Brakes or No Brakes—Stay in Control

Dump truck crashes on 2222

The dump lost its brakes, went through the intersection and hit several vehicles before it went off the bridge off of Texas 2222.

Brake Check!

Professional drivers do a brake check before starting the day AND before fully committing to a downgrade.

This can mean daily doing those ‘dumb’ checks required by the CDL test like the Air Brake Leak Down Test and the Stall Test, and fully stroking the brakes by pressing the pedal to the floor—so the automatic slack adjusters (ASAs) stay in adjustment.

           Air-Brake Check Checklist

Chock or Block wheels and start the engine

Build air pressure up to 120 PSI

Turn engine off

Release the parking/trailer brakes (push knob(s) in/down) After air pressure stabilizes wait 1 minute

Air Pressure should drop no more than 3 PSI in a minute Hold the brake pedal down firmly

After pressure stabilizes hold pedal for 1 minute

Listen for audible air leaks

Air pressure should drop no more than 3 PSI in one minute (tractor only) or 4 PSI in 1 minute if combination unit

Turn the ignition switch on (but not the engine)

Pump the brake pedal until the low air warning buzzer sounds at 60 PSI

Continue to pump brake pedal until the red brake button pops out between 20 & 45 PSI

Remove chocks/blocks

If a trailer is attached:

With trailer brakes applied and tractor brakes released, complete 2 firm tug tests to be sure the trailer brakes are properly adjusted and hold against the tug

When the truck is in motion apply the service brakes to be sure they are operational

 

Check the Brakes before a Downgrade, Too . . .

The integrity of the brake system needs to be checked before a downgrade as well. It only takes a second to see if you have some pedal. And be sure to place the vehicle in the proper gear for the grade.

Why Are Daily Brake Checks Necessary?

Daily brake checks are necessary for several reasons:

  • All equipment degrades over time due to wear and tear. Drivers then start to adjust their driving behavior to compensate for the failing performance of the brake system. There have been serious crashes where it was later found that only one of the foundation brakes were properly working and in adjustment.
  • We need to catch things before bigger problems occur
  • Sometimes adjustments are made that compromise the system (slacks are backed off by mistake, or air lines mis-routed during a service—It happens!)
  • Your life and the lives of the public are on the line
  • Brake citations—year after year—are the number one citation during roadside inspections

Stay in Control

A cardinal rule of diving is always keep the vehicle under control—no matter the situation. It is never a good situation when a driver loses control of the vehicle.

Daily brake checks can catch a small problem before it turns into a big problem, help keep the ASAs in proper adjustment, and help the driver to always stay in control.

Thank you for reading this.

Learn more about brake inspections:  Commercial Motor Vehicle (CMV) Inspections

Maintenance Matters . . .

no maintenance

Don’t Worry About It . . .

Long ago I checked the oil on a company F-350 that I needed to use to haul some wood mouldings. Nobody told me to check the oil. It was already an ingrained habit from operating farm equipment. Always check your fluids — all of them.

The oil was black and tarry. I had never seen anything like it before.

I mentioned this fact to the company owner.

“Don’t worry about it,” he said. “It’s on a lease.”

I cringed when I heard that. To make a long story short . . . the truck later required some major service . . . and the wood moulding plant — built with a government loan — experienced several fires, resulting in the eventual loss of the business to the auction gavel.

The Golden Window of Opportunity

Anything made has a service life. Almost anything made needs both routine and preventative maintenance (PM) or it won’t even come close to its expected life. Pay now or pay later.

But investment in maintenance shouldn’t be a burden. In fact it can — and should— represent an opportunity.

That window of opportunity presents itself in the period of time a part or system starts to show poor performance — prior to a repair being made. The part may be in a sub-critical condition and is doing its job, but could be showing signs of wear, a need of an adjustment or a service. This is the time replace the part or do the repair — before it fails.

The window of opportunity is the basis of a good maintenance. Good maintenance means preventative maintenance. Most of our maintenance efforts (translation: 80%) should be preventative maintenance.

Another key to good maintenance results is the preventative maintenance inspection.

Risk-Based Preventative Maintenance Inspections (PMI)

• Insure risk of failure is reduced to as low as possible.

• Result in optimum inspection schedules.

•.Focus inspection efforts on the the most critical areas.

• Create value from inspections.

There are many apps out there that can help in setting up or refining your preventative maintenance program.

Than you for reading this.

The Delivery Area Safety Inspection

Night loading at papermill

Identifying Hazards

A hazard is sometimes defined as the precondition for an accident. Management needs to create a safety culture in which the entire organization—every employee, every function, every level—has the capability and the responsibility for hazard identification.

One effective tool for hazard identification is the workplace inspection. Inspections can be conducted at anytime and, with proper training, by employees, supervisors or managers.

The Delivery Area Safety Inspection is an example of a safety or hazard inspection which can be conducted at a dock, cross-dock, or shipping and receiving area.

Security*

  • How is the load secured when the driver is not in attendance?
  • Is there a load seal on each delivery/shipment? What is the procedure to break the seal?
  • What is the policy/procedure to check shipping papers/manifest against the delivery/shipment?
  • What is the policy/procedure to check for damage to the shipment?

Conformance to Job Safety Analysis (JSA)

  • Is there a Job Safety Analysis (JSA) on file for dock-area staff? Is the JSA signed by management?
  • What Personal Protection Equipment (PPE) are required?
  • Do drivers follow the 3 Points of Contact during ingress/egress?
  • What kind of a barrier gate is in place that prevents loading equipment from colliding with and damaging the dock doors?
  • What kind of dock-lock system or vehicle restraint is in place? Does dock-lock system have a light bar with roll-up door control? What is the plan for regular maintenance on the vehicle restraint equipment as bumpers, lights, communication packages, and other loading dock accessories?
dock lock

A dock-lock system

If no vehicle restraint system is in place, how are the tires chocked or vehicle secured against movement?

  • What is the policy/procedure for Loading/Unloading? Tank hook up? Tank filling?
  • What Safety Data Sheets (formerly MSDS) are posted?
  • What is the policy/procedure for Emergency Procedures? Co-Mingling of Hazmat Classes?
  • What is the procedure to report hazards or concerns, unsafe practices, or damaged equipment to supervisors?

Top Tip: Workers on foot should never be on the
opposite side of a flatbed truck from a forklift while it is loading or unloading material. CNA

Driver and Location Issues

  • Is there a need to back up?
  • Where do drivers take their Shipping Papers/Load Manifest?
  • How is the area control? Where do drivers go when loading/unloading?
  • What are any access obstructions?
  • What kind/nature of any slopes are present?
  • What foot traffic is allowed in the area?
  • Are there any storm drains?
  • What kind of worker exposure is there to open loading dock doors and other areas that employees could fall 4 feet or more?

