vehicle inspection & maintenance requirements and best practices

Vehicle Inspection & Maintenance Requirements and Best Practices

This webcast will cover ...• DOT Inspection & Maintenance

Requirements,• Raising the Inspections & Maintenance

Bar,• The Pepsi Experience, and• Question & Answer

ModeratorDr. Gary Petty, President & CEO, NPTC

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questions to our Panelists. We’ll try to answer them during the Q&A period if they are not covered in the presentation.

PanelistsTom Bray, Editor, Transportation Management, J. J. Keller & Associates, Inc.Tom Moore, Vice President of Education, NPTCDan Norris, CTP, Fleet Operations Manager Atlantic Region, Pepsi Bottling Group

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Introduction

Dr. Gary Petty

President & CEO

National Private Truck Council

Gary Petty National Private Truck Council

Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

Introduction• DOT Inspection & Maintenance Requirements

– Tom Bray• Raising the Inspection & Maintenance Bar – Tom Moore• The Pepsi Experience – Dan Norris• Housekeeping issues:

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DOT Inspection & Maintenance Requirements

Thomas Bray

Editor, Transportation Management

J. J. Keller & Associates, Inc.

Tom BrayJ. J. Keller &

Associates, Inc.


Inspection, Repair & Maintenance (Part 396)

• Systematically maintain & inspect (396.3(a)) Vehicles controlled thirty (30) consecutive days

• You get to “write the rule” - carrier is allowed to determine inspection, maintenance, and lubrication schedule, and “checklist requirements,” based on OEM recommendations, past experience, and other factors.

• Once established, it must be followed!


Associates, Inc.


A “Systematic” Program• Typical “systematic” program (complete

with supporting checklists): PM-A “Safety check” - Inspection of key components

and lubrication. Typically ½ of oil change interval or each time the vehicle leaves or enters terminal

PM-B “Oil change and service” - All PM-A items, plus oil change and more in-depth inspection (removing covers, etc.)

PM-C “Annual” - All PM-A and B items, plus more in-depth inspection, replacement of specific parts, and annual inspection


Associates, Inc.


Required Records (396.3(b))• Required records (396.3(b)):

Vehicle identification (396.3 (b)(1)), including fleet number, VIN, make, model, year, tire size, and owner (if not owned by the carrier)

Schedule for inspection, maintenance, and lubrication (396.3 (b)(2))

Record of inspections, maintenance, lubrication and repairs (396.3 (b)(3))

• Records of inspections, maintenance, lubrication and repairs retained for one (1) year and six (6) months after vehicle leaves carrier control


Associates, Inc.


Audit Point - Recordkeeping

• The auditor will verify that you are performing the inspections, maintenance, and lubrication on the systematic schedule you have established for yourself.

• Common violations are not having a schedule, not following an established schedule, and not maintaining records.

• Third parties may perform maintenance and recordkeeping but carrier is ultimately responsible for providing such records at the time of audit.


Associates, Inc.


Unsafe Operations Forbidden (396.7)

• Catchall for law enforcement and auditors• A motor vehicle shall not be operated in such

a condition as to likely cause an accident or a breakdown of the vehicle.

• Knowingly operating an unsafe vehicle can make a carrier criminally liable.


Associates, Inc.


Audit Point – Roadside Inspections

• Major point of DOT Compliance Review If roadside OOS rate 34% or more, cannot receive

“Satisfactory” rating in vehicle factor. Auditor will verify that violations noted in roadside

inspection reports were repaired in a timely manner. If the vehicle was placed out-of-service, the auditor will verify that

the repairs were done before the vehicle was operated. Frequently asked question: Can a carrier or driver be cited (issued

a citation) for a mechanical violation NOT listed in Appendix G or the CVSA Out-of-Service Criteria?

YES, any violation of Parts 393, 396, or 571 discovered at the roadside can be cited by the officer (they will at the very least be listed as a “violation” on the inspection report). Only the more serious violations lead to an out-of-service order!


Associates, Inc.


Driver Inspections• Required by the regulations• Pre-Trip (392.7 and 396.13)• Enroute inspections (392.9 and 397.17)• Post-Trip/DVIR (396.11)


Associates, Inc.


