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Interpretations to Part 396 — Inspection, repair, and maintenance
Question 1: Does a CDL with an airbrake endorsement qualify a person as a brake inspector under §396.25?
Guidance: No.
Question 2: May a driver who does not have the necessary experience perform the adjustment under directions issued by telephone by a qualified inspector?
Guidance: Yes. A driver is permitted to perform brake adjustments at a roadside inspection providing they are done under the supervision of a qualified brake adjuster and the carrier is willing to assume responsibility for the proper adjustment.
Question 3: May a driver or other motor carrier employee be qualified as a brake inspector under §396.25 by way of experience or training to perform brake adjustments without being qualified to perform other brake-related tasks such as the repair or replacement of brake components?
Guidance: Yes. A driver may be qualified by the motor carrier to perform a limited number of tasks in connection with the brake system, e.g., inspect and/or adjust the vehicle’s brakes, but not repair them.
Question 4: Would a mechanic who is employed by a leasing company and only works on CMVs that the leasing company leases to other motor carriers be required to meet the brake inspector certification requirements?
Guidance: No. The mechanic is not required to meet