TCI Magazine asked a few member companies how they manage adherence to Department of Transportation (DOT) regulations in order to avoid failing roadside inspections. Among the points they seemed to agree on is that a broken lightbulb is enough to get a truck put out of service, and that the cost and effort it takes to stay in compliance is worthwhile in terms of productivity, overall costs and safety.
Kendal “Kenn” Goodson wears many hats at McCoy Tree Surgery, a 38-year TCIA member company based in Norman, Oklahoma, including that of fleet manager.
McCoy Tree Surgery is like most businesses in the arborist industry – our drivers are arborists first, and driving a truck is a secondary task. That doesn’t mean they don’t have the same responsibilities as over-the-road truck drivers. Vocational fleets have to manage regulatory requirements just like any other fleet. Pre- and post-trip inspections don’t take long and will save you money in the long term. For one thing, they allow you to have planned maintenance instead of having unplanned repairs.
It is necessary to simplify the inspection process as much as possible. The first thing we train in our organization is, if there is something that is part of the truck, it has to work properly. I know that sounds silly, but it really is the baseline. With today’s modern trucks, there is no “extra” equipment. Everything is required and mission critical. When the driver has developed a mindset that all defects have to be corrected before the truck hits the public roadway, you’ve already won half the battle.
That being said, you can’t just hand a driver Appendix G of the Federal Motor Carrier Safety Regulations (FMCSRs) and expect the driver to memorize it. You should have an easily understood checklist to guide all inspections. It has to be detailed, too; if it’s not on the checklist, you can be sure it won’t get addressed. It also does no good to hand the driver a checklist and then not give him or her enough time to complete the inspection. The idea is to generate complete inspections, not to complete paperwork.
In the industry, many times we treat trucks as an afterthought, but in reality, we should treat trucks the way pilots treat airplanes. The driver of a 20-ton truck has a huge amount of responsibility to the public, his passengers and, of course, the company for which he drives. This is doubly true for trucks that have aerial lifts installed.
Q: What are two or three areas of DOT vehicle-fitness requirements that you find particularly challenging?
Ten years ago, the answer would have been lights, lights and lights. LED lighting has made lighting much more reliable. There is absolutely no excuse for having a brake light or taillight that doesn’t function, and enforcement officers know it.
In today’s environment, tires, trailer couplers and trailer brakes are the most common failing inspection items we see. As a wear item, tires need constant attention, and inflation is important to minimize wear. Drivers need tire-pressure
gauges on their trucks. Without them, they can’t do a proper inspection. Pintle eyes, or lunette rings, are wear items, too. They are often overlooked by drivers, but not by enforcement officers.
Electric trailer brakes are a challenge. They are difficult to inspect, and roadside enforcement officers will sometimes use novel ways of testing electric brakes on the roadside. There are red flags that must be addressed; wires hanging down underneath trailer axles or a disconnected pigtail are an easy invitation to get pulled over for inspection. Testing the trailer brakes for braking action on the way out of the yard every day is easy and should be a habit for all drivers.
Q: What are the things that would cause a vehicle to fail a DOT roadside inspection?
First and foremost, know the rules and know where you can find information for your state. Next, don’t make it easy for enforcement personnel to pull you over – keep your trucks clean, inspected and maintained. They can be ugly, but everything should work. Don’t fall prey to the “good enough” mentality. If something on the truck isn’t right, fix it before you roll it.
Know your hours-of-service classification. Are you required to (maintain a) log, or are you exempt for some reason?
Know your weight. Enforcement officers hate to put a non-CDL driver out of service because his under-CDL truck weighs in at 27,000 pounds on the roadside. I have seen drivers who were ticketed for being overweight and for operating a CDL vehicle without a commercial license.
Lastly, keep your paperwork straight. Enforcement officers don’t want to stand at the roadside with traffic whizzing by them at 70 miles an hour while you sort through 10 years’ worth of expired registrations and insurance cards that you’ve dug out of a dirty glove box. Keep your current paperwork together – a zip-lock bag works if you have nothing else – where it can be accessed in seconds. While you are at it, keep a second zip-lock with your spare fuses and lights, because he will want to see those, too.
