Latest Industry News Brief Courtesy of PMTA

July 2022

ATA Safety Management Council Honors Industry’s Commitment to Safety

Orlando, FL…  American Trucking Associations’ Safety Management Council honored a number of fleets and industry leaders for their commitment to safety on the highway and in the workplace.

“Trucking is a safety-first industry, and the professionals being recognized today have made it their mission to build strong safety practices into the culture of their companies,” said ATA President and CEO Chris Spear. Through their dedication to safety, they provide a tremendous example to our industry, and I congratulate them on receiving these important honors.

The winners were recognized at ATA’s 2022 Safety, Security & Human Resources National Conference & Exhibition.

They include:

* The ATA President’s Trophy, sponsored by Great West Casualty Company

o Under 25 Million Miles: Fortune Transportation, Windom, Minnesota;

o 25-100 Million Miles: A. Duie Pyle Inc., West Chester, Pennsylvania;

o Over 100 Million Miles: FedEx Freight, Harrison, Arkansas

* ATA National Safety Director, sponsored by Great West Casualty Company: Jeff Mercadante, vice president of safety, Pitt Ohio;

* ATA National Driver of the Year, sponsored by EROAD: Robert Rossi, FTC Transportation Inc.

* ATA Excellence in Safety, sponsored by Great West Casualty Company: Colorado Motor Carriers Association.

“SMC is pleased to honor this year’s winners – all of whom play an important role in building our industry’s safety culture,” said SMC Executive Director Jacob Pierce. “Motor Carriers, safety directors, drivers and our state association executives do critical work in promoting and improving safety across our industry and we thank them all for their commitment.”

ATA Truck Tonnage Index Fell 2% in April -Index 1.8% Above April 2021

Arlington, VA…  American Trucking Associations’ advanced seasonally adjusted (SA) For-Hire Truck Tonnage Index decreased 2% in April after rising 1.8% in March. In April, the index equaled 115.8 (2015=100) versus 118.2 in March.

“After eight straight gains totaling 6.9%, for-hire tonnage finally slid back in April. Despite being the largest sequential drop since August 2020, the index was still above where it started in 2022 and a year earlier,” said ATA Chief Economist Bob Costello. 

“It is important to note that ATA’s for-hire tonnage data is dominated by contract freight with minimal amounts of spot market loads. The spot market has softened more than for-hire contract freight, as the market transitions back to pre-pandemic shares of contract versus spot market," Costello said.

"While I expect contract freight to outperform spot market freight, the rate of growth will be slower than in 2021. Most contract carriers are still struggling with maintaining enough capacity, both equipment and drivers,” he said.

March’s increase was revised down from our April 19 press release.

Compared with April 2021, the SA index increased 1.8%, which was the eighth straight year-over-year gain. In March, the index was up 3.3% from a year earlier. In 2022, year-to-date and compared with same period in 2021, tonnage was up 2.3%. 

The not seasonally adjusted index, which represents the change in tonnage actually hauled by fleets before any seasonal adjustment, equaled 114.1 in April, 7.4% below the March level (123.2). In calculating the index, 100 represents 2015. ATA’s For-Hire Truck Tonnage Index is dominated by contract freight as opposed to spot market freight. 

Trucking serves as a barometer of the U.S. economy, representing 72.5% of tonnage carried by all modes of domestic freight transportation, including manufactured and retail goods. Trucks hauled 10.23 billion tons of freight in 2020. Motor carriers collected $732.3 billion, or 80.4% of total revenue earned by all transport modes. 

ATA calculates the tonnage index based on surveys from its membership and has been doing so since the 1970s. This is a preliminary figure and subject to change in the final report issued around the fifth day of each month. The report includes month-to-month and year-over-year results, relevant economic comparisons, and key financial indicators. 

Bill to Streamline for Security Credentialing Process for Truckers Receives Strong Praise from Industry

Arlington, VA… The American Trucking Associations lauded the introduction of a bill in the U.S. Senate today that would streamline the credentialing process for millions of professional truck drivers.

The Transportation Security Administration Security Threat Assessment Application Modernization Act, introduced by Senators Roger Wicker (R-Mississippi) and Deb Fischer (R-Nebraska), would enable drivers to use a single valid background check from TSA when applying for multiple credentials, such as a Transportation Worker Identification Credential, Hazardous Materials Endorsement and PreCheck.

