The Driver Daily Vehicle Inspection (DVIR) is part of a driver’s daily responsibility to protect themselves, the motoring public, and the equipment they operate. But does your driver know the difference between a “defect” and a “safety sensitive” defect?
Drivers and technicians need to understand the Federal Motor Carrier Safety Regulations contained in CFR 399 Appendix G that defines “safety-sensitive” defects that would render the unit out of service during a pre-or post-trip inspection.
Here is the Guidance for FMCSA CFR 396.11:
Question 6: Does §396.11(c) require a motor carrier to effect repairs of all items listed on a DVIR prepared by a driver before the vehicle is subsequently driven?
Guidance: The motor carrier must affect repairs of defective or missing parts and accessories listed in Appendix G to the FMCSRs before allowing the vehicle to be driven.
The Drivers Daily Inspection Processes are a requirement of the Federal Motor Carrier Safety Regulations to ensure the vehicle is in safe operating condition.
A crucial part of each driver’s daily operation is to inspect the commercial vehicle they are operating. Over the years there has been confusion regarding pre-and post-trip inspections. Let us start with the pre-trip inspection. FMCSA regulations CFR 396.13 state that before driving a motor vehicle, the driver shall:
- Be satisfied that the vehicle is in safe operating condition
- Review the last driver vehicle inspection report
- Sign the report, only if it's 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, noted defects or deficiencies. The signature requirement does not apply to listed defects on a towed unit, which is no longer part of the vehicle combination.
Does the pre-trip inspection need to be documented? Although the pre-trip is not required by regulation to be documented, it is a good idea to document the inspection; I recommend that the pre-trip inspection be “flagged” on the driver’s record of duty status in the “Grid” section.
Now let us take a look at the post-trip inspection. The FMCSA CFR 396.11 requires that every driver report, and prepare a report in writing at the completion of each day’s work on each vehicle operated, and that report (DVIR) shall cover the following parts and accessories:
- 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
The report shall identify the vehicle and list any defect or deficiency in the vehicle that would affect the safe operation of the vehicle or cause a mechanical breakdown. 95% of all driver inspections do not have defects. In 2014 the Obama administration, to save trees, removed the regulation that a driver documents the post-trip inspection even if there are no defects. However, most companies still require the driver to complete and sign the DVIR upon completion even with no defects.
Now if there are defects or deficiencies noted by the driver the motor carrier is required to correct or cause to have corrected the defects or deficiencies of the CMV prior to allowing or permitting the operation of the vehicle. Does this mean all defects and deficiencies must be corrected? NO, only those as outlined in appendix G of the FMCSR that would directly affect the safe operation of the CMV. Technicians, drivers, and service managers should all become familiar with Appendix G to determine which defect/deficiencies must be corrected immediately and which can be held off until the next PM or later date. Once the defect /deficiency(s) have been corrected the original DVIR is required to be “certified” as corrected or that the correction was unnecessary. The DVIR is then to be signed by the repairing technician. The “certification” is required to be on all copies of the DVIR. The driver is to retain the previous days' DVIR on the CMV and the motor carrier is required to maintain all DVIRs for ninety days.
If you have not reviewed Appendix G of FMCSA CFR 399 with your drivers, I would recommend that you include this information in your next driver safety meeting.
Click here to read Appendix G.
To further assist your drivers with a quality pre-post trip inspection our Idealease Pre-Post Trip inspection driver training videos are available for both straight trucks and tractor-trailers in both English and Spanish on YouTube.
Use the following links to access the training videos:
How to Properly Mark a Commercial Motor Vehicle
A common question I receive from customers is “What size do the letters and numbers need to be on the placard or marking on the side of my commercial vehicle?” Ironically, there is NO size designation by measurement. Keep reading to determine how the Federal Motor Carrier Safety Administration (FMCSA) addresses the marking of a vehicle.
- The legal name or a single trade name of the motor carrier operating the self-propelled CMV, as listed on the motor carrier identification report (Form MCS-150) and submitted in accordance with CFR 390.19.
- The motor carrier identification number issued by the FMCSA, preceded by the letters “USDOT”.
- The City and State of the motor carrier are no longer required to be displayed.
- Appear on both sides of the self-propelled CMV.
- Be in letters that contrast sharply in color with the background on which the letters are placed.
- Be readily legible during daylight hours, from a distance of 50 feet (15.24 meters) while the CMV is stationary.
- Be kept and maintained in a manner that retains the legibility of the above requirements.
- The Idealease CMV is marked in accordance with the provisions of the marking requirements as stated above.
- The legal name or a single trade name of the Idealease location is displayed.
- The Idealease location identification number preceded by the letters “USDOT” is displayed.
The Idealease rental agreement entered by the Idealease location and the customer renting motor carrier conspicuously contains the following information:
1. The name and complete physical address of the principal place of business of the Idealease customer renting the CMV.
2. The identification number issued to the Idealease customer by the FMCSA, preceded by the letters “USDOT,” if the Idealease customer has been issued such a number. In lieu of the identification number required in this paragraph, the following may be shown in the rental agreement:
- Information that indicates whether the Idealease customer is engaged in “interstate” or “intrastate” commerce; and
- Information that indicates whether the Idealease customer is transporting hazardous materials in the Idealease rented CMV.
3. The sentence: “That Idealease cooperates with all Federal, State, and local law enforcement officials nationwide to provide the identity of Idealease customers who operate the Idealease rental CMV”. The rental agreement entered by Idealease and the Idealease customer is carried on the Idealease rental CMV during the full term of the rental agreement.
