the National Shippers Strategic Transportation Council (NASSTRAC).’It’s important that transportation and supply chain executives remain educated on the ‘what-ifs’ of decisions coming out of Washington in order to adequately plan and execute their supply chain strategies,’ he says. ‘As they continue to educate themselves, they also need to educate legislators on the impact their decisions will have on supply chains nationwide.'”
  • Another Red Herring is bringing up the statistic that the number of crashes which need more than the current minimum liability insurance amount is only 1%. If that is true, then surely underwriters will not be writing policies with premiums which are inappropriate or exponentially-increased. 
  • Refusing to raise a limit because such a small percentage reach the limit has only indicates that the increase in cost should be minimal. It can’t be both ways, either this increase should raise the cost of doing business or the effect should be minimal. This isn’t life insurance where all the money is always paid out. Nor is this homeowner’s insurance in which you have a set amount of house that can be destroyed. This is liability insurance in which the amount paid out is based on the amount of damage being done. If such a small percentage of claims reaches the limit then greedy lawyers, increased costs, and mythical “windfall” payments are all proven absurd or irrelevant.

    What we actually have here is discrimination against the minority. “You are so small a portion of the people we harm we are not obliged to deal with you fairly.”  Under such logic, they might as well suggest that they shouldn’t be compelled to have insurance at all.

 

  • Look at what Senator Daines said about this at the Surface Transportation subcommittee hearing yesterday. “Sen. Steve Daines, R-Mont., struck back on increasing the insurance requirements, underscoring that less than 1 percent of all crashes exceed the current amounts.’The only ones who will benefit from increasing the insurance amounts are trial lawyers, Daines said.” – See more at: http://www.landlinemag.com/Story.aspx?StoryID=28601#.VPhxZ_zF-Sp

 

  • Does he think so little of all the victims and their needs that he completely overlooks the benefit to them? If he is concerned about the lawyers, let him work on tort reform and cap their amount; don’t prevent victims from being appropriately compensated. Furthermore, he overlooks the fact that the minimum has not been raised for 35 years despite the fact that the Secretary of Transportation has already been given the authority to do so.
  • Look at what happened to this issue last June:  https://annaleahmary.com/2014/06/fact-sheet-on-the-daines-amendment-to-halt-minimum-liability-insurance-for-truckers/
  • “ The FMCSA concluded in a recent report to Congress that current minimum financial responsibility limits for the commercial motor vehicle industry — including the $750,000 limit for general freight carriers— are inadequate to meet the costs of some crashes, mainly because of rising medical costs.The regulatory agency stopped short of recommending specific new limits but could have a proposal by the end of June and new limits could be published in November.”

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Speak Up For Increased Trucker Minimum Insurance; Rally With Us To Be Heard Above the Vocal Opposition

AnnaLeah and Mary, Truck Safety,

Petition Photo Bags at DOT, bestPhoto Button

With the Federal Motor Carrier Safety Administration (FMCSA) in the process of considering a rulemaking to increase the minimum liability, NOW is the time to speak up in support of increasing minimum liability insurance for trucking companies.

Please take 5 minutes to submit a comment to the Federal Motor Carrier Safety Administration supporting an inflation adjustment of liability insurance requirements that have been unchanged since the Reagan Administration. It is critically important for truck accident victims (often truck drivers), who almost never get a full recovery even when receiving policy limits.

To submit a comment to the FMCSA, go here and click on Submit a Formal Comment: https://www.federalregister.gov/articles/2014/11/28/2014-28076/financial-responsibility-for-motor-carriers-freight-forwarders-and-brokers

Note: If you have already signed the AnnaLeah & Mary Petition, you can also individually sign the Federal Register. I have verified this with the administrative official at FMCSA who posted our petition to the Public Comments.

In your own words, tell FMCSA that you think it is important for them to proceed with the rulemaking to raise the minimum liability insurance for truck drivers.

