Tom Bray - Industry Consultant - J. J. Keller & Associates, Inc.
February 08 , 2019
ENCOMPASS® EDVIR APP
Easily customize your inspection criteria, resolve defects, and meet compliance recordkeeping requirements with the NEW Encompass® DVIR app.
Drivers are required to conduct several inspections over the course of their workday, including pre-trip, en route, and post-trip. Specific inspections are conducted for different reasons, but all are completed with one goal in mind: keeping the vehicle operating safely.
Under §392.7 of the Federal Motor Carrier Safety Regulations (FMCSRs), the driver must be satisfied the vehicle is in “good working order” before operating it. The regulations provide a shortlist of items that must be checked, however, most carriers insist the driver use a disciplined step-by-step approach and inspect everything on the vehicle. The “seven-step inspection process” detailed in the states’ CDL manual is one common technique, which involves:
If a problem is found during the pre-trip, the driver should not operate the vehicle until it is corrected. Though the regulation does not require documentation related to the pre-trip, many carriers ensure inspections are being conducted by using a pre-trip form and/or requiring drivers to note one was completed on their daily log.
Two en route inspections are required by the regulations:
Cargo securement inspections (§392.9) are required within the first 50 miles after loading, and then every 3 hours, 150 miles or at a duty change, whichever comes first. If transporting cargo sealed in the cargo area or loaded in such a way that checking securement is not possible, the driver is not required to do so.
Drivers transporting hazardous materials must check the condition of their tires (§392.17) before beginning the trip, any time the vehicle is parked, and at the end of the trip. If the driver discovers a low or flat tire, the driver can proceed to the nearest place to have it repaired. However, if the tire has overheated, the driver may not operate the vehicle again until the tire has been repaired.
Even drivers not transporting hazardous materials should perform a quick walkaround inspection of the vehicle to check tires, lights, hub heat and cargo securement. As with the pre-trip, no documentation is required, but many carriers insist drivers put a comment on their log indicating when an en route inspection was done to encourage its completion.
According to §396.11, the driver may need to report the condition of the vehicle to the company at the end of each workday, typically by submitting a daily vehicle inspection report (DVIR). Though required for passenger-carrying drivers, property-carrying drivers have an exception allowing them to submit a DVIR only if there is a defect on the vehicle, unless the carrier requires the driver to file one daily (which many do). To complete the DVIR, the driver must perform a post-trip inspection checking the same items checked during a pre-trip with the exception of fluids and hot items.
When a DVIR (paper or electronic) identifies a defect on the vehicle, the following must be completed:
NOTE: If a repair is made, the DVIR will then need to be provided to the technician doing the repair, who will need to sign and provide it to the vehicle’s next driver. This is particularly arduous for carriers running regional or long-haul operations where vehicles may not return to the company facility at the end of the day. In this case, the carrier must designate the driver as the official in charge of securing and overseeing repairs.
The carrier is responsible for having a systematic maintenance program in place to ensure all vehicles remain in good condition. Similarly, the driver is responsible for regularly inspecting the vehicle and communicating any problems. To verify inspections are taking place as expected, you can:
If inspections are not being performed as required, you will end up with vehicles receiving violations and/or being placed out of service during roadside inspections. Worse, a poorly maintained vehicle may end up being involved in a crash when it is unable to respond effectively in an emergency situation.
For more information on vehicle inspections, download our Driver Inspections: Critical Vehicle Maintenance Practices for a Safe and Compliance Operation.
E-DVIRs address many of the issues brought on by paper systems. For example, when the inspecting driver submits the e-DVIR with a defect, it is automatically forwarded to the person responsible for reviewing DVIRs, allowing them to immediately arrange for repairs, even if the vehicle is 500 miles away.
Once the carrier is notified the repair is completed, he or she can digitally sign the e-DVIR and forward it to the next driver using the vehicle. If the next driver is unknown, the carrier official can load the e-DVIR into the system to be signed by the driver once established. The next driver will then digitally sign the e-DVIR and submit it for retention.
Intrastate ELD Requirements
States are adopting the federal ELD rules for intrastate commerce. Updated December 2019.
The Rise of Off-Site Audits
Off-site motor carrier safety audits have increased over 300% in the past year. Are you at risk?
ELD Transition Guidance From Fleets That Know
Fleets who have already switched from AOBRDs to ELDs give their advice on the transition.