Q: Many of our readers are at small businesses with relatively small fleets. What advice on staying DOT compliant would you offer them?
Get help. A small-business operator already has too much burden to carry. The FMCSA website has materials for fleets, and there are commercial offerings from JJ Keller and others. The National Safety Council has some great material on driver safety; their “What If” strategy should be part of everyone’s vocabulary. Talk to your insurer as well to see what materials they can offer.
Q: Would you like to highlight or discuss any programs your company uses to proactively avoid failed DOT inspections?
Most of our fleet is composed of aerial-lift trucks with an arborist body on them. Since the aerial lift requires so much attention and inspection to comply with manufacturers’ recommendations and the ANSI A92.2 standard, we include the truck as part of that inspection process. In real terms, that means the driver/operator is not the only person who will be inspecting the vehicle on a regular basis. Besides the driver’s daily inspections, our first-line managers inspect as part of their role as trainers and supervisors, plus we have quarterly inspections of the entire truck by a third-party technician and, of course, our annual A92.2 inspection with dielectric testing.
It is important that as many different sets of eyes as possible perform the inspection function on each truck. We’re all human and subject to fatigue and a whole host of biases. We can miss some things and overlook others. When you have multiple inspectors on a piece of equipment, it is less likely that defects can escape notice.
Lastly, we have a safety director who has created a culture in our organization where truthfulness and trust are valued and practiced. Our drivers don’t need to fear reprisal for pointing out defects or delivering bad news. Mistakes are viewed as training opportunities, and responsibility is not equated with blame. That makes a world of difference.
Bill Carney is in charge of DOT compliance for The Townsend Corporation, a duel-accredited, 43-year TCIA member company headquartered in Muncie, Indiana.
I’ve heard a lot of stories about the high cost of fines and of drivers having items on the truck to avoid a fine, but being told “It’s too late.”
You don’t forget paying a fine for not having washer fluid in the reservoir when you had two gallon containers of it in your work box on the same truck. The same has been reported about coolant, power-steering fluid and oil. Or having the up-to-date registration cab card in the boss’s truck next to you at a weigh station, but still getting cited because it was not on your truck at the time you were traveling on the road. Once the inspection starts, you can’t fix anything. It is a snapshot in time of the vehicle. A good pre-trip inspection is your last chance before traveling on the road to fix problems before it is too late.
The best way to avoid any problems with DOT is by performing a thorough pre-trip inspection every day before a vehicle goes out on the road. This ensures that all components of your vehicle are functioning as the manufacturer intended, as well as that all documentation and safety equipment are present. If you’re not making pre-trips a priority, you are probably having problems. It used to be good enough to check fluids, lights and tires. Not anymore.
If you have a CDL license, you should be well versed in performing pre-trip inspections, since you needed to demonstrate one to get your license. Your state CDL-license training manual is a good place to start if looking for more information.
Non-CDL drivers who operate commercial motor vehicles need more training. (The definition of a commercial motor vehicle is state specific.) (See the pre-trip outline accompanying this article.)
This process is easy enough if a company only has a few vehicles. But as the number of vehicles on the road increases, the issues can be a little more daunting. More than a few companies have neglected the problem only to find themselves facing fines, audits and bankruptcy. After all, in the eyes of the DOT, our vehicles make many businesses trucking companies.
At Townsend, we addressed DOT concerns by upgrading driver training and implementing an incentive program that aided in the improvement of our DOT score dramatically. It takes a commitment from management to enforce morning pre-trips and resolve any issues prior to going out on the road – every day!
The problem has always been time. Time is money, as are increased insurance costs, incidents, property damage, workers’-comp claims, fines and audits. All are results of improperly maintained vehicles and poorly trained drivers.