*Definitions

Safety refers to the measures taken to protect the driver, vehicle and cargo during transport operations from hazards.

Security refers to the measures taken to protect driver, vehicle and cargo against sabotage, attacks, and theft while it is in transport.

Dock Incidents and Accidents are Rare . . . but Deadly

dock hazards

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Drivers — especially new drivers — need to know where to be at all times while in the Material Transfer Zone (MTZ). There are potential hazards from moving vehicles and lift trucks, many times moving in reverse with limited sight distance, slip and fall hazards from climbing up and down or from uneven or slippery surfaces, and unique location hazards.

That’s why it’s a good idea to periodically inspect your dock areas — before something happens . . .

Thank you for reading this.

The Walkaround Inspection

inspect

 

A daily safety inspection is required by Federal Motor Carrier Safety Regulations

Inspection/Inspect – this refers to personnel performing a visual examination usually performed using a checklist, a flashlight, and personal protective equipment (PPE) as gloves, goggles, bump cap, and an air gauge.

Tip: When walking up, approach vehicle from a different direction each time.

Look for:

Faults 

Fault – a defect in need of correction ranging from minor to serious or major.

Damage: new damage or “mystery” damage to vehicle,
Check body exterior for accident damage, scratches, dents, rust, etc.

• Note if the Vehicle is leaning or tilted to one side indicating:
– a flat (80% or less of rated inflation) or underinflated tire
– a broken spring or suspension,
– a shifted load.
Things and people around and under vehicle:
– other vehicles (yard trucks or smaller vehicles)
– low power lines, tree branches, overhead or low building overhangs,
– people around or under vehicle*
• Fluid puddles under engine area: oil, transmission fluid, etc. ,
• Loose or hanging items under the vehicle.

* A teen was found sleeping under a trailer at a terminal. Intoxicated persons have been found sleeping under trailers, or a mechanic may be working under the vehicle.

Body Exterior

a.) Check that no body damage has sharp edges or protrusions that could present a snagging or hazard to people around the exterior of the vehicle.

b.) Body panels, rivets, or other components are damaged or corroded to the point where joint strength or body structural integrity is compromised.

c.) Body has rusted through areas on body panels or water leaks

NO-GO: Until repaired: b. above; record all other defects.

NOTE: A sufficient repair for item b. would be a complete body panel replacement

walkaroundThere is no “right way” to inspect a truck as every truck is different.

Top Tip: Always do the safety inspection the same way every time.

Use and follow any Safety Inspection checklists your company provides.  Inspecting the vehicle is a legal matter, a safety matter and a Commercial Driver License (CDL) obligation.

Check the king-pin release, if you have been away from the truck.

Check the king-pin release, if you have been away from the truck.

Keep in mind that the Federal Motor Carrier Safety Regulations (FMCSRs) are the MINIMUM safety standards.

§393.1: SCOPE OF THE RULES IN THIS PART.

(a) The rules in this part establish minimum standards for commercial motor vehicles as defined in § 390.5 of this title.

Critical Inspection Areas – components or systems that need to be at a high level of safety, generally containing no faults.

Thank you for reading this.

 

Periodic Inspection Training (PIT)

cropped-mast1.jpgThe Michigan Trucking Association offers Periodic Inspection Training (PIT) classes each quarter. This is a two day class held in Lansing, MI.

What are Periodic Inspections?

Every commercial motor vehicle shall be inspected as required by this section. The inspection shall include, at a minimum, the parts and accessories set forth in Appendix G of this subchapter. §396.17 Periodic inspection

Part 396.17 refers to the the annual or “Periodic inspection” that must be done on every truck, trailer, and converter dolly if so equipped that is used in business (commerce).

Inspectors must be qualified. Are your Part 396.17 inspectors properly qualified? Most are not.

Inspector Qualifications

§ 396.19: INSPECTOR QUALIFICATIONS.

(a) Motor carriers and intermodal equipment providers must ensure that individuals performing annual inspections under § 396.17(d) or (e) are qualified as follows:

(1) Understand the inspection criteria set forth in part 393 and appendix G of this subchapter and can identify defective components;

(2) Are knowledgeable of and have mastered the methods, procedures, tools and equipment used when performing an inspection; and

(3) Are capable of performing an inspection by reason of experience, training, or both as follows:

(i) Successfully completed a Federal-or State-sponsored training program or have a certificate from a State or Canadian Province that qualifies the individuals to perform commercial motor vehicle safety inspections, or

(ii) Have a combination of training or experience totaling at least 1 year. Such training or experience may consist of:

(A) Participation in a commercial motor vehicle manufacturer-sponsored training program or similar commercial training program designed to train students in commercial motor vehicle operation and maintenance;

(B) Experience as a mechanic or inspector in a motor carrier or intermodal equipment maintenance program;

(C) Experience as a mechanic or inspector in commercial motor vehicle maintenance at a commercial garage, fleet leasing company, or similar facility; or

(D) Experience as a commercial motor vehicle inspector for a State, Provincial or Federal government.

(b) Motor carriers and intermodal equipment providers must retain evidence of that individual’s qualifications under this section. They must retain this evidence for the period during which that individual is performing annual motor vehicle inspections for the motor carrier or intermodal equipment provider, and for one year thereafter. However, motor carriers and intermodal equipment providers do not have to maintain documentation of inspector qualifications for those inspections performed either as part of a State periodic inspection program or at the roadside as part of a random roadside inspection program.

Options for Qualification

There are two and only options listed above in 396.19:

  1. Training, or
  2. Training and experience

There are few training courses available in the U.S. like the PIT classes at the Michigan Trucking Association.

Being a truck mechanic does not qualify one to do periodic inspections, even if holding a state license. This training is essential.

Contact:

Michigan Trucking Association
1131 Centennial Way, Lansing, MI
517-321-1951

Next class is April 6-7th, 2016 and it’s full.

Thank you for reading this.

Test Your Air Brakes

runaway truckOn February 26, 2016 a loaded dump truck was caught on camera as it slammed into a car and careened out of control through a busy intersection at 2222 and Jester Blvd in Austin, TX, resulting in a crash that involved four vehicles.

On February 29, 2016 an 18-wheeler loaded with gravel slammed into a home at 260 Windsor Drive in San Carlos (between Redwood and San Francisco, CA). It was the second time in two years, according to the daughter of the homeowner. The driver was taken to the hospital.

In both of these recent crashes, the trucks were not able to stop.

Brakes are the No. 1. Out-of-Service (OOS) Violation

Every year the Commercial Motor Vehicle Safety Alliance (CVSA) holds its annual International Roadcheck. Every year the number one Out-of-Service violation is a faulty brake system.

While the numbers are trending down, last year 27.5% of vehicle violations were for bad brakes (and 15.5% of OOS was for brakes that were out of adjustment).

