The early springtime morning hours bring the smell of bacon and burnt toast at many truck stops around the country. While we sit in the driver’s seat with our morning coffee, we see and hear the closing of cab doors and starter motors after drivers return to their trucks to perform their pre-trip inspections before heading out on the open …or that’s what an ideal morning would start like.
Sadly, we don’t see very many pre-trip inspections performed from our view from the front seat. What we often see are trucks leaving the parking lot with an inoperative headlamp or other required lamp. We see missing mud flaps, bad tires or a broken air hose retention spring. Later on down the road, we see one of the non-pre-trippers on the shoulder with a state trooper performing a roadside inspection prompted by an inoperative tail lamp. This most likely would have been avoided with the conduct of a proper pre-trip inspection as required by the FMCSA regulations in §392.7.
PRE-TRIP INSPECTION
The regulation is quite clear. No driver may operate a CMV until being satisfied that all of the following parts and accessories are in good working order:
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Service brakes including trailer brake connections
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Parking (hand) brake
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Steering mechanism
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Lighting devices and reflectors
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Tires
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Horn
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Windshield wipers
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Rear vision mirror or mirrors
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Coupling devices
Intermodal transport drivers have additional inspection requirements particular to their equipment. These include rails and supports frames; tie-down bolsters; locking devices and sliders or slider frame locks.
The DOT does not require a written record of pre-trip inspections; however a driver must be recording an on-duty status while performing the inspection, so it would be wise to flag the driver’s daily log indicating the time and duration of a proper inspection. Any safety defects must be corrected before the vehicle is placed in operation.
POST-TRIP INSPECTION
Regulation 49CFR396.11 discusses the requirement for every driver to prepare a report in writing at the end of each day’s work on each vehicle operated. The report, known as the Driver Vehicle Inspection Report (DVIR) would be completed after the driver is satisfied about the condition of all of the parts and accessories listed above, plus the wheels and rims, which are required to be in working order following a pre-trip inspection. The DVIR(s) must identify the vehicle(s) driven during the day and list any defect or deficiency discovered by or reported to the driver, which would affect the safe operation of the vehicle. The purpose of the DVIR is for the driver to report the safety condition of the vehicle(s) to the motor carrier; therefore, it is not required to be duplicated by a co-driver if the co-driver agrees with the driver’s DVIR.
There is more than one format or method of DVIR preparation. The most common form is contained either on the front or rear of a Driver’s Record of Duty Status form. Some carriers have a separate form just for the DVIR and those carriers that utilize electronic logs may have an electronic form that is submitted at the end of the day. Many drivers’ eleven-hour shift behind the wheel spans two calendar days, so when is the end of an OTR driver’s day? The regulations talk about a “day” but do not define that as a calendar day or a 24-hour period. Since the driver’s log is based on a calendar day, it would be best to create a DVIR for each calendar day and not create controversy with a law enforcement officer.
What corrective action is required when a driver submits a DVIR with a defect or deficiency listed? §396.11(c) is specific in the following statement: “Prior to requiring or permitting a driver to operate a vehicle, every motor carrier or its agent shall repair any defect or deficiency listed on the [DVIR] which would be likely to affect the safety of operation of the vehicle.” In summary, if a driver has a safety-related defect on the vehicle, it must be so indicated on the DVIR and corrected before the vehicle is used again.
EMERGENCY EQUIPMENT INSPECTION AND USE
A driver may not drive a commercial motor vehicle (CMV) unless satisfied that the following emergency equipment specified in §393.95 is in place and ready for use:
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Fire Extinguisher (accessible, securely mounted, fully charged)
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Spare fuses (one spare for each type in use in the power unit)
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Warning devices for a stopped vehicle (3 bi-directional reflective triangles or, 6 fuses or 3 flares)
CARGO SECUREMENT INSPECTION
Shifting cargo is a common cause of off-ramp rollovers and unsecured cargo or dunnage is often the cause of vehicle accidents and injuries to the motoring public. FMCSA regulations are written to minimize these occurrences by requiring that a CMV’s cargo be properly distributed and adequately secured as specified in §393.100 through §393.136. It is ultimately the driver’s responsibility to ensure proper cargo securement before the CMV is driven.
After leaving the shipper’s facility, a driver must inspect cargo securement and make any necessary adjustments on the following schedule:
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Within the first 50 miles after beginning a trip and
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When the driver makes a change of duty status, or
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The CMV has been driven for 3 hours or 150 miles, whichever occurs first.
The rules concerning freight securement examination do not apply to the driver of a sealed commercial vehicle who has been ordered not to open it or inspect the cargo, or to the driver of a CMV that has been loaded in a manner that makes the inspection of its cargo impractical.
Thorough inspections and safe operation has its rewards for the professional driver, whether owner-operator, fleet driver, or company employee. A clean inspection behind the scale house or alongside the highway is usually the product of daily, conscientious inspections. Additional inspection benefits include the avoidance of accidents, citations and fines, towing fees and repair costs at unfamiliar shops. You’ll also avoid the issuance of CSA severity weight points and the loss of income while out of service for repairs.
Be Safety
Smart and be safe.