“This commonsense legislation will ease the burden on many hardworking men and women and allow them to focus on navigating the nation’s highways instead of government bureaucracies,” said ATA President and CEO Chris Spear. “Duplicative fees and redundant background checks are placing unnecessary costs – both financial and time – on truckers at a time when our economy is short more than 80,000 drivers. We thank Senators Wicker and Fischer for their leadership and urge the Senate to pass this much-needed legislation.”

Earlier this year, ATA endorsed this legislation’s companion bill in the House.

In a letter to the Senate, ATA Senior Vice President Edwin Gilroy called the bill “a tangible step toward a more resilient workforce and American economy.”

“This legislation will result in significant financial and time savings for truck drivers. It also makes well-paying careers in the trucking industry more accessible for qualified drivers who are otherwise deterred by financial and/or logistical barriers to entry,” Gilroy wrote.

“This legislation would meaningfully ease the burden of duplicative and redundant background checks on many thousands of hard-working, patriotic Americans – allowing them to focus on delivering goods and moving our economy forward. I want to commend Senators Wicker and Fischer for their commitment to the trucking industry and to improving the lives of truck drivers,” said Mississippi Trucking Association President Hal Miller.

“We are very grateful that Senators Fischer and Wicker have listened to pleas for help raised by the trucking industry. Across Nebraska and the nation, truckers are working every available hour to address the crisis in America’s supply chain. But we are often handicapped by red tape, particularly when it comes to obtaining the proper clearances from the TSA,” said Nebraska Trucking Association President Kent Grisham. “By sponsoring this Act, the Senators are taking a critical step toward removing that handicap, allowing us to get vetted drivers in the trucks sooner, and getting much need freight moving safely and efficiently.”

Truckers Hail Passage of Ocean Shipping Reform Act

Washington , DC…  American Trucking Associations leaders hailed passage of the Ocean Shipping Reform Act of 2022, and urged President Biden to quickly sign the bill aimed at improving efficiency in our supply chain.

“This day has been a long time coming,” said ATA President and CEO Chris Spear. “This bill provides important tools to address unjustified and illegal fees collected from American truckers by the ocean shipping cartel – fees that have contributed to the shipping lines raking in $150 billion in profits just last year. Those fees hurt American motor carriers and consumers – helping to drive record inflation. We thank Congress for passing this bipartisan solution and urge President Biden to quickly sign it into law.”

The House passed the bill 369-42 on June 13th,  following passage in the Senate by voice vote on March 31.

“This is the first significant change to ocean shipping regulations in more than two decades – a period of time when the industry has been shaped into a cartel of 10 foreign-owned companies who have exercised a tremendous amount of power over American truckers and consumers,” said ATA Intermodal Motor Carrier Conference Director Jonathan Eisen. “Thanks to this bipartisan legislation, those carriers will no longer be able to charge truckers exorbitant and illegal detention and demurrage fees, increasing efficiency and reducing costs across the supply chain.”

President Biden, USDOT Announce New Guidance and $6.4 Billion to Help States Reduce Carbon Emissions Under the Bipartisan Infrastructure Law

WASHINGTON, DC…  The U.S. Department of Transportation’s Federal Highway Administration announced a new program that unlocks $6.4 billion in formula funding for states and localities over five years. The new Carbon Reduction Program (CRP), created under the President’s Bipartisan Infrastructure Law, will help states develop carbon reduction strategies and address the climate crisis facing our nation. States can use the funds in CRP to expand transportation options for American families that can help them save money on gas.

“As the sector generating the most carbon emissions in the U.S. economy, transportation must play a leading role in solving the climate crisis,” said U.S. Transportation Secretary Pete Buttigieg. “The Carbon Reduction Program will help reduce pollution from transportation and move us closer to the President’s ambitious goal of cutting emissions in half by 2030.”

The Carbon Reduction Program will fund a wide range of projects designed to reduce carbon dioxide emissions from on-road highway sources — from installing infrastructure to support the electrification of freight vehicles or personal cars, to constructing Bus Rapid Transit corridors, to facilitating micro-mobility and biking. Under the CRP, states must also develop carbon reduction strategies in consultation with Metropolitan Planning Organizations to identify projects and strategies tailored to reduce carbon dioxide emissions in their states, although states and localities may begin using the CRP funds even before plans are developed and reviewed.

