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					                                      UNITED STATES DEPARTMENT OF TRANSPORTATION
                            Legal: GRUPO BEHR DE BAJA CALIFORNIA SA DE CV
                            Operating (DBA):
MC/MX #: 371235            RFC #: GBB971008165        Federal Tax ID:                        Application Tracking #: 8244
Review Type: Safety Audit - Pre-Authority (OP1)
Scope:           Entire Operation           Location of Review/Audit: Company facility in another country      Territory:
Operation Types Interstate Intrastate
         Carrier: Non-HM N/A          Business: Corporation
        Shipper:  N/A       N/A       Gross Revenue: $120,000.00                         for year ending: 12/31/2006
   Cargo Tank:         N/A
Company Physical Address:
 BLVD BELLAS ARTES#17686 INTERIOR 116
 TIJUANA, BN 22509 MEXICO

 Contact Name:
 Phone numbers: (1) 664- 647-5501             (2)                        Fax
 E-Mail Address:
Company Mailing Address:
 2498 ROLL DRIVE PMB 506
 SAN DIEGO, CA 92154
Process Agent Address:
 1535 Quiet Trail Dr
 Chula Vista, CA 91915

 Contact Name:
 Phone numbers: (1)                           (2)                        Fax
 E-Mail Address:

Carrier Classification
     Authorized for Hire
Cargo Classification
    General Freight
 Does carrier transport placardable quantities of HM?        No
 Is an HM Permit required?                                   N/A
Driver Information
                        Inter       Intra    Average trip leased drivers/month: 0
       < 100 Miles:         2                                     Total Drivers: 2
      >= 100 Miles:                                                CDL Drivers: 2
Equipment
                            Owned Term Leased Trip Leased
    Truck                        3         0           0                 Truck Tractor               1             0               0
    Trailer                      1         0           5
Power units used in the U.S.:4
Percentage of time used in the U.S.:50




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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                               Review Date:
                                            Application Tracking #:8244                RFC #: GBB971008165         11/07/2007

                                             Part B - Questions and Answers



 Question General # 1 - Section # 387.7(a) Acute                                                                   Answer
   Does the carrier have the required minimum level of financial responsibility in effect?                           Yes
  Comments

 Question General # 2 - Section # 387.7(d) Critical                                                                Answer
   Does the carrier have required proof of financial responsibility?                                                 Yes
  Comments

 Question General # 3 - Section # 390.15(b)(1)                                                                     Answer
   Can the carrier provide a complete accident register of recordable accidents?                                     N/A
  Comments

 Question General # 4 - Section # 390.15(b)(2) Critical                                                            Answer
   Does the carrier have copies of all accident reports required by States or other government entities or           N/A
   insurers?
  Comments

 Question General # 5 - Section # 390.3(e)                                                                         Answer
   Is the carrier knowledgeable of the FMCSRs/HMRs?                                                                  Yes
  Comments

 Question General # 6 - Section # 390.21                                                                           Answer
   Does the carrier know the commercial motor vehicles marking requirements?                                         Yes
  Comments

 Question Driver # 1 - Section # 391.51(a) Critical                                                                Answer
   Does the carrier maintain complete driver qualification files?                                                    No
  Comments
   Carrier is missing Annual List/Certification of Violations of Motor Vehicle Laws
   Driver
   Interstate trip date: 10/10/07
 Question Driver # 2 - Section # 391.11(b)(4) Acute                                                                Answer
   Is the carrier using physically qualified drivers?                                                                Yes
  Comments

 Question Driver # 3 - Section # 391.45(a), 391.45(b) Critical                                                     Answer
   Does available evidence indicate the motor carrier has used a driver without a medical certificate or with an     No
   expired medical certificate?
  Comments

 Question Driver # 4 - Section # 391.15(a) Acute                                                                   Answer
   Is the carrier using any disqualified drivers?                                                                    No
  Comments



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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                 Review Date:
                                            Application Tracking #:8244                RFC #: GBB971008165           11/07/2007

                                             Part B - Questions and Answers



 Question Driver # 5 - Section # 391.51(b)(2) Critical                                                               Answer
   Does the carrier maintain driving and employment history inquiry data in driver qualification files?                Yes
  Comments