Out-of-adjustment brakes and brake system violations combine to represent half of all out-of-service violations issued for commercial vehicles on the road. Brake systems that are improperly installed or poorly maintained can reduce the braking capacity and stopping distance of trucks or buses, a serious safety risk. CVSA

Some Simple Brake Tests

Always chock the wheels when preforming brake checks!

Smaller commercial vehicles may have hydraulic brakes

• Hydraulic Brake Check

With the engine running, pump the brake pedal three times, then hold the pedal down for five seconds. The brake pedal should not move (depress) during the five seconds.

•Air Brakes

Air Gauge(s) Check ►

For vehicles built after April 1, 1977, check for presence of two (2) air pressure gauges (or a single gauge with dual needles).

Gauge(s) must be accurate to within ± 7% (at 100 PSA 7% = 7 PSI).

Governor Check ►
Check air brake system governor operation. While building up system air pressure, note pressure at which governor cuts-out (compressor quits compressing). With engine still running, pump brakes to lower air pressure until compressor cuts-in (starts compressing again). Note pressure.
(a) Cut-out pressure is too low (below 100 PSI) or too high
(above 130 PSI).
(b) Difference between governor cut-out and cut-in pressure
exceeds 25 PSI
(c) Cut-out pressure is below 120 p.s.i. (for buses equipped with air dryer system; repair).

Parking Brake Check or “Stall” Test ►

With parking brake applied, place in gear and gently tug against the brake to see if it will hold the vehicle.

Air Loss or Leak-Down Test ►

With the engine running, air pressure should be at the governed cut-out (120-125 psi).
1) Shut off the engine (in 2nd or 3rd gear).
2) Release (push in) the YELLOW tractor protection valve/parking brake valve. RED valve should be IN also.
3) Roll down window and listen for any audible air leaks which may be a blown diaphragm in the chamber or leak in line. (Any audible air-leak is a NO-GO condition)
4) Make a note of the air pressure.
5) Apply the foot brake, and hold for one minute.
6) Note air pressure drop resulting from brake application. Check the air gauge to see if the air pressure drops more than three pounds in one minute (single vehicle) or four pounds in one minute (combination vehicle) or five pounds in a minute for combination vehicle with doubles.

NO-GO: If pressure drop is greater than 15 p.s.i. do not move the vehicle until brakes have been adjusted or repaired.

Low air warning devices §393.51(c)
Turn the key to the “on” position without starting the
engine and begin fanning off the air pressure by rapidly applying and releasing the foot brake.

Low air warning device(s) (buzzer, light, or flag) should activate before air pressure drops below 60 p.s.i. on gauge.

Protection valves Pop-off Test §393.43
• Continue to fan off the air pressure starting with at least 60 p.s.i. in air system and noting air pressure at which valve “pops out.”

Between approximately 20-40 PSI on a tractor-trailer combination vehicle, the tractor protection valve and parking brake valve should close (pop out). On other combination vehicle types and single vehicle types, the parking brake valve should close (pop out).

NO-GO: If valve pops over 50 psi or does not work between 15 – 40 PSI.

Check Your Air Brakes Daily

Drivers can inspect their brake systems every day. Even if you can’t go under the vehicle, you can listen for air leaks, check low air signals and look for component damage. If you can go under your vehicle, you can measure pushrod stroke the same way a CVSA-certified inspector does, and compare the results to the pushrod stroke limits set by regulation.  CVSA

Thank you for reading this.

More . . . Operation Airbrake Inspection Procedures

False Accusations Abound!

bad1The more corrupt the state, the more numerous the laws. — Tacitus, The Annals of Imperial Rome

The more laws and restrictions, there are, the poorer people become. The more rules and regulations, the more thieves and robbers. Lev Kopelev

“You Were Texting and Not Wearing a Seat Belt.”

A while back a truck driver was pulled over, the reason given was for texting and not wearing a seat belt.

When shown a video tape that these allegations in fact, did not occur, the arresting officer (yes— when you’re given a ticket or citation in lieu of arrest, this is sometimes called a “warrantless arrest” or an arrest without warrant ), decided to issue a clean North American Standard Level III Driver/Credential Inspection (which includes the seat belt), saying he had decided “I am going to let you go.”

The truck driver was perplexed. What if no video was available? What might have happened if the existence of the video was not made known?

And how many more times that day were similar citations issued to undeserving truck drivers? How many would fight them?

Lunch Money

One of the finest truck driving instructors I worked with was an old Teamster who at one time delivered beer to Chicago. Charlie had over forty years of truck driving experience and was a fountain of knowledge and knew all of the facts of life about truck driving.

Back in his day, when Charlie went through Chicago he had to fold a $10 bill (worth about $50 in today’s dollars) called “lunch money” and clip it to his driver’s license with a paper clip. Every time he was stopped by local authorities, he would get his license back and the “lunch money” would be gone.

Lesson’s Learned

The driver in the beginning of the blog learned a valuable lesson: As a truck driver one can be accused at any time of the most outrageous violations. Be prepared.

The driver immediately stopped at the next exit and removed all electronic devices from the dash: GPS, cell phone, electronic logging tablet, etc.

Event Recorders

A big selling point for “Video Event Recorders” that capture real-time video and sometimes other data in the course of an event, incident, or accident, is the video can be used to defend a driver against false claims. Lytx says in 80% of collisions, it’s not the truck driver’s fault. Swift has agreed to install Lytx DriveCam recorders on thousands of power units.

Verizon makes similar defense claims about their Networkfleet’s vehicle tracking diagnostics, as does Telogis.

Accusations Abound

Everyday fleets and their drivers are accused of all sorts of things ranging from stone damage to glass, to vehicle or property damage.

1. Take all reports seriously. In the case of stone damage, unless unsecured rocks were falling off of the back of the vehicle, there is not much relief warranted — especially in the instance of vehicles following too closely. Other the other hand, further investigation may reveal bad judgment and choices on part of the driver. Have a system in place to capture and respond to these types of events.

2. Take advantage of new technology. There are opportunities to deploy new accident avoidance systems to avoid trouble and accident recording devices to help defend against claims. Some insurance companies may reduce premiums for installing these devices.

3. Protect your reputation. Protecting your reputation has been called by some a critical job skill. There is endless business pressure to cut corners, “bend the rules,” and take shortcuts. Nobody is immune from this pressure. Good risk management teaches us to be aware of catastrophic risk — a risk that might have the potential to inflict serious damage. Breaking and bending the rules, and taking shortcuts can result in catastrophic outcomes, no matter how good the intentions.

Thank you for reading this.

You Can’t Expect . . . Unless You Inspect

Feel the sidewalls for bulges and defects.

Feeling the sidewalls for bulges and defects.

Management needs to create a safety culture in which the entire organization—every employee, every function, every level—has the capability and the responsibility for hazard identification.

