2019 ROADSIDE INSPECTION E-BOOK Preparing Drivers for a Successful Electronic Hours-of-Service Inspection Roadcheck 2019 This year’s International Roadcheck will focus on suspension and steering. In addition to having credentials current and with them; ensuring the vehicle is “ready” for inspection; and being willing and able to follow the officer’s instructions, drivers will also need to be well versed on how to present their electronic log and any related materials. 2019 JUNE 4-6 Check driver readiness with our ELD & AOBRD Role Play exercise on page 11. Table of Contents Overview: Significance of Preparing for Roadside Inspections. . . . . . . . . . . . . . . 4 Prepare for ELog Inspections . . . . . . . . . 8 Tips for a Successful Inspection . . . . . . 5 ELD & AOBRD Role Play . . . . . . . . . . . . . . . . . . 11 Pretrip Inspections. . . . . . . . . . . . . . . . . . . . . . . . 5 Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Post-trip Inspections. . . . . . . . . . . . . . . . . . . . . . 7 Cab Inspections. . . . . . . . . . . . . . . . . . . . . . . . . . 7 Positive Attitude . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ELD vs. AOBRD Inspections. . . . . . . . . . . . . . . 8 ELD Exemption Declaration. . . . . . . . . . . . . . 14 Hours-of-Service Training Checklist. . . . . . . 16 Driver Quiz. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Cab Card . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Look for this icon throughout the guide for materials that can be printed for use in your training program. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 2 ROADSIDE INSPECTION E-BOOK Avoid violations. Minimize the negative impact to your CSA score. Reduce the chance of an audit. It all starts with a successful roadside inspection — and a successful inspection starts with proper training. Use the information provided in this resource to help drivers and staff navigate the roadside inspection process. We’ll help you better understand the various types of inspections and key differences between roadsides with ELDs and AOBRDs, including requirements for showing correct device documentation, and displaying, printing, and/or transferring the required logs. Armed with the right information, your drivers will be better equipped to survive their next roadside inspection and ultimately, protect the overall health of your compliance program. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 3 OVERVIEW: ROADSIDE INSPECTIONS Roadside inspections are a critical component of the Compliance, Safety, and Accountability (CSA) model, which relies on data from over 3 million annual roadside inspections to grade motor carriers and drivers on their safety performance. Every roadside inspection report attributed to a motor carrier and driver — with or without a violation — is factored into the carrier's and driver’s CSA scores for the next 24 or 36 months, respectively. The Safety Management System (SMS) is updated once per month to recalculate your CSA score in each Behavior Analysis Safety Improvement Categories (BASIC). There are over 900 possible CSA violations, each with a severity weighting from 1 through 10, organized in seven BASICs. Authorized and specifically trained state and Federal Motor Carrier Safety Administration (FMCSA) officials can perform roadside inspections and issue citations at a roadside location, weigh scales, portable scales, ports of entry, rest areas, or even a carrier’s terminal. If you want to have a good safety reputation with fewer inspections and fewer crashes, your drivers need to perform well on roadside inspections. Motor vehicles likely to cause an accident or break down are placed out of service to prevent an unsafe situation from continuing, and must not be operated or towed by an emergency towing vehicle unless the vehicle(s) meets performance requirements of the Federal Motor Carrier Safety Regulations (FMCSRs), except for conditions listed on the Driver Vehicle Inspection Examination Report (roadside inspection form or “ASPEN” report). The “Out of Service” vehicle sticker must not be removed until all required repairs have been satisfactorily completed. Penalties for violating out-of-service orders are severe. Drivers can lose their driving privileges for 90 days on the first offense. Also, the fines for violating an “out-ofservice notice” can be more than $1,800 for the driver and more than $18,000 for the carrier. Copyright 2019 J. J. Keller & Associates, Inc. 90 DAYS 855.693.5338 | KellerEncompass.com 4 LIGHTS BRAKES TIRES 5 TIPS FOR A SUCCESSFUL INSPECTION In addition to providing new hire and annual refresher training, the following tips will prove especially valuable when preparing your drivers for a successful roadside inspection. 