 Question Driver # 6 - Section # 382.115(a) Acute                                                                    Answer
   Has the carrier implemented an alcohol and/or controlled substances testing program?                                Yes
  Comments

 Question Driver # 7 - Section # 382.213(b) Acute                                                                    Answer
   Has the carrier used drivers who have used controlled substances?                                                   No
  Comments

 Question Driver # 8 - Section # 382.215 Acute                                                                       Answer
   Has the carrier used a driver who has tested positive for a controlled substance?                                   No
  Comments

 Question Driver # 9 - Section # 382.201 Acute                                                                       Answer
   Has the carrier used a driver known to have an alcohol concentration of 0.04 or greater?                            No
  Comments

 Question Driver # 10 - Section # 382.505(a) Acute                                                                   Answer
   Has the carrier used a driver found to have an alcohol concentration of .02 or greater but less than .04 within     No
   24 hours of being tested?
  Comments

 Question Driver # 11 - Section # 382.301(a) Critical                                                                Answer
   Has the carrier ensured that drivers have undergone testing for controlled substances prior to performing a         Yes
   safety sensitive function?
  Comments

 Question Driver # 12 - Section # 382.303(a) Critical                                                                Answer
   Has the carrier conducted post accident testing on drivers for alcohol and/or controlled substances?                N/A
  Comments

 Question Driver # 13 - Section # 382.305 Acute                                                                      Answer
   Has the carrier implemented random testing program?                                                                 Yes
  Comments

 Question Driver # 14 - Section # 382.305(b)(1) Critical                                                             Answer
   Has the carrier conducted random alcohol testing at an annual rate of not less than the applicable annual rate      Yes
   of the average number of driver positions?
  Comments




11/15/2007 8:19:46 AM                                       Page 2 of 7                                              Capri 6.6.0.18
              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                         Review Date:
                                           Application Tracking #:8244              RFC #: GBB971008165      11/07/2007

                                                            Part A


        Questions about this report or the Federal Motor Carrier Safety or Hazardous Materials regulations
        may be addressed to the Federal Motor Carrier Safety Administration at:
                    2297 Niels Bohr Court, Suite 204
                    San Diego (Otay Mesa), CA 92154
                    Phone: (619)710-8400      Fax:(619)710-2804

                              This SAFETY AUDIT will be used to assess your safety compliance.
Person(s) Interviewed
 Name: ARTURO PEREZ                                                      Title: OWNER
 Name: ROBERTO GARCIA DE LEON                                            Title: CO OWNER




11/15/2007 8:19:46 AM                                     Page 2 of 2                                        Capri 6.6.0.18
              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                   Review Date:
                                            Application Tracking #:8244                RFC #: GBB971008165             11/07/2007

                                            Part B - Questions and Answers



Question Driver # 15 - Section # 382.305(b)(2) Critical                                                                Answer
  Has the carrier conducted controlled substance testing at an annual rate of not less than the applicable annual        Yes
  rate of the average number of driver positions?
 Comments


Question Driver # 16 - Section # 40.305(a)                                                                             Answer
  Has the carrier conducted the required return-to-duty tests on employees returning to safety-sensitive                 N/A
  functions?
 Comments


 Question Driver # 17 - Section # 40.309(a)                                                                            Answer
   Is the carrier conducting follow-up testing as directed by the Substance Abuse Professional?                          N/A
  Comments


 Question Driver # 18 - Section # 382.211 Acute                                                                        Answer
   Has the carrier used a driver who has refused to submit to an alcohol or controlled substances test required          N/A
   under Part 382?
  Comments

 Question Driver # 19 - Section # 382.503 Critical                                                                     Answer
   Has the carrier used a Substance Abuse Professional as required by 49 CFR Part 40 Subpart O?                          N/A
  Comments


 Question Driver # 21 - Section # 383.37(a) Acute                                                                      Answer
   Has the motor carrier allowed it's drivers who's CDLs have been suspended, revoked or canceled by a state,            No
   have lost the right to operate a CMV in a State, or have been disqualified from operating a CMV to operate a
   commercial motor vehicle?
  Comments



 Question Driver # 22 - Section # 383.51(a) Acute                                                                      Answer
   Has the motor carrier knowingly allowed, required, permitted, or authorized a driver to drive who is disqualified     No
   to drive a commercial motor vehicle?
  Comments