A hazard is sometimes defined as a precondition for an incident or accident. One effective tool for hazard identification is the inspection. Inspections can be conducted at anytime and, with proper training, by employees, supervisors or managers. Pay particular attention to the maintenance area as it is frequently overlooked.

Vehicle inspections need to be conducted daily with the results of the inspection documented. Annual or periodic inspections for Commercial Motor Vehicles (CMVs) should be conducted by properly qualified inspectors.

Vehicle Inspections

Daily vehicle safety inspections of commercial vehicles (as defined in 49 CFR Part 390.5 Definitions) – are required under the regulations. Critical items must be inspected and a Driver’s Vehicle Inspection Report (DVIR) made and signed by the driver, and if any safety defects are found – signed by the attending mechanic and the original again signed by the driver. These inspection records must be kept for at least ninety days as part of the Vehicle File.

Proper inspection protocol includes a pre-trip, en-route (and/or any conditional inspections) and written post trip inspection and should include information as times the inspection was conducted and beginning and ending mileage.

All material handling equipment should be inspected as well by the operator before use, on a schedule and after routine maintenance. Be sure any worn warning labels or damaged decals are replaced and the inspection is documented.

What are Conditional Inspections?

Conditional Inspections, are “conditional” on the presence of red flags or warning signs, and are perhaps the most important, but least talked about inspection.  For example, a driver who had lost a 40,000 pound steel coil resulting in a triple fatality reported he had braked suddenly, but following the braking incident he had neither stopped nor had he checked the load securement. Another example of a failed opportunity for a conditional inspection was a truck that struck a tree limb, knocking down freight inside the trailer resulting in a fire that flashed and hurt several firemen when they opened the trailer door.

Conditional inspections should be conduced on a vehicle or its load after:

  • sudden braking, swerving or lane changes;
  • striking live wires or power lines; (driver may have to remain in vehicle for safety)
  • striking tree limbs, electric poles or guide wires, etc.

Conditional inspections should be done on an as-needed basis.

Periodic Inspections

Periodic or annual inspections of all Commercial Motor Vehicles (CMVs) – as listed in 49 CFR Part 390.5 Definitions – are required at least once every twelve months under Part 396, documenting the inspection of all the parts and components listed in Appendix G, performed by qualified inspector. Some companies require this inspection be performed:

  • every quarter
  • prior to every international border crossing
  • after involvement in a major collision

Who is a qualified DOT Inspector to administer the periodic or annual vehicle inspection?

While the annual or periodic vehicle inspector is “qualified” by the company, certain forms must certify the inspector has 1) experience and 2) training or is qualified by proper training. Evidence of training would be a Certificate of training.  (49 CFR 396.17 and 396.19).

Proper inspections are the only way to ensure a minimal level of safety. After all, you can’t expect . . . unless you inspect.

Thank you for reading this.

More  . . . CSA Tire Inspection

J Taratuta

 

John Taratuta is a safety advocate and Risk Engineer. (989) 474-9599

Equipment Mug Shots from Recent Roadside Inspections

loose or missing

All the lug nuts are loose. Except for the one that’s not there at all . . .

Clues: Shiny metal. Steams of corrosion.

But it only gets worse . . .

1of10

This photo was also recently taken at a roadside inspection. There was only one lug nut on this set of wheels.

What was this driver thinking?

During a pre-trip inspection, drivers need to look for:
– Stud or bolt holes out of round.
– Cracks between the hand holes (or air vents).
– Cracks between hand hold and bolt holes.
– Cracks from handhold to rim.
– Cracks from bolt hole to bolt hole.
– Check valve stem for damage and valve cap is in place.
– Check valve hole for damage or severe corrosion.
– Look for illegal welds or repairs.

Grab each lug nut and give it a hard twist to check for any looseness.
– Check for looseness indicated by rust streaks or shiny metal.
– Look for oxidation on aluminum rims.
– There should be no missing lugs or missing studs.

I like to highlight training points with newspaper stories.

Seriously injured by a loose wheel.

Now, Let’s Check the Brakes . . .

loose chamber

The old “piece of rope and bungee cord trick” to hold up your brake chamber . . .  A good way to someday meet in the judge’s chambers.

baldy

Been putting on some miles lately? Slick road meet slick tire.

Lastly, here is a recent, short video (less than 1 minute) that shows what happens when the suspension system is not inspected . . .

Incredible Tales of Woe

The stories coming from Roadside Inspectors are unbelievable. When you hear of the trucks with tires and wheels about to fly off (wheel offs), steering with massive free play, trailers with no kingpins, etc., it can send a chill down your spine.

When you actually see it, it’s hard to fathom how any driver would allow things to go that far or get that bad. Somebody is not doing their job. Part of the job is doing a good pre-trip inspection.

A Good Pre-trip Inspection

A good pre-trip means drivers should “Inspect to fail.”

Inspect to fail means to give as thorough an inspection as possible looking for all of a vehicle’s present safety defects or faults. Inspect to fail means, if a part, component or system on a vehicle (or the driver) does not meet, or fails to meet the standards in the Federal Motor Carrier Safety Regulations, (FMCSRs) 49 CFR Part 393 Parts and Accessories Necessary for Safe Operation, then the vehicle is not roadworthy and should not be driven.

Keep in mind that the FMCSRs are the MINIMUM safety standards.

  • 392.7 Equipment, inspection and use.

No commercial motor vehicle shall be driven unless the driver is satisfied that the following parts and accessories are in good working order, . . .

  • Service brakes, including trailer brake connections
  • Parking (hand) brake
  • Steering mechanism
  • Lighting devices and reflectors
  • Tires
  • Horn
  • Windshield wiper or wipers
  • Rear-vision mirror or mirrors
  • Coupling devices.
  • 393.1 Scope of rules in this part.

“Every employer and employee shall comply and be conversant with the requirements and specifications of this part. No employer shall operate a commercial motor vehicle, or cause or permit it to be operated, unless it is equipped in accordance with the requirements and specifications of this part.”

Drivers need to know these regulations like the back of their hands to be “conversant.”

Thank you for reading this.

What are DOT Log Book Form & Manner Violations?

regulations

 

 

 

 

 

 

 

 

Learning the nuances of logging (running under a DOT log book — also known as the Record of Duty Status or RODS) is something that sometimes falls through the cracks in the course of many driver’s development. Instructions and the example found on the back of the logbook may have been the only training many drivers have ever had. On occasions, a DOT officer will sit down with the driver and explain the facts of life about logging.

“My school, nor my company ever got into this specific rule . . .”  Driver

Electronic logging is not a solution, if the driver does not know what he is doing. (See: 395.15(c) Onboard recording device improper form and manner.)