1. Conduct a Thorough Pretrip A proper pre-trip is required by §392.7 and minimizes not only vehicle-related violations, but also accidents and vehicle repairs. 1. Take note of the vehicle’s general condition. 2. Check under the hood for worn belts, leaking fluids, or cracked wires. 3. Start engine and listen for unusual noises. Check gauges, emergency devices, and confirm fire extinguisher is charged and secured. 4. Check the lights, especially headlights, taillights, brake lights, and warning lights. 5. Walk around the vehicle and inspect all major equipment items. 6. Check the directional lights. 7. Check the brake system. 8. Review the prior day's DVIR, and verify all reported safety or potential breakdown-related defects were corrected and the form is signed by the person verifying the repairs. Sign the document when you are satisfied the vehicle is safe to operate. If defects still exist, do not operate the vehicle and report the defects to your company. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 5 Tips for a Successful Inspection 2. Maintain Current and Accurate Documentation Make sure all applicable documentation is in order, including: Driver’s License must be valid and appropriate for the vehicle operated. A non-CDL driver must have a current medical card, and a CDL driver operating a CDL vehicle must have a valid CDL with a current medical certification showing in the Commercial Driver License Information System (CDLIS). The driver must also have any applicable medical waiver with them. A CDL driver must carry the medical card with them at least 15 days after the physical examination, though longer is recommended in the event there is an issue with the officer’s system or the state transmission of information. Supporting documents, such as bills of lading and expense receipts, should be available and organized so they can be provided upon the officer’s request. Only short-haul drivers are exempt from the provision. Hazmat documentation is especially critical to have in order, as a single violation can result in a $78,000 fine. The paperwork must have hazardous products listed correctly, and contain emergency response and contact information. When a driver hauling a load of placarded hazmat leaves the truck, the paperwork should be left on the driver’s seat or put in the driver’s door pouch, and should be within the driver’s reach while operating the vehicle. Annual Inspection – A copy of the annual inspection or annual inspection sticker with the date of the last inspection, must be on the vehicle, and the driver must know the location. Permit credentials including the IRP cab card, IFTA license and decals, and any temporary permit should be readily available. ELD-related documents must be accessible in the truck to avoid violations, including eight days of blank logs, the correct driver (logging device user) information, and malfunction/transfer process documentation as applicable for the AOBRD or ELD being used. Find answers to more ELog FAQs here. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 6 Tips for a Successful Inspection 3. Conduct Post-trip Inspections Post-trip vehicle inspections are required based on §396.11 and include the vehicle components in the pretrip inspection. Drivers of property-carrying vehicles must complete a DVIR only when a defect exists that affects the safety of the vehicle or could cause a potential breakdown. Passenger-vehicle drivers must complete a DVIR each day. If there is a defect, the person responsible for the repairs must sign the document as should the next driver of the vehicle. 4. Inspect the Cab In addition to a thorough pretrip, pay close attention to the overall cleanliness of the cab. Remove any garbage, especially from the top of the dashboard, which could impact visibility and potentially cause items to drop into the area of the brake and accelerator pedals. Tidy up as the officer may dig deeper if the cab is in disarray. A messy cab makes the officer ask, “What else isn’t in order with this driver or vehicle?” Prepare for a successful inspection with our Code of Conduct cab card on page 18. Roadside Insp ect ion Cod e of Conduc If an officer requests a cab inspection, you have the right to ask: 1. What has led you to believe that there is a reason to search my vehicle? t cab 1. Clean the trip 2. Plan your pret rip a thorough 3. Conduc t devices connect HOS 4. Charge and s of limit s and rule 5. Know HOS used ption(s) exce r ork is in orde erw pap re 6. Ensu ) uding Hazmat (incl are certified r days’ hours 7. Confirm prio ce devi on post-trip a thorough 8. Conduc t any e DVIR to note 9. Complet ty defects safe tive 10. Be posi 2. What specific areas of the vehicle do you want to search? 