The importance of pre- and post-trip vehicle inspections cannot be overemphasized and are an essential part of the overall safe operation of a commercial vehicle. A quality inspection allows drivers to catch any issues before heading out on the road.
When used properly, quality vehicle inspections can avoid expensive roadside repairs, increase safety, prevent accidents, reduce downtime and fines, meet the regulatory requirements of the U.S. and Canadian DOT, and help drivers reach their destinations on schedule.
Federal Motor Carrier Safety Administration (FMCSA)
The primary mission of the FMCSA is to reduce crashes, injuries, and fatalities involving large trucks and buses. Among its functions, the FMCSA:
- Develops and enforces data-driven regulations that balance motor carrier safety with efficiency
- Harnesses safety information systems to focus on higher-risk carriers in enforcing safety regulations
- Conducts roadside inspections of commercial motor vehicles and/or drivers by Motor Carrier Safety Assistance Program (MCSAP) inspectors
The MCSAP inspectors conduct roadside examinations to check that drivers and vehicles are in compliance with the Federal Motor Carrier Safety Regulations and/or Hazardous Materials Regulations. If an inspection results in serious violations, the driver will be issued a driver or vehicle Out-of-Service Order. These violations must be corrected before the driver or vehicle can return to service.
It’s the law
Federal safety regulations require that a driver be “satisfied” that basic parts and accessories are available and in good working order prior to driving the vehicle.
As spelled out in the Federal Motor Carrier Safety Regulations (FMCSR) Part 396.13, before driving a motor vehicle, the driver shall:
- Be satisfied that the motor vehicle is in safe operating condition
- Review the last driver vehicle inspection report (DVIR)
- Sign the report—only if defects or deficiencies were noted by the driver who prepared the report—to acknowledge that the driver has reviewed it and certified that the required repairs have been performed
No-defect driver vehicle inspection reports
In a final ruling published on December 18, 2014, the FMCSA rescinded the requirement that commercial motor vehicle drivers operating in the U.S. in interstate commerce (except drivers of passenger-carrying commercial motor vehicles) submit, and motor carriers retain, the driver vehicle inspection reports (DVIRs) when the driver has neither found nor been made aware of any vehicle defects or deficiencies.
This change applies to operations in the U.S. only. To continue to comply with Canadian national and provincial regulations, U.S.-based motor carriers need to complete and retain DVIRs when operating in Canada, regardless of whether or not defects are noted.
Furthermore, the driver vehicle inspection report must identify the vehicle and list any defect or deficiency discovered by, or reported to, the driver that would affect safety during operation of the vehicle or result in its mechanical breakdown. The driver must sign the DVIR.
If a driver operates more than one vehicle during the day, FMCSR Part 396.11 requires that a report on a defect or deficiency be prepared for each vehicle operated.
Procedures and the sequence for vehicle inspections vary, but all cover certain areas, as stated in FMCSR Part 392.7 below.
No commercial motor vehicle shall be driven unless the driver is satisfied that the following parts and accessories are in good working order, nor shall any driver fail to use or make use of such parts and accessories when and as needed:
- Service brakes, including trailer brake connections
- Parking (hand) brake
- Steering mechanism
- Emergency equipment
- Lighting devices and reflectors
- Tires
- Horn
- Wheels and rims
- Windshield wiper or wipers
- Rear-vision mirror or mirrors
- Coupling devices
MEDICAL CARDS
- All commercial drivers of vehicles in interstate commerce with a maximum gross vehicle weight rating of more than 10,000 pounds are required to obtain and maintain a valid Medical Examiner’s Certificate. Commercial drivers who drive vehicles requiring a CDL have two additional requirements. All CDL holders must now declare to their State Driver Licensing Agency (SDLA) that they only operate or expect to operate commercially in 1 of 4 possible categories with their CDL. This process is called self-certification.
- These four categories are: interstate non-excepted, interstate excepted, intrastate non-excepted, and intrastate excepted.
- CDL holders must provide their SDLA with a copy of their Medical Examiner’s Certificate. This information is added only to the state driving records of CDL holders. Non-CDL holders are not required to self-certify or submit a copy of their Medical Examiner’s Certificate to their SDLA.
