Helping drivers understand their role in keeping vehicles safe on the road is a strong first step toward overall driver and carrier safety. Take the time to train them on both the regulatory requirements and your company requirements, and then give them a disciplined approach to conducting inspections.
By Tom Bray
When training drivers on vehicle inspection requirements, a three-step approach is a best practice. The first step is making sure the drivers understand the regulations. The second step is making sure that the drivers understand your expectations. Finally, the third step is making sure drivers actually know how to conduct an inspection. This means they should have a practiced routine and know what to look for.
In industries where vehicles see harsh duty, such as the waste industry, this kind of thorough training is critical. These vehicles could stop and start hundreds of times a day and may regularly pass near potential hazards. They may also operate in rough terrain and/or in areas (transfer stations, landfills, etc.) that can cause defects (like tire issues) to occur.
Step 1: Teaching Drivers their Regulatory Responsibilities
The first requirement drivers must understand is that the carrier must have a systematic maintenance program that ensure its vehicles are always in a safe condition (see §396.3, page 52). In other words, it is the company’s responsibility to give the driver a vehicle that is in good condition.
It is important that drivers understand this obligation, so that they get the vehicles in for service when required and report any defects they discover. The carrier must be able to rely on the driver to help ensure vehicles stay in good condition.
Pre-Trip Inspections
As part of ensuring vehicles stay in good condition, drivers are required by the regulations to complete daily inspections. The first is the pre-trip inspection. The driver must be satisfied with the condition of the vehicle before operating it (see §392.7 and §396.13, page 52) and therefore must check the following:
• Service brakes
• Parking (hand) brake
• Steering mechanism
• Lighting devices and reflectors
• Tires
• Horn
• Windshield wiper or wipers
• Rear-vision mirror or mirrors
• Coupling devices
• The previous DVIR (driver-vehicle inspection report)
If the previous driver has noted any defects on a DVIR, the driver doing the pre-trip must sign the DVIR agreeing that the repairs were completed. If the repairs were not completed, the driver must sign that he/she agrees that the repairs are not necessary. Under a separate regulation, §392.8, the driver must also inspect the required emergency equipment (fire extinguisher, warning devices and spare fuses) as part of the pre-trip inspection.
Post-Trip Inspections
Drivers also have inspection responsibilities at the end of the workday, when they must determine the condition of the vehicle as part of a post-trip inspection. The regulations require that the condition of the following components be reported on in a post-trip inspection:
• Service brakes, including trailer brake connections
• Parking (hand) brake
• Steering mechanism
• Lighting devices and reflectors
• Tires
• Horn
• Windshield wipers
• Rear vision mirrors
• Coupling devices
• Wheels and rims
• Emergency equipment
If the driver finds a defect, §396.11(a) requires the driver to note it on a DVIR and submit it to the carrier. The company must then address the defect before the vehicle is operated again. Again, addressing the defect can include repairing it or determining that the vehicle is safe and compliant with the defect, so it does not need to be repaired.
Step 2: Training Drivers on Company Inspection Requirements
The second step in training on driver inspections is training your drivers on your expectations. Explaining your company requirements and processes and clearly stating that you will be using various means to verify that drivers are doing the inspections as you require are both critical steps.
Many carriers have expanded on the basic inspection requirements in the regulations. They may have company policies that require their drivers to inspect more components than the regulations call for. Many carriers simply require the driver to “inspect everything on the vehicle.” This is especially common if the vehicle has additional or special components (as a waste truck does).
Some companies also require their drivers to complete a pre-trip form (which is not required by the regulations) and to submit a DVIR, even if no defect is discovered (also not required in the regulations). By requiring a pre-trip report and a DVIR every day, the carrier can verify that the driver did the required inspections.
Companies may also require that their drivers do a walkaround inspection every time the vehicle is parked for more than a few minutes. These inspections involve going around the vehicle at a walking pace with the lights, four-way flashers, and warning lights turned on, and checking:
• The lights
• The tires and hub assemblies (condition and inflation of the tires)
• Securement of attachments (tools, loading arms, etc.)
Step 3: Teaching a Practiced Routine
The final step in training drivers on vehicle inspections is making sure that the driver has a routine to follow. There are several very valid routines available, such as the “five-step” routine for pre-trips and post-trips that involves:
1. Checking all of the engine compartment components (and steer axle components)
2. Checking the in-cab area
3. Conducting a walkaround
4. Checking the lights that could not be checked during the walkaround
5. Conducting a brake system check
An important consideration is training drivers to follow a specific pattern during each step. An example would be using a “top down and under, and inside out” approach when conducting the walkaround. This involves standing in one place and looking up at the top of the vehicle, and then checking everything that is on the vehicle as he or she looks from the top down.