 Question Operation #1 - Section # 395.8(a) Critical                                                                   Answer
   Does the carrier require drivers to make a record of duty status?                                                     No
  Comments
   Time card shows driver ending day at 5pm, but Mexican customs docuements shows 19:01(7:01 pm).
   Driver
   Interstate trip date: 9/12/07



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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                Review Date:
                                            Application Tracking #:8244                RFC #: GBB971008165          11/07/2007

                                            Part B - Questions and Answers



 Question Operation #2 - Section # 395.8(i) Critical                                                                Answer
   Does the carrier require drivers to submit records of duty status within 13 days?                                  N/A
  Comments
   Question #1 above was answered "no".
 Question Operation #3 - Section # 395.8(k)(1) Critical                                                             Answer
   Can the carrier produce records of duty status and supporting documents for selected drivers?                      N/A
  Comments
   Question #1 above was answered "no".
 Question Operation #4 - Section # 395.3(a)(1) Critical                                                             Answer
   Has the carrier allowed driver(s) to exceed the 11-hour rule? (Property)                                           No
  Comments

 Question Operation #5 - Section # 395.3(a)(2) Critical                                                             Answer
   Has the carrier allowed driver(s) to exceed the 14-hour rule? (Property)                                           No
  Comments

 Question Operation #6 - Section # 395.3(b)(1) Critical                                                             Answer
   Has the carrier allowed driver(s) to drive after having been on duty more than 60 hours in 7 consecutive days?     No
   (Property)
  Comments

 Question Operation #7 - Section # 395.3(b)(2) Critical                                                             Answer
   Has the carrier allowed driver(s) to drive after having been on duty more than 70 hours in 8 consecutive days?     N/A
   (Property)
  Comments

 Question Operation #8 - Section # 395.5(a)(1) Critical                                                             Answer
   Has the carrier allowed driver(s) to exceed the 10 hour rule? (Passenger)                                          N/A
  Comments

 Question Operation #9 - Section # 395.5(a)(2) Critical                                                             Answer
   Has the carrier allowed driver(s) to exceed the 15 hour rule? (Passenger)                                          N/A
  Comments

 Question Operation #10 - Section # 395.5(b)(1) Critical                                                            Answer
   Has the carrier allowed driver(s) to drive after having been on duty more than 60 hours in 7 consecutive days?     N/A
   (Passenger)
  Comments

 Question Operation #11 - Section # 395.5(b)(2) Critical                                                            Answer
   Has the carrier allowed driver(s) to drive after having been on duty more than 70 hours in 8 consecutive days?     N/A
   (Passenger)
  Comments



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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                  Review Date:
                                            Application Tracking #:8244                RFC #: GBB971008165            11/07/2007

                                            Part B - Questions and Answers


 Question Operation #12 - Section # 395.8(e) Critical                                                                  Answer
   Does available evidence indicate a selected driver has prepared a false record of duty status?                        N/A
  Comments

 Question Operation #13 - Section #                                                                                     Answer
   Does the carrier adhere to a disciplinary policy for noncompliance with Part 395?                                      Yes
  Comments

 Question Operation #14 - Section # 395.1(e)                                                                             Answer
   Does the carrier have a system for recording hours of duty status on 100- mile radius drivers, and are they              No
   properly utilizing the 100 air-mile radius exemption?
  Comments
   Available evidence indicates any instances in which the motor carrier is not properly utilizing the 100 air-mile radius exemption.
   Time card shows driver ending day at 5pm, but Mexican customs docuements shows 19:01(7:01 pm).
   Driver
   Interstate trip date: 9/12/07

Question Operation #15 - Section # 392.2 Critical                                                                      Answer
  Does the motor carrier ensure that drivers operate commercial motor vehicles in accordance with the laws,              Yes
  ordinances, and regulations of the jurisdictions in which they are operating?
 Comments


Question Operation #16 - Section # 392.9(a)(1) Critical                                                                Answer
  Does the carrier ensure that drivers are not permitted to drive a vehicle without the cargo properly distributed       Yes
  and adequately secured?
 Comments

