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Vehicle Inspection & Maintenance Requirements and Best Practices

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Vehicle Inspection & Maintenance Requirements and Best Practices

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  1. Attention Attendees: • Thank you for attending! • The presentation will start in a few minutes at 1:00 p.m. Central. • You will be muted during the event. • Please use the Question feature to text questions to our Panelists. We’ll try to answer them during the Q&A period if they are not covered in the presentation. 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 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 For audio, please use computer speakers or dial: 1-888-824-5783 or 1-617-213-8002, Pass Code: 61156559# Technical difficulties: 1-888-259-8414, Webinar ID: 198466121

  2. Introduction Gary Petty National Private Truck Council Dr. Gary Petty President & CEO National Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  3. Introduction • DOT Inspection & Maintenance Requirements – Tom Bray • Raising the Inspection & Maintenance Bar – Tom Moore • The Pepsi Experience – Dan Norris • Housekeeping issues: • You will be muted during the event. • Please use the Question feature to text questions to the Q&A Panelist. We’ll try to answer them during the Q&A period if they are not covered in the presentation. • If you lose sound at any point, you can dial-in by phone using the number and Pass Code listed below. • If you lose the program window and need to re-loginbe sure to enter a different e-mail address to avoid being denied access for multiple logins. Gary Petty National Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  4. DOT Inspection & Maintenance Requirements Tom BrayJ. J. Keller & Associates, Inc. Thomas Bray Editor, Transportation Management J. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  5. Inspection, Repair & Maintenance (Part 396) • Systematically maintain & inspect (396.3(a)) Vehicles controlled thirty (30) 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! Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  6. A “Systematic” Program • Typical “systematic” program (complete with supporting checklists): • PM-A “Safety check” - Inspection of key componentsand 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 Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  7. Required Records (396.3(b)) • Required records (396.3(b)): • Vehicle identification (396.3 (b)(1)),including fleet number, VIN, make, model, year, tire size, and owner (if not owned by the carrier) • 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 Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  8. Audit Point - Recordkeeping • The auditor will verify that you are performing the inspections, maintenance, 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. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  9. Unsafe Operations Forbidden (396.7) • Catchall for law enforcement and auditors • A motor vehicle shall not be operated in such a condition as to likely cause an accident or a breakdown of the vehicle. • Knowingly operating an unsafe vehicle can make a carrier criminally liable. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  10. Audit Point – Roadside Inspections • Major point of DOT Compliance Review • If roadside OOS rate 34% or more, cannot receive“Satisfactory” rating in vehicle factor. • 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! Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  11. 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) Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  12. Pre-trip (392.7 and 396.13) • Driver cannot operate the vehicle until the driver is satisfied with the condition of the 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). Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  13. Enroute • “Walk-around inspection” checking tires, lights, hubs, cargo securement, coupling 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. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  14. Post-trip/DVIR (396.11) • Pre-trip cannot take place of post-trip/DVIR • Copy of last DVIR NOT required to be 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 Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  15. Practical Recordkeeping Compliance Issues • When to complete DVIR: • 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 • 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! Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  16. Audit Point - Records • DVIR violation in compliance reviews common (number one critical violation). • Common violations: • 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 Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  17. 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 Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  18. Periodic (Annual Inspection) • Appendix G lists the requirements for successful passage of a periodic/annual 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. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  19. Appendix G v. CVSA OOS Criteria • Appendix G and CVSA Out-of-Service Criteria follow the same format whenever Appendix G and CVSA Out-of-Service Criteria 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-of-Service criteria would allow the vehicle to continue its current trip, if the one defective brake is on a non-steering axle. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  20. Technician Qualifications • 396.19 details periodic/annual inspector requirements • 396.25 details brake inspector qualification • Carrier is responsible for documenting qualification of their technicians Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  21. Technician Qualifications • Anyone performing periodic annual inspections must: • 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. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  22. Technician Qualifications • Anyone inspecting, maintaining, or repairing brakes on a commercial vehicle must: • 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. Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  23. Raising the Bar Tom MooreNational Private Truck Council Tom Moore, CTP Vice President of Education National Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  24. Why the Regs Aren’t Followed Poor communication Conflicting goals Forms and processes that lead to poor follow-through Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  25. Raising the Bar: Daily Inspections Best Practices Hire intelligently Train drivers 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 Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  26. Raising the Bar: Roadside Inspections Best Practices Weekly and spot inspections Review SafeStat data monthly 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) Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  27. Raising the Bar: Annual Inspections Best Practices Consider more frequent inspections Enhance internal communications Improve vendor relationships Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  28. Audit Your Inspection Practices Out of service rates Accident rates Equipment violation citations Maintenance cost and repair Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  29. Benefits of Raising the Bar Lower overall maintenance costs Increased fuel mileage Improved driver retention Improved on-time percentages Tom MooreNational Private Truck Council Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  30. The Pepsi BottlingGroup Experience Dan NorrisPepsi Bottling Group Dan Norris, CTPFleet Operations Manager Atlantic RegionPepsi Bottling Group (PBG) Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  31. 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. Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  32. PBG’s Situation Before Driver Training • Before Training • Pre-trips not completed • 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 • 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  33. Driver Vehicle Inspection Report Pre-Trip Checklist Post-Trip Checklist Vehicle Maintenance Action Driver Review PBG’s DVIR Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  34. PBG’s Pre-trip Process • Review prior day DVIR to see if vehicle was written up for maintenance • 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  35. 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  36. 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  37. 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 • Driver Take Away: It takes about 10-15 minutes but it is one of the most important things a driver does each day. Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  38. PBG’s “Defect Found” Process • Check off items as pre-trip inspection is completed • 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  39. PBG’s Post-trip Process • The post-trip inspection is divided into different sections. Each section has several 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 Dan NorrisPepsi Bottling Group • Horn • Windshield wipers • Rear vision mirrors • Coupling devices • Wheels and rims • Emergency equipment Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  40. PBG’s Post-Trip “No Defect” Process • Check only items that need repair • If no repair is needed, check “NO DEFECTS” • 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. Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  41. PBG’s Post-Trip “Defect Found” Process • Check only item(s) that need repair • Legibly sign your name • 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  42. PBG’s Critical Success Factors • Clear communication is essential • Establish responsibilities: • 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. Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  43. PBG’s DVIR Document Flow Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  44. “White Copy” Document Flow Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  45. “Yellow Copy” Document Flow Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  46. “Pink Copy” Document Flow Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  47. 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 Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  48. Results of Driver Training • After Training • Pre/Post-trip are completed • Passing internal DOT audits with flying colors • Employee and manager ownership • Improved communication between driver and technician • Driver Benefits • Improved asset uptime • No departure delays • Decreased risk of DOT fines • Clearer lines of communication • Technician Benefits • Improved asset uptime • Improved productivity • Streamlined paper work process • Educated driver Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  49. PBG’s Results • System benefits • DOT Compliant • 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 • Validating quality of DVIR’s • Tie in to new hire process • Determining cycle for retraining • Electronic DVIR Dan NorrisPepsi Bottling Group Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

  50. Question & Answer Please submit questions to “Q&A” using the Q&A tool Dan NorrisPepsi Bottling Group Tom MooreNational Private Truck Council Gary Petty National Private Truck Council Tom BrayJ. J. Keller & Associates, Inc. Dial-in: 1-888-824-5783, Pass Code: 61156559#; Tech Support: 1-888-259-8414, Webinar ID: 198466121

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