Many recyclers use transportation brokers to arrange carriers to transport their materials. This can be a cost effective way to find carriers traveling routes you use infrequently or need on short notice. Since they are not contracting directly with the carrier, however, they are essentially outsourcing the Provision 12(b) due diligence requirements to the broker. Consequently, they must implement a process to qualify a broker to ensure it conducts due diligence regarding these requirements on their behalf. The process of qualifying a broker includes:
- Determining if the broker’s process of carrier qualification meets the R2 requirements for new carriers.
- Determining if the broker’s process re-evaluates carriers on regular basis.
- Verifying conformance by auditing the broker’s records for carriers used to transport the recycler’s shipments.