Question Operation #17 - Section # 392.4(b) Acute                                                                     Answer
  Have any drivers operated a commercial motor vehicle while under the influence of, or in possession of,               No
  narcotic drugs, amphetamines, or any other substances capable of rendering the drivers incapable of safely
  operating motor vehicles?
 Comments

Question Operation #18 - Section # 392.5(b)(1) Acute                                                                  Answer
  Have any drivers operated a commercial motor vehicle while under the influence of, or in possession of,               No
  intoxicating beverages?
 Comments


Question Operation #19 - Section # 392.5(b)(2) Acute                                                                  Answer
  Have any drivers operated a commercial motor vehicle within 4 hours of having consumed intoxicating                   No
  beverages?
 Comments


Question Maintenance # 1 - Section # 396.3(b) Critical                                                                Answer
  Can the carrier produce maintenance files for requested vehicle(s)?                                                   Yes
 Comments


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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                   Review Date:
                                             Application Tracking #:8244                RFC #: GBB971008165            11/07/2007

                                             Part B - Questions and Answers



 Question Maintenance # 2 - Section # 396.17(a) Critical                                                               Answer
   Can the motor carrier produce evidence of periodic (annual) inspections for selected vehicles?                        Yes
  Comments

 Question Maintenance # 3 - Section # 396.11(a) Critical                                                               Answer
   Does the motor carrier require drivers to complete vehicle inspection reports daily?                                  Yes
  Comments

 Question Maintenance # 4 - Section # 396.11(c) Acute                                                                  Answer
   Does the carrier ensure that out-of-service defects listed by the driver in the driver vehicle inspection reports     Yes
   are corrected before the vehicle is operated again?
  Comments

 Question Maintenance # 5 - Section # 396.9(c)(2) Acute                                                                 Answer
   Does the carrier ensure vehicles that have been declared "out-of-service" do not operate before repairs have           Yes
   been made?
  Comments

 Question Maintenance # 6 - Section # 396.19                                                                          Answer
   Is the carrier using qualified inspectors (mechanic) and maintaining evidence of the inspector's qualifications?      N/A
  Comments
    Motor carrier uses an outside independent vendor to complete the periodic/annual inspections, or state certified periodic
    inspection program.

 Question Maintenance # 7 - Section # 396.3                                                                            Answer
   Can the carrier explain its systematic, periodic maintenance program?                                                 Yes
  Comments

 Question Other # 1 - Section # 375.211                                                                                Answer
   Does the carrier participate in an Arbitration Program?                                                               N/A
  Comments

 Question Other # 2 - Section # 13702                                                                                  Answer
   Does the carrier assess shipper freight charges based upon published tariffs?                                         N/A
  Comments

 Question Other # 3 - Section # 375.401(c)                                                                             Answer
   Does the carrier provide reasonably accurate estimates of moving charges?                                             N/A
  Comments

 Question Other # 4 - Section # 375.407(a), 375.703(b)                                                                 Answer
   Has the carrier avoided "hostage freight" or other predatory practices?                                               N/A
  Comments




11/15/2007 8:19:46 AM                                        Page 6 of 7                                               Capri 6.6.0.18
              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                             Review Date:
                                            Application Tracking #:8244               RFC #: GBB971008165        11/07/2007

                                            Part B - Questions and Answers



 Question Other # 5 - Section # 387.301(a), 387.301(b)                                                           Answer
   Does the HHG carrier have sufficient levels of public liability and cargo insurance?                            N/A
  Comments

 Question Other # 6 - Section # 13901                                                                            Answer
   Is the motor carrier authorized to conduct interstate operations in the United States?                          Yes
  Comments

Note: No Hazardous Materials questions were asked because the carrier does not carry Hazardous Materials in Interstate
Commerce.




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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                 Review Date:
                                           Application Tracking #:8244               RFC #: GBB971008165             11/07/2007

                                 Part B Requirements and/or Recommendations

 1. Copies of the regulations, forms, interpretations, and manuals are available from a variety of sources. Check the
    FMCSA website for a current list of suppliers. www.fmcsa.dot.gov/safety-security/eta/index.htm

 2. A copy of your carrier profile can be obtained for $20 from the SAFER website (http://safer.fmcsa.dot.gov) or by
    calling 800-832-5660 or 703 280-4001. You can also write: Computing Technologies Inc. P.O. Box 3248, Merrifield,
    VA 22116-3248. Profile cost if ordered by mail or phone is $27.50.