The best rule of thumb is to ask, “Is this (light, hose, spring, brake, etcetera) working as the manufacturer intended?” If the answer is “No,” then it needs to be repaired or replaced. Pre-trip inspections ensure the safety of your people and help avoid issues with DOT. Make time for them and make them a regular routine.
Tim Cheever, CTSP, is manager, MCS support, in the Beverly Hills, Florida, branch of The Davey Tree Expert Company, an accredited, 48-year TCIA member company headquartered in Kent, Ohio.
A carrier will avoid most all violations by completing proper pre- and post-trip inspections and not operating until any defects discovered are corrected prior to use. Most violations are preventable with proper training and oversight. Easier said than done, however, a proven fact!
A few things we do to try to be proactive include:
- Peer checks: Inspect each other’s trucks. But this doesn’t relieve the driver’s responsibility to inspect themselves.
- Truck rodeos: Each of these is a fun day of hands-on inspections, driving skills, on-road driving (scored, and gives drivers a fun way of ribbing each other for hitting cones, etcetera) We provide a first-, second- and third-place gift, and it provides bragging rights until the next one.
- Gate checks: A knowledgeable, competent person checks a couple of random items as drivers leave the yard in the morning. Example: license and emergency equipment, lights and breakaway device and so on. It can be daily or a couple of days a week, modified to meet your operation.
- Quality pre/post inspections
- Correcting minor defects prior to use, i.e., replacing one of three center ID lamps on the rear of a truck. It is not an imminent hazard, but it is a violation, and might result in a failed inspection all the same.
- Breaking the idea that we are arborists, not truck drivers. To and from the job, we are professional truck drivers and regulated as such.
- Commit to a compliant Motor Carrier Safety Program (use the “What If” approach). Once the unintended incident occurs, you cannot go back and fix it. Everything freezes at that moment!
- Right driver, right truck, right credentials.
- Ensure all CDL drivers have registered with the FMCSA Drug/Alcohol Clearinghouse.
- Ensure your drivers are fully qualified in accordance with state/federal requirements.
- Be prepared for the unforeseen. You will sleep better and be able to focus your attention on building your business if you are. A compliant program can help recruitment and retention, as the drivers know you have interest in their safety and their license, since many violations can go against their license.
The Townsend Pre-Trip Inspection Checklist
This pre-trip inspection outline can be tailored to type of vehicles and/or location. It is not meant for all vehicles.
Approach from front and move around vehicle
Leaks (no puddles under truck indicating a leak), Leans (not leaning left or right indicating a suspension or tire problem), Lights (all securely mounted, no broken lenses or debris, all working).
All exterior items securely mounted – Bumper, headache rack, cones, steps, lights, fuel tank, etc., are securely mounted, secured and/or strapped down.
Under the hood
Fluids – Oil, coolant, washer, power-steering, transmission and brake-fluid levels are between the min. and max. No leaks.
Belt(s) – Should not be worn, frayed or cracked; should not move more than three-quarters of an inch when pressed.
Components – Alternator, power-steering pump, water pump and air compressor. All are securely mounted by their bolts. Wires and/or hoses are secured by their fittings. Hoses have no leaks.
Hoses – Should be properly attached, clamped and not frayed or cracked. No leaks.
Steering – Linkage and shaft, steering box (no leaks), Pitman arm and drag link (pins and crowns present), control arms and tie rods should have no damage and be properly secured.
Suspension – front and rear
Springs and spring mounts – Securely mounted by bolts and U-bolts. No scissoring or damage.
Shock absorbers – Securely mounted. No damage and not leaking.
Tires, rims – Inflation (check w/tire-pressure gauge), Condition (no cupping, bulging or side-wall damage), Depth (min. 4/32 of an inch front and 2/32 rear), Valve stems (not cracked or leaking and capped with a metal cap). Rims not bent or welded. Lug nuts – No rust or shiny threads. Hub and seal – securely mounted, full and no leaks.
Budd rims (rear, dual wheels) – No debris and tires are not touching. There should be no illegal welds.
