1. 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
Moderator
Dr. Gary Petty, President & CEO, NPTC
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Panelists
Tom Bray, Editor, Transportation Management, J. J. Keller & Associates, Inc.
Tom Moore, Vice President of Education, NPTC
Dan Norris, CTP, Fleet Operations Manager Atlantic Region, Pepsi Bottling Group
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2. Dr. Gary Petty President & CEO National Private Truck Council
Introduction
Gary Petty National Private Truck Council
Dr. Gary Petty
President & CEO
National Private Truck Council
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3. Gary Petty National Private Truck Council
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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Gary Petty National Private Truck Council
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4. DOT Inspection & Maintenance Requirements
Tom Bray J. J. Keller & Associates, Inc.
Thomas Bray
Editor, Transportation Management
J. J. Keller & Associates, Inc.
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5. 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!
Tom Bray J. J. Keller & Associates, Inc.
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6. 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
Tom Bray J. J. Keller & Associates, Inc.
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7. 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
Tom Bray J. J. Keller & Associates, Inc.
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8. 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.
Tom Bray J. J. Keller & Associates, Inc.
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9. 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.
Tom Bray J. J. Keller & Associates, Inc.
Delete or keep?
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10. 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!
Tom Bray J. J. Keller & Associates, Inc.
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11. Tom Bray J. J. Keller & Associates, Inc.
Driver Inspections
Required by the regulations
Pre-Trip (392.7 and )
Enroute inspections (392.9 and )
Post-Trip/DVIR (396.11)
Tom Bray J. J. Keller & Associates, Inc.
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12. Tom Bray J. J. Keller & Associates, Inc.
Pre-trip (392.7 and )
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).
Tom Bray J. J. Keller & Associates, Inc.
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13. Tom Bray J. J. Keller & 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.
Tom Bray J. J. Keller & Associates, Inc.
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14. Tom Bray J. J. Keller & 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
Tom Bray J. J. Keller & Associates, Inc.
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15. 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!
Tom Bray J. J. Keller & Associates, Inc.
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16. Tom Bray J. J. Keller & 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
Tom Bray J. J. Keller & Associates, Inc.
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17. 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
Tom Bray J. J. Keller & Associates, Inc.
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18. 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.
Tom Bray J. J. Keller & Associates, Inc.
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19. 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.
Tom Bray J. J. Keller & Associates, Inc.
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20. Technician Qualifications
details periodic/annual inspector requirements
details brake inspector qualification
Carrier is responsible for documenting qualification of their technicians
Tom Bray J. J. Keller & Associates, Inc.
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21. 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.
Tom Bray J. J. Keller & Associates, Inc.
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22. 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.
Tom Bray J. J. Keller & Associates, Inc.
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23. Vice President of Education National Private Truck Council
Raising the Bar
Tom Moore National Private Truck Council
Tom Moore, CTP
Vice President of Education
National Private Truck Council
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24. Why the Regs Aren’t Followed
Poor communication
Conflicting goals
Forms and processes that lead to poor follow-through
Tom Moore National Private Truck Council
If that’s the case, then why do so many fleets struggle with compliance?
In most of the cases drivers simply don’t understand the need for doing so and in many cases they don’t see the reward for doing so. What I’m talking about here is that even if they fill out the paperwork, their issues are not addressed by the shop. And in many cases, they are not rewarded financially for completing the pre-trip inspection.
Remember the old rule that what gets rewarded, gets done. So if drivers are bing paid by the mile, most are going to want to get out and start rolling as quickly as possible.
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25. 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
Tom Moore National Private Truck Council
Remember a good safety and maintenance program must take inspection procedures beyond mere compliance. Inspections allow the maintenance manager to keep his or her finger on the pulse of that equipment, helping to pinpoint problems in the formative stages, allowing the shop to schedule repairs without interrupting the utilization of the vehicle. These inspections can also help uncover safety-related defects. Remember that to a driver, safety and maintenance are one in the same.
So how are NPTC members raising the bar? They recognize that it is a shared responsibility. It is an opportunity for effective communications.
A good compliance program is built upon a strong, informed staff. Questions that determine if the employee understands why the procedure exists should also be asked.
Questions such as, “Why do you need to document your daily vehicle inspections at the end of the day?” will give an indication if the employee understands and believes in the regulation, or if they are just going through the motions in order to comply with company policy. An answer like, “I do it because that is how you told me to do it,” indicates that the employee is just going through the motions. If the answer indicates that the inspection is best documented at the end of the day because that is when the employee is most aware of defects in the truck, then they generally have a good understanding of the regulation exists.
To encourage the highest amount of cooperation, daily inspection forms should be quick and painless to complete. That is, provide a checklist of major component systems and allow a space for the driver to write in any remarks. Make sure there is a place for the reporting driver to sign and date the form, along with a section for the maintenance department to describe the actions taken.
If drivers believe you do not care about vehicle condition and maintenance, they will not care either. If new truck assignments, performance bonuses, and/or awards are tied to maintaining vehicle conditions drivers will start caring!
