177.804(a) - Citing of Catchall Violations
| Entry Date | August 16, 2021 |
|---|---|
| Issue Number | 21-041-HAZ |
| Name | Rex |
| Agency | Railsback |
| Address | 312 Lawrence AveLawrence, KS, 66049United StatesMap It (opens in a new tab) |
| Phone | 9135683001 |
| [email protected] | |
| Committee | Hazardous Materials Committee |
| Status | Closed |
| Summary of Issue | enforcement citing "catchall" violations, when also citing for individual violations, e.g., citing 177.804(a), to an HM carrier, who also has a safety regulation violation. |
| Justification or Need | Due to the ever increasing, behind the scenes, punitive actions associated with roadside inspection violations, a policy and/or request to FMCSA, for any type of stacking or catchall violations, associated with another violation, on the same report, needs to be declared as stacking and/or the SMS point value placed at 0. |
| Request for Action | Put into policy a prohibition for stacking and submit letter to FMCSA to either remove catch all cites from the SMS list or assign a 0 point value for such cites. |