Do You See What I See?

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Three hundred bucks is a pretty stiff rap on the knuckles for failing to note a defect on an inspection report. You’d think that would be enough incentive for a driver to conduct a proper trip inspection. Apparently, it’s not. Carriers take a hit, too, when drivers fail to properly note the condition of their vehicle on the inspection report. In Ontario, Canada’s trucking hub, the penalties are especially stiff: five points against your operator record, plus a fine, plus the cost of the repair, and possibly a towing charge as well.

Maybe the driver’s too lazy to get under the truck every morning before leaving. Maybe he just doesn’t want to get dirty. Maybe the drivers don’t get the support they need from operations or dispatch. Maybe there’s no mechanic in the shop at 4 a.m. when the defect is discovered, or perhaps they simply don’t know what to look for when performing a trip inspection. There are plenty of other reasons for not accurately recording the vehicle condition before beginning a trip, not the least of which is the bind they’re in when trying to balance compliance requirements with delivery deadlines and company budgets.

Or maybe it’s just completely unrealistic to expect a driver’s pre-trip inspection to even come close to the thoroughness of a CVSA Level 1 inspection.

The difficulty lies with regulations that require trucks to be in perfect condition, and regulations that force drivers to attest to the fact that the truck is in perfect condition, before venturing out on to public highways. If a defect is discovered during a roadside inspection, both the driver and the fleet could be cited: the fleet, for not repairing the defect, and the driver for not reporting it on the trip inspection report, or, for operating an unsafe vehicle. Either way, the driver has a lot of reasons for not recording the defects on the trip report.

There are 21 items on a daily inspection report. The CVSA out-of-service criteria, on the other hand, lists more than 90 items, and describes in exquisite detail, exactly what constitutes an out-of-service defect. To use an academic analogy, if the driver’s handbook is the study material, then the CVSA out-of-service criteria is the exam.

Here it is in a nutshell: A driver who is not required to take any formal training nor to have any formal knowledge of matters mechanical, is required, by law, to pass judgment on the condition of a vehicle. Ultimately, a process designed to discover defects by people whose livelihoods depend on their findings will judge the driver’s assessment of the vehicle condition. Taken at face value, even the driver who does a pre-trip as required by law won’t stand a chance of his work measuring up to that of a CVSA Level 1 inspection. In order to meet today’s zero-tolerance policies, drivers are essentially required to perform the equivalent of an annual safety inspection on each and every vehicle they operate, each and every day. That goes far beyond their scope of their ability or responsibility.

“I’m mechanically inclined, but I’m not a mechanic,” says Darrell Pearson, an owner-operator with St. Catharines, Ont.-based Roseman Transport. “I can identify the obvious problems like a leaky wheel seal, or a cracked spring, but I couldn’t tell you if the defect poses any immediate danger, or if it’s something I can write-up when I get back to the yard.”

That’s not an indictment of Pearson’s mechanical acumen, by the way. Like most drivers and many owner-operators, he’s never had the finer points of truck maintenance explained to him, nor has he ever had any training in how to spot potential mechanical failures or CVSA out-of-service conditions, beyond the obvious.

Vehicle maintenance should be a fleet responsibility, with the driver’s role being that of a compliance monitor. The driver shouldn’t be held accountable for the fleet’s maintenance shortcomings. However, the driver does play an important role in keeping an eye on the equipment when it’s out of the yard.

And that’s where the Ontario Motor Coach Association, the Ontario Trucking Association (OTA), and Ontario’s Ministry of Transportation (MTO) have jumped in, drafting a new set of trip inspection procedures and vehicle defect identification criteria. It’s still a proposal, and not law, but the work acknowledges the need for more realistic trip inspection rules, and guidelines for drivers defining what is or isn’t a safety-related defect, and what is and is not expected of a driver during a trip inspection.

A pilot project involving several carriers and some 200 drivers undertaken last year in Ontario proved so successful that there’s now interest in integrating the trip inspection standard into the National Safety Code. From there, it’s hoped the provinces will incorporate the NSC guidelines into provincial legislation across the country.

A project group of provincial truck safety regulators and industry representatives has been working on this since last summer, says OTA’s maintenance and technical advisor, Rolf VanderZwaag.

This month, a draft of the proposed standard was to be submitted to the standing committee on compliance and regulatory affairs of the Canadian Council of Motor Transport Administrators. “At this point, about 95% of the proposal is supported by all the provinces,” VanderZwaag says. “But there are still a few significant barriers to a full-scale buy-in.”

What the proposal seeks to do, according to VanderZwaag, is add some reasonability to the regulations, and to remove some of the inconsistencies in interpretation and enforcement of the rules by giving drivers the tools and the latitude to make some decisions themselves. The proposal creates clearer definitions of what’s required by the driver in terms of the trip inspection by defining how the vehicle system or component is to be inspected, and what constitutes a minor or critical defect.