3. What specifically are you looking for? Note: Remember to maintain a positive attitude when requesting additional information. OUT OF SERVICE 5. Maintain a Good Attitude Attitude is everything. Coach drivers to remain calm, be respectful, avoid argument, and ask the officer to explain the violation(s). If the driver is unclear regarding a mechanical issue, they should request that the officer point out the defect. Then, the driver will learn how to avoid similar violations in the future. There aren’t quotas for citations, but there are quotas for inspections. In other words, a driver can’t talk themselves out of an inspection, but they can certainly talk the officer into one. Out of Service Copyright 2019 J. J. Keller & Associates, Inc. If placed out of service, drivers should contact the company immediately. 855.693.5338 | KellerEncompass.com 7 PREPARE FOR ELOG INSPECTIONS The following tools can be used to train your drivers and provide them with an idea of what to expect during the hours-of-service portion of an inspection when using ELogs. These pages can be copied and distributed to your team as necessary. ELD vs. AOBRD Inspections Even if you have AOBRDs in your vehicles, you must help drivers understand how ELD requirements differ to avoid misunderstandings that could generate citations during roadside inspections. Confusion regarding the technical differences between an automatic on board recording device (AOBRD) and a registered electronic logging device (ELD) has been one of the most frequent obstacles during roadside inspections since December 18, 2017. As basic as it sounds, your drivers must know if they have an ELD or AOBRD in the vehicle. Use the information provided on pages 9-10 to help your drivers and affected personnel understand the critical differences between ELD and AOBRD technical requirements. Is your electronic logging system compliant with the technical requirements of the next ELD mandate deadline? Verify your hardware is compliant with the J. J. Keller Compliance Check. MARK YOUR CALENDAR: As of December 16, 2019, you must be in full compliance with the ELD MANDATE. ELDs must be installed in your trucks before this date. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 8 Prepare for ELog Inspections ELD vs. AOBRD Understanding the Technical Requirements During a Roadside Inspection SCENARIO Manner of presentation of record of duty status to officers: ELD AOBRD 1)T elematics method: Be able to electronically transfer data to an authorized safety official on demand via wireless web services and email, OR Display or printout (§395.15(b) (1)) that includes a sequenced list of duty changes, see §395.15(i)(5) for list of required information that must be provided on display or printout (no grid-graph or form and manner requirements). If officer wants a hard copy of the records, the driver and/ or carrier have 48 hours to forward them to the officer after the inspection (Interpretation Question 6 to §395.15). 2) Local transfer method: Be able to transfer data to an authorized safety official on demand via USB2.0 and Bluetooth NOTE: The device must only be able to use one of the two general methods, not both. However, within the selected general method, the device must be able to use both of the methods. There is no direct assignment for the backup methods. The device can use either backup (display or printout), regardless of what it uses as the means of transfer. Display or printout must include header, grid-graph, and detailed list of all data captures for the 24hour period. Rules found in: 395 Subpart B & 395 Appendix 395.2 & 395.15 Yes, provided it is listed on the ELD registry. Yes, provided it was placed in service prior to December 18, 2017. Technical Specifications: The device must consider the driver as driving when the vehicle reaches 5 miles per hour. The device must use engine data to determine when the driver is driving. All other duty changes can be made by the driver. Can device be used to satisfy the requirement as of December 18, 2017? The device must default to “on duty” when the vehicle is stopped, has not be in motion for five consecutive minutes, and/or when the driver has not responded to an ELD prompt within one minute (unless the driver indicates otherwise). Exemptions after December 18, 2017? Locations must be automatically generated by the device. Requires automated entry at each change of duty status, at 60-minute intervals while CMV is in motion, at engine-on and engine-off instances, and at beginning and end of personal use and yard moves. Locations can be automatically generated or entered by the driver at each change of duty status. All “users” in the system must have an “account” and user ID. Not identified and/or required. All drivers’ accounts must include the driver’s license information (license number and state of issue, along with other information). Not identified and/or required. An ELD must be able to present a grid-graph of driver’s daily duty status changes, a header including driver, vehicle, and carrier information, and a list detailing the location and nature of all duty changes and data captures, either on a display or on a printout. A graph grid is not required. 