The deadline for submitting Public Comments is FEBRUARY 26.

What follows is our Public Comment on this issue. . .

A fair-minded, thoughtful citizen would evaluate this issue from every angle and make comments accordingly. As parents of two daughters, AnnaLeah (17) and Mary (13), who are no longer with us due to a truck crash on May 4, 2013, that is what we tried to do–and have continued to do–in the aftermath of this unimaginable tragedy.

Our story and the changes we are trying to make–including increased minimum liability insurance for trucking–can be found in great detail at https://annaleahmary.com/ .

We have not merely reacted emotionally but have gathered facts and even played the devil’s advocate in questioning our own thoughts and actions. As we read the comments from others, we too often find that others are less circumspect. Let me try to address some of the factors involved in this complex issue.

Perhaps the simplest thing to say is that our first acquaintance with this issue was when we were told by our U.S. Senator, Richard Burr (R-NC), that the Secretary of Transportation actually has the authority to raise the level of the minimum liability insurance for truckers. This was intended when Congress gave DOT the mandate for this regulation; nonetheless–despite inflation–DOT has not taken action to bring about an increase since it was set at $750,000 in 1980–over 35 years. Adjusted for the rate of medical inflation, the $750,000 minimum would be over $4.4 million today.

Is this logical? Is it common sense? Would it be acceptable for say your salary/wages? Many others have written on the mathematics of this, e.g., you can find a detailed analysis at this website, http://saferhighways-oneclickpolitics.nationbuilder.com/ , with some of the key points listed below:

  • The purpose of insurance is to spread risk for catastrophic loss.
  • One of the original purposes of federally-mandated insurance minimums was increased safety entry standards for commercial truck drivers who wish to transport people and goods. This continues to be a goal of insurance—the driver who can’t afford insurance also can’t afford routine maintenance of brakes, tires and other equipment.
  • The safer a company is, the lower its insurance rates.
  • The FMCSA’s report to Congress gave the legislative history of the 1980 minimum insurance levels. Part of that history is that minimum levels were set to ”assure the public safety is not jeopardized”. Another part of that history was setting insurance minimums to achieve a level ”sufficient to require on site inspection by the insurance company with minimums to be updated regularly.”
  • It is basic economics that all prices must eventually be adjusted for inflation. The time has passed to adjust the minimum insurance limits for inflation.

Secondly, I would like to address the concern that many trucking companies–particularly the smaller ones–keep bringing up. They are convinced that if the minimum level is raised, their premiums will skyrocket and consequently put them out of business.

On April 17, 2014, OOIDA, which is the Owner-Operator Independent Drivers Association http://www.ooida.com/,  wrote about this in a press release (http://www.ooida.com/MediaCenter/PressReleases/pressrelease.asp?prid=344 ):

FMCSA acknowledges that more than 99 percent of commercial vehicle accidents are readily covered under current requirements and that they have not done an assessment of the financial impact that increased requirements would have on small businesses. 

“Even though the agency’s report confirms that fewer than one percent of all truck-involved accidents result in injuries or property damage that exceed current insurance requirements, it seems pretty clear they plan to raise those requirements anyway,” said Todd Spencer, executive vice president. 

OOIDA contends that an increase in insurance would be a death nail for the small businesses that comprise over 90 percent of the trucking industry.

In response to OOIDA’s comment about “fewer than one percent,” our son Peter made this observation prior to our meeting with FMCSA on May 5, 2014,

The 1% issue is at best a red herring. Refusing to raise a limit because such a small percentage reach the limit only indicates that the increase in cost should be minimal. It can’t be both ways, either this increase should raise the cost of doing business or the effect should be minimal.

This isn’t life insurance where all the money is always paid out. Nor is this homeowner’s insurance in which you have a set amount of house that can be destroyed. This is liability insurance in which the amount paid out is based on the amount of damage being done. If such a small percentage of claims reaches the limit, then greedy lawyers, increased costs, and mythical “windfall” payments are all proven absurd or irrelevant. 

