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