 3. The Federal Motor Carrier Safety Administration has a Spanish language version of its website at:
    www.fmcsa.dot.gov/spanish/.

 4. A complete Educational and Technical Assistance package entitled " A MOTOR CARRIER'S GUIDE TO
    IMPROVING HIGHWAY SAFETY" is available free on the FMCSA website to assist you in complying with the safety
    regulations. It contains many forms and documents useful for improving the safety of your operations. Check:
    www.fmcsa.dot.gov/factsfigs/eta/index.html.

 5. Ensure that all drivers are fully and properly qualified before operating in interstate commerce. Maintain a complete
    file as required for each driver, documenting the qualification process.

 6. If you want some drivers to use the 100 air-mile radius exemption, make sure that the drivers meet all terms of the
    exemption, including being released from duty no more than 12 hours from when they report for duty. Logs must be
    prepared if a driver does not meet the 12 hour requirement.

 7. Require all drivers to prepare complete and accurate records of duty status for each day, and to submit them within
    13 days. Maintain all duty status records on file, with all supporting documents, for at least 6 months.




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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                        Review Date:
                                              Application Tracking #:8244                 RFC #: GBB971008165               11/07/2007

                                                                Part C


    Corporate Contact: ARTURO PEREZ                                                      Special Study Information:
    Corporate Contact Title: OWNER
    Remarks:
    (a) The motor carrier has been in operation since March, 2000 after receiving US DOT number on 3/16/2000. Carrier
    applied for OP1 operating authority on 02/26/2007.

    (b) The motor carrier is currently operating within the United States, San Diego, California commercial zone.

    (c) The motor carrier received a certificate of registration to operate within the United States municipalities and commercial
    zone on March 9, 2000 as a private carrier and then received For-hire authority type on 6/10/2003.

    (d) The motor carrier is currently operating within the United States commercial zone, and has not had any expedited action
    letters. A safety audit was conducted on 10/14/2003 with a commercial zone PASS letter dated 12/06/2005.

    (e) If long-haul operating authority is granted, the carrier has plans to continue operations within the commercial zones to
    include Los Angeles and Riverside California.

    (f) The motor carrier does not have a parent company, affiliation, or association with a motor carrier operating in the United
    States. Arturo Perez owns two other business'; Customs Broker Logisticas Aduanales del Pacifico, and a sales company
    Logix Sales LLC dba Pacific Customs Services, no vehicles assigned.

    (g) The motor carrier does not have Mexico only units currently operating.

    (h) The Advisement of Obligation to Comply with Statutes and Regulations was discussed with the motor carrier official and
    a copy of the signed and dated form was provided to the carrier.

    (i) The motor carrier officials present during the discussion of the Advisement was Company owners Arturo Perez and
    Roberto de Leon.

    (j) The Protested Application Process was discussed and a copy was provided to the motor carrier.

    Our initial contact to schedule the PASA with business owner Arturo Perez was on 10/09/2007. The PASA began at
    10:00a.m. on 11/06/2007. Upon our arrival we were met with owner Arturo Perez .

    We were accompanied by a SCT representative whose name was Jesus Lopez Medina. After introducing all personnel
    and explaining the purpose of our visit, the carrier provided a tour of the facility. The carrier directed us to a location for the
    PASA to be conducted.

    I asked the carrier if they had previously been contacted by the SCT, regarding the PASA and he answered no. Business
    owner Arturo Perez stated that he didn't receive a call from the SCT office.

    Business owner Arturo Perez was advised of all the requirements that must be met before OP-1 authority is granted as a
    long-haul carrier.

    The carrier was provided a copy of the OCE-46, which was properly signed, dated and executed by the carrier. The
    Reinstatement of OP-2 Operating Authority form was also signed and dated by the carrier.

    We next proceeded to start the verification process (Phase 1 of the PASA) and questioned the carrier regarding each of the
    five mandatory elements. After we assured each of the five mandatory elements were satisfied, we provided copies of
    various forms and information on required documents to be used by the carrier and kept on file to assist in compliance with
    the FMCSR.