“This new program provides states and local agencies in both urban and rural areas the flexibility and funding needed to reduce emissions and build a more sustainable transportation network that will benefit all travelers,” said Deputy Federal Highway Administrator Stephanie Pollack. “The Bipartisan Infrastructure Law makes transformative investments in our nation’s transportation infrastructure, and this is one of the key programs that will help address the climate crisis.”

Eligible projects include on- and off-road trail facilities for pedestrians, bicyclists and other nonmotorized forms of transportation and projects that support the deployment of alternative fuel vehicles. These types of projects, which are determined at the state and local level but could be supported with federal funding, include zero emission vehicles and facilities, projects that support congestion pricing and travel demand strategies; truck stop and port electrification systems to reduce the environmental impacts of freight movement and carbon dioxide emissions at port facilities; and public transportation projects such as the construction of bus rapid transit corridors or dedicated bus lanes. Micro-mobility and electric bike projects, including charging infrastructure, may also be eligible.

FHWA previously announced state-by-state totals, which included funding for the CRP. In total, the U.S. Department of Transportation has sent $52.5 billion to states for Fiscal Year 2022 for Federal-aid Highway Program apportionments, which is determined by a formula set by Congress.

For more information about the new Carbon Reduction Program and guidance released, please visit FHWA’s web site and fact sheet.

PA Turnpike Adds New Payment Network for Customers Wishing to Use Cash

HARRISBURG, PA… The PA Turnpike Commission has partnered with the KUBRA Cash Payment Network, www.KUBRA.com, to provide customers the ability to use cash to pay their Toll By Plate invoices or add funds to their E-ZPass accounts at one of more than 70,000 retail locations within KUBRA’s nationwide network.

Customers who want to pay in cash can select the “pay” option when accessing their account online or via the PA TOLL PAY app. A list of participating retailers near the customer’s location will display. The customer must generate a pay slip — which includes a $1.50 service fee — before stopping at one of the retail locations to make a PA Turnpike toll payment in cash.

“We are pleased to offer our customers yet another way to pay. This new KUBRA option provides anyone who wishes to travel the PA Turnpike a way to pay tolls with cash at a nearby retailer,” explains PA Turnpike CEO Mark Compton. “Many travelers already visit these local drug, convenience, or discount stores, and now they can pay a PA Toll By Plate invoice or replenish their E-ZPass accounts while there.”

Adding this payment option will help customers who don’t have a bank account or don’t want to tie up funds in an E-ZPass account until they travel. 

The PA Turnpike Commission’s partnership with the KUBRA Cash Payment Network allows Turnpike customers to go to any participating retailers in their network. Most of the retailers in the KUBRA network are in Pennsylvania, but PA Turnpike customers can pay at any location throughout the U.S. The retailers include:

   7-Eleven®                                     

   CVS®                                 

   Dollar General®                                       

   Duane Reade™ 

   Family Dollar® 

   GoMart, Inc.®

   Kum & Go® 

   Kwik Trip™

   Pilot Travel Center®         

   Royal Farms®

   Rutter’s®

   Sheetz®

   Speedway®

   Stop & Go®

   Stripes®

   TravelCenters of America®

   Walgreens®

                    

The PA Turnpike last year launched its PA TOLL PAY app that allows Toll By Plate customers to pay invoices. With the app, Toll By Plate customers can also sign up for AutoPay to get a 15% discount on their invoice. The PA Toll Pay App makes it easy for both E-ZPass and Toll By Plate customers to update and manage their accounts and review account activity.

“We will continue to look to expand options to make it more convenient for customers to pay,” Compton said. “We are exploring other payment methods that will allow travelers to pay virtually based on their preferences.”

To learn more about the unique and flexible KUBRA payment program and find retailer updates, visit paturnpike.com/pay-a-bill.

New StatsCan Data Highlights Demographic Crisis Underpinning Truck Driver Shortage

TORONTO… Canada faces record retirements from an aging labour force at a time of record high job vacancies and historically low unemployment, reports Stats Canada. 

 No industry is feeling the complications of this demographic crisis more than the trucking industry, which, already in the midst of a severe labour shortage, has the oldest workforce in Canada, says the Canadian Trucking Alliance. 