If everything flies, drivers will soon be required to undergo formal trip inspection training with an emphasis on how to determine what constitutes a defective system or component. The driver’s manual used in the pilot project goes so far as formally defining the two distinct types of defects:

1. “Defect”: Any condition of a vehicle, vehicle component or system described as minor, or non-safety related defect.

2. “Prescribed defect”: Any condition of a vehicle, vehicle component or system that is defined as a CVSA out-of-service defect.

The revised trip inspection report contains 22 inspection items divided into the above two categories. A driver who finds a minor defect would note it accordingly and be allowed to proceed with the trip. A prescribed defect, however, would ground the truck.

The working group also developed a guidebook telling the driver what to look for, what each system on the vehicle does, and the proper way to inspect it.

Here’s an example from the guide, section 18 on suspension systems:

Inspection Requirements: Drivers must inspect the suspension system for condition of springs and other components, vehicle position and response.

Safe Performance Requirements: The suspension must support the vehicle and provide stable vehicle operation.

Defects (minor):

– Air leak in air suspension system.

– Broken spring leaf.

– Abnormal vehicle behavior.

Prescribed Defects (major):

– Deflated air spring

– Cracked or broken main spring leaf or more than one broken secondary spring leaf.

– Part of the leaf or suspension is

missing, shifted, noticed by driver, out of place or in contact with another vehicle component.

– Suspension fastener is loose, missing, or broken.

Method of Inspection: This inspection will require you to get into a position that provides a good view of the springs or air bags, such as crouching, kneeling or squatting. Look for broken or cracked leaf springs. With the air system at full operating pressure, listen for leaks in the bags or the air suspension system. While driving, check for abnormal vehicle behavior that may indicate a defect in the suspension.

As in other sections of the guide, the references to kneeling, crouching, or squatting suggest that drivers will no longer be expected or required to crawl under the truck to complete the inspection. VanderZwaag says the emphasis has been placed on dealing with inspection points that the driver has reasonable access to and could be expected to spot with a reasonable amount of contortion. In the case where certain components are obscured by fairings or cab skirts, the responsibility for maintenance will fall squarely on the carrier.

If enacted, the proposal would be a win/win situation for drivers and fleets alike when it comes to enforcing the vehicle condition and trip inspection standards.

Drivers would have precise guidelines to follow, leaving less room for inaccurate interpretation. The fleet would have written documentation of the defect having been found. There would be no more room for drivers forgetting to note a defect they might have discovered but didn’t want to expose to prying eyes.

The only ones who would be hurt by the proposed new standard are the carriers who refuse to accept their maintenance responsibilities and drivers who refuse to do their inspections.

“There would be a paper trail because the driver has nothing to lose and a lot to gain in noting the defects,” observes VanderZwaag. “There certainly is an effort to encourage drivers to write these things down captured within this proposal.”

For the Darrell Pearsons of the world, this proposal should come as good news. “I want to do the right thing, and I want to keep my equipment as safe as possible,” he says. “A little direction and guidance certainly wouldn’t hurt.”

SIDEBAR: Leveling the Playing Field
How the proposed trip inspection standard would affect carriers and drivers

The proposed NSC Trip Inspection Standard would remove the guesswork for the driver, allow the carrier to operate a truck with some minor defects, but ultimately hold everyone to a higher standard of compliance and cooperation.

Specifically, here’s what the proposed standard would do:

– Provide a specific list of conditions drivers are expected to find during a trip inspection.

– Divide vehicle defects into minor and major categories: “defects” and “prescribed” (major) defects.

– Require “defects” to be repaired before next inspection, providing a window for use of the vehicle.

– Prohibit use of a vehicle before major defects are repaired (based on CVSA out-of-service criteria).

– Limit a driver’s responsibility for the condition of the entire vehicle.

– Provide a common basis for carriers to identify the appropriate action in response to vehicle defects.

– Require a driver handbook that will contain detailed reference for drivers.

– Require drivers to complete and carry a report of the vehicle inspection and list defects on the report.

– Allow separation of the schedule of inspection items and the trip inspection report, which would reduce a carrier’s paperwork.

What the proposed standards would not do:

– Require additional time for completing trip inspections.

– Increase responsibility for drivers or carriers.

– Necessarily exempt a carrier from being charged when operating with a defect.

For more information about the proposal, contact Rolf VanderZwaag, Ontario Trucking Association, at 416/249-7401.

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Jim Park was a CDL driver and owner-operator from 1978 until 1998, when he began his second career as a trucking journalist. During that career transition, he hosted an overnight radio show on a Hamilton, Ontario radio station and later went on to anchor the trucking news in SiriusXM's Road Dog Trucking channel. Jim is a regular contributor to Today's Trucking and, and produces Focus On and On the Spot test drive videos.

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