1) Units older than model year 2000 (verified through the vehicle’s VIN number) and units newer than model year 2000 that have been retrofitted with an engine older than model year 2000 (verified through engine’s serial number) 2) Drivers that are not required to complete paper logs on eight or fewer days out of the last 30 days 3) Drivers operating a power unit that is part of a driveaway/ towaway shipment 4) Drivers that are driving or towing a recreational vehicle that is part of a driveaway/towaway shipment. 5) Drivers that are driving a vehicle that has been rented under the terms of a rental agreement that is 8 days or less in duration. (continues on page 10) Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 9 Prepare for ELog Inspections ELD vs. AOBRD Understanding the Technical Requirements During a Roadside Inspection (continued from page 9) SCENARIO ELD AOBRD Whenever the vehicle is in operation, the driver must have with him/her: Records for the current day and the previous seven days in the ELD, plus: Records for the current day and the previous seven days in the AOBRD, plus: • A user’s manual • An instruction sheet on how to retrieve and present the data during roadside inspections • An instruction sheet on data transfer during roadside inspections • An instruction sheet detailing malfunctions and actions to take in case of certain malfunctions • A supply of blank paper logs (at least eight days) to be used if the device fails Data capture must include: • Date and time • Location (accurate to within one mile in normal operation, 10 miles during personal use) • Engine hours • Enough blank logs to complete the current trip Note: An ELog vendor letter certifying that the device meets the regulatory requirements under 395.2 and 395.15 does not have to be in the vehicle. However, having it in the driver’s possession is a best practice. Only basic data (time, duty status, and location) is required to be captured at duty changes (display requirements do not include location) (§395.15(c), (d), and (i)(5)). • Vehicle miles • Driver • Vehicle • Carrier Special driving categories? 1) Personal use: To be used when the driver is using the commercial vehicle as a personal vehicle to commute to a purely personal destination. The driving will be recorded by the device as off-duty time. AOBRDs do not have “special driving categories,” §395.15 only details four duty status lines: OFF, SB, D, and ON (§395.15(c)). 2) Yard time: To be used when the driver is operating the vehicle off of the public roadway. The driving is captured as on-duty time and does not count toward the driver’s driving limit. Editing of logs? Under this final rule, drivers are allowed to enter missing information and make edits to the records. Supervisors can request edits, but all supervisor edits must be approved by the driver. All edits must include an explanation of why the change was made. The system must also indicate which user made the change. If an edit is made, the record in the system must include the original record, the updated record, and the details of the change. Drivers or supervisors can make edits. Edits made by supervisors must be approved by the driver by recertifying the log after the edit. A record of the original and all changes must be retained. The record must include the date and time of the edit, and the name of the person doing the edit (Interpretation Question 2 to §395.15). This information does not have to be visible on the display. If the record has already been submitted and it was edited, the driver will need to recertify and resubmit the record. DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 10 Prepare for ELog Inspections ELD & AOBRD Role Play A “mock” roadside inspection may be beneficial training for all drivers who are not seasoned users of your ELD/AOBRD, or drivers who would benefit from a roadside inspection refresher. This involves a company supervisor walking up to a driver at the company facility and asking the driver to present: His/her credentials (license and medical card if required to carry it) The vehicle’s credentials (registration, proof of annual inspection, and fuel permitting, if required) Shipment paperwork Today’s and the previous seven days' logs The documentation the driver must carry along with his/her logging device As part of this, the supervisor should ask, “If an officer asks for a copy of your logs, what is the process for getting them to the officer?” The driver should be able to answer this correctly (either transfer them directly, or send them via fax or email after the inspection). Use the ELD & AOBRD questions featured on the following pages to perform a mock roadside inspection with your drivers. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 11 Prepare for ELog Inspections Driver Resource ELD Logging Questions Roadside Inspectors Could Ask With the FMCSA’s ELD rule now in effect, keep these questions and answers handy, and be prepared to accurately answer questions asked by roadside inspectors regarding your use of an electronic logging device (ELD). These answers are generally accurate for J. J. Keller ELD customers. Your answers may vary depending on your vendor. What type of log are you using? I’m using an ELD. Is your electronic log connected to your vehicle and getting data from the vehicle? Yes. Is your ELD on the FMCSA Registry? Yes. If there’s no cell coverage to send the file, or if another connectivity issue occurs, can I see a display or printout? Yes, you can see a display including all the required information. Can you provide me with a copy of your records? Yes, I can directly transfer the records to you. Which transfer method will you be using to provide your HOS information? [If using telematics]: I can transfer the information via email or web service. [If using local transfer]: I can transfer the information via USB 2.0 or Bluetooth. Do you have the required in-cab documentation? Yes, I have: • My ELD user’s manual •A n instruction sheet detailing the data transfer process used to provide records to officers during roadside inspections • An ELD malfunction card • At least 8 blank paper logs Copyright 2019 J. J. Keller & Associates, Inc. DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” 855.693.5338 | KellerEncompass.com 12 Prepare for ELog Inspections Driver Resource AOBRD Logging Questions Roadside Inspectors Could Ask With the FMCSA’s ELD rule now in effect, keep these questions and answers handy, and be prepared to accurately answer questions asked by roadside inspectors regarding your use of an automatic on-board recorder (AOBRD). These answers are generally accurate for J. J. Keller ELD customers. Your answers may vary depending on your vendor. What type of log are you using? I’m using an AOBRD. Is your electronic log connected to your vehicle and getting data from the vehicle? Yes. Do you have the required in-cab documentation? Yes, I have: •A n instruction sheet on how to retrieve and present the AOBRD data during roadside inspections • Enough blank paper logs to complete my current trip When was this AOBRD placed into service? My device was placed into service before December 18, 2017. Can you provide me with today’s and your previous 7 days’ records? I can display the records so you can view all the required information. DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 13 Prepare for ELog Inspections Fleet Manager/Trainer Resource ELD Exemption Declaration The officer may also ask drivers detailed questions about any exception they may be using especially if the driver tells the officer, “My carrier told me I don’t need to use an ELD/AOBRD.” The major exemptions from using an ELD/AOBRD are: 1. Operating within 100 or 150 air-miles of the work reporting location. See §395.1(e). 2. Operating a vehicle older than model-year 2000 or with an engine older than model-year 2000. 3. Operating a vehicle that is towing an RV for delivery, or driving a vehicle that is being delivered as part of a driveaway/towaway shipment. 4. The driver has logged eight or less days in the prior rolling 30-day period. 5. The driver is operating a rental vehicle with a contractual period of 8 or less days. (The driver must have a copy of the rental agreement with a rental period of 8 or less days and a copy of the Federal Register Notice for this exemption.) There are other temporary industry-specific waivers, but it is imperative to abide by the detailed requirements of the exception or waiver. In most cases, the driver will need to carry a copy of the Federal Register notice that created the exemption. Even if this is not required, it is still good practice as it helps the driver explain to the officer why he or she does not have an ELD. Use the ELD Exemption Declaration to help drivers communicate correctly the exemption(s) for which the driver is qualified, to avoid violations being issued in error. Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 14 Prepare for ELog Inspections ELD Exemption Declaration Motor carrier name: ________________________________________ DOT #: _________________________ Driver’s name: _____________________________________________ Vehicle ID: _____________________ The driver of this vehicle is exempt from the Electronic Logging Device (ELD) mandate of 49 CFR Part 395, Subpart B, for the reason(s) identified below: F The driver is using a “grandfathered” automatic on-board recording device (AOBRD) that complies with §395.15 and that was installed and in use before December 18, 2017 (§395.8(a)(1)(ii)), but cannot be used December 16, 2019 and later. F The logging device in this vehicle is part of a fleet running grandfathered AOBRDs but was added after December 18, 2017. It is ELD-capable but is running compliant AOBRD software as allowed under FMCSA guidance issued March 9, 2018.The ELD-capable device must be updated to ELD compliant software before use on December 16, 2019 and later. F The vehicle/engine is from model year _______________________ (§395.8(a)(1)(iii)(A)(4)). F The driver has not been required to log more than 7 days out of the last 29 consecutive days and therefore is eligible to use a paper record of duty status today (§395.8(a)(1)(iii)(A)(1)). F The driver is complying with the terms of the 100-air-mile exception and is exempt from needing a record of duty status (§395.1(e)(1)). F The driver is complying with the terms of the non-CDL, 150-air-mile exception and is exempt from needing a record of duty status (§395.1(e)(2)). F This is a driveaway-towaway operation engaged in the delivery of the vehicle being driven, or transportation of an RV trailer or motor home (§395.8(a)(1)(iii)(A)(2)-(3)) F The vehicle is operating under a rental agreement with a term of 8 days or less. The driver is carrying the rental agreement and a copy of the FMCSA exemption notice (as published on October 11, 2017). The driver is eligible to use paper logs during the term of the rental. F The driver is providing transportation to or from a motion-picture production site and is eligible to use paper logs, as stated in the FMCSA exemption notice carried in the vehicle (as published on January 19, 2018). F The ELD unit in this vehicle is malfunctioning as of _______________________ and the driver is eligible to use paper logs for up to 8 days or until the ELD is operational (§395.34(b)). F Other (explain): __________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ Motor carrier official: _______________________________________ Date: __________________________ Contact information: _________________________________________________________________________ Copyright 2019 J. J. Keller & Associates, Inc. All rights reserved. J. J. Keller & Associates, Inc. grants permission to reproduce this page for internal use at one business location only, provided that J. J. Keller’s copyright notice remains visible on all copies. DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 15 Prepare for ELog Inspections Fleet Manager/Trainer Resource Hours of Service Training Checklist – Property Carrying Drivers Once drivers have been trained, use the following checklist to test their knowledge of critical hours-of-service regulations. On-duty time versus Off-duty time (§395.2) 10-hour break requirement (§395.3(a)(1)) 14-Hour (on duty) Limit (§395.3(a)(2)) 11-Hour (driving) Limit (§395.3(a)(3)) 60/70-Hour (on duty) Limit ((§395.3(a)(3)) Minimum 30-minute break within 8 hours of on-duty time (§395.3(b)) 34-hour restart (§395.3(c)) Record of Duty Status – form and manner requirements for paper and electronic logs (§395.8) 100 and 150 air-mile exceptions to logging (§395.1(e)(1) and (§395.1(e)(2)) Other Hours of Service exceptions (§395.1 sub-paragraphs (a) through (x)) Supporting documents (§395.11) Differences between AOBRDs and ELDs (§395.15 AOBRD and §395.20-38 ELD) DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 16 Prepare for ELog Inspections Roadside Inspection Driver Quiz Are you ready to pass your next roadside inspection? Take the following quiz to find out. (Answer Key can be found on page 19.) 