    The carrier operates three straight trucks, one truck tractor, one owned, and five trip leased semi trailers (per month), which
    it plans on operating in the U.S. if granted OP-1 Authority. It should be noted that upon our FMVSS verification, all CMVs
    met the Federal Motor Vehicle Safety Standards (FMVSS) as required. All units displayed a current CVSA decal, inspected
    by the California Highway Patrol. The carrier was advised vehicles which do not meet FMVSS would not be allowed to
    travel into the United States.

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              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                    Review Date:
                                             Application Tracking #:8244                RFC #: GBB971008165             11/07/2007

                                                              Part C


    Changes were made or needed to the MCS-150, as information on file is not current and incorrect. Carrier had submitted
    an updated MCS 150 to Headquarters.

    The CAPRI process (Phase II of the PASA) Demonstration Program was conducted on 11/07/2007 at carrier's Place of
    Business located at Blvd Bellas Artes #17686 Interior 116, Tijuana, Baja California, Mexico. Present for the PASA were
    Company owners Arturo Perez and Roberto de Leon, who signed and received a copy of Part A (Page 1 and 2) and
    Receipt Page of the report.

    Review of Part 387: The carrier is currently operating with OP-2 authority and provided proof of insurance along with copy
    of MCS-90. Insurance companies explained they can cover carrier if Long-Haul Authority is granted. Furthermore, no
    claims or gaps in insurance coverage were identified. The current policy with Monterey Insurance Company and Hartley
    Cylke Pacific 6SAP3-545028 was verified and confirmed by contacting Aida Rangel a Hartley Cylke Pacific representative
    located at 2747 University Ave, San Diego, Ca. 92164, contact number (800) 328-3460. Remaining units covered with
    Commercial Alliance Insurance Company (CAIC) policy PCOC005775 certificate # 013965 was verified and confirmed by
    contacting Carlos Ursua, CAIC operations manager located at 415 Lockhaven Dr. Houston, TX. 77073, contact number
    (713) 960 1214.

    Review of Part 383: CDLIS check inquiry of the two drivers on the list created by the carrier to operate in the US revealed a
    valid Licencia Federal for each driver. Copies of CDLIS inquiry are included in this review, as well as a copy of the Licencia
    Federal de Conductor provided by the carrier for each driver they intend to operate in the US.

    Review of Part 40 and 382: The motor carrier has a Drug and Alcohol Testing Program. The carrier has a Random Testing
    Program run by a consortium Ruiz and Associates. Discrepancies were not found as the carrier is correctly following the
    procedures for random testing selections. The collection site conducting the controlled substance and alcohol testing was
    contacted by phone. We spoke to Ruiz and Associates representative Cindy Cunnigham and, located at 8684 Avenida de la
    Fuente #2 San Diego, Ca 92154 contact number (619) 661 0572. Cindy Cunningham stated they utilize Pacific Taxicology
    Laboratories 9348 de Soto Ave, Chatsworth Ca. 91311 contact number (818) 596 3118 as their certified laboratory. The
    collection site confirmed they do conduct pre-employment, random, post accident, and reasonable suspicion controlled
    substance/alcohol testing (as applicable), and that it has no involvement in the random selection process. The carrier was
    also advised of the required Supervisor Training under 382.603. The D&A regulations were discussed in-depth with the
    carrier.

    Review of Part 390: The motor carrier has had zero recordable accidents in the last 12 months. The carrier was made
    aware of the definition of an accident involving a CMV and the requirements of documents to be maintained on file. The
    carrier has had zero recordable accidents in Mexico.

    The motor carrier was notified of the marking requirements in the event they are granted provisional operating authority.
    Currently the carrier is displaying the correct markings but on some units were missing the Z after the USDOT.

    Review of Part 391: The list of drivers created by the motor carrier identifies the drivers they are planning to operate in the
    United States. DQ files for each driver were reviewed and violations were discovered. While checking driver DQ files
    discovered a missing Annual List/Certification of Violations of Motor Vehicle Laws for driver
    Interstate trip date 10/10/07.

    Review of Part 395: The motor carrier produced Time Cards and supporting documents for all drivers. The supporting
    documents they maintain are as follows: Mexican Manifest, company shipper documents, and Mexican Customs
    documents. A review of 30 day time cards for each driver was completed. The carrier was advised and explained of the
    importance and responsibility of keeping accurate and legitimate RODS. The carrier was also instructed on the required
    retention period for such records. The carrier stated he has a verbal disciplinary policy for non-compliance with Part 395. A
    total of 30 days of Time Cards were scanned.