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26. 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)
Tom Moore National Private Truck Council
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27. Raising the Bar: Annual Inspections Best Practices
Consider more frequent inspections
Enhance internal communications
Improve vendor relationships
Tom Moore National Private Truck Council
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28. Audit Your Inspection Practices
Out of service rates
Accident rates
Equipment violation citations
Maintenance cost and repair
Tom Moore National Private Truck Council
Fleets can only be sure their system is working properly if they audit it on a regular basis. By entering information into a spreadsheet or database, they can begin to see trends in compliance patterns. Some of the items fleets should consider tracking include:
Out-of-Service Rates: If DOT is putting the vehicles out of service, then your employees are not detecting the problems. If your drivers are putting the vehicles out of service, then they are doing their job.
Accident Rates: A good accident investigation program will help you determine the cause of your problems. If you begin to see vehicle problems appearing as causes, then you likely have problems with your inspection and maintenance programs.
Equipment Violation Citations: Equipment violation trends are good indicators of how well your system is working. You should require your divers to provide you with copies of any violations and citations they receive as soon as possible after they occur. You can also obtain a copy of your carrier profile by contacting FMCSA. You should monitor these information sources on a regular basis in order to determine if your program is working effectively.
Maintenance Cost and Repair: Reviewing maintenance cost and repair types is also a good indicator of how your system is working. An exorbitant amount of expensive, “emergency” repairs may indicate that your preventive maintenance and inspection programs are breaking down. Stable repair costs, involving mostly routine repairs, are a good indicator that your procedures are being followed properly.
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29. Benefits of Raising the Bar
Lower overall maintenance costs
Increased fuel mileage
Improved driver retention
Improved on-time percentages
Tom Moore National Private Truck Council
Lower overall maintenance costs (PM and in-house repairs are always cheaper than on-road emergency repairs due to breakdowns or OOS orders),
increased fuel mileage (tire inflation and lubrication),
improved driver retention (drivers that are constantly broken down tend to go to work somewhere else), and
improved on-time percentages due to less breakdowns and out-of-service orders.
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30. The Pepsi Bottling Group Experience
Dan Norris Pepsi Bottling Group
Dan Norris, CTP Fleet Operations Manager Atlantic Region Pepsi Bottling Group (PBG)
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31. Dan Norris Pepsi 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.
Dan Norris Pepsi Bottling Group
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32. 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
Dan Norris Pepsi Bottling Group
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33. Vehicle Maintenance Action
PBG’s DVIR
Driver Vehicle Inspection Report
Pre-Trip Checklist
Dan Norris Pepsi Bottling Group
Post-Trip Checklist
Vehicle Maintenance Action
Driver Review
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34. 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
Dan Norris Pepsi Bottling Group
Why is my hand writing so important?
DVIR is a legal document
Readability of unit number affects filing
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35. 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
Dan Norris Pepsi Bottling Group
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36. 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
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37. 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 minutes but it is one of the most important things a driver does each day.
Dan Norris Pepsi Bottling Group
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38. 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
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39. PBG’s Post-trip Process
The post-trip inspection is divided into different sections. Each section has several components you must inspect.
FMCSA Must Haves
Service brakes (including trailer brake connections)
Parking (hand) brake
Steering mechanism
Lighting devices and reflectors
Tires
Dan Norris Pepsi Bottling Group
Horn
Windshield wipers
Rear vision mirrors
Coupling devices
Wheels and rims
Emergency equipment
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40. 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 minutes, but the best way to avoid morning delays is to conduct a thorough post-trip.
Dan Norris Pepsi Bottling Group
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41. 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 copy
Dan Norris Pepsi Bottling Group
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42. 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.
Dan Norris Pepsi Bottling Group
When you visit the doctor, do you only tell her about a few symptoms your having or do you disclose everything? If your doctor only has half the story what’s the chance of her making the proper diagnoses? For example: you wouldn’t tell the doctor your leg hurts when in fact you have a broken leg. You would probably tell the doctor it’s broken and how you broke it.
The same applies when writing up your vehicle for service. The more information you communicate about what’s happening with your vehicle, the more likely it can be fixed right the first time.
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43. PBG’s DVIR Document Flow
Dan Norris Pepsi Bottling Group
3 Copy v 4 copy
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44. “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
Dan Norris Pepsi Bottling Group
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45. “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).
Dispatcher / Supervisor
N/A
DVIR File Owner
Mechanic
Upon completion of repair mechanic signs, dates, and records work order repair number on yellow & pink copy. File in master asset file jacket.
Dan Norris Pepsi Bottling Group
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46. “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.
Dispatcher / Supervisor
N/A
DVIR File Owner
Mechanic
Upon completion of repair mechanic signs, dates, and records work order repair number on yellow and pink copy.
Dan Norris Pepsi Bottling Group
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47. 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
Dan Norris Pepsi Bottling Group
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48. 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 productivity
Streamlined paper work process
Educated driver
Dan Norris Pepsi Bottling Group
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49. Dan Norris Pepsi Bottling Group
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
Dan Norris Pepsi Bottling Group
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50. Please submit questions to “Q&A”
Question & Answer
Gary Petty National Private Truck Council
Tom Bray J. J. Keller & Associates, Inc.
Tom Moore National Private Truck Council
Dan Norris Pepsi Bottling Group
Please submit questions to “Q&A”
using the Q&A tool
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51. Gary Petty National Private Truck Council
Closing Remarks
Checkout the archive of past topics at:
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
Gary Petty National Private Truck Council
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