Pre-trip (392.7 and 396.13)• Driver cannot operate the vehicle until the

driver is satisfied with the condition of the vehicle (Appendix G is the guide)

• Regulations list the MINIMUM that must be checked. Many carriers require more!

• No required form, however, many carriers have developed mandatory forms or require flagging on the driver’s log (best practice).


Associates, Inc.


Enroute• “Walk-around inspection” checking tires,

lights, hubs, cargo securement, coupling devices, and general condition.

• Tire check is only required if vehicle is hauling hazardous materials.

• Cargo check only required if hauling unsealed cargo.• Done every time the vehicle is parked.• Driver must stop every 3 hours/150 miles to check

unsealed cargo (HM tire check whenever stopped).• No required form. Best practice, “flag” on log.


Associates, Inc.


Post-trip/DVIR (396.11)• Pre-trip cannot take place of post-trip/DVIR• Copy of last DVIR NOT required to be

carried on the power unit anymore-retained by company for three months

• Carrier must maintain original records containing: Repairs needed and driver signature Certification of repairs or decision to not repair Certification of driver review repairs or decision to not repair


Associates, Inc.


Practical Recordkeeping Compliance Issues

• When to complete DVIR: Driver done for the day Switch trailers – can have one DVIR for all trailers Switch truck – new DVIR Slip-seat – new DVIR when driver done Team – 24 hours 1 DVIR

• DVIR can be on back or bottom of driver’s log: The log must be available by equipment number in case of audit. If on back or bottom of the driver’s record of duty status (log), the

driver(s) must guide the DVIR thru the process—the requirements are the same.

Maintenance needs DVIR if deficiency Retention changes to six months!


Associates, Inc.


Audit Point - Records• DVIR violation in compliance reviews

common (number one critical violation).• Common violations:

Failure to submit Failure to act on reported defects (can lead to claims of knowingly

operating unsafe equipment) Failure to have certifying signatures Failure to retain


Associates, Inc.


Periodic (Annual Inspection)

• Each CMV inspected at least every twelve (12) months (396.17(c))

• Inspected per Appendix G (396.17(a))• Proof of inspection (396.17(c)(1))• Must use a qualified inspector (396.19)• Records retained for fourteen (14)

months (396.21(b)(1))• Can use state equivalent (396.23)• Closely related to roadside inspection


Associates, Inc.


Periodic (Annual Inspection)

• Appendix G lists the requirements for successful passage of a periodic/annual inspection.

• The vehicle must constantly be maintained in a status that complies with Appendix G, not just pass the inspection once a year.

• Final portion compares Appendix G to the CVSA Out-of-Service Criteria.


Associates, Inc.


Appendix G v. CVSA OOS Criteria

• Appendix G and CVSA Out-of-Service Criteria follow the same format whenever Appendix G and CVSA Out-of-Service Criteria differ – Appendix G is stricter.

• Example: One defective brake (bad shoe, drum, or brake out-of-adjustment) would lead to a vehicle not passing a periodic inspection. The CVSA Out-of-Service criteria would allow the vehicle to continue its current trip, if the one defective brake is on a non-steering axle.


Associates, Inc.


Technician Qualifications

• 396.19 details periodic/annual inspector requirements

• 396.25 details brake inspector qualification• Carrier is responsible for documenting qualification

of their technicians


Associates, Inc.


Technician Qualifications

• Anyone performing periodic annual inspections must: Understands the inspection criteria; Be knowledgeable of and has mastered the methods and

procedures used to performing the inspection; Be capable of performing an inspection by reason of experience,

training, or both; and Meet the specific requirements for training and experience.


Associates, Inc.


Technician Qualifications • Anyone inspecting, maintaining, or

repairing brakes on a commercial vehicle must: Understand the brake service or inspection task; Be knowledgeable of and mastered the methods, procedures, tools

and equipment used when performing an assigned brake service or inspection task; and

Be capable of performing the assigned brake service or inspection by reason of experience, training or both.


Associates, Inc.