Brakes – front and rear
Brake lines – Securely mounted and no leaks.
Brake chamber (air brakes) – Securely mounted and no leaks.
Slack adjuster and push rod (air brakes) – 90-degree angle, pin is present, pull and should not move 1 inch.
Drums, rotors, linings and pads – Not dangerously thin. No damage or debris.
Drive shaft – Not dented or twisted and no debris. Universal joints securely mounted.
Exhaust – All original components present. Not dented or leaking. No black soot that would indicate a leak.
Frame – Securely mounted and not welded or bent. All items are secured to it.
Exterior items – Fuel tank (cap secured w/chain and seal, no leaks), battery box (secured all sides), work boxes, doors, tailgate, steps, lights, wheel chocks, outrigger pads, boom, mud flaps, pintle hitch, cones, coolers, DEF cap, etc., all securely mounted by their bolts, straps, hinges, latches and/or pins. Ratchet straps, chains or cables should be used for items needing to be tied down.
All gauges rise to a safe level (air gauge approx. 120 psi), check indicator lights (incl. ABS light goes on and off). The wiper and wash must work. Heater, defrost, horn(s), windows (no cracks or debris), mirrors (no cracks or debris and adjusted to driver) and seat belt (always wear) all must work. Emergency equipment – fully charged and mounted fire extinguisher, three reflective triangles and six replacement fuses must all be in the cab. You should also have a first-aid kit.
Documents – Driver’s license and DOT medical card, registration cab card, insurance and DOT inspection report, pre- and post-trips (DVIR) and IFTA paperwork – all must be up to date, filled out and in the cab, plus
Light check – Turn signals, hazards, brake, back-up, headlights, high beams and running lights. All must work!
Air- and Hydraulic-Brake Check
Air-brake safety devices vary. However, this procedure is designed to see that any safety device operates correctly as air pressure drops from normal to a low-air condition.
For safety purposes, you will use wheel chocks during the air-brake check.
The proper procedures for inspecting the air-brake system are as follows:
- With the air pressure built up to governor cutoff (120 – 140 psi), shut off the engine, chock your wheels, release the parking brake (all vehicles) and the tractor-protection valve (combination vehicle), fully apply the foot brake and hold it for one minute. Check the air gauge to see if the air pressure drops more than three pounds in one minute (single vehicle) or four pounds in one minute (combination vehicle).
- Without restarting the engine, turn electrical power to the “on” or “battery charge” position and begin fanning off the air pressure by rapidly applying and releasing the foot brake. Low-air warning devices (buzzer, light, flag) should activate before air pressure drops below 60 psi or level specified by the manufacturer.
- Continue to fan off the air pressure. At approximately 40 psi on a tractor-trailer combination vehicle (or level specified by the manufacturer), the tractor protection valve and parking-brake valve should close (pop out). On other combination vehicle types and single vehicle types, the parking-brake valve should close (pop out).
Service-brake check (pedal)
Check the application of air or hydraulic service brakes. This procedure is designed to determine that the brakes are working correctly and that the vehicle does not pull to one side or the other. Pull forward at 5 mph, apply the service brake and stop. Check to see that the vehicle does not pull to either side and that it stops when brake is applied.
With the parking brake engaged (trailer brakes released on combination vehicles), check that the parking brake will hold vehicle by gently trying to pull forward with parking brake on. With the parking brake released and the trailer parking brake engaged (combination vehicles only), check that the trailer parking brake will hold vehicle by gently trying to pull forward with the trailer parking brake on.
Pump the brake pedal three times, then hold it down for five seconds. The brake pedal should not move (depress) during the five seconds.
If equipped with a hydraulic-brake reserve (back-up) system, with the key off, depress the brake pedal and listen for the sound of the reserve-system electric motor.
Check by placing the vehicle in gear and tugging against it. If it tugs, it is working properly.
Service brake (pedal)
Check the proper operation of the foot brake by moving the vehicle forward slowly at about 5 mph and applying the brake firmly.