 The working-age population of persons aged 15 to 64, who produce the bulk of goods and services in the Canadian economy, has reached a turning point. Statscan reports the number of seniors aged 65 and older grew six times faster than children 0-14 – another indication Canada’s population is exiting the workforce much faster than those about to enter it. More than 1 in 5 (21.8%) persons of working age in the general economy are aged 55 to 64. The ratio of people nearing retirement never been so high.

 The situation is even more amplified in trucking, where at least 32% of truck drivers in Canada are 55 years or older compared to 21.8% of the entire Canadian labour force. At least 6% of truck drivers are 65 and older. 

 The trucking and logistics sector employs nearly 4 percent of Canadians, but with an economic multiplier effect much larger than most sectors, the pressures weighing down trucking’s current labour pool might be the single greatest wildcard in the path to full economic recovery, says CTA president Stephen Laskowski. 

 “While demographics, industry conditions and policy issues have all contributed to retirements and exits, trucking has at the same time continued to see a declining share of young people entering the industry over the past few decades,” says CTA president Stephen Laskowski. “Combined, these forces are leading to a demographic cliff in one of the economy’s most important sectors. This is fundamentally unsustainable and a huge red flag for the Canadian economy and North American supply chain.” 

Undoubtably, the impact of the worsening driver shortage is reverberating throughout the supply chain and contributing to rising prices and inflation. 

“The is a direct connection,” says Laskowski. “The industry has been experiencing this for some time and now and, clearly, all Canadians are feeling it as well.” 

 The Canadian trucking industry has over 23,000 truck driver job vacancies right now and that hole is expected to sink deeper very soon. By the end of 2023, the truck driver supply deficit has been estimated to reach over 55,000 drivers. While there are undoubtably many industry sectors that need qualified labour, the vacancy rate in truck transportation on a percentage basis is much higher than that of the general economy and virtually all other sectors. 

 Many provinces have started to take a serious look at the relationship between training and the driver shortage and supply chain fragility. CTA is calling for federal and provincial programs designed to support truck driver training. The Alliance has submitted several recommendations to the federal government to help the trucking industry meet the demands of the supply chain, including: 

* The Government of Canada should approve Trucking HR Canada’s proposal to the Sectoral Workforce Solutions Program (SWSP). This proposal focuses on shorter term support to help address barriers for new entrants entering the trucking industry;

* CTA would like to see widely available, and long-term new training funding support established for trucking, like forgivable grants to cover entry level training costs;

* An institutionalized wage subsidy program to support the onboarding/training of new entrants into the industry. This is needed to support post-licensing on-the-job training;

* CTA would like to see the Temporary Foreign Worker Program (TFWP) application process streamlined, a recognized trusted employer program finalized, and a seamless path to permanent residency created for our sector;

 * Establish training tax credits for carriers to support investments in their training programs and onboarding new drivers;

 * Establish a national Driver Inc. enforcement campaign to ensure current drivers are not working in the underground economy and that their rights are protected;

 * Establishing a federal-provincial heavy truck rest stop infrastructure program to support our commercial drivers.

FHWA Highlights Actions to Tackle Climate Change with New Programs and Historic Funding Under President Biden’s Bipartisan Infrastructure Law

WASHINGTON … The U.S. Department of Transportation’s Federal Highway Administration (FHWA) today highlighted a variety of actions the agency is taking to protect the environment and combat climate change as part of a suite of announcements to celebrate Earth Day 2022. These include new programs and funding under President Biden’s Bipartisan Infrastructure Law that will lower transportation sector emissions and accelerate the deployment of clean technologies.  

 “Thanks to President Biden’s Bipartisan Infrastructure Law, FHWA can offer states more funding and flexibility to address the climate crisis to benefit future generations,” Deputy Federal Highway Administrator Stephanie Pollack said. “These programs will help communities invest in clean transportation projects, including electric vehicle (EV) charging, transit, and walking and biking infrastructure.”

Leading up to Earth Day 2022—

 *       FHWA kicked off the week by announcing the Carbon Reduction Program that will provide $6.4 billion in formula funding to states over the next five years under the Bipartisan Infrastructure Law.

* This week FHWA also issued an updated brochure – Federal Funding is Available for Electric Vehicle Charging Infrastructure on the National Highway System – which 

outlines how to access funding opportunities for charging infrastructure.