Raising the Bar

Tom Moore, CTP

Vice President of Education

National Private Truck Council

Tom MooreNational Private Truck Council


Why the Regs Aren’t Followed

• Poor communication• Conflicting goals• Forms and processes that lead to poor follow-

through



Raising the Bar: Daily Inspections Best Practices

• Hire intelligently• Train drivers• Arm them with the right tools• Ensure follow-up with all personnel• Pay a driver incentive tied to inspection performance

with inspections as one metric



Raising the Bar: Roadside Inspections Best Practices

• Weekly and spot inspections• Review SafeStat data monthly• Compare your data to SafeStat Vehicle data to

locate problems• Track ALL roadside inspections for trending• Address vehicle issues that repeat through

maintenance adjustments (improve schedules or checklists)



Raising the Bar: Annual Inspections Best Practices

• Consider more frequent inspections• Enhance internal communications• Improve vendor relationships



Audit Your Inspection Practices

• Out of service rates• Accident rates• Equipment violation citations• Maintenance cost and repair



Benefits of Raising the Bar• Lower overall maintenance costs • Increased fuel mileage • Improved driver retention• Improved on-time percentages



The Pepsi BottlingGroup Experience

Dan Norris, CTPFleet Operations Manager Atlantic Region

Pepsi Bottling Group (PBG)


Dan NorrisPepsi Bottling Group

PBG Fleet Operations• Atlantic Fleet consists of :

490 Class 8 tractors 1,525 Class 6 and 7 Trucks 1,990 Trailers

• 69 Locations• Responsible for maintaining 6,800

total pieces of equipment including floor scrubbers, pallet jacks, forklifts, pickups vans, etc.



PBG’s Situation Before Driver Training

• Before Training Pre-trips not completed Post-trips not completed DVIR’s not being signed by mechanics or drivers No formal retention process Limited communication between technicians and drivers

• Results of these actions were People were not trained or were unwilling to comply with process Not DOT compliant Failing internal DOT audits High level of break downs and road calls The need for a defined process was identified



PBG’s DVIR



Pre-Trip Checklist

Post-Trip Checklist

Vehicle Maintenance

Action

Driver Review

Driver Vehicle Inspection Report

PBG’s Pre-trip Process• Review prior day DVIR to see if vehicle was

written up for maintenance• Review comments written by driver• If work was performed by the fleet shop, it must have

a mechanic’s signature. This lets you know that the vehicle is OK to drive

• If work was performed, but the vehicle is not signed off, inquire with fleet shop about its status. The mechanic either signs off on the DVIR or assigns a new vehicle



PBG’s Pre-trip Process• Prior to operation of vehicle, driver must

sign off (legibly and dated) stating that he or she has reviewed the report and any repairs made



PBG’s Pre-trip Inspection• Step 1: Legibly write in the follow items

Date Truck#/Power Unit# and Trailer# (must

include all numbers) Location Mileage



PBG’s “No Defect” Process• Check off items as pre-trip inspection

is completed• If all items are in good working condition

check “NO DEFECTS”• Legibly sign name• Fill in route number• Exit facility

Driver Take Away: It takes about 10-15 minutes but it is one of the most important things a driver does each day.



PBG’s “Defect Found” Process

• Check off items as pre-trip inspection is completed

• If vehicle is operable, transport to fleet shop and see mechanic. If not, walk over to fleet shop and see mechanic.

• If possible, mechanic will make repair and sign off on white copy. If not, mechanic will assign new vehicle and driver must complete a new pre-trip.

• Exit facility



PBG’s Post-trip Process• The post-trip inspection is divided into different

sections. Each section has several components you must inspect.

• FMCSA - 396.11 Must Haves Service brakes (including

trailer brake connections) Parking (hand) brake Steering mechanism Lighting devices and reflectors Tires



Horn Windshield wipers Rear vision mirrors Coupling devices Wheels and rims Emergency equipment

PBG’s Post-Trip “No Defect” Process

• Check only items that need repair• If no repair is needed, check “NO DEFECTS”• Legibly sign your name• Proceed to check in lane• Turn white copy into checker/dispatcher

Driver Take Away: I am required to check more items during my post-trip. It generally takes 15-20 minutes, but the best way to avoid morning delays is to conduct a thorough post-trip.