Once at the bottom of the vehicle, the driver would check the underside components, starting from the middle and working out (under and inside out). Once done in that location, take one step and repeat. The driver should continue this pattern all the way around the vehicle. By teaching the driver to use a pattern, you reduce the odds that the driver will miss something.
Three Steps to Safer Vehicles
Helping drivers understand their role in keeping vehicles safe on the road is a strong first step toward overall driver and carrier safety. Take the time to train them on both the regulatory requirements and your company requirements, and then give them a disciplined approach to conducting inspections. By doing this, you have taken key steps toward making sure your equipment—and your drivers—are staying safe on the road.
Tom Bray is an industry consultant on transportation who has been with J. J. Keller & Associates, Inc. (Neenah, WI) since 2005. He brought with him an extensive background that includes years of experience in DOT compliance, policy development, driver training, and accident and injury prevention. Tom can be reached at [email protected].
Regulations
§396.3 Inspection, Repair and Maintenance
(a) General. Every motor carrier and intermodal equipment provider must systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles
and intermodal equipment subject to its control.
(a)(1) Parts and accessories shall be in safe and proper operating condition at all times. These include those specified in Part 393 of this subchapter and any additional parts and accessories that may affect the safety of operation, including but not limited to, frame and frame assemblies, suspension systems, axles and attaching parts, wheels and rims, and steering systems.
§392.7 Equipment, Inspection and Use
(a) 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
• Lighting devices and reflectors
• Tires
• Horn
• Windshield wiper or wipers
• Rear-vision mirror or mirrors
• Coupling devices
• Wheels and rims
• Emergency equipment
§396.13 Driver Inspection
Before driving a motor vehicle, the driver shall:
(a) Be satisfied that the motor vehicle is in safe operating condition;
(b) Review the last driver vehicle inspection report; and
(c) 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 that there is a certification that the required repairs have been performed. The signature requirement does not apply to listed defects on a towed unit which is no longer part of the vehicle combination.
§392.8 Emergency Equipment, Inspection and Use
No commercial motor vehicle shall be driven unless the driver thereof is satisfied that the emergency equipment required by §393.95 of this subchapter is in place and ready for use; nor shall any driver fail to use or make use of such equipment when and as needed.
§396.11 Driver Vehicle Inspection Report(s)
(a) Equipment provided by motor carrier. (1) Report required. Every motor carrier shall require its drivers to report, and every driver shall prepare a report in writing at the completion of each day’s work on each vehicle operated, except for intermodal equipment tendered by an intermodal equipment provider. The report shall cover at least the following parts and accessories:
(a)(1)(i) Service brakes including trailer brake connections;
(a)(1)(ii) Parking brake;
(a)(1)(iii) Steering mechanism;
(a)(1)(iv) Lighting devices and reflectors;
(a)(1)(v) Tires;
(a)(1)(vi) Horn;
(a)(1)(vii) Windshield wipers;
(a)(1)(viii) Rear vision mirrors;
(a)(1)(ix) Coupling devices;
(a)(1)(x) Wheels and rims;
(a)(1)(xi) Emergency equipment.
(a)(2) Report content. (i) The report must identify the vehicle and list any defect or deficiency discovered by or reported to the driver which would affect the safety of operation of the vehicle or result in its mechanical breakdown. If a driver operates more than one vehicle during the day, a report must be prepared for each vehicle operated. The driver of a passenger-carrying CMV subject to this regulation must prepare and submit a report even if no defect or deficiency is discovered by or reported to the driver; the drivers of all other commercial motor vehicles are not required to prepare or submit a report if no defect or deficiency is discovered by or reported to the driver.
(a)(2)(ii) The driver must sign the report. On two-driver operations, only one driver needs to sign the driver vehicle inspection report, provided both drivers agree as to the defects or deficiencies identified.
(a)(3) Corrective action. (i) 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 driver vehicle inspection report which would be likely to affect the safety of operation of the vehicle.
(a)(3)(ii) Every motor carrier or its agent shall certify on the driver vehicle inspection report that lists any defect or deficiency that the defect or deficiency has been repaired or that repair is unnecessary before the vehicle is operated again.