* In addition, this week, as part of a Department-wide effort to challenge transportation agencies and others to find innovative ways to reduce transportation sector greenhouse gas emissions, FHWA launched its own highway-specific “climate challenge” on Quantifying Emissions of Sustainable Pavements. This challenge presents a unique opportunity to improve the sustainability of pavement structures and work towards goals for net-zero emissions.

* In partnership with the Federal Transit Administration, a joint Flex Funding Website launched this week to help states utilize flex funding and to increase access to transit in order to encourage public transportation projects that reduce single-occupancy vehicle travel and associated air pollution on congested highways.

Over the past year U.S. DOT has taken a number of steps to work towards the President’s goals of building out a nationwide network of EV chargers and making sure that 50% of new cars sold by 2030 are electric. 

 * In April 2021, FHWA issued guidance to states clarifying that activities including solar panels and EV charging can be acceptable uses in the right-of-way. 

* In December 2021, U.S. DOT joined the U.S. Department of Energy in December in signing a memorandum of understanding to create a Joint Office of Energy and Transportation to support the deployment of a national electric vehicle charging network.

* In February of this year, USDOT issued the Rural EV Toolkit to help rural communities build out electric vehicle charging infrastructure. 

* Also in February of this year, President Biden, USDOT and USDOE announced the availability of $5 billion  over five years to help states build out a national EV charging network, with funding from the Bipartisan Infrastructure Law.

 For more information on FHWA resources, please see the Bipartisan Infrastructure Law website.

Feds Confirm Border Vaccine Mandate Remains in Place for Truck Drivers; Domestic Mandate for Federally Regulated Sectors Suspended

TORONTO, CANADA…. Government of Canada announced on June 14th that the mandatory vaccination mandate at the land border remains in place for all travelers entering the country, including truck drivers crossing the border. 

 Although there are no changes to land border polices regarding the vaccine mandate, the federal government did announce the suspension of mandatory vaccination requirements for most domestic and international air travellers to assist with delays related to air travel.  

 The border vaccination mandate has been in place for both Canada and the U.S. since January of 2022. The Canadian Trucking Alliance (CTA) is reminding members that any future removal of the land border vaccination mandate remains a bilateral decision, and the Alliance continues to work with officials on both sides of the border on this policy.

 Mandatory vaccination requirements for entry into Canada by foreign nationals also remains unchanged. Foreign nationals who are not fully vaccinated continue to be prohibited entry into Canada.

 The Government of Canada also announced that, as of June 20, 2022, it will be suspending the mandatory vaccination requirement for employers in the federally regulated air, rail, and marine sectors. Furthermore, the Government of Canada is no longer moving forward with consultations and proposed regulations on mandatory vaccination requirements for all federally regulated workplaces. 

 The federally regulated trucking sector was granted exempt status from the domestic mandate in the summer of 2021. 

 The Government of Canada emphasized “it would continue to evaluate measures and will not hesitate to make adjustments based on the latest public health advice and science to keep Canadians and the transportation system safe and secure.”

 CTA will continue to update members on any changes regarding entry requirements or vaccination mandates as they are announced.

CVSA Launches Revitalized Emergency Declarations Site

Greenbelt, MD…  – The Commercial Vehicle Safety Alliance (CVSA), working with the U.S. Department of Transportation’s Federal Highway Administration and the American Association of State Highway and Transportation Officials, has updated, improved and re-released its emergency declarations website. 

  In addition to the reliable, up-to-date content previously available on the site, the emergency declarations website now also provides: 

* Information on changes to allowable weights through a standard set of pertinent information, which includes contact information for each state’s overweight permitting office 

* An interactive map of declarations throughout Canada, Mexico and the U.S. 

* The ability to subscribe to notices of new declarations

* Information on the issuer of the relief, the type of relief granted, and emergency declarations’ beginning and end dates 

* Comprehensive exemption details, including all relevant information for vehicle permits for size, overweight restrictions on interstates, waivers for overweight restrictions on state roads, and marking and lighting relief

* Contact information for the jurisdiction’s issuer

Previously, the emergency declarations website focused on emergency relief of the Federal Motor Carrier Safety Regulations Title 49 Code of Federal Regulations § 390-399 provided to motor carriers through the states or the Federal Motor Carrier Safety Administration. CVSA has expanded the site’s offerings and capabilities and improved the user experience.

