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Safety Bulletin - Does your Driver know the difference between a "Defect" and a "Safety Sensitive" Defect?

Mar. 26 2021 Miscellaneous By McCandless Idealease

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The March 26th Edition of the weekly Idealease Safety Bulletin provides important information and resources, including:

  • Differences between 'Defects' and 'Safety Sensitive Defects' - Does your driver know the difference? 
  • Video training for your drivers (in both Spanish and English) for proper Pre and Post Trip Inspections
  • Flooded roadways - what to do
  • Entry-Level Driver Training information from the FMCSA
  • National Work Zone Awareness Week - April 26th-30th

Click here to read the entire bulletin online or access a PDF version to read, print and/or distribute to your team through the image below.  Remember to sign up to receive the newest bulletins each week to your email inbox! 

Want to review past bulletins? Click here to access the full archive. 

DOES YOUR DRIVER KNOW THE DIFFERENCE BETWEEN A “DEFECT” AND A “SAFETY SENSITIVE” DEFECT?

The Drivers Daily Vehicle Inspection (DVIR) is part of the driver's daily responsibility to protect themselves, the equipment they operate and the motoring public. 

It is important that both drivers and technicians understand the FMCSA safety regulations within CFR 399 Appendix G that define 'safety sensitive' defects that  would render a unit out of service during a pre or post-trip inspection.  

FMCSA CFR 396.11 - Guidance Q&A on Driver Vehicle Inspection Report(s)

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 effect repairs of defective or missing parts and accessories listed in Appendix G to the FMCSRs before allowing the vehicle to be driven.

DRIVERS DAILY INSPECTION PROCESSES - required to ensure vehicle is in safe operating condition and are a crucial part of each and every driver's daily operation.  

PRE-TRIP INSPECTIONS:

Per FMCSA regulations CFR 396.13, before operating a motor vehicle, the driver shall:

  1. Be satisfied that the vehicle is in safe operating condition;
  2. Review the last driver vehicle inspection report; and
  3. Sign the report, only if 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.

Although the pre-trip inspection is not required to be documented by regulation, it is recommended to do so. It can be 'flagged' on the driver's record of duty status in the 'grid' section. 

POST-TRIP INSPECTIONS:

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:

  1. Service brakes including trailer brake connections
  2. Parking (hand) brake
  3. Steering Mechanism
  4. Lighting devices and reflectors
  5. Tires
  6. Horn
  7. Windshield Wipers
  8. Rear vision mirrors
  9. Coupling devices
  10. Wheels and rims
  11. Emergency equipment

Any defect or deficiency in the vehicle that would affect its safe operation or cause a mechanical breakdown must be identified and listed on the report.  If no defects or deficiencies are present, the driver shall indicate so on the DVIR.  The driver is required to sign the DVIR upon completion. 

If there are defects/deficiencies noted by the driver, the motor carrier is required to correct or cause to have corrected them prior to allowing or permitting the operation of the CMV. 

Does this mean all defects and deficiencies must be corrected? 

A: No. Only those outlined in Appendix G of the FMCSR that would directly affect the safe operation of the CMV. 

  • Technicians, drivers and service managers should become familiar with Appendix G to determine which must be corrected immediately and which can be held off until the next PM or a 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. 

FMCSA CFR 399

APPENDIX G

PRE AND POST TRIP INSPECTIONS - DRIVER TRAINING RESOURCES FROM IDEALEASE

Visit https://www.mctrux.com/--Pre-Post-Trip-Inspection-Training-Videos for both English and Spanish driver training videos on Tractor Trailer and Straight Truck pre and post trip inspections


TURN AROUND, DON'T DROWN!

If you encounter a flooded road, do not attempt to drive or walk through the water.  You will not know the depth, nor the condition of the road underneath. 

If flooding occurs, or you the potential for flooding exists:

  • Get to higher ground and out of areas subject to flooding. This includes dips, low spots, canyons, washes etc.
  • Avoid areas already flooded, especially if the water is flowing fast. Do not attempt to cross flowing streams. 
  • NEVER drive through flooded roadways. If your vehicle is suddenly caught in rising water, leave it immediately and seek higher ground.
  • Do park your vehicle along streams and washes, particularly during threatening conditions.
  • Be especially cautious at night when it is harder to recognize flood dangers
  • Avoid low water crossings.
  • Use alternate routes to avoid flood prone areas.
  • Leave your vehicle immediately if it stalls in flood waters.
  • Most cars and light trucks will begin to float in as little as 1 to 2 feet of water.
    • 6” of fast moving water can knock and adult down and carry them away
    • 12” of fast moving water can take a small car and carry it away
    • 18”-24” of fast moving water can take a large SUV and carry it way

For weather and flood conditions, visit the National Weather Service at https://www.weather.gov/ 


ENTRY-LEVEL DRIVER TRAINING INFORMATION RELEASED BY THE FMCSA

These new entry-level driver training (ELDT) requirements go into effect in less than a year

 ELDT Training Provider Registry (TPR) is slated to open this summer:

  • FMCSA has released details on what information a training provider will be required to submit
  • Being listed on the TPR is a requirement to provide ELDT as of February 7, 2022.

When registering, training providers will need to provide:

  1. Provider name and contact information;
  2. Facility name and contact information;
  3. Type of provider (for-hire/not-for-hire, in-house/not-in-house);
  4. Type of training provided;
  5. Average training hours;
  6. Third-party affiliations, certifications, or accreditations;
  7. Average training cost; and
  8. Self-certification that the provider meets all requirements.

If a training provider operates more than one location, each location will need to register. No fee will be required to register on the TPR.

View additional details for the TPR on the ELDT website.

Key to remember:  As of February 7, 2022, to provide instruction to an individual wanting to obtain Class A or B CDL, upgrade from a Class B to Class A CDL, or obtain a passenger, school bus, or hazmat endorsement, an entity must meet all of the ELDT requirements and must be listed on the TPR. Without this listing, an entity's training program will not be recognized when an individual attempts to register for the CDL skills test, passenger or school bus endorsement skills test, or hazmat endorsement written test. The individual will be denied the test until he or she has proof of successfully completing a course of instruction, provided by an entity listed on the TPR.