DOT & ELD Guidance Blog

Is Your Fleet Technician Qualified?

Are you aware of the FMCSRs concerning training, certifications, and documentation for your maintenance technicians?

J.J. Keller Industry Consultant Tom Bray

Tom Bray - Sr. Industry Business Advisor - J. J. Keller & Associates, Inc.

November 29 , 2022

It seems rudimentary to ensure that your maintenance technician is qualified. But are you aware that there are Federal Motor Carrier Safety Regulations (FMCSRs) concerning training, certifications, and documentation for your technicians?

The DOT requires a fleet or motor carrier to verify that anyone they employ who works on brakes or conducts periodic (annual) inspections must:

  • Understand the related regulations,
  • Understand the tools and techniques necessary to conduct maintenance inspections, and
  • Have one year of experience, adequate training, or a combination of experience and training.

Companies must then document that the individual is qualified to work on brakes, conduct periodic inspections, and retain the documentation (see §396.19 and §396.25).

These are the minimum requirements based on the regulations. And while the Federal Motor Carrier Safety Administration (FMCSA) doesn’t require efforts that exceed the regulations, they have created the Safety Management Cycle (SMC) as a recommended approach to support best-in-class fleet compliance in the following areas:

  • Having and using policies and procedures,
  • Assigning roles and responsibilities,
  • Using qualification and hiring standards,
  • Training and ongoing communications,
  • Monitoring and tracking, and
  • Taking meaningful action when necessary.

Let’s look at one of these areas — using qualification and hiring standards — as it applies to maintenance technicians.

Hiring and Qualification Standards & Documentation

Hiring and qualification standards include recruiting and screening applicants for maintenance positions. This is more than verifying that the applicant can fulfill the roles and responsibilities of the job. It requires planning to ensure that current managers, supervisors, and technicians remain qualified.

Before hiring a candidate, ensure the technician's background meets the specific training and experience requirements you've established. Typical requirements for technicians include:

  • Training and instruction at a recognized learning institution,
  • The appropriate certifications and qualifications, and
  • At least one year of experience.

A technician can only be assigned to particular tasks once they have met specific DOT requirements. These tasks should be considered when developing your qualifications. Additionally, you must have documentation showing that the technician is qualified to execute the following:

  • Periodic (normally annual) inspections — Any technician performing periodic (annual) inspections for you must meet the training and experience requirements in §396.19. In addition, you must have documentation showing the technician's qualifications on file the entire time the technician does annual inspections and then for one year after the technician stops doing annual inspections.
  • Brake inspection and repair — Any technician you have inspecting and/or repairing brakes must meet the qualifications requirements in §396.25. You must retain records supporting the technician's qualifications for the entire time the technician is inspecting and/or repairing brakes and then for one year after the technician stops inspecting and/or repairing brakes.
  • Air conditioning service — Technicians who service or repair motor vehicle air conditioners must be certified under the U.S. Environmental Protection Agency (EPA) rules. The certification and proof of training must be provided through an EPA-approved program. SAE (Society of Automotive Engineers), ASE (Automotive Service Excellence), and vehicle and component manufacturers offer this training.

Maintenance supervisors and managers should also have specific qualification requirements. These requirements should be based on experience, leadership skills, management knowledge, and the ability to think strategically and multitask. These skills are different from the skills a technician needs; therefore, your selection process needs to be based on these qualification requirements more than being technically sound as a technician. Having an experience requirement should address this.

Facing the Future

One issue the industry is dealing with is a shortage of technicians. Because of this, many carriers have decided to train their technicians through an apprenticeship program. The key to success is having a regimented program with in-house and external training benchmarks.

As a safety professional, you want to ensure that your company and technicians exceed basic requirements. Doing quality-control checks and insisting on ongoing training are standard methods used by fleet professionals to make sure their technicians are exceeding the requirements.

The Encompass® Fleet Management Solution supports your DOT compliance efforts and best practices related to maintenance. Whether you are hiring, qualifying, documenting, training, or monitoring maintenance personnel or processes, Encompass makes it easier with a cloud-based platform. Contact a compliance specialist at 855-693-5338 or visit JJKeller.com/TryEncompass to request a conversation.


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