It’s Time to Debunk Those Persistent CDL Myths

Follow these steps and do some more reading to get that bigger vacuum truck running down the road legally

It’s Time to Debunk Those Persistent CDL Myths

Jeff and Terri Wigley

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Coincidently, each of this month’s questions involves large organizations that have many rules, regulations and an alphabet soup of acronyms. As we answer questions involving the DMV (Department of Motor Vehicles), CDL (commercial driver’s license) and the CDC (Centers for Disease Control and Prevention), we will try to make it as easy as it can be!

Question: I have a fleet of smaller (under 26,001-pound gross vehicle weight rating) vacuum trucks. I am looking at purchasing a larger vacuum truck requiring a CDL driver. I am confused, however, about the rules and regulations concerning a CDL driver in our industry. For example, I have been told that a CDL driver cannot be on the road for more than 10 hours per day. Is that true, and could you please give me a simple outline of the applicable CDL requirements?

Answer: We will preface our answer by strongly suggesting you obtain your state’s Commercial Driver’s Manual as a good foundation for your education in this area. As you stated in your question, federal law mandates a CDL driver is to operate a single vehicle with a GVWR of 26,001 pounds or more. The various vehicle classifications, however, make the CDL manual quite voluminous. For example, there are individual sections devoted to vehicles that are used for intrastate versus interstate commerce, trailers, double/triple trailers, tankers, hazardous waste transport, passenger vehicles, school buses and a host of other variations. We will attempt to address some of the myths we have encountered. Again, you should do additional research, and we will make some suggestions in that area as well.

In addition to the 26,001-pound GVWR truck rating, the basic CDL requirements for a driver in the portable restroom industry are very basic. To address some of the myths:

•  Your question regarding the “10-hour rule” only applies to CDL drivers who operate a passenger vehicle. The driver “cannot drive a passenger-carrying vehicle for more than 10 hours following 8 consecutive hours off duty.”

• There is no hazmat requirement for hauling portable restroom waste. A hazmat endorsement for a CDL driver involves the transport of such materials as explosives, flammable gases (such as propane), nonflammable gases (such as helium), combustible liquids (such as fuel oil), corrosives and radioactive elements. Portable restroom waste is regulated by the federal Resource Conservation and Recovery Act and the Clean Water Act. The transportation of this waste is not hazardous. In fact, after the proper treatment at an authorized wastewater treatment facility, the resulting treated water is released back into the environment. Our industry is in fact extremely environmentally friendly.    

• Special endorsements for air brakes. This one is tricky. If you are driving a truck requiring a CDL and it is equipped with air brakes, you do indeed need the air brake endorsement to the CDL. If, however, you are driving a non-CDL truck (under 26,001 pounds) with air brakes, you do not need an air brake endorsement.

Research is definitely needed in this complex area, and here are some recommendations:

• The Federal Motor Carrier Safety Administration is the basis for all regulations. The website is www.fmcsa.dot.gov, and they may be reached at 800-832-5660.

• Contact your state Department of Transportation for its requirements. In Georgia, for example, the Department of Driver Services has an app (DDS 2 GO) that addresses all motor carrier issues for the state. We obtained a copy of the 2018-19 Georgia Commercial Drivers Manual for research on this question. It is well-written in an easy-to-understand magazine-format. We would suggest obtaining a copy and keeping it in your office for reference.

• Other resources would include contacting your state’s Motor Trucking Association (if applicable). In our state, the Georgia Motor Trucking Association is a valuable source of information concerning current issues, as well as proposed regulation changes.

• CDL training schools in your state would be able to address general questions and serve as another additional resource.           

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Question: I often hear about cleaning with a “bleach solution.” What is it? What is the recipe?

Answer: Actually a bleach solution is not used for cleaning. It is the generally accepted method of disinfecting. The standard is a 10 percent bleach solution, which is recognized by both the U.S. Environmental Protection Agency and the CDC as being effective for disinfecting. Bleach is usually composed of 5.25 or 6 percent sodium hypochlorite. A mixture of one part bleach to 10 parts water — approximately 1 1/2 cups of bleach to 1 gallon of water — produces the desired result.

We have always called the 10 percent bleach solution the “magic potion” as it is extremely effective for many applications in our industry. The Portable Sanitation Association International standards suggest cleaning the supply lines of a hand-wash station every 45 days with the 10 percent bleach solution. This will prevent and kill mold that may form in these lines. In a freshwater flush unit, this will reduce algae buildup in the freshwater tank. You may also use the 10 percent solution in the bottom of a recirculating unit and pump several times to clean the waterlines.

One important point to keep in mind is that the 10 percent bleach solution will degrade over time, primarily based on temperature. Since hand-wash stations, recirculating portable restroom units and freshwater flush units are primarily used during event season, degradation due to hot weather is a definite consideration.

The sodium hypochlorite in bleach can be measured and detected with high-chlorine test strips. An online check of these products revealed pricing for 100 test strips for $10 to $15. This is a small investment to ensure your bleach solution has not degraded to a 100 percent solution of water! 



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