Form and manner violations are log inaccuracies (usually unintentional), sometimes caused by carelessness or even bad habits in filling out the log sheet, and are considered minor violations. (Major violations would be: missing logs, false logs, 70 Hour Rule violations carrying over for more than one day, 11 or 14 Hour Rule violations not created by grid errors, dropped trips.) But small things can start to snowball, and even a form and manner violation will result in one CSA severity point (multiplied by a Time Weight (TiW) of 3 points = 3 points).

One definition of form is the manner or conduct as tested by a prescribed or accepted standard. Manner is defined as a way in which a thing is done or happens.

So a form and manner log violation has to do with the way a log book is done, according to the standard. The standard would be the requirements of 49 CFR Sec. 395.8.

Section d. lists the following:

(1) Date;
(2) Total miles driving today;
(3) Truck or tractor and trailer number;
(4) Name of carrier;
(5) Driver’s signature/certification;
(6) 24-hour period starting time (e.g. midnight, 9:00 a.m., noon, 3:00 p.m.);
(7) Main office address;
(8) Remarks;
(9) Name of co-driver;
(10) Total hours (far right edge of grid);
(11) Shipping document number(s), or name of shipper and commodity;

required information on a DOT log book

Missing information in any of the above requirements would result in a citation for improper form and manner. Trouble comes in the form of abbreviations in the remarks area (as putting down SLC instead of writing out Salt Lake City, UT). But that’s not all.

Sloppiness Counts As Well

clean corners

 

 

 

 

 

Drivers should show clean corners on a paper log book. Use the edge of a ruler to guide the line.

extension line

 

 

 

 

 

Here the extension line should be extended to the remarks section for precision.

center lines

 

 

 

 

 

In this example the status line is not centered between the grid lines.

thin_line

This line has been drawn too light by a fine pen and may not copy well in a fax or copy machine. This is an example of a scripting error. Use a medium point pen for logging.

writing on the grid

Writing on the grid is another error.

Form and manner violations include:

Log Sheet Missing: Drivers shall submit a log for each day, except that two or more consecutive off duty days may be on one sheet Note: regulations require that driver separates off duty days that fall between months by submitting a minimum of two logs;

Date Missing/Duplicate Logs: Each log must be dated and there must be only one log submitted for each day;

Miles Driven Missing: Total actual miles driven in the 24- hour period must be entered;

Vehicle/Trailer Number(s) Missing: Unit numbers of all company vehicles operated in the 24-hour period must be entered;

Driver‘s Signature Missing in Error: The driver must sign his or her full legal name on each daily log sheet;

Co-Driver Name Missing: The driver must enter first name, initial and complete last name of his/her co-driver if operating as a team;

Missing Shipment Identification Error: The driver must show a Trip Number(s) for each trip in the 24-hour period;

Pre-Trip Inspection/Post-Trip Inspection Improperly Noted: Drivers shall identify locations, by full city name and state abbreviation, when performing vehicles inspections;

Change In Duty Status/improper Remarks: Driver’s shall identify locations when changing duty status, by full city name and state abbreviation.

Different Log For Same Day: Each log graph can carry only one set of information;

Hours Missing Error: Drivers must record total hours used at the end of each line of the graph. The hours added together must equal 24;

Graph Incomplete Error: A driver must account for all time on the graph. Drivers must show a complete continuous line for each 24-hour period.

Each year tens of thousands of form and manner violations are cited by the DOT. Work to educate your drivers on the importance of precision logging.

This information was condensed from our Log Audit Guide.

As always, thank you for reading this.

 

The 8 Biggest Mistakes Made In Dealing With Regulations . . .

1. Ignoring Deadlines

time

 

 

 

 

 

If you get an official notice or a notice from an official, then deal with it. Immediately. Wait until the last day and you are asking for trouble. Once the deadline passes, if you were facing a fine or other sanctions, you may lose your rights to an appeal. Don’t wait until the end of the day: remember the government’s “business day” legally ends at 5 PM not midnight.

Some current problem areas include the Biennial Update or renewal of DOT Number registration or the return of the completed roadside inspection form to the issuing agency (§396.9 Inspection of motor vehicles in operation).

2. Not Filling out Forms — Completely

Mr. Doc

 

 

 

 

 

 

An incomplete form or unsigned form may be taken for a missing form. If the correct response is “NONE” then write “NONE” not “n/a.” And don’t accept “bad paperwork” from employees.

Common errors are found in applications for employment, log books, driver’s vehicle inspection reports (DVIRs), shipping paperwork and supporting documents for logbooks.

3. Not reading, checking or verifying incoming paperwork

why

 

 

 

 

 

When checking documents, ask yourself “Why?” Why does the results of a drug test have a certain box checked off? Why don’t the supporting documents match the logbook? Why didn’t the driver (or mechanic) sign the DVIR?

You are responsible for every piece of paper crossing your desk. So make every day
your why day.

4. Not Reading the Regulations

regs

 

 

 

 

 

“Every employer shall be knowledgeable of and comply with all regulations contained in this subchapter which are applicable to that motor carrier’s operations.” (49 C.F.R. Part 390.3(e) Knowledge of and compliance with the regulations)

Sure it’s dry stuff. But here’s a tip: Start the Federal Motors Carrier Safety Regulations (FMCSRs) at 49 C.F.R. Part 390 — that would be Chapter One of any other book . . .

5. Not Reading Into the Regulations Far Enough

read me

 

 

 

 

 

The same section goes on to say in (2) “Every driver and employee shall be instructed regarding, and comply with, all applicable regulations contained in this subchapter.” If you are the employer and driver, then all the regulations apply.

Don’t stop reading at the point when it seems the regulations meet our predisposed expectations. Keep going . . .

6. Not Setting up a Tickler File

tickler file

 

 

 

 

 

 

 

 

A tickler file is a term used by office professionals to remind themselves and keep track of upcoming events. For example: vehicle maintenance and inspections, annual inspections, driver annual reviews, driver’s license renewals, medical examiner’s renewals, the biennial update, all of these documents and forms have due dates or renew dates. Loss of ability to operate and fines may occur to employer and/or driver, if any actions take place after the due dates.

There are many apps that can help in this area.

7. Not Doing Your Homework . . .

due diligence

 

 

 

 

 

 

 

 

 

In business it’s called “due diligence.” There is no requirement for any government agency to inform you of your legal and regulatory responsibilities. Transportation laws may vary from state to state and even city to city. Bridge laws and seasonal load restrictions may restrict when and how much you may carry.

Know what you are allowed to do or not do. Get any special permits, if necessary. If you are not sure what you need for a trip, then ask a specialist.

8. Falling Short of the Regulations

rAIN

 

 

 

 

 

 

Just as we can’t leap a gap in two jumps, it’s bad policy to ignore regulations or go around them for the sake of expediency. Missing permits, missing paperwork, incomplete files, can lead to trouble, months or years later.

STAR — Stop. Think. Act. Review.

STAR is a safety acronym. In approaching a new work challenge, before rushing in it’s always better to first stop, think it over, before taking action, and then reflect on whether we made the best possible decision.