- CDL holders who drive in a category other than one to which they self-certified are subject to suspension or revocation of their commercial driving privileges.
- CDL drivers who do not update the expiration date of their Medical Examiner’s Certificate with their state will have their commercial driving privileges downgraded and will not be eligible to drive a commercial motor vehicle that requires a CDL.
More information can be found at: https://www.fmcsa.dot.gov/registration/commercial-drivers-license/medical
Who is responsible?
When properly performed, pre-trip and post-trip vehicle inspections help to prevent mishaps that can occur because of vehicle deficiencies. Drivers should employ at least four of their five senses—feeling, touching, looking, listening and smelling—when inspecting a vehicle’s condition. A good detective will locate all possible mechanical, electrical and/or other conditions that may cause a breakdown or an accident, helping to keep drivers and others safe while on the road.
Quality vehicle inspections eliminate the frustration of waiting for repairs or a vehicle replacement during a run. They also assist in keeping a vehicle in good working order, which also prolongs vehicle life and reduces operating costs.
Establishing a consistent step-by-step process of for the pre- and post-trip inspection enables a driver to complete the inspection faster, more efficiently and without omitting anything.
While both drivers and vehicle owners have a duty to make sure their vehicles are inspected daily, the driver is ultimately responsible for making certain that the vehicle is in a safe operating condition.
HOW TO CONDUCT AN INSPECTION
Pre- and post-trip vehicle inspection procedures, checklists and sequences vary. A best practice is to use an 11- step process:
- Vehicle overview
- Driver side of the tractor
- Front of tractor
- Passenger side of tractor
- Rear of tractor
- Coupling system of the tractor
- Driver side of the trailer
- Passenger side of the trailer
- Rear of the trailer
- Coupling system on the driver’s side
- Inside the tractor
Run through engine start procedures and check that warning lights, gauges, and back-up alarms (if so equipped) are all in good working order. Check previous driver vehicle inspection reports for any problems, and if any, make certain that any safety problems have been repaired.
Also, while in the cab, the driver should perform the following air brake checks:
- Static air loss (less than 3 PSI per minute for combination vehicles)
- Pressurized air loss (less than 4 PSI per minute for combination vehicles)
- Low air warning device (must come on when the air pressure falls below 60 PSI)
- Emergency brake system
- Parking brake (should pop out when the pressure is in the 20 to 40 PSI range)
- Service brake
- Trailer brake
Several trucking industry organizations offer easy-to-understand instructions and a step-by-step approach to help drivers learn how to efficiently and effectively inspect a vehicle in compliance with the U.S. Department of Transportation (DOT) regulations.
SIX LEVELS OF INSPECTION
The U.S. Department of Transportation’s vehicle inspection program is comprised of six levels:
Level I
North American Standard Inspection. The most comprehensive of the inspections and includes an examination of compliance with the critical elements of both driver and vehicle regulations.
Level II
Walk-Around Driver/Vehicle Inspection. Similar to the Level I inspection, but includes only those items that can be inspected without physically getting under the vehicle.
Level III
Driver/Credential Inspection. An examination of a driver’s license, medical certification, hours of service (HOS) compliance, seatbelt use, driver vehicle inspection report (DVIR), and hazardous materials requirements (as applicable).
Level IV
Special Inspection. Typically includes a one-time examination of a particular item and are normally made in support of a study or to verify or refute a suspected trend.
Level V
Vehicle-Only Inspection. Includes each of the vehicle inspection items specified under the Level I inspection, without a driver being present and conducted at any location.
Level VI
Enhanced North American Standard Inspection for Radioactive Shipments. An inspection for select shipments of radioactive material that includes enhancements to the Level I inspection.
EMERGENCY EQUIPMENT
Federal Motor Carrier Safety Regulations (FMCSR) Part 392.8 (Emergency Equipment, Inspection, and Use) states:
No commercial motor vehicle shall be driven unless the driver is satisfied that emergency equipment required by Part 393.95 (Emergency Equipment on All Power Units) is in place and ready for use; nor shall any driver fail to use or make use of such equipment when and as needed.
Emergency equipment listed in Part 393.95 includes: a properly charged, inspected and operable fire extinguisher; spare fuses; and warning devices for stopped vehicles.