During an emergency, moving relief supplies efficiently to an affected area may require shippers to route through multiple jurisdictions. To facilitate speedy delivery of such supplies, jurisdictions may use emergency declarations to temporarily alter certain requirements for shippers and motor carriers. There may be multiple sources of information about waivers, amendments, extensions, exemptions, executive orders, etc., as well as changes to allowable vehicle weights issued during emergencies, which results in confusion among drivers, shippers, motor carriers and state departments of transportation. The emergency declarations website aims to eliminate that confusion by offering one easy-to-access, up-to-date public online repository that the commercial motor vehicle enforcement community and the motor carrier industry may reference at any time.

“Providing necessary regulatory relief during emergencies is crucial to preventing loss of life and preserving critical transportation infrastructure,” said CVSA Executive Director Collin Mooney. “CVSA’s emergency declarations website is a reliable online source for emergency information, resulting in improved movement of critical relief supplies during national, regional and local emergencies.”

CVSA will be offering a webinar on Friday, June 24, about the enhanced CVSA emergency declarations website and its new features.

Check out the CVSA emergency declarations website and bookmark it for quick and easy access to the site whenever you need it. 

Note: If the president should provide a major disaster declaration for any state, that state and any others may choose to issue special permits for trucks carrying divisible loads of emergency relief supplies in excess of federal weight limits to (or hauling debris from) the affected area on the interstate highway system up to the end of the 120-day period of availability of that declaration. Permits are eligible for travel to and through a state for which a current declaration is active from any other state. View presidential declarations.

Brake Safety Week Is Aug. 21-27

  Greenbelt, MD…  The Commercial Vehicle Safety Alliance (CVSA) has announced Aug. 21-27 as the dates for this year’s Brake Safety Week. Brake Safety Week is an annual commercial motor vehicle brake-safety inspection, enforcement and education initiative conducted by law enforcement jurisdictions in Canada, Mexico and the U.S. During Brake Safety Week, inspectors will conduct their usualNorth American Standard Level I and V Inspections and capture and report brake-related data to CVSA. The results will be released in the fall.

  Brake-related violations comprise the largest percentage of all out-of-service vehicle violations cited during roadside inspections, and according to last year’s three-day International Roadcheck data, brake systems and brake adjustment violations accounted for 38.9% of all vehicle out-of-service violations, the most of any category of vehicle violations. To address this, CVSA’s Brake Safety Week seeks to: 

* Identify and remove commercial motor vehicles with critical vehicle inspection violation items identified in the North American Standard Out-of-Service Criteria from roadways.

* Conduct inspections and identify and acknowledge commercial motor vehicles that do not have critical vehicle inspection violations by affixing those vehicles with a CVSA decal.

* Encourage proactive vehicle maintenance in advance of the week.

* Highlight the hard work and commitment to safety by inspectors, drivers and motor carriers.

* Remind drivers and motor carriers about the importance of proper brake maintenance and vehicle pre-trip and post-trip inspections.

* Provide an opportunity for outreach and educational brake-safety efforts by inspectors.

During the brake portion of a vehicle inspection, inspectors will look for missing, non-functioning, loose, contaminated or cracked parts on the brake system, and non-manufactured holes (such as rust holes and holes created by rubbing or friction) and broken springs in the spring brake housing section of the parking brake. They will listen for audible air leaks around brake components and lines, and ensure the air system maintains air pressure between 90-100 psi (620-690 kPa). Inspectors will also check for S-cam flip-over and measure pushrod travel. They will check that slack adjusters are the same length (from center of S-cam to center of clevis pin) and the air chambers on each axle are the same size. They will also inspect required brake-system warning devices, such as ABS malfunction lamp(s) and low air-pressure warning devices. In addition, inspectors will ensure the breakaway system is operable on the trailer, and inspect the tractor protection system, including the bleed-back system on the trailer. 

In addition to reporting total inspections and brake-related out-of-service violations, inspectors will also capture and provide data on brake hose/tubing chafing violations – the focus area for this year's Brake Safety Week. 

“Poorly maintained brake systems can reduce the braking capacity and stopping distance of large trucks and motorcoaches, which poses a serious risk to driver and public safety,” said CVSA President Capt. John Broers with the South Dakota Highway Patrol. “In those split-second emergency situations, the proper functionality of the brake systems on large commercial motor vehicles is crucial.”