PBG’s Post-Trip “Defect Found” Process

• Check only item(s) that need repair• Legibly sign your name• Proceed to check in lane• Turn white copy into checker• Take vehicle to fleet shop• See on duty mechanic and inform him of the

problem• Park vehicle as directed by mechanic• Mechanic will make repairs and sign off on Yellow

and Pink copy in the DVIR book. If repairs can not be immediately made a spare truck will be assigned

• Mechanic will file Yellow copyDial-in: 1-888-824-5783, Pass Code: 61156559#;

Tech Support: 1-888-259-8414, Webinar ID: 198466121


PBG’s Critical Success Factors

• Clear communication is essential• Establish responsibilities:

Driver: At the end of day, the white copy of your DVIR shall be turned in to the dispatcher or supervisor. The yellow copy is for repairs only. If no repair is needed discard the yellow copy. The pink copy remains in the book. Once your book is completely full, return it to fleet shop and pick up a new one.

Dispatcher/Supervisor: Must ensure the integrity and accuracy of the DVIR

Manager: Must ensure daily compliance and ultimately own the retention process. Manager should conduct random mock DOT audits to measure success.



PBG’s DVIR Document Flow



(If no repair is required yellow copy may be discarded)

White Copy Yellow Copy Pink Copy

UNIT FILE COPY FILE COPY DRIVER REVIEW COPY

Dri

ver

Upon final inspection of vehicle; driver turns in white copy of DVIR to

dispatcher/supervisor

Fill out Service Request Log at service desk in Fleet Shop.

Leave yellow copy in book in truck cab. (Mechanic will get)

Driver signs pink copy after review of mechanics repair. Pink copy stays with the book in truck cab until book is full.

Dispatcher/supervisor collects and records on "Daily DVIR Compliance

Sheet"Process owner forwards DVIR copies along with "excepted versus received"

number to MU Fleet Admin.

DV

IR F

ile

Ow

ner

File owner files white copy of DVIR in asset file and retains for 90 days

N/A N/A

Upon completion of repair mechanic signs, dates, and records work order repair number on yellow & pink copy

File in master asset file jacket.Mech

an

ic

N/AUpon completion of repair mechanic

signs, dates, and records work order repair number on yellow & pink copy

DVIR File Process

N/A N/A

Dis

patc

her

Su

perv

iso

r

“White Copy” Document Flow



UNIT FILE COPY

Driver Upon final inspection of vehicle; driver turns in white copy of DVIR to dispatcher / supervisor

Dispatcher / Supervisor

Collects and records on "Daily DVIR Compliance Sheet”; Process owner forwards

DVIR copies along with "excepted versus received" number to MU Fleet Admin.

DVIR File Owner

File owner files white copy of DVIR in asset file and retains for 90 days

Mechanic N/A

“Yellow Copy” Document Flow



FILE COPY

Driver Fill out Service Request Log at service desk in Fleet Shop. Leave yellow copy in book in

truck cab (Mechanic will get).


N/A

DVIR File Owner

N/A

Mechanic Upon completion of repair mechanic signs, dates, and records work order repair number

on yellow & pink copy. File in master asset file jacket.

“Pink Copy” Document Flow



DRIVER REVIEW COPY

Driver Driver signs pink copy after review of mechanics repair. Pink copy stays with the

book in truck cab until book is full.


N/A

DVIR File Owner

N/A

Mechanic Upon completion of repair mechanic signs, dates, and records work order repair number

on yellow and pink copy.

PBG’s Document Storage• DVIR’s are filed under a 90 day rolling

calendar system• Pros/Cons of keeping DVIR for more

than 90 days



Results of Driver Training• After Training

Pre/Post-trip are completed Passing internal DOT audits with flying colors Employee and manager ownership Improved communication between driver and technician

• Driver Benefits Improved asset uptime No departure delays Decreased risk of DOT fines Clearer lines of communication

• Technician Benefits Improved asset uptime Improved productivity Streamlined paper work process Educated driver



PBG’s Results• System benefits

DOT Compliant Trained/harmonious employees DOT Compliance tied in with manager performance appraisal Tracking system

No DVIR / No Check-in Key Performance Indicator in data system (excepted versus received)

• Next Steps Validating quality of DVIR’s Tie in to new hire process Determining cycle for retraining Electronic DVIR



Question & Answer

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using the Q&A tool





Associates, Inc.


Closing Remarks• Checkout the archive of past topics at:

http://www.jjkeller.com/nptcinfo PowerPoint slides up in 1-2 days Recording up in 1 week

• Topics for 2009: August 19 – OSHA Compliance for Private Fleets October 21 – Accident Management: A Nuts and Bolts

Approach



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