    While reviewing time cards, revealed an inaccurate log for driver                    on 9/12/07. Time card shows starting at
    8:00 am and ended day at 5:00 pm, Mexican customs documents show 19:01(7:01 pm). While an inaccurate log was
    discovered, no evidence of driver exceeding 12 hour day therefore not properly using 100 mile exemption. Per EFOTM and
    service center guidance, an inaccurate time record is considered to be a failure to prepare a ROD, therefore Operations
    questions #1, 4, 5, 6, 13, 14 were answered. Carrier's system for recording hours of duty status on 100 air-mile radius
    drivers was inaccurate therefore Operations question #14 was answered NO.


11/15/2007 8:49:05 AM                                       Page 2 of 3                                                  Capri 6.6.0.18
              GRUPO BEHR DE BAJA CALIFORNIA SA DE CV                                                                  Review Date:
                                            Application Tracking #:8244               RFC #: GBB971008165             11/07/2007

                                                             Part C

    Review of Part 396: The motor carrier was able to produce complete maintenance files for all selected vehicles they intend
    to operate in the United States. Current copies of annual inspections were on file. The carrier produced Driver Vehicle
    Inspection Reports for the selected vehicles. The carrier was advised of the required retention period for such records. The
    motor carrier explained its systematic periodic maintenance program. The carrier was able to describe their scheduled
    maintenance program. Level V inspections were not performed due to all units displaying a current CVSA decal. Inspection
    of the units included a walk around, verification of CVSA decal, FMVSS, and VIN plates.

    Inspection Report Number CA9026588E revealed zero critical item violations for unit number Straight truck, 2000, Ford
    E-350, CA-6B84696, VIN 1FDWE35L4YHA61859, GVWR 14,000 lbs, was issued CVSA decal 7259763. Inspection report
    CA90266753 revealed one critical item that was repaired, Straight truck, 1989 GMC 7000 CA-7J24270, VIN
    1GDL7D1E4KV501386, GVWR 23,001 lbs, was issued CVSA decal 7254702. Inspection report CA902651D1 revealed two
    critical items that were repaired, Straight truck, 2000, GMC 6500, CA-9D76502, VIN 1GDJ7H1D3YJ904703, GVWR 23,501
    lbs, was issued CVSA decal 7258452. Inspection report CA90265131 revealed two critical items that were repaired, Truck
    Tractor, 1991 Freightliner, CA-9B42757, VIN 1FUYACXB3MH512943, GVWR 33,001 lbs, was issued CVSA decal
    7258128. Inspection report CA90265131 revealed zero critical item violations, 1995 Trailmobile 53 foot trailer,
    CA-4AW6431, VIN-1PT01JAH9S9012783, was issued CVSA Decal 7258129. Maintenance files were verified of repairs
    made for vehicles that were placed Out Of Service.

    The motor carrier had 21 inspections listed on company profile. Web sites reviewed for carrier information include MCMIS,
    QUERY CENTRAL, SAFER, L&I and CDLIS. Throughout the PASA the carrier was courteous, attentive and receptive of
    recommendations made.

    The motor carrier is aware they must be in full compliance to avoid any future violations.

    Upon completion of the PASA, I reviewed with company owners Arturo Perez and Roberto de Leon, the Protest Procedures
    flowchart “Attachment 5” from the PASA memo. I notified the motor carrier of the possibility of a protest to their application
    for OP-1 long haul operating authority, and the time limits for responding to a protest. I provided a signed copy of the
    Protest Procedures flowchart to owners Arturo Perez and Roberto de Leon.

    Safety Investigator Omar Salomon US1164 assisted with this PASA. San Diego (Otay Mesa) Border Supervisor Lynda
    Holst and Safety Investigator Susan Cerritos observed this PASA.

    Director of the Transportation Safety Institute, Frank Tupper and Project Manager for the Border Crossing Program
    Evaluation, Felix Ammah-Tagoe, were present as an evaluation panel for the Border Demonstration Program.

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11/15/2007 8:49:05 AM                                      Page 3 of 3                                                 Capri 6.6.0.18

				
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