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
Attention Attendees:
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Dr. Gary Petty, President & CEO, NPTC
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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Introduction
Dr. Gary Petty
President & CEO
National Private Truck Council
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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:
Gary Petty
National Private
Truck Council
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DOT Inspection & Maintenance
Requirements
Thomas Bray
Editor, Transportation Management
J. J. Keller & Associates, Inc.
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Tom Bray
J. J. Keller &
Associates, Inc.
Inspection, Repair &
Maintenance (Part 396)
• Systematically maintain & inspect
Tom Bray
(396.3(a)) Vehicles controlled thirty (30)
J. J. Keller &
Associates, Inc.
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!
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A “Systematic” Program
• Typical “systematic” program (complete
with supporting checklists):
Tom Bray
J. J. Keller &
Associates, Inc.
 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
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Required Records (396.3(b))
• Required records (396.3(b)):
 Vehicle identification (396.3 (b)(1)), including fleet
Tom Bray
number, VIN, make, model, year, tire size, and owner
J. J. Keller &
(if not owned by the carrier)
Associates, Inc.
 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
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Audit Point - Recordkeeping
• The auditor will verify that you are
Tom Bray
performing the inspections, maintenance,
J. J. Keller &
Associates, Inc.
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.
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Unsafe Operations
Forbidden (396.7)
• Catchall for law enforcement and auditors
Tom Bray
• A motor vehicle shall not be operated in such J. J. Keller &
a condition as to likely cause an accident or a Associates, Inc.
breakdown of the vehicle.
• Knowingly operating an unsafe vehicle can make a
carrier criminally liable.
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Audit Point – Roadside
Inspections
• Major point of DOT Compliance Review
Tom Bray
 If roadside OOS rate 34% or more, cannot receive
J. J. Keller &
“Satisfactory” rating in vehicle factor.
Associates, Inc.
 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!
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Driver Inspections
•
•
•
•
Required by the regulations
Pre-Trip (392.7 and 396.13)
Enroute inspections (392.9 and 397.17)
Post-Trip/DVIR (396.11)
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Tom Bray
J. J. Keller &
Associates, Inc.
Pre-trip (392.7 and 396.13)
• Driver cannot operate the vehicle until the
Tom Bray
driver is satisfied with the condition of the
J. J. Keller &
Associates, Inc.
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).
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Enroute
• “Walk-around inspection” checking tires,
Tom Bray
lights, hubs, cargo securement, coupling
J. J. Keller &
Associates, Inc.
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.
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Post-trip/DVIR (396.11)
• Pre-trip cannot take place of post-trip/DVIR
Tom Bray
• Copy of last DVIR NOT required to be
J. J. Keller &
Associates, Inc.
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
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Practical Recordkeeping
Compliance Issues
• When to complete DVIR:

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
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
Tom Bray
J. J. Keller &
Associates, Inc.
• 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!
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Audit Point - Records
• DVIR violation in compliance reviews
common (number one critical violation).
• Common violations:
Tom Bray
J. J. Keller &
Associates, Inc.
 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
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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
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Tom Bray
J. J. Keller &
Associates, Inc.
Periodic (Annual
Inspection)
• Appendix G lists the requirements for
Tom Bray
successful passage of a periodic/annual
J. J. Keller &
Associates, Inc.
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.
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Appendix G v.
CVSA OOS Criteria
• Appendix G and CVSA Out-of-Service
Tom Bray
Criteria follow the same format whenever
J. J. Keller &
Appendix G and CVSA Out-of-Service Criteria Associates, Inc.
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-ofService criteria would allow the vehicle to continue
its current trip, if the one defective brake is on a nonsteering axle.
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Technician Qualifications
• 396.19 details periodic/annual inspector
Tom Bray
requirements
J. J. Keller &
Associates, Inc.
• 396.25 details brake inspector qualification
• Carrier is responsible for documenting qualification
of their technicians
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Technician Qualifications
• Anyone performing periodic annual
inspections must:
Tom Bray
J. J. Keller &
Associates, Inc.
 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.
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Technician Qualifications
• Anyone inspecting, maintaining, or
repairing brakes on a commercial vehicle
must:
Tom Bray
J. J. Keller &
Associates, Inc.
 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.
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Raising the Bar
Tom Moore, CTP
Vice President of Education
National Private Truck Council
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Tom Moore
National Private
Truck Council
Why the Regs Aren’t
Followed
• Poor communication
Tom Moore
• Conflicting goals
National Private
Truck Council
• Forms and processes that lead to poor followthrough
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Raising the Bar: Daily
Inspections Best Practices
•
•
•
•
•
Hire intelligently
Tom Moore
Train drivers
National Private
Truck Council
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
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Raising the Bar: Roadside
Inspections Best Practices
• Weekly and spot inspections
Tom Moore
• Review SafeStat data monthly
National Private
Truck Council
• 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)
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Raising the Bar: Annual
Inspections Best Practices
• Consider more frequent inspections
• Enhance internal communications
• Improve vendor relationships
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Tom Moore
National Private
Truck Council
Audit Your Inspection
Practices
•
•
•
•
Out of service rates
Accident rates
Equipment violation citations
Maintenance cost and repair
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Tom Moore
National Private
Truck Council
Benefits of Raising the Bar
•
•
•
•
Lower overall maintenance costs
Increased fuel mileage
Improved driver retention
Improved on-time percentages
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Tom Moore
National Private
Truck Council
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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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.
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Dan Norris
Pepsi Bottling Group
PBG’s Situation Before
Driver Training
• Before Training
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
Dan Norris
Pre-trips not completed
Pepsi Bottling Group
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