1. What paperwork must be presented during a roadside inspection if requested? a. Driver's license or CDL, if applicable b. Any bills of lading, hazmat documents, or expense receipts, and ELD documentation if asked c. A copy of the annual inspection or inspection sticker, IFTA and IRP license and decals d. All of the above 2. During a walk-around inspection while en-route, you noticed you had one marker light out, but didn’t have a replacement bulb with you. Now you are getting pulled into a scale for inspection. What should you do about the burned-out light? a. Ignore it; maybe the inspector won’t see it b. Tell the inspector that you have a light out, but you are planning on getting it fixed at the nearest truck stop ahead c. Tell the inspector that it doesn’t matter because it's daytime and you don’t need your lights d. Nothing 3. Which score is the reason, most often, a driver gets pulled in for an inspection? a. Driver Safety Management System (DSMS) score b. Compliance, Safety, and Accountability (CSA) score c. Independent Selection System (ISS) score d. Fair Isaac Credit Organization (FICO) score 4. If asked for your electronic log book, you should: a. Tell the inspector you don’t have one because it is easier to log on paper logs b. Prepare the electronic log by getting the last 7 days' hours and the current day's hours to display, or set the ELD to the appropriate data transfer mode c. Hand the device to the inspector so they can inspect or transfer the logs to themselves d. Call your dispatcher and ask them what to do DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 5. You haul hazardous materials. Where must load-related paperwork be stored, if you leave the vehicle? a. Anywhere that is convenient b. In the trailer, where the receiver will see it c. Where it is accessible from the driver’s seat, when seated d. On the driver’s seat or in the door pouch of the driver’s door 6. If you are using an AOBRD or ELD using AOBRD software, what is the date by which you must be using an ELD running ELD-compliant software? a. April 1, 2020 b. December 16, 2019 c. December 31, 2019 d. January 31, 2020 7. If you receive a vehicle violation you can ask the officer to explain the violation, so you can have it repaired. a. True b. False 8. What are the some steps a driver should take to experience a good roadside inspection? a. Conduct a thorough pretrip b. Ensure paperwork is in order and have a good attitude c. Know which device you have, AOBRD or ELD, and understand how to use the device d. All of the above My score is: _________ What’s Next? 8 CORRECT: Well done! Your CSA Score is in good hands. 7-6 CORRECT: Not bad. Brush up on the basics before you hit the road. 5-4 CORRECT: You’re almost there. Perform some of the exercises in this guide, and try again. 3-1 CORRECT: WARNING: Seek remedial training before you receive an out-of-service violation. 0 CORRECT: DANGER! Your fleet’s reputation could be at risk. 855.693.5338 | KellerEncompass.com 17 Prepare for ELog Inspections Driver Resource Cab cards Copy the cab cards below, cut along the dotted line, and distribute one card to each of your drivers. To create a wallet-size version, copy and fold the card in half. Roadside Inspection Code of Conduct 1. Clean the cab Roadside Inspection Code of Conduct 1. Clean the cab 2. Plan your trip 2. Plan your trip 3. Conduct a thorough pretrip 3. Conduct a thorough pretrip 4. Charge and connect HOS devices 4. Charge and connect HOS devices 5. Know HOS limits and rules of exception(s) used 5. Know HOS limits and rules of exception(s) used 6. Ensure paperwork is in order (including Hazmat) 6. Ensure paperwork is in order (including Hazmat) 7. Confirm prior days’ hours are certified on device 7. Confirm prior days’ hours are certified on device 8. Conduct a thorough post-trip 9. Complete DVIR to note any safety defects 10. Be positive Roadside Inspection Code of Conduct 1. Clean the cab 8. Conduct a thorough post-trip 9. Complete DVIR to note any safety defects 10. Be positive Roadside Inspection Code of Conduct 1. Clean the cab 2. Plan your trip 2. Plan your trip 3. Conduct a thorough pretrip 3. Conduct a thorough pretrip 4. Charge and connect HOS devices 4. Charge and connect HOS devices 5. Know HOS limits and rules of exception(s) used 5. Know HOS limits and rules of exception(s) used 6. Ensure paperwork is in order (including Hazmat) 6. Ensure paperwork is in order (including Hazmat) 7. Confirm prior days’ hours are certified on device 7. Confirm prior days’ hours are certified on device 8. Conduct a thorough post-trip 9. Complete DVIR to note any safety defects 10. Be positive 8. Conduct a thorough post-trip 9. Complete DVIR to note any safety defects 10. Be positive DUPLICATE & DISTRIBUTE J. J. Keller grants full permission to print this page and provide to other members of your fleet for reference. Material must include “Copyright J. J. Keller & Associates, Inc.” Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 18 Prepare for ELog Inspections Roadside Inspection Driver Quiz ANSWER KEY 1. What paperwork must be presented during a roadside inspection if requested? a. Driver's license or CDL, if applicable b. Any bills of lading, hazmat documents, or expense receipts, and ELD documentation if asked c. A copy of the annual inspection or inspection sticker, IFTA and IRP license and decals d. All of the above 2. During a walk-around inspection while en-route, you noticed you had one marker light out, but didn’t have a replacement bulb with you. Now you are getting pulled into a scale for inspection. What should you do about the burned-out light? a. Ignore it; maybe the inspector won’t see it b. Tell the inspector that you have a light out, but you are planning on getting it fixed at the nearest truck stop ahead c. Tell the inspector that it doesn’t matter because it's daytime and you don’t need your lights d. Nothing 3. Which score is the reason, most often, a driver gets pulled in for an inspection? a. Driver Safety Management System (DSMS) score b. Compliance, Safety, and Accountability (CSA) score c. Independent Selection System (ISS) score d. Fair Isaac Credit Organization (FICO) score 4. If asked for your electronic log book, you should: a. Tell the inspector you don’t have one because it is easier to log on paper logs b. Prepare the electronic log by getting the last 7 days' hours and the current day's hours to display, or set the ELD to the appropriate data transfer mode 5. You haul hazardous materials. Where must load-related paperwork be stored, if you leave the vehicle? a. Anywhere that is convenient b. In the trailer, where the receiver will see it c. Where it is accessible from the driver’s seat, when seated d. On the driver’s seat or in the door pouch of the driver’s door 6. If you are using an AOBRD or ELD using AOBRD software, what is the date by which you must be using an ELD running ELD-compliant software? a. April 1, 2020 b. December 16, 2019 c. December 31, 2019 d. January 31, 2020 7. If you receive a vehicle violation you can ask the officer to explain the violation, so you can have it repaired. a. True b. False 8. What are the some steps a driver should take to experience a good roadside inspection? a. Conduct a thorough pretrip b. Ensure paperwork is in order and have a good attitude c. Know which device you have, AOBRD or ELD, and understand how to use the device d. All of the above c. Hand the device to the inspector so they can inspect or transfer the logs to themselves d. Call your dispatcher and ask them what to do Copyright 2019 J. J. Keller & Associates, Inc. 855.693.5338 | KellerEncompass.com 19 J. J. Keller Can Help As the nation’s leading regulatory compliance and best practice expert, J. J. Keller is your reliable source for help complying with the ELD rule and other motor carrier safety requirements, preparing for roadside inspections, reducing violations, and preventing crashes. J. J. Keller® Encompass® Fleet Management System The Encompass® system is the industry's most versatile online tool for improving fleet compliance, simplifying regulatory tasks and automating administrative work. The system's easy-to-navigate regulatory dashboards give you: •Interactive tools for managing all aspects of driver compliance, vehicle compliance and performance tracking, with optional ELogs, Video Event Management with Dash Cam Pro and standalone electronic DVIR capabilities •In-depth reporting to identify trends and potential risks across all locations for a holistic view of compliance •Proactive alerts for required and expiring paperwork, training and violations •24/7 online access to your records and data, including user-defined permissions for added security Visit KellerEncompass.com for more information. J. J. Keller® Managed Services Relieve your organization of time-consuming compliance management and recordkeeping for your drivers, vehicles and employees with J. J. Keller® Managed Services. Our skilled team of compliance specialists offer expert services, which include: • Managing driver qualification and your drug and alcohol testing program • Monitoring and auditing drivers’ hours of service • Ensuring FMLA program compliance • Managing your employee training program • Obtaining DOT authority and credentials • Handling vehicle title and registration details • Obtaining fuel, mileage and trip permits Visit JJKeller.com/ManagedServices for more information. Discover more regulatory products and services by visiting JJKeller.com Laws, regulations, and best practices change. The observations and comments drawn today may not apply to laws, regulations, or best practices as they may be in the future. J. J. Keller & Associates, Inc. cannot and does not assume responsibility for omissions, errors, or ambiguity contained in this planner. Individuals needing legal or other professional advice should seek the assistance of a licensed professional in that field. FMCSA is the owner and author of CSA. 427690-049 Copyright 2019 J. J. Keller & Associates, Inc.