Crotty explains other side guard waiver examples
Crotty gives other side guard waiver examples, including dump trucks with tri-axles that cannot support side guards. She says BIC reviews each application individually, may request mechanics letters, and has revisited waivers to require modified side guards.
So you were going into the bases for which BIC would issue side guard waivers, and this example is one of them.
Are there other examples where a side guard exemption would be appropriate?
Sure.
Many of the trucks that fall under BIC's regulation are trucks that are used to remove construction and debris, not traditional waste, but we're talking about heavy-duty construction debris, and those are dump trucks.
We regulate a large number of dump trucks.
And if you look at the average dump truck, it doesn't just have a front axle, a rear axle, and lots of space in between.
It usually has additional wheels, including something that's called a...
like a third axle, a tri-axle, which is a wheel that is used to help the vehicle navigate uneven terrain.
And so there's a series of these wheels.
And a tri-axle vehicle, the vehicle moves in such a way that if you install a side guard,
the side guard would break when the vehicle wheel turns or the wheel could get damaged.
So one of the things that we require when we receive an application for a waiver is if we don't feel like we have enough information, we will ask the company for more.
They may send us a mechanics letter that explains just what I explained to you, that the vehicle, the dump truck, for example, can't support a side guard.
So that's one example of a type of vehicle that's different from the one involved at 14th Street.
Does BIC ever revisit or reevaluate a waiver after it has been issued, and has it ever been rescinded at any moment?
We have revisited waivers that have been granted, and what it's allowed us to do is have an iterative, ongoing conversation with the company.
So we may take another look at where we've given a waiver and said, you know what, there is still a one-foot space, for example, between the step to the cab and that gas tank.
And can you install a modified side guard in that limited space?
And we will keep working with the company until they do so.
And we've had success in that regard.