Many of us make these mistakes due to biases in our thought process.

Availability bias — making a decision based on limited information. “Well, I found it on the Internet, so it must be true . . .”

Anchor bias — making a decision based on an “anchor” fact you have been given. “I won’t vote because the polls show my candidate is down.”

Overconfidence bias — making a decision based on one’s own subject judgement. “I can have it there by tomorrow. No, really . . .”

Confirmation bias — making a decision based on one’s preconceptions, ignoring evidence to the contrary. “The economy will keep growing forever.”

Rush-to-solve bias  — making a decision without considering all of the data. “My intuition tells me it’s a go.”

Summary

Nobody wants to make mistakes. Mistakes cost time and money. Regulatory mistakes often carry a high price tag: audit risk, the potential for unbelievable fines, and even the loss of ability to engage in certain aspects of your business. There is always a lot going on in any successful business or organization, but skipping or going around regulations to save the bother is not one of the options.

Five Good Habits of Professional Drivers

window view

Habit 1. Professional drivers keep their windows and mirrors clear.

Professional drivers use a good quality automotive glass cleaner when washing their windows—never dish soap or common household cleaners.

Tip: Don’t use the window-washing squeegee device found in self-service fuel stations as it may contain embedded gas, oil, and road salts that will transfer onto your windshield. For best results use a microfiber cloth to apply the cleaner and another microfiber cloth to wipe it off.

wipers

Habit 2. Professional drivers keep their window wipers in good working condition.

Professional drivers know the rule of thumb is to replace the wipers every six to twelve months— the frequency depending on driving conditions and climate.

Tip:  Replace your wipers during normal service. Don’t to wait until the wipers start to chatter or streak. Clean the wiper blades whenever you are cleaning the window glass. Some drivers use 303 wiper treatment on the blades.

Washer Reservoir

 

 

 

 

 

 

Habit 3. Professional drivers keep their window-washer reservoir full.

Professional drivers top the window-washer reservoir with a quality windshield glass cleaner.

Tip: Don’t use plain water as it can become a breeding ground for bacterium. Be wary of cheap, “home-brew” cleaning solutions that may damage paint or the rubber on the wipers.

tires

Habit 4. Professional drivers check their tire air pressure frequently.

There are all kinds of tire pressure systems. Tire pressure monitoring systems (TPMS), adopted by about 1/3 of fleets (NACFE 2013 Benchmark Study), cannot add air to an underinflated tire, and automatic tire inflation systems (ATIS)— used by about 10% of fleets (Ibid)—  while able to restore air to tires, usually can not report the actual inflation pressure in any given tire. The best tire inflation checker, for the majority of fleets, is still the professional driver.

Tip: Check cold PSI with a quality air gauge.

sidewall

 

 

 

 

Habit 5. Professional drivers constantly check their vehicle.

Every time they stop, professional truck drivers do a quick walk around the truck before hitting the road. They check the tires, the lights, brakes, load securement, etc.

Tip:  If you are out of view of the truck— be sure to check the coupling release, too.

It’s not Easy

It’s not easy being a pro— if it were, everyone would be above average and there would be nothing new to learn. Simply put, professional drivers have high standards and do more than expected.

Thank you for reading this.

 

 

What are some Driver Out-of-Service (OOS) Violations?

false log

Roadside Inspectors follow Commercial Vehicle Safety Alliance (CVSA) criteria for placing drivers Out-of-Service (OOS) for regulatory violations. During the stop the Roadside Inspector will ask the driver some basic questions about his or her recent activities and ask for today’s logsheet and the previous seven days’ worth, and possibly various supporting documents as trip bills, receipts, tolls, etc.

Some examples of Hours of Service (Part 395) violations resulting in an OOS include:

On Duty Beyond Maximum Periods Permitted
No driver shall drive after being on duty in excess of the maximum periods permitted by this part. Part 395.13 (b)(1).

No Record of Duty Status (RODS)
No record of duty status in possession, when one is required. Part 395.8(a)

No Previous 7 Days Logs
Failing to have in possession a record of duty status for the previous seven (7) consecutive days. Part (395.8(k)(2) — See Exception in Part 395.13(b)(3) – if the duty status is not current on the day of examination and the prior day, but driver has completed records of duty status up to that time (previous 6 days) — the driver will be given the opportunity to make the duty status record current, but may be cited for 395.8(f)(1) – Driver’s record of duty status not current (which is better than an OOS).

False Record of Duty Status
A false record of duty status is one that does not accurately reflect the driver’s actual activities and duty status (including time and location of each duty status change and the time spent in each duty status) in an apparent attempt to conceal a violation of an hours of service limitation within the current 60/70 hour rule period. Part 395.8(e)

Consequences of Being Placed Out-of-Service
• The driver must be placed Out-of-Service for ten (10) consecutive hours. The driver cannot drive any commercial motor vehicle while in OOS status.
• In addition, a driver may get a fine up to $200, per violation, per log-book page.
• The company may receive a $1,000 or greater fine by the FMCSA after a compliance audit or CSA intervention.
• The company will get CSA points.

Drivers can be placed Out-of-Service, if not medically fit, missing their prescription glasses or contacts, ill, under the influence of drugs or alcohol, not having a CDL in their possession, driving on a suspended license, etc.

Drivers should abide by any and all OOS orders. Fines to a company for violation of an OOS order can run in thousands of dollars and/or result in suspension of credentials to operate.

Thank you for reading this. Have a safe day.


J Taratuta

John E. Taratuta is an Independent Risk Engineer. Call (989) 474-9599 to chat him up.

 

 

 

 

Deadly Com·pla·cen·cy

detached trailer

Any DOT Roadside Inspector with some experience will tell you one of the most shocking discoveries they make time and time again, are how many tractor-trailers they inspect with the trailer not secure to the tractor. In some cases the “jaw” is not secure to the trailer’s kingpin. In other cases, critical components like the kingpin are totally missing, but the trailer “sits” on the tractor.

Recent news tell of the deadly consequences of a trailer not secured to the power unit.

  • March 17, 2015 — Four people were killed and two injured after a trailer detached from the tractor on a foggy U.S. 27 in Palm Beach County, in Florida
  • April 7, 2015 — a semi-trailer detached on on South Park Avenue Lower Providence Township, Montgomery County, PA, killing an oncoming truck driver.
  • May 7, 2015 — a woman was killed when a trailer detached from the tractor on the I-5, south of the Kern and Kings counties line, near Bakersfield, CA.

Many trailer detachments occur on smaller roads and go unreported. Trailer detachments unfortunately are fairly common, but almost always preventable.