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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
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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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PBG’s Pre-trip Process
• Review prior day DVIR to see if vehicle was
Dan Norris
written up for maintenance
Pepsi Bottling Group
• 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
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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
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Dan Norris
Pepsi Bottling Group
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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Dan Norris
Pepsi Bottling Group
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
Dan Norris
Pepsi Bottling Group
 Driver Take Away: It takes about 10-15 minutes but it
is one of the most important things a driver does
each day.
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PBG’s “Defect Found”
Process
• Check off items as pre-trip inspection is
Dan Norris
completed
Pepsi Bottling Group
• 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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PBG’s Post-trip Process
• The post-trip inspection is divided into different
Dan Norris
sections. Each section has several
Pepsi Bottling Group
components you must inspect.
• FMCSA - 396.11 Must Haves
 Service brakes (including
trailer brake connections)
 Parking (hand) brake
 Steering mechanism
 Lighting devices and reflectors
 Tires
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


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
Horn
Windshield wipers
Rear vision mirrors
Coupling devices
Wheels and rims
Emergency equipment
PBG’s Post-Trip “No
Defect” Process
•
•
•
•
•
Check only items that need repair
Norris
If no repair is needed, check “NO DEFECTS”PepsiDan
Bottling Group
Legibly sign your name
Proceed to check in lane
Turn white copy into checker/dispatcher
 Driver Take Away: I am required to check more items
during my post-trip. It generally takes 15-20 minutes,
but the best way to avoid morning delays is to
conduct a thorough post-trip.
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PBG’s Post-Trip “Defect
Found” Process
•
•
•
•
•
•
•
•
Check only item(s) that need repair
Dan Norris
Legibly sign your name
Pepsi Bottling Group
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
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PBG’s Critical Success
Factors
• Clear communication is essential
• Establish responsibilities:
Dan Norris
Pepsi Bottling Group
 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.
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PBG’s DVIR Document Flow
DVIR File Process
Yellow Copy
Pink Copy
UNIT FILE COPY
FILE COPY
DRIVER REVIEW COPY
Driver
Upon final inspection of vehicle; driver
turns in white copy of DVIR to
dispatcher/supervisor
Fill out Service Request Log at service
desk in Fleet Shop.
Leave yellow copy in book in truck cab.
(Mechanic will get)
Driver signs pink copy after review of
mechanics repair. Pink copy stays with
the book in truck cab until book is full.
Dispatcher
Supervisor
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.
N/A
N/A
File owner files white copy of DVIR in
asset file and retains for 90 days
N/A
N/A
Mechanic
White Copy
DVIR File
Owner
(If no repair is required
yellow copy may be discarded)
N/A
Upon completion of repair mechanic
signs, dates, and records work order
repair number on yellow & pink copy
File in master asset file jacket.
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Upon completion of repair mechanic
signs, dates, and records work order
repair number on yellow & pink copy
Dan Norris
Pepsi Bottling Group
“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
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Dan Norris
Pepsi Bottling Group
“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
N/A
Mechanic
Upon completion of repair mechanic signs,
dates, and records work order repair number
on yellow & pink copy. File in master
asset file jacket.
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Dan Norris
Pepsi Bottling Group
“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
N/A
Mechanic
Upon completion of repair mechanic signs,
dates, and records work order repair number
on yellow and pink copy.
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Dan Norris
Pepsi Bottling Group
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
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Dan Norris
Pepsi Bottling Group
Results of Driver Training
• After Training
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Pre/Post-trip are completed
Dan Norris
Passing internal DOT audits with flying colors
Pepsi Bottling Group
Employee and manager ownership
Improved communication between driver and technician
• Driver Benefits
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Improved asset uptime
No departure delays
Decreased risk of DOT fines
Clearer lines of communication
• Technician Benefits
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Improved asset uptime
Improved productivity
Streamlined paper work process
Educated driver
Dial-in: 1-888-824-5783, Pass Code: 61156559#;
Tech Support: 1-888-259-8414, Webinar ID: 198466121
PBG’s Results
• System benefits
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Dan Norris
DOT Compliant
Pepsi Bottling Group
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
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Validating quality of DVIR’s
Tie in to new hire process
Determining cycle for retraining
Electronic DVIR
Dial-in: 1-888-824-5783, Pass Code: 61156559#;
Tech Support: 1-888-259-8414, Webinar ID: 198466121
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
Dial-in: 1-888-824-5783, Pass Code: 61156559#;
Tech Support: 1-888-259-8414, Webinar ID: 198466121
Closing Remarks
• Checkout the archive of past topics at:
http://www.jjkeller.com/nptcinfo
 PowerPoint slides up in 1-2 days
 Recording up in 1 week
• Topics for 2009:
 August 19 – OSHA Compliance for Private Fleets
 October 21 – Accident Management: A Nuts and Bolts
Approach
Dial-in: 1-888-824-5783, Pass Code: 61156559#;
Tech Support: 1-888-259-8414, Webinar ID: 198466121
Gary Petty
National Private
Truck Council