The FMCSA is pretty clear about their expectations around how vehicles should be properly maintained. 

This key area of safety and compliance often causes a great deal of frustration for carriers of all sizes due to the volume of regulations rather than their complexity. 

Most of the regs are pretty straightforward in this area, but there are plenty to adhere to.

Carriers and drivers must both take a proactive role in order to keep the fleet legal and operational. 

A formal vehicle maintenance plan is the cornerstone of a great program. Spending some time and effort on this process is a very wise investment.

We have a nice plan for you to use if you click the link below. 

Feel free to review that and base your program off of this plan.

For smaller carriers and owner-operators, this may be a bit of overkill, but it's a worthwhile exercise.

If nothing else, try to adhere to the manufacturer's recommended service schedule for your trucks and trailers and pay close attention to your tire wear. 

Simply ensuring that all of your lamps and lights are operational is a great first step in avoiding any trouble with roadside inspectors. 

An ounce of prevention is worth a pound of cure, right? How many times have we heard that before? Sayings like this have been around forever for a reason...because they're usually true.

I'm not going to preach that you have to have some sort of super rigid preventative maintenance program in place for your tractors and trailers.

But, as your fleet operations grow and become more complicated, you'll end up saving yourself a ton of headaches and money by setting up even a basic preventative maintenance program and following it.

The FMCSA requires that you have a PM program (See 396.3), but they don't specify what has to be included in that program or how it is administered.

If nothing else, try to follow each truck and trailer manufacturer's preventative maintenance guidelines. You can ask any big truck dealer or do a simple google search and find lots of resources around this for each truck make and model.

The actual maintenance portion of PM is composed of scheduled and standardized inspections and maintenance.

If you want to be a little more structured and organized about how you implement your program, the easiest thing to do is to set up a basic schedule for each truck's preventative maintenance.

Here are the typical Preventative Maintenance "levels" and a good guideline for when each should be completed:

PM A

Usually consists of a safety check lube job and basic inspection of key components and systems like the brake and lighting systems, fluid checks and replacement and checking for tire tread depth and wear patterns.

Generally, heavy duty trucks should undergo a PM A every 10 to 15,000 miles.

PM B 

Includes everything from the PM A, but this level also includes an oil and filter change as well as more comprehensive checks of the engine and drivetrain components.

Generally, heavy duty trucks should undergo a PM B every 20 to 30,000 miles.

(Most carriers do a PM A at 1/2 of the PM B Interval. So, if you schedule your trucks to undergo a PM B every 30,000 miles, you could set your PM A interval at 15,000 miles).

PM C

You guessed it, it's a combo of PM A and B with your annual DOT inspection thrown into the mix.

Generally, these are scheduled for every 11 months rather than at a specific mileage.

PM D

This is sometimes used as a special service category like a complete engine rebuild or some other major component replacement. These are irregular and are usually not scheduled. It's mostly just used as a placeholder service type for major non-scheduled service.

Don't forget your trailers! These also have to be inspected under FMCSA regulations.

Trailer service schedules generally follow time intervals rather than specific mileage intervals.

T1 (or TA)

Basic inspection of lighting and brake systems, check of tire tread depth and inflation pressures, check and lube of all coupling devices and sliding axles. Check of the reefer unit, if attached. Check of all tie-downs and other load securement devices.

T1s are generally scheduled for every 3 months.

T2 (or TB)

Everything in T1 plus any additional maintenance needed like re-torqueing lose lug nuts and checking hub grease levels.

T2s are generally scheduled for every 6 months.

T3 (or TC)

Everything from T1 and T2 and any other major service needed like complete brake system overhaul or wheel alignments, etc. Most fleets also do the trailer's annual inspection at this time as well.

T3 Inspections are normally set for every 11 months.

Every commercial motor vehicle must be inspected every 12 months by a qualified inspector who has training or certification to inspect and maintain commercial motor vehicles.

Click on the link below to grab a blank inspector qualification form.

Each truck/trailer inspector needs to fill one of these out for you. Keep it with that truck's Annual Inspection Report in your office. (Yes, the FMCSA inspectors can ask to see these).

The term commercial motor vehicle includes each vehicle in a combination vehicle. For example, for a tractor semitrailer, full trailer combination, the tractor, semitrailer, and the full trailer (including the converter dolly if so equipped) must each be inspected.

A motor carrier must not use a commercial motor vehicle unless each component identified in Appendix G of 396 subchapter B has passed an inspection at least once during the preceding 12 months, and documentation of such inspection is on the vehicle.

Your specific State may have additional requirements regarding vehicle inspections. Please check with your respective State for additional inspection requirements.