After a trailer detachment, the truck driver:

  • may be charged with homicide by vehicle or vehicular manslaughter, or Recklessly Endangering Other Persons
  • may have his CDL license suspended
  • may be put on probation or incarcerated
  • face civil court cases/lawsuits

An investigation by Lower Providence Township Police and the Montgomery County Detective Bureau revealed that on the morning of the fatal crash, the defendant (driver) failed to properly secure the trailer component of his tractor-trailer before setting out from a business in Reading, Berks County. (Police Report)

The truck driver is responsible for any trailer detachment. A dropped trailer is usually grounds for termination of employment. If the driver is not sure about the equipment condition, the driver has an obligation to inform management of his inspection and observations, and have the equipment professionally inspected, and if necessary, repaired. This would be evidenced by a mechanic’s signature on the Driver’s Vehicle Inspection Report (DVIR), per FMCSA regulations.  All companies and carriers and drivers regulated by U.S. DOT are bound by FMCSA regulations. 

Criminal charges can be brought against drivers pulling a trailer that breaks free or becomes detached.

Training Competence

Never assume a new driver knows how to drop and hook. This aspect of driving is not on the CDL test and therefore is not always practiced. It is possible to have a CDL driver who has never dropped or hooked a trailer in his life.

tractor with no fifth wheel hitch

This “tractor” in a CDL school has no fifth wheel.

Countermeasures

Drivers must visually inspect the jaws/kingpin each time before they set out.

Drivers must visually inspect the jaws/kingpin each time they leave the truck and trailer unattended.

Drivers must preform trailer hook-up procedures according to accepted safety practices or manufacturer’s guidelines including: setting proper lineups and heights, doing several pull tests, visual inspections, brake tests, checking to ensure the 5th wheel is free of ice, snow, excessive grease or any other debris, etc.

Management has a duty to be knowledgeable on safety policies and FMCSA regulations.

Management has a duty to enforce safety policies and FMCSA regulations.

Cold weather can affect hook-ups. The locking mechanism may need extra time to work in very cold conditions.

Proper uncoupling procedures are important as well, and uncoupling should be done in mind with making the hook-up as safe and as easy as possible.

Thank you for reading this.

John Taratuta is an independent Risk Engineer and driver trainer. (989) 474-9599

Operation Airbrake Inspection Procedures

Roadside Inspection

Brake Safety Week is an annual nationwide enforcement program focused on improvement of commercial vehicle brake safety throughout North America.

National Brake Safety Week, starts Sunday September 6th and runs through Sept. 12.

Inspection Items (from CVSA

  • Driver License
  • Registration
  • Low Air Warning Device
  • Pushrod Travel (Adjustment)
  • Brake Linings/Drums
  • Air Loss Rate (If leak detected)
  • Tractor Protection System

Brake inspections conducted during Brake Safety Week include inspection of brake-system components to identify:

  • Loose or missing parts,
  • Air or hydraulic fluid leaks,
  • Worn linings, pads, drums or rotors, and
  • Other faulty brake-system components.

Antilock braking systems (ABS) malfunction indicator lamps also are checked. Inspectors will inspect brake components and measure the pushrod stroke when appropriate. Defective or out-of-adjustment brakes will result in the vehicle being placed out of service.

Results for 2014

Of the vehicles inspected, the Out-of-Service (OOS) rate for all brake-related violations conducted in North America was 16.2 percent, compared with 13.5 percent for the 2013 event. The OOS rate for brake adjustment rose to 10.4 percent from 9.0 percent in 2013. The OOS rate for brake components was 9.3 percent, up from 7.1 percent in 2013.

Note: All brakes and equipment need to be 100% (zero defects, zero mechanical faults) every time a commercial motor vehicle leaves the yard. That is the standard under Federal Motor Carrier Safety Regulations. Most, do, meet that standard.

 

Essential Driver Application Requirements

Driver application

One of the most problematic areas of DOT compliance, next to hours of service and drug and alcohol testing, are driver applications (Part 391.21). Driver applications may be audited by state and federal agencies and surveyed by insurance companies. Missing information, missing pages, or blank lines can lead to DOT write-ups, fines, and a request (more like an order) from the DOT to fix the mess. Here are some common DOT “application for employment” error areas to avoid.

Driver Application— Common Error Checklist

• Has the applicant listed his/her address for at least the last three years?
• Does it show an out-of-state address? If yes— then this means that the carrier needs to get the out-of-state Motor Vehicle Record (MVR), for each state listed.

• Has the applicant listed at least 3 years of past employment, if new to driving as a job, or if the driver has obtained a recent CDL?

• Has the applicant listed at least 10 years of employment if he or she had a CDL over 3 years ago?

Has the applicant explained any gaps in employment in excess of one month?

• Has the applicant answered YES or NO to each question for every job:
» Was this job subject to Federal Motor Carrier Safety Regulations?
» Were you subject to drug and alcohol testing under DOT rules?

Note: These questions apply to both interstate and intrastate drivers.

(It may help to ask the applicant if they even understand and know what these questions mean. In many instances the applicant does not know if they were subject to DOT regulations in their previous job(s) and will check off they were, when in reality were not or were DOT exempt.)

• Has the applicant listed a date of birth?

• Has the applicant answered BOTH of the following questions:
» Have you ever been denied a license, permit or privilege to operate a motor vehicle?
» Has any license, permit or privilege ever been suspended or revoked?
If the answer to either of the above questions is yes, has the applicant given details?

The applicant needs to fully answer each section:
• DRIVING EXPERIENCE
• ACCIDENT RECORD
• TRAFFIC VIOLATION RECORD

• Are there any “blank” answers?. If an answer is “none,” then the applicant must write “NONE.” (Not leave it blank or NA)

Top Tip: Have a statement on the application: “Every question must be answered. If the answer is “none,” then write “None,” not N/A.”

Has the applicant SIGNED and DATED the application?

Was the application completed by the applicant? The applicant, not a friend or family member, must fill out the application— in his own handwriting.

Are the Organization’s/Company’s Name and Address on the application??

The DOT driver application is an important document that forms the basis of the background investigation of the driver. Check your driver applications for these common errors. Don’t accept improperly filled out applications.

Applicants should be aware that improperly filled out applications potentially can lead to federal charges.

Thank you for reading this. Have a safe day. If you find this helpful, please pass this along.

J Taratuta

John Taratuta is an independent Risk Engineer. (989) 474-9599 Twitter @part380com

Keys to DOT Audit Success: the Mindset

shutterstock_179203754-300x300

You Get the Notice

Somebody, usually from a state DOT agency, or occasionally from the U.S. DOT wants to look at some or all of your records. In fact, there are over 60 (sixty) regulating U.S. government agencies that issue compliance regulations. Insurance companies also may review your policies, procedures, and work-safety files.

Don’t panic. The best way to approach any audit is by having the proper mindset.

Mindset has been defined as:

The established set of attitudes held by someone.

 

A fixed mental attitude or disposition that predetermines a person’s responses to and interpretations of situations.

