Every June, tens of thousands of commercial vehicles and their drivers are inspected across North America in the largest targeted safety enforcement campaign in the world.
The annual inspection action is called Roadcheck, a safety initiative run by the nonprofit safety coalition Commercial Vehicle Safety Alliance (CVSA) in conjunction with local, state, provincial and federal transportation departments.
The inspections regularly include an examination of drivers’ licenses and credentials such as medical cards, records of duty status, pre-trip and post-trip inspections, safety belt use, driving behaviors and other driver safety conditions. All vehicle systems that are critical to safe operation are checked.
The preponderance of vehicle violations concerns brakes, tires and lights, says William Schaefer, director, vehicle programs for CVSA. The top two driver violations are outdated hours-of-service logs and missing medical cards.
Last year’s Roadcheck also emphasized cargo securement. Local jurisdictions were also encouraged to establish a focus item. Not only are inspectors looking for non-compliant vehicles and drivers, but also general infractions such as texting or cellphone use while driving.
Out of Luck
It doesn’t take much to put a vehicle or driver out of service, says Don Scare, regional fleet services manager for PHH Arval, a fleet management services provider. This means the vehicle or driver will be grounded on the spot until the citation is remediated or the vehicle is towed from the scene. And then the problem snowballs into other issues such as towing costs, loss of productivity and poor customer service.
According to CVSA, being put out of service costs $861 on average per occurrence, which does not include the costs of repairs or fines as a result of the inspection. Roadcheck fines can be steep — $10,000 or higher.
What’s the best way to avoid getting fines? First of all, drivers need to be able to present proper documentation such as hours-of-service logs (if applicable), medical cards and properly filled out pre- and post-trip inspection checklists. “As they [inspectors] find violations, the deeper they’ll dig,” which entails a thorough vehicle examination, says Scare.
Proper vehicle maintenance is paramount. “If you follow the maintenance standards set by the auto manufacturers, you should never get a vehicle violation from our enforcement inspectors,” Schaefer says.
For small fleets, Roadcheck can be especially tricky because they may think this enforcement is just for truckers. However, the inspections are conducted on all commercial vehicles and their drivers. This spotlights a bigger issue: Do you need to be compliant with regulations governed by the FMCSA (Federal Motor Carrier Safety Administration) and USDOT (U.S. Department of Transportation)?
Certainly, getting stopped during RoadCheck isn’t the time to find out.
Do You Need to Comply?
Companies that operate commercial vehicles transporting passengers or hauling cargo in interstate commerce must be registered with the FMCSA and must have a USDOT Number. Fleets carrying hazardous materials fall under USDOT regulations, though these fleets are most likely well aware of their obligation already, Scare says.
Even if you don’t operate outside of your state, you may fall under these regulations, as more than half of the 50 states have adopted federal rules.
Another potential conundrum for small fleets is the definition of a commercial vehicle, because that definition has changed. As of 2008, a commercial vehicle is defined as any vehicle with a GVWR (gross vehicle weight rating) of more than 10,000 lbs., down from 16,000 lbs. previously.
Fleet administrators may not know that moving from a half-ton to a three-quarter-ton pickup will put them over 10,000 lbs. GVWR. And if you’re towing a trailer, that weight is counted toward the 10,000-pound threshold.
Concurrently, vehicle specifications, including GVWRs, have also changed. New versions of the same truck may have lost weight and thus allow more payload. On the other hand, some new models’ GVWRs have been adjusted higher to meet safety certifications such as braking capacity. “Some GM and Ford vehicles were at one time less than 10,000 lbs., but are no longer,” Scare says.
An Education Challenge
Some companies that are beginning to replace fleet since the Recession are learning these new rules the hard way.
“We have had a dramatic increase of clients that are operating commercial vehicles and need our services to become DOT compliant,” Scare says, and with this change has come greater scrutiny from regulators. “There has been more of a focus on light- and medium-duty trucks in the last few years as states became more aware of fleets that are operating in that class that are not compliant with the law,” he adds.
Fleets that run vehicles in the 10,000 to 26,000 lbs. GVWR range pose a particular education challenge, says Rob Kooken, director, business development for PHH Arval. Those vehicles don’t require drivers with commercial drivers’ licenses, yet they still fall under regulation.
“Those types of fleets, the ones where driving is not their living, they are the toughest to manage,” Kooken says. “The way they identify that they need to be in compliance is when we get the phone call from the fleet: ‘I got this citation, what do I need to do?’”
As a result, fleets try to avoid regulations by using vehicles under 10,000 lbs. GVWR and overloading them. “Now they are in another situation,” Scare says. “They are being pulled over not only for inspection but also because they are overweight. It creates a whole gamut of issues.”
Kooken says a common mistake is to confuse the trucks’ actual weight (or curb weight) with its carrying capacity, a function of GVWR. The curb weight is always less than GVWR. Scare and Kooken discourage fleets from attempting to under-spec a truck to avoid compliance.
Steps to Compliance
“The first time you’re exposed to [DOT compliance] it can be very intimidating,” says Kooken. “But it feels more intimidating than it really is.”
The first step is to register, at which time each fleet vehicle will be assigned a DOT number to display. At that point, expect a visit from the local DOT office for a cursory safety check, Kooken says, and annual inspections going forward.
Fleets need to assemble, maintain and update a driver qualification file for each driver. This consists of nine documents, including a motor vehicle record and a medical certificate. This medical or health card is issued and renewed every two years with an FMCSA-certified physical exam, and drivers must keep this card while driving. “By simply carrying their health cards, the biggest driver violation would be erased,” Kooken says.
Fleets implementing the physicals for the first time may uncover medical conditions that would preclude some from being able to drive under these regulations. While this could cause challenges in the workplace, companies need to take a hard look at those drivers who shouldn’t be driving for the company anyway, Kooken contends.
The rules also require commercial vehicles to carry safety equipment such as flares, fire extinguishers, hazard triangles and load securement equipment.
Not all companies governed by federal regulations fall under hours-of-service rules, but you need to find out if you do. Separately, all drivers under FMCSA regulations need to complete a pre- and post-trip safety and maintenance checklist and keep it with the vehicle. Proper accident reporting procedures are also required, Kooken says.
In all, compliance may seem onerous for fleets new to the regulations. “Once you step into the commercial arena, your documentation, your accuracy of auditing and your retention of records become very important,” Scare says. “But once you go through the initial set up of that process, it becomes turnkey.”
Nonetheless, staying compliant can be an ongoing issue, especially for those fleets with “casual drivers.”
“The biggest problem is that these are not truck drivers, they’re salesmen,” says Joe Boyd, fleet technician for Model Coverall Services in Grand Rapids, Mich. “They don’t always do their pre- and post-trip inspections or report damage and vehicle issues to me like they are supposed to.”
“I let them know, ‘if you don’t do your pre-and post-trip inspections and turn it into me like you’re supposed to, when you get caught, it’s your butt, not mine,” Boyd says.
Roadcheck 2013 by the Numbers
- 73,023: Total inspections conducted
- 47,771: North American Standard Level I (most comprehensive) inspections
- 10,000: Approximate number of inspectors
- 2,500: Inspection locations across North America
- 24.1%: Of Level 1 inspections, percentage of vehicles found with Out-of-Service (OOS) violations
- 11.7%: Cargo securement-related violations as a percentage of all OOS violations
- 49.6%: Brake adjustment and brake system violations as a percentage of all OOS violations
- 2,927: Log violations (largest number of violations by type)
- 883: Number of safety belt violations issued
- 822: Number of violations issued for lack of medical certificate in driver’s possession