TOP VIOLATIONS
Vehicles: Drivers: Out-of-Service
- Defective lighting/reflective devices
- Parts/accessories in an unsafe condition
- Oil and/or grease leaks
- Tire tread depth less than 2/32 of an inch
- No/discharged/unsecured fire extinguisher
Vehicle violations related to the transportation of hazardous materials/ dangerous goods:
- Loading and securement
- Shipping papers
- Placarding
- Log violations
- Non-English-speaking driver
- Speeding
- Hours of service violations
- Failing to use seat belt while operating a commercial motor vehicle
Cargo securement violations:
- No/improper load securement
- Failure to secure vehicle equipment
- Leaking, spilling, blowing, falling cargo
Vehicle violations:
- Brake systems
- Cargo securement
- Tires/wheels
UNSAFE OPERATION
Related to pre-trip inspections is Federal Motor Carrier Safety Regulations (FMCSR) Part 396.7 (Unsafe Operations Forbidden). It states that a motor vehicle shall not be operated in such a condition as to likely cause an accident or a breakdown of the vehicle.
However, this regulation contains an exemption that allows any motor vehicle on the highway discovered to be in an unsafe condition to continue to operate, but only to the nearest place where repairs can safely be made. Furthermore, this exemption states that this can be done only if it is less hazardous to the public than it would be to permit the vehicle to remain on the highway.
CARGO SECUREMENT
Vehicle inspections also must include cargo securement, per Federal Motor Carrier Safety Regulations (FMCSR) Part 392.9, (Inspection of Cargo, Cargo Securement Devices and Systems). Under this rule, a driver may not operate a commercial motor vehicle unless its cargo is properly distributed and adequately secured as specified in Part 393.100 through Part 393.136. These sections cover cargo- securement devices and systems along with the specific securement required by commodity type.
The tailgate, tailboard, doors, tarpaulins and other equipment used in a vehicle’s operation, and the means of fastening the cargo, must be secured as well. Also, the cargo or any other object cannot obscure the driver’s view ahead or to the right or left sides.
Additionally, Part 392.9 states that a driver must inspect the cargo and the load securement devices within the first 50 miles after beginning a trip and make any adjustments to the cargo or load securement devices as necessary—including adding more securement devices— to ensure that cargo cannot shift on or within, or fall from the commercial motor vehicle.
A driver also must re-examine and make any necessary adjustments whenever there’s a change-of-duty status, the vehicle hasn’t been driven for three hours, or the vehicle has been driven for 150 miles, whichever occurs first.
Attention to detail
There are three essential elements to safely transporting cargo: loading the cargo properly, restraining the cargo correctly, and using adequate securing devices.
Under the FMCSA’s Compliance, Safety, Accountability (CSA) safety initiative, violations for improperly secured cargo negatively impact both a fleet and a driver. While there are some violations for which a driver is not responsible (including aspects of the law that assigns responsibility to either the shipper or the fleet), if an inspector determines that the violation is one the driver could have rectified, a separate violation will be entered into that driver’s personal database.
A Driver’s Handbook on Cargo Securement is available from FMCSA and can be found online at: https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Drivers_Handbook_Cargo_Securement.pdf
ROADSIDE INSPECTIONS
The Federal Motor Carrier Safety Administration (FMCSA) authorizes roadside vehicle inspections. These are on-the- spot safety checks used to enforce motor carrier safety laws, promote highway safety, and reduce commercial vehicle related incidents by removing unsafe trucks or loads and unqualified drivers from the highway. These inspections can take place alongside the road, at a rest area or weigh station, or at a port of entry.
If a vehicle does not pass a roadside inspection because serious defects are discovered, it will be placed out-of- service. Necessary repairs must be made before the vehicle can be driven again.
Drivers are also subject to inspection and may be placed out-of-service if they don’t have their proper credentials or have violated hours of service regulations.
Drivers who conduct proper vehicle inspections can help ensure that a roadside inspection will not be a problem.
Federal, state, and local safety inspectors use the North American Uniform Out-of-Service Criteria as a reference guide for determining whether to place a commercial motor vehicle or its driver out-of-service. The criteria are a detailed list of conditions that are sufficiently hazardous to justify restricting further operation by a driver or vehicle and must be corrected before operations can resume.