 

The thought processes characteristic of an individual or group: ethos, mentality, mind, psyche, psychology.

What are a few things that should be kept in mind during a DOT audit? Here are a few suggestions.

The Audit Mindset

1.) Even the best get audited.

2.) Keep everyone informed of the upcoming audit. If not informed, staff might assume something is wrong.

3.) The auditor is there to do his or her job; help them to help you.

4.) The key to audit success is preparation.

5.) Prepare on a daily basis, not the day before the audit.

6.) If you are not prepared, things start to happen: control of the situation rapidly shifts to the auditor, turning the audit into an emotional event.

7.) If you are not prepared, you may not have necessary documents ready, or are ready to supply unnecessary documents, overloading the auditor.

a. Examples of “information overload” include:

• An accident register recording all accidents and incidents, including non-DOT incidents.
• Providing three months of records, when only one month was asked for.
• Accident files with too much paperwork or details.
• Driver qualification files with other paperwork of a personal nature or documentation not required by the auditor.

b. Tip: Hand over only what was asked for: nothing more, nothing less.

8.) Conduct a “re-audit” as you are audited: keep a list of all documentation provided.

9.) A key component of DOT audit preparation is to know the Federal Motor Carrier Safety Regulations (including Hazardous Materials Regulations, if applicable). Know your rights. Know your duties and responsibilities.

10.) Nobody is perfect. Nobody is expected to be perfect.

(Source: DOT Safety Audit Guide management program)

Top Tip: You are never required to sign an “admissions statement” that reads, “This statement is being made of my own free will . . .”

Thank you for reading this.

J Taratuta

John Taratuta is an independent Risk Engineer. (989) 474-9599 Twitter @part380com

Setting up a Hands-Free Mobile Phone Home Button

No texting.

Texting or using a hand held mobile telephone while operating a CMV is illegal and considered a serious violation. Very serious. Texting while driving can result in driver disqualification. Penalties range from a $2,750 fine for drivers and up to an $11,000 fine for employers.

A hands-free mobile phone is acceptable. For example, the Satechi BT Button Series makes your smart phone accessible with a single press of a button. The button is 1.375 inch in diameter so it can be mounted on the dash or a key chain. The button can be used to activate Siri or S Voice for hands-free operation.

While a hands-free mobile phone is acceptable, distraction.gov reminds us that studies show headset cell phone use is not substantially safer than hand-held use.

*     *     *

Disclaimer: Reference to any specific product, process, or service by trade name, trademark, manufacturer, company name or otherwise does not constitute or imply its endorsement, recommendation, or favoring by the author.

 

 

Light Checks

headlights on

One of the most common DOT violations are lighting defects or faults. While the technology has improved, the problem hasn’t gone away. A bad turn signal is an automatic Out-Of-Service (OOS) violation.

In addition to having a turn signal out on either side, other DOT OOS violations for lighting occur when:

  • Both headlamps are inoperative
  • Both tail lamps are inoperative, or
  • Both stop lamps are inoperative

What to do to avoid lighting problems?

The electrical system, like any other system, needs proper care and maintenance. This means having a preventative maintenance system in place, properly documenting inspections and maintenance, and focusing on proactive, not reactive, measures, as in replacing lamps or bulbs at the first signs of corrosion, not when they already don’t work anymore.

Tip 1. Don’t start the engine with the lights on.

Starting the engine with the lights on creates a draw on the electrical system that can burn out bulbs or cut bulb-life in half. Shut your lights off before engaging the starter or jump-starting the vehicle.

Tip 2. Spec replacement lamps properly.

A bulb or lamp is a bulb or lamp . . . right?  Not every time. Be extra careful here.

Make sure the correct lamp or bulb is going into the correct socket. Do not attempt to “upgrade” the lighting system by replacing, for example, a Halogen bulb with a high intensity discharge (HID) bulb. Even if the bulbs look alike, fit in the same headlamp, have the same wattage rating and seem to be completely interchangeable, switching the bulbs could result in an “optical mismatch,” bad lighting results, and may even be illegal.

The beam aim and pattern should not change when a bulb is replaced. This can happen if an improper bulb or a low quality replacement bulb is installed. A cheap or improper bulb could result in glare for opposing drivers and/or be illegal.

Ensure the bulbs or lenses are marked “DOT,” if *required. Headlamp bulbs are sometimes checked for the required “DOT” markings as part of a DOT vehicle inspection program.

*No marking is required by NHTSA (108) except for headlights and conspicuity tape

Tip 3. Don’t directly touch the bulbs/lamps during installation.

Fingertips contain oils which can burn onto the bulb. Protect the lamps/bulbs from contamination during installation. This will help extend the bulb’s service life.

Tip 4. Upgrade to LED stop, turn and tail lights.

LED lights have a longer life than filament bulbs and, because there is no filament, light up quicker. Use of LEDs could result in a higher level of safety performance and much longer service life cycles.

Tip 5. Use dielectric grease on the pigtail and/or other connections.

Dielectric grease helps to keep moisture, road chemicals, and resulting corrosion out of the electrical connections, ECM connectors, or connections. Corrosion is one of the major causes of truck light or electrical failures.

Summary

Lighting is one of the top areas of vehicle inspection violations. But you can proactively keep your lighting system in good working order with a preventative maintenance program, proper spec’ing of replacement parts, and following some of the above installation tips. This will result in fewer roadside inspections, less downtime, and best of all, a higher level of safety performance.

To learn more, see CMV Safety Inspection and Load Securement.

Thank you for reading this.

The Level One Post-crash Inspection

Crash Indicator BASIC

Q. Can a Roadside Inspector conduct an inspection after a collision? How is this fair, if the vehicle has been mashed up?

A. A commercial vehicle involved in a crash can be given a Level I North American Standard Inspection (Safety Inspection) covering: driver’s license, medical examiner’s certificate (if required), and medical waiver, if applicable, alcohol and drugs, driver’s record of duty status as required, hours of service, seat belt, vehicle inspection report, and critical items as the brake system, coupling devices, exhaust system, frame, fuel system, turn signals, brake lamps, tail lamps, head lamps, lamps on projecting loads, safe loading, steering mechanism, suspension, tires, van and open-top trailer bodies, wheels and rims, windshield wipers, emergency exits on buses, and HM requirements, as applicable.

If some of the parts and accessories are damaged due to the crash, the officer may document any defects that need to be repaired before the vehicle can go back on the road. If the defects were the result of the collision, then no CSA points for the defects should be assessed against the carrier.

Tip: Check your Crash Indicator BASIC After a Crash

Any post-crash vehicle damage to parts or accessories due to a collision should not result in CSA points. Check your CSA scores on your Crash Indicator BASIC at least thirty to forty-five days after the collision.  If CSA points were assessed against your organization in error, they can be challenged through the DOT’s DataQs system.