Demountable Truck Body System

The Demountable Truck Body System we have manufactured for over 25 years (and has been on US and Canadian Roads for over 50 years) has met some resistance by enforcement agencies in Quebec. We have a fleet of vehicle running with Pepsi-co. The authority has deemed the entire system subframe lift and the container as "payload". Therefore the authority is contending that the "system" does not meet the NSC Standard 10 in section 22. The system being unique does not fall into an exact category since it is NOT an ISO container by use. It is also NOT a roll off container, BUT only by definition since the roll off container definition states that it MUST Tilt to load. The definition in Standard 10 and in US Standard § 393.134 States that extra securement is required only if "not equipped with an integral securement system". Our issues it that our Demountable Truck Body System is safe, has millions of miles of safe use, has an integral locking system, has a lock warning system and has been proven to meet the jurisdictions "payload securement" in the Pepsi Co case. (see attached engineering data) Therefore, we respectfully request including this system into the definition of Roll Off and amending the definition to be tilting or vertical lift.

The Province of Quebec is the only authority in North America who has asked an operator to STOP using this system and treat the entire system as payload. We have Thousands of trucks on the road in North America and Mexico, delivering millions of dollars of goods to businesses and consumers every day. As we move forward in the Province of Quebec, we are being told by the authority that each operator MUST petition with engineering data to get approval. This is a cost of over $10,000 USD per user. We have a major contract pending for a major furniture retailer who wants to use our equipment in Quebec. This issue has been discussed with the National Truck Equipment Association and they also agree the system is more like a roll off than anything else. (see attached)

We respectfully request that you include the demountable truck body system in your definition of Roll Off. Since, in practice both have removable cargo carrying containers. In addition, our system has an integral locking system. Plus, as an added benefit we have a lock warning system in cab to alert the driver that the container is NOT hooked. Even roll-off or hook lift does not have this. Even ISO containers do not have this. Defining our entire system as "payload" does not make sense, since it is a proven container handling system with years of service and millions of miles of safe use.