So you can help us on FMCSA regulations?

Eric Arnold of Arnold Safety Consulting: “I worked at FMCSA as an enforcement officer and safety investigator, among other duties for 13 years. In 2003, I started Arnold Safety Consulting to help fleets understand and follow the various regulations and vehicle inspection mandates.”

Can you tell us about the pre-trip inspection mandate?

“Basically, the regulation says no motor vehicle should be driven until the driver is satisfied it’s in good working order, following an inspection of the service brakes, including brake connections, parking brake, steering mechanism, lighting devices and reflectors, tires, horn, windshield wipers, rear vision mirror or mirrors, and coupling devices.”

That’s it?

“In a word, I would use ‘vague’ to describe the regulation. It’s caused quite a bit of confusion as to exactly what a pre-trip check should entail.

“We recommend that a pre-trip inspection should include a full walk-around the tractor and trailer. Honk the horn. Turn on the wipers. Get up and inspect the mirrors. Get down and inspect the tires. Turn on the lights.

“Spend a minimum of ten minutes making sure all systems on the truck are in good working order.”

What does ‘good working order’ mean?

“Again, another part of the regulation that’s rather vague. Nowhere is the term clearly defined.

“We recommend relying on Part 393 of the Federal Motor Carrier Safety Regulations for guidance. This code plainly states the performance standards of each and every part and accessory on that vehicle in order to legally operate on the public highway. 

“If the steering or tires or headlamps are not operating properly, they clearly are not in ‘good working order.’”

And if something is found?

“If a driver discovers a defect that could affect the safety of the vehicle or cause it to break down, they should not operate the vehicle until the defect is repaired.

“I recommend to my fleet clients that they prepare a checklist of everything they want inspected on a daily basis. Just as pilots use a pre-flight checklist so nothing is missed and procedures are consistent across the board, fleets could benefit from a similar course of action.

“A checklist isn’t a task for mega-sized transportation companies only. In fact, many smaller fleets rely on their drivers to check and maintain equipment so their trucks stay running, hauling freight.”

Is a written copy of the pre-trip inspection required?

“No, just the results of the post-trip inspection.

“Also, drivers need to note the length of time spent on the pre-trip inspection in their log book. During the inspection, they are on duty, but not driving.”

Is this for all drivers who drive a class 6 to 8 truck?

“The FMCSA requires all drivers of commercial vehicles used in interstate commerce, class 3 and up – that’s 10,001 lbs or more in gross vehicle weight – to conduct a pre-trip inspection.

“Most people are surprised that smaller trucks and vehicles used for plumbing, electrical and landscaping contractors are subject to daily pre-trip inspections. It’s not widely known because many of these drivers are not required to fill out a log book, and most rarely travel by weigh stations.”

So do you have any advice for fleets out there?

“Put together a pre-trip inspection checklist, train your drivers and give them enough time to complete the procedure.

“Vehicle inspections are a means to spot potential problems before they occur. An emergency mechanical breakdown is so much more costly than a repair at the terminal or yard.

“Safety is a core part of any trucking company. It just makes good business sense.”

Editor’s note: Our thanks to Eric Arnold at Arnold Safety Consulting for technical assistance on this article. To contact Eric,
call 1-610-582-4356 or e-mail eric@arnoldsafety.com.

Inspection guidelines from the Federal Department of Transportation can be found in many places, including the inside front cover of the Rand McNally Motor Carriers’ Road Atlas.

“Look for the unexpected; you never know what you may find,” said the logistics coordinator for Atlantic Bulk Carrier in Providence Forge, VA to his drivers. Luckily for this little guy found napping under the trailers, they heeded his advice.