Understanding Appendix G of the FMCSA Regulations
This week's Safety Bulletin discusses Appendix G of the FMCSA regulations and reminds you how to prepare your vehicle for the cold weather. Read the full safety bulletin here and subscribe to receive future safety bulletins straight to your inbox.
The Drivers Daily Inspection 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 should understand the Federal Motor Carrier Safety Regulations in CFR 399 Appendix G, which 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 make repairs of all items listed on a DVIR prepared by a driver before the vehicle is subsequently driven?
Guidance: Before driving the vehicle, the motor carrier must repair the defective or missing parts and accessories listed in Appendix G to the FMCSRs.
The Driver's Daily Inspection Processes are a requirement of the Federal Motor Carrier Safety Regulations to ensure the vehicle operates safely.
A crucial part of each driver's daily operation is to inspect the commercial vehicle they are operating. Two inspections of the commercial vehicle are required daily. Over the years, there has been confusion regarding pre and post-trip inspections. Let's start with the pre-trip inspection. FMCSA regulations CFR 396.13 state that before driving a motor vehicle, the driver shall:
(a) Be satisfied that the vehicle is in safe operating condition.
(b) Review the last driver's vehicle inspection report.
(c) Sign the report only if the driver who prepared it acknowledges that the driver has reviewed it and that there is a certification that the required repairs have been performed and 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? No documentation is required for pre-trip inspections; noting the inspection is a good idea. I recommend that the pre-trip inspection be "flagged" on the driver's record of duty status in the "Grid" section.
Now, let's look at the post-trip inspection. The FMCSA CFR 396.11 requires that every driver complete a post-trip inspection at the end of their tour of duty. As of December 18th, 2014, the post-trip needs to be documented if there are defects or safety concerns. The inspection shall cover the following parts and accessories:
(a) Service brakes, including trailer brake connections.
(b) Parking (hand) brake
(c) Steering Mechanism
(d) Lighting devices and reflectors
(e) Tires
(f) Horn
(g) Windshield Wipers
(h) Rear vision mirrors
(i) Coupling devices
(j) Wheels and rims
(k) 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. If there are no defects or deficiencies, a written daily vehicle inspection report in writing is not required. As the motor carrier, you can go above and beyond the regulations and require your drivers to document the post-trip inspection daily, with or without defects.
Now, suppose the driver notes safety-sensitive defects or deficiencies. In that case, the motor carrier must correct or plant to correct the defects or weaknesses of the CMV before allowing or permitting the vehicle's operation.
Does this mean all defects and deficiencies must be corrected?
No, only those safety-sensitive defects, as outlined in Appendix G of the FMCSR. Technicians, drivers, and service managers should all become familiar with Appendix G to determine which defects/deficiencies must be corrected immediately and which can be held off. Once the issues are fixed, the original DVIR must 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 yet to review Appendix G of FMCSA CFR 399 with your drivers, I recommend including this information in your next driver safety meeting.
Here is the link to Appendix G:
Are You Prepared for the Artic Temperatures Blanketing the Country Next Week?
This week, the Midwest is getting its first dose of measurable snow and subzero temperatures. This is the best time to review with your drivers how to take care of their fuel during these times.
- Diesel supplement should be added to the ultra-low sulfur diesel fuel when temperatures drop below 32 degrees.
- Plug in your engine block heater when the temperature is below 32 degrees. Non-utilized trucks should be started and run daily to keep the unit up to normal operating temperature.
- The initial startup procedure should be as follows: Complete pre-trip of the unit, unplug the block heater, turn the ignition switch to on, wait for glow plug lights to go out, start the engine, and leave the engine run until engine operating temperatures increase.
- For trucks equipped with air brakes, drivers should purge air tanks daily. If the unit has an air drier, bringing the PSI to 120 will automatically purge the system.
- If you are driving in snow, ice, slush, rain, etc., before parking the unit at the end of the day, lightly apply the brakes while the unit is moving to dry the brake shoes, drums, rotors, and pads so the brakes do not freeze while parked.
- Ensure the windshield washer solvent is full, and all windows are clean.
- Remove any ice-snow build-up from steps and grab handles to prevent a slip or fall.
When parking the truck, make sure that if heavy snow is forecasted, the unit is not left parked on an outside dock or near a building overhang. Snow can drift off the building, causing excessive accumulation on the top.
Fuel Additive Use during Cold Weather Conditions
As colder weather approaches, you must use fuel additives to prevent fuel jelling. Fuel additives should be added anytime the ambient temperature is below 32 degrees F. Power Service and Penray are popular manufacturers of fuel additives, and both companies have two different products available through Navistar and Idealease locations.
Power Service:
-The "Red Bottle" is Power Service 911 and is to be used only when the fuel in a unit has been jelled and NOT TO BE USED AS A PREVENTATIVE MEASURE TO KEEP FUEL FROM JELLING!
-Power Service Diesel Fuel Supplement + Cetane "White Bottle" will be added to the fuel at each fill when the ambient temperature is < 32 degrees F.
-This is the additive you should use regularly during the winter months.
Penray:
Winter Thaw Emergency Diesel Fuel Supplement
Dissolves already gelled fuel fast and reduces clogging of fuel filters. Prevents ice crystal build-up in fuel lines and filters by disbursing moisture.
It eliminates hard starting, pounding, and excessive smoking and helps improve combustion. 100% compatible with low sulfur fuel and fuel blends.
Winter Thaw Emergency is ONLY USED WHEN THE FUEL IS ALREADY GELLED!
Winter Pow-R Plus Diesel Fuel Supplement
- ULSD compliant.
- Prevents gelling of diesel fuel.
- Prevents ice crystal formation.
- Reduces cold filter plug point b as much as 30ºF.
- It helps enhance cetane.
- Improves fuel economy.
- Utilizes HAFI® technology.
- Improves cold weather starting.
- Stabilizes and prevents corrosion.
- It helps reduce emissions.
- It helps improve lubricity.
Got Chains?
If you are operating in state that require chains to be on board, make sure the chains are the correct size, properly secured, clean, and not broken as to be easily applied when necessary.
Not sure what your states chain laws are go to:
http://www.tirechainsrequired.com/laws.html
2024 FMCSA DOT Random Testing Rates Notice
The Federal Motor Carrier Safety Administration has announced that its random testing rates for drug and alcohol tests will remain unchanged for 2024. Throughout the year, motor carriers must test 50% of their CDL drivers in their random testing pool for use of controlled substances and test 10% of their CDL drivers in their random testing pool for illegal alcohol use.
Random testing must be conducted in an unannounced manner and the selection periods must be evenly spaced out throughout the year. At a minimum, selection periods are required to be at least quarterly.
For additional information on the testing rates: Random Testing Rates | US Department of Transportation
*The Idealease Safety Bulletin is provided for Idealease locations and their customers and is not to be construed as a complete or exhaustive source of compliance or safety information. The Idealease Safety Bulletin is advisory in nature and does not warrant, guarantee, or otherwise certify compliance with laws, regulations, requirements, or guidelines of any local, state, or Federal agency and/or governing body, or industry standard.