Click on the link below to grab a sample annual inspection form.

FMCSA regulations (396.11) require that each driver prepare a daily vehicle inspection report if a defect has been discovered during their required post-trip inspection.

This should be completed and retained by the motor carrier for a period of no less than 3 months.

If your drivers complete their DVIRs on their ELD, most ELD providers (KeepTruckin and Samsara for sure) will allow you to set up email alerts to let you know when a defect has been reported.

Once the repairs have been made, be sure to drop the receipt with a copy (hard copy or electronic) of the DVIR into that truck or trailer's VM file for easier access in the future.

If your drivers still complete DVIRs on paper, here is a copy of a blank Vehicle Inspection Report that you can use: 

FMCSA regulations (396.3(b)) require that each company keep a record on each piece of equipment that they have control of for over 30 days.

These documents should be kept for at least 18 months after the vehicle is no longer under the carrier's control.

This information can be maintained on the front of the vehicle's maintenance folder. But, it's a good idea to maintain an electronic version as well.

A FMCSA developed Fleet Register can be found in the Quick Links to the left and a Vehicle Information Record template can be accessed below:

FMCSA regulations (396.19 and 396.25) require that each inspector of vehicles and brakes be qualified according to their specific standards. 

You can check those out here:

Vehicle Inspector Qualifications

Brake Inspector Qualifications

 

Each carrier must maintain proof of inspector qualification on file for at least 12 months after that inspector ceases to perform inspections.

Here are some documents that you can use to prove inspector qualification:

Truck Tire Maintenance is as easy a 1-2-3!

By following our simple 1-2-3 tire inspection guideline, you will have fewer tire emergencies, better CSA BASIC scores, lower costs and an improved level of fleet safety and DOT compliance!

1 - Drivers should inspect each tire/wheel for visible signs of damage (bulges, bumps or flats, etc. at least 1 time per day.

2 - Drivers should inspect their tire inflation at least 1 time every 2 weeks

3 - A complete tire pressure check should be made of each tire at least once every 3 weeks. By tracking tire tread depth, fleet owners become more aware of their tire wear patterns and can be more proactive on replacement when a tire nears the end of the road.

Each year, about 1/2 of the top 20 vehicle violations are related to the truck and trailer brake systems!

In other words, brake maintenance is extremely important.

Here are our top 5 brake system compliance tips:

 

1) Have your drivers complete 1 full brake compression each day. After the system pressure builds fully, have the driver slowly but firmly press the brake pedal all the way to the floor. This helps keep the automatic slack adjusters working properly.

2) Don't adjust automatic slack adjusters manually. If you have to do this, there is a good chance that some part of the brake system is failing and needs to be inspected by a qualified brake mechanic ASAP.

3)  Make sure that you're having all of your automatic slack adjusters lubricated every 25,000 miles. This ensures that they are functioning correctly and gets all of the water, dirt and other road gunk (a technical term) out of the lines.

4) Have your drivers do a visual inspection of their pigtails at least once a week to ensure that there is no significant chaffing or kinking of the hoses/tubes. This is a leading cause of brake violations and is easily preventable. Investing $15 to $25 in a quality hose tender is a great investment!!

5) Have each driver walk around the truck once daily (pre-trip inspection) and listen carefully for air leaks (especially around the Gladhand seals). These seals wear out over time (even quicker if exposed to extreme weather regularly) and should be replaced at least annually. These seals are pretty simple and cheap to replace, but often overlooked.

Preventing lighting violations is the number one way to avoid issues with the FMCSA!

About 50% of all vehicle violations are either related to the truck or trailer's lighting system and reflective sheeting.

But, lighting issues CAUSE about 85% of all driver/vehicle violations. (If they don't pull your drivers over in the first place, they can't check their ELD or brakes...or tires...etc.)

Law enforcement officers always go for the low hanging fruit and a truck or trailer with a lighting violation is like you painting a giant target on the side of your trailer with flashing lights that say "Please Inspect Me!".

This holds true especially for trucks with a headlight out or trailers with a burnt taillight or turn signal.

Yes, things happen and lights do burn out. But, drivers should be inspecting each light regularly enough to make sure that they detect lighting issues before the cops do.

Simply walking around once each week and making sure that all required lights are operational should be enough to prevent almost all lighting violations.

If you want to take it a step further, you can have each driver do a walkaround once a month while recording with their smartphone or taking pictures of the front, rear and sides of the truck and trailer while the lights are on and it's close to dark. Then have them send you the photos or video for you or your safety person to review.

If you're going to make your drivers do this, please make sure that you review the videos/photos and take action when you find a violation! BTW, this is a service that we offer for all of our My Safety Manager members)