What we actually have here is discrimination against the minority. “You are so small a portion of the people we harm we are not obliged to deal with you fairly.” Under such logic, they might as well suggest that they shouldn’t be compelled to have insurance at all.

Furthermore, not everyone in the trucking industry would agree with OOIDA. We noted a Public Comment on December 3, 2014, by Brian Taylor as a spokesperson for a trucking company ( http://www.regulations.gov/#!documentDetail;D=FMCSA-2014-0211-0057 ):

We are a 23 truck fleet and carry 25 million in liability insurance. We carry that much to protect not only us but our customers. The argument that only 1 % of the claims exceed the current threshold for insurance makes no sense. You carry insurance to cover you no matter what happens. 1 % exposure is too much. The fact that it seldom happens makes the coverage cheap. The actuaries price according to probability. I don’t believe that this coverage will be cost prohibitive unless the carrier has a dismal safety rating in which case they shouldn’t be in business. When carriers don’t carry enough coverage the expose responsible carriers, shippers and the general public. We need responsible carriers, pricing their services correctly to cover all costs and excepting responsibility for the liability created by their business. Skirting this liability and charging for services is deceptive to shippers and puts the public or state at financial risk in the form of a claim that is part of a service they get no remuneration for. When you provide a service, charge fees and profit you must also be responsible financially which means carrying adequate insurance.

I want to say a few additional things, in response to trucking industry concerns about a raise in premiums.

In preparing to travel to Washington,  DC, on May 5, 2014, to present over 11,000 AnnaLeah & Mary Stand Up For Truck Safety Petitions to DOT, I wanted to have accurate information to be able to intelligently discuss this issue and our concerns with DOT administrative officials. As a result, I found out some interesting information by making phone calls to insurance companies.

It is very difficult to get information on trucking insurance rates unless you are actually applying. And the information which I got included this (from my email correspondence to family members where I recorded my phone calls in April & May 2014):

  • I could not get anything from Travelers about internal company information. She told me that I could submit a request for information in writing to “Procurement” with my company name, research I am doing, reasons for wanting the information and general questions. They will respond–even if (probably) only to say  that they cannot give me any information.
  • Also, one of the first things which I found out was that Geico transfers calls requesting information about trucking insurance to OOIDA agents! I did not finish that  call.

I was suddenly enlightened to find out that OOIDA is actually–among other things– a large, for-profit insurer of owner-operator truck drivers. That set off a lot of red flags in my mind. How much control do they actually have over the premiums which most independent truck drivers end up paying? http://www.ooidatruckinsurance.com/

Aside from that, many of the truck drivers/companies which I see making comments complain about how the premiums will skyrocket. But on what are they basing that opinion?

John Lannen, executive director of the Truck Safety Coalition, has shared background information with us which he has gathered from numerous sources, presentations, and conversations regarding the economics of additional insurance coverage for motor carriers.  It turns out that the first million dollars’ worth of  trucking insurance is the most expensive and each incremental amount is cheaper.  Additional points include:

–$1,000,000 in carrier liability coverage per unit can range from $4,500  – $8,000.  The FMCSA used an estimate of $5,000 per unit for the first $1M in their study.

– In today’s marketplace, the second million is quite a bit more affordable, even for small fleets.  A cost estimate for an additional $1M coverage (to raise the limit to $2M total) is $1,000 to $1,500 for the second million per unit annually.

– For the first $1M, some small motor carriers can gain access to a group purchasing model if they are closely aligned to a large motor carrier. 

– There are both national insurance companies and regional insurance companies focused on this market.  The national carriers are developing more sophisticated underwriting models that consider tens of underwriting characteristics as well as regional pricing competition.

– Estimates for the cost for the third additional million (3 million total)  are much cheaper than the second million, which was considerably cheaper than the first. As the risk of a payout goes down, so does the cost of additional coverage.  

