CSXI Roadability Compliance Status Update Jun 11, 2010 Ron Bethmann Vernon Prevatt

Roadability Compliance Supporting our Industry Partners To assist the Trucking Community and Intermodal Equipment Providers with compliance to the new FMCSA Roadability Rules, CSXI will establish new policies and procedures at all CSX Intermodal Terminals. The new policies and procedures are expected to: - make compliance easy and productive; - enhance safety and quality of equipment; - improve productivity for terminal operators, drivers and M&R vendors.

Roadability Compliance Timeline 17 June 2009: Final rule effective date 17 Dec 2009: IEP established systematic inspection, repair and maintenance program, and record keeping system IEP registered for USDOT Number Motor carriers/ Drivers required to report DVIR/DVER (deferred 6 months by FMCSA) 1 July 2010: Restart of requirement for Driver to reporting defects at in gate 17 Dec 2010 IEP mark IME with USDOT identification number Full implementation of final rule

Roadability Compliance New Requirements Drivers/ MC must report defects to IEP … at the time the equipment is returned to the provider… (390.42b). Must report defects on any of nine identified components as a minimum If there are NO defects, the driver must report No defects IEP/IME Owners must establish system to receive driver reports. IEP/IME Owners must establish system to inspect, repair and maintain IME equipment (Chassis) IEP must ensure roadability component defects are corrected prior to returning equipment to service on public highways. IEP must ensure all IME interchanged is safe and in proper operating condition. IEP must refrain from placing defective equipment in service on public highways. Before operating equipment over the road, Drivers accepting the equipment MUST inspect IME and be satisfied equipment is in safe working order. Drivers MUST NOT knowingly accept or use defective equipment, remove from facility or place in service on public highways.

Roadability Components Roadability Component Defect (RCD) – Any component that affects the safe operation of the equipment or could result in mechanical breakdown of equipment. Roadability Components include: (01) Brakes- Brakes (02) Lights – Lighting devices, lamps, markers, and conspicuity marking material (03) Wheel – Wheels, rims, lugs, tires (04) Air line – Air line connections, hoses, and couplers (05) Coupling – King pin upper coupling device (06) Frame – rail or support frames (07) Bolster – Tie down bolsters (08) Fastener – Locking pins, clevises, clamps, or hooks (09) Slider – Sliders or sliding frame lock (00) No defect

Roadability Compliance Supporting our Industry Partners CSXI will implement the following policies and procedures at all CSX Intermodal Terminals in Establish new gate procedures to make it easy for Drivers to comply with Roadability Component Defect (RCD) reporting requirements. Provide driver reports to IANA for distribution to Intermodal Equipment (IME) Providers and Owners and generation of official DVIR. Improve Maintenance and Repair procedures to help IME providers and M&R Vendors ensure equipment is removed from service and repaired before returning to operational use. Automatically bad order any driver reported RCD at the in gate. Reduce opportunities for loads to be placed on equipment with RCD. Ensure driver delays are minimized when problems are discovered on driver pre-trip inspection. Improved M&R availability or established flip criteria

Roadability Compliance Supporting our Industry Partners CSXI onsite terminal M&R vendors are qualified to repair all roadability items for equipment owners. All equipment owners need to establish repair relationships with CSXI approved terminal M&R vendors to repair roadability items. The nine roadability component defects and any other safety defects need to be repaired by the on site terminal M&R vendor. Any unit bad ordered for one of the nine roadability components will not be allowed to depart terminal. CSXI will allow terminal M&R Vendors access to ITOPS to enter equipment status information. (Pending system upgrade ECD August 2010) Chassis with RCD can only be removed from terminal by tow truck or flat bed. CSX is not an intermodal equipment provider (IEP). CSX is not an agent for any IEP or motor carrier. CSX does not own any intermodal equipment. CSX does not repair any intermodal equipment.

Roadability Compliance DVIR / DVER Driver Vehicle Inspection Report (DVIR) – a report submitted by a driver to report a roadability component defect (RCD) to the intermodal equipment provider (IEP). Includes report of no defects if applicable. Driver Vehicle Examination Report (DVER) – a result of a citation from a government agency, a report by the driver/ motor carrier to record results of motor vehicle and IME inspections conducted by authorized FMCSA personnel.

Roadability Compliance - In Gate Process and Reporting DVIR Data to IEP/ Owners 1.CSXI modified ITOPS to electronically capture Driver reported reportable component defects at the in gate. (see flow chart for details) 2.CSXI ITOPS provides electronic reporting data and specific defect data to IANA for distribution to IEP/ equipment owners. (OCEMA equipment not included) Electronic format - EDI IANA will use various databases (GIER, UIIA, and IDD) to secure information required to complete the equipment report. 4.IANA will provide DVIR electronically to IEP/ Owners. Electronic format EDI IEPs will retain DVIR and coordinate with M&R vendor for repair records if audited by FMCSA.

CSXI procedures are same as IANA recommended practices except for the following: IANA recommended procedure B.3: Facility operator furnishes copy of Drivers Vehicle Inspection Report (DVIR) to driver reflecting Roadability Component Defect. A No Roadability Component Defect will also be furnished to driver. (only if required by Regulation) CSXI procedure: CSXI will provide driver with interchange receipt (J1) that includes drivers roadability response (yes/no) and any damage reported or identified during equipment inspection at in gate. The J1 does not contain all the data elements required for an official DVIR, and the facility operator is not required to provide a DVIR. The DVIR will be provided by IANA to the IEP/ owner. IANA recommended practice variance

Roadability Compliance DRS Process for OCEMA IME 1.OCEMA will collect DVIR data on owned equipment from drivers prior to interchange through DRS. 2.OCEMA will notify appropriate M&R vendors at interchange terminal to place unit in bad order status and ensure equipment is repaired prior to returning to operational service. 3.When OCEMA drivers report defects at in gate, CSXI will bad order the equipment, and M&R vendor will repair unit. 4.If OCEMA driver chooses not to report equipment status, the report will indicate a NO answer on the J1. 5.OCEMA equipment inspection information received at the in gate will be used for local repair and hold status only. CSXI will parse OCEMA equipment from in gate RCD data sent to IANA in EDI 322.

1.No CSXI ITOPS system changes required 2.Motor Carrier/ Truck Ops/ driver cited for RCD by local, state or federal agency 3.Driver required to furnish DVER to his Motor Carrier/ Truck Ops 4.Motor Carrier/ Truck Ops must forward DVER to IEP within 24 hours 5.IEP notify M&R vendor or terminal personnel to place unit in bad order status 6.IEP must ensure M&R vendor repairs unit before placed back in service 7.IEP must ensure repair documented on DVER – vendor signature required 8.IEP must provide completed DVER and evidence of repair to issuing agency within 15 days of citation. 9.If cited prior to interchange, driver should report RCD at in-gate CSXI will follow in gate DVIR process placing unit in bad order CSXI will NOT process DVER Roadability Compliance DVER Handling Process

1.No change to current gate procedures. 2.CSXI does NOT conduct any out gate equipment inspections. 3.Driver is required to conduct thorough pre-trip inspection to ensure equipment free of RCDs. 4.If driver identifies RCD during pre-trip inspection: Driver take unit to M&R vendor in roadability maintenance area for repair If unit is not movable, driver contact M&R vendor or terminal personnel for assistance If after M&R vendor is not available or excessive delay, driver contact terminal personnel to arrange for a flip 5.If driver arrives at out gate and reports RCD Gate personnel direct driver to roadability for repair If M&R vendor not available or repair time is excessive, gate personnel arrange for flip and place chassis in bad order (customer options) Roadability Compliance CSXI Terminal Out Gate Process