One of the unintended consequences of the Federal Motor Carrier Safety Administration’s Compliance, Safety, Accountability (CSA) program is that it seems to have linked tank truck carriers and wash racks more closely than ever before. Actions (or inactions) by wash workers definitely impact equipment inspections by enforcement officials.

“We can’t survive without each other,” said Dan Wright, Kenan Advantage Group. “Commercial wash racks have become a critical part of our quality control process in this era of CSA. We need your expertise more than ever before to remain successful in our businesses.”

Wright was a member of a six-person panel that addressed the tank wash role under CSA. The panel was part of the National Tank Truck Carriers’ Tank Cleaning & Environmental Council Seminar held June 4 and 5 at The Hotel Monteleone in New Orleans LA.

Steve Niswander, Groendyke Transport Inc, described how wash rack workers will replace a damaged placard on a trailer that has multiple placards. The undamaged placards are left in place. “Unfortunately, the remaining placards won’t be as bright as the as the new one, and some inspectors will cite the trailer for faded placards,” he said. “One solution is to change all of the placards, but that is an extra cost.”

Wright agreed that placards are getting more attention under CSA. He said even small amounts of product residue on the exterior of a tank can draw attention (and potentially citations) from roadside inspectors. Inspectors will target virtually anything.

Several speakers said condensation dripping from a clean tank trailer has been tagged as a hazmat leak by inspectors. “It’s a problem we see with new state troopers,” said Randy Vaughn, Superior Bulk Logistics. “They are climbing on trailers more than ever before, and some of them will cite a trailer for water in the crash box.”

Vaughn said he fights the bad citations, and gets the scores fixed in CSA, but it takes time. He pointed out that it is important to fix both the carrier and driver scores.

Ed Matlage, Miller Transporters Inc, said it should be the wash rack’s responsibility to make sure everything is in order before a tank trailer is sent back out on the road. “We need good communication between wash rack and carrier,” he said. “You are our eyes and ears while our trailer is at your facility.

Gene Patten, The Dana Companies, added “Many of our own wash rack personnel have been to spot maintenance issues, such as bald tires, bad gaskets, and leaking wheel seals.”

CSA scores matter greatly, and wash racks can impact those scores, said Andrew Wood, Bulk Transportation. “We are measured on those scores by FMCSA and by our customers,” he said. “Shippers monitor our scores constantly, and they are always pushing us to do better.”