If it is so hard to get information on the question of how much the premiums would actually increase if the minimum liability is raised, then on what are these statements based which are made by the people who claim it will put them out of business?

It is my understanding from FMCSA, in our meeting with them on May 5, 2014, that even they have a hard time getting that information from insurance companies and that the rule-making process would give them authority to get that kind of information from insurance companies in order to be able to make a fully-informed policy decision. I look forward to seeing what they find out.

In regard to the issue of “will it put them out of business?”. . . I hope that responsible, accountable, safety-minded companies with the best interests at heart–of both their truck drivers and the other travelers on the road–would have good records and have decisions and actions at all levels which would withstand the impact of a change which has been needed for some time. If not, then perhaps it is better for them to not be in business any longer.

Besides which, if small trucking companies are under-insured, then they might be taking the chance of losing everything if involved in a catastrophic accident.

There is another thing which I wanted to mention and that is the concern about frivolous lawsuits. Exactly upon what are people basing their claim that there are too many frivolous lawsuits related to truck crashes? If there is only a totaled car, do they really think that there will be an attempt to get the full available amount? And when there are fatalities involved, then there is a reason why laws were changed to allow wrongful death suits.

Fatality is a word that can too easily cover up the unimaginable, tragic grief which family members are left with after the death of a loved one in a truck crash. It is true that no settlement amount will ever assuage (appease, mollify, soothe) the terrible pain and gaping hole left by an unexpected loss. But I encourage you to put yourself in the shoes of a bereaved family and imagine that this is what wrongful death laws are about–above and beyond covering the immediate expenses incurred from the crash.

http://en.wikipedia.org/wiki/Wrongful_death_claim

http://en.wikipedia.org/wiki/Solatium Solatium (plural solatia) is a form of compensation for emotional rather than physical or financial harm.

http://en.wikipedia.org/wiki/Fatal_Accidents_Act_1846

  • The Fatal Accidents Act 1846 (9 & 10 Vict. c.93), commonly known as Lord Campbell’s Act, was an Act of the Parliament of the United Kingdom, that, for the first time in England and Wales, allowed relatives of people killed by the wrongdoing of others to recover damages.
  • Under the common law of England and Wales, the death of a person causes solely emotional and pure economic loss to their relatives. In general, damages cannot be recovered for either type of damage, only for physical damage to the claimant or their property. This was the rule declared by the court in Baker v. Bolton (1808).[1][2][3] Scottishlaw was different in that the court could grant a solatium in acknowledgment of the family’s grief.[4][5]
  • Thus, if a person was injured through a tort, the wrongdoer would be liable for causing injury. If the person were killed, there would be no liability. Perversely, the wrongdoer had a financial interest in killing, rather than injuring, a victim.

In fact, many times I have thought of the fact that there were more actual expenses for our daughter who required hospitalization before her death than for our daughter who died at the scene of the crash–her life abruptly ended. Without the ability to claim a wrongful death, what would we be left with besides compensation for her burial expenses? (And even saying that is likely to be misunderstood.) Surely her life was of more value than that.

11,000+ signatures from the AnnaLeah & Mary Stand Up For Truck Safety Petition have been added to the Public Comments on this rulemaking: http://www.regulations.gov/#!documentDetail;D=FMCSA-2014-0211-0111

Note: If you have already signed the AnnaLeah & Mary Petition, you can also individually sign the Federal Register. I have verified this with the administrative official at FMCSA who posted our petition to the Public Comments. Please lend your support by clicking on this link and then clicking on Submit a Formal Comment in order to post your comment:

https://www.federalregister.gov/articles/2014/11/28/2014-28076/financial-responsibility-for-motor-carriers-freight-forwarders-and-brokers

 The deadline for submitting Public Comments is FEBRUARY 26.

Some are opposing the proposed rule-making, claiming it is all about lawyers who want more money for themselves and disregarding the impact on lives and families devastated in truck crashes.

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