Correction of less-severe violations may be deferred to a more convenient time and place.
The criteria were developed and are maintained by the Commercial Vehicle Safety Alliance (CVSA), a not-for- profit organization comprising local, state, provincial, territorial, and federal motor carrier safety officials and industry representatives from the United States, Canada, and Mexico. Its mission is to promote commercial motor vehicle safety and security by providing leadership to law enforcement, industry professionals, and policymakers.
Each year, the CVSA reviews its North American Uniform Out-of-Service Criteria and makes necessary changes. A commercial motor vehicle that passes a Level I or Level V roadside inspection will be awarded a CVSA decal that indicates that no violations were found of those items listed in the North American Standard Out-of-Service Criteria. The decal, affixed to the vehicle by a certified CVSA inspector, is issued only for the vehicle portion of any roadside inspection.
Decals remain valid for no longer than three months. The quarter in which an inspection is performed is indicated by the color of the decal issued. An inspection done in January/February/March gets a green decal; April/May/June, yellow; July/August/September, orange; October/November/December, white.
Locations for affixing the decals have been designated as follows:
- Power Unit – Lower right corner of the exterior surface of the passenger’s windshield.
- Trailers – Lower right corner, as near the front as possible.
- Cargo Tanks – Right side of the undercarriage near the front of the cargo tank (vehicle inspection items); eye-level on the right side near the front of the cargo tank (specification inspection items).
Vehicles displaying a valid decal are generally not subject to re-inspection unless a problem is observed.
Bypass inspections
There are weigh station bypass systems that allow “pre-cleared” commercial vehicles to continue at highway speeds without having to stop at weigh stations/inspection sites.
These systems use two types of technologies: one, radio frequency identification (RFID); and two, Commercial Mobile Radio Services (CMRS).
RFID uses a transponder mounted inside the windshield of the vehicle to identify a specific vehicle. CMRS uses cellular phone technology, i.e., mobile phones, tablets, and in-cab telematics devices.
Depending on the system, the truck-mounted transponder or mobile device sends a signal to a weigh station. The signal connects the carrier to an application used by law enforcement/safety officials to determine whether or not to inspect the truck or let it pass by. The system automatically checks the truck’s safety and credential clearance status and if all clear, sends a signal notifying the driver to bypass the weigh station/inspection site.
Two companies offer inspection bypass programs: PrePass from HELP and PreClear from Drivewyze.
HOW TO PREPARE FOR A ROADSIDE INSPECTION
Drivers should be prepared for a roadside inspection at any time. While keeping a commercial vehicle well-maintained is very important, so is the driver’s attitude. How drivers conduct themselves during an inspection can greatly impact the results.
Here are some tips for a smoother roadside inspection:
- Always perform a quality pre- and post-trip inspection.
- Be aware of the out-of-service criteria.
- Don’t give law enforcement an excuse to pull you over because of something visibly wrong.
- Keep the cab clean and organized. Clear your dashboard of papers, trash, hats, etc. A messy truck cab increases the odds of an inspection.
- Have all required documentation available, such as your commercial driver’s license (CDL), medical examiner’s certificate, annual inspection, permit credentials, all load-related paperwork, etc.
- Be professional and courteous.
- Don’t be combative.
- Don’t be afraid to ask questions.
- Use common sense and cooperate.
CSA Scores
Compliance, Safety, Accountability (CSA) is a data-driven safety compliance and enforcement program by the Federal Motor Carrier Safety Administration (FMCSA). CSA is designed to improve safety and prevent commercial motor vehicle crashes, injuries, and fatalities. In most cases, drivers and their motor carriers share responsibility for vehicle maintenance violations under CSA.
Following are some of the most common vehicle maintenance violations cited during roadside inspections, along with the severity, according to CSA’s scoring system. The higher the severity, the more it will impact a driver’s and carrier’s score.
- Tire-tread depth less than 2/32 of an inch – 8
- Stop lamp violations – 6
- Brake(s) out of adjustment – 4
- No/defective lighting/reflective devices – 3
- No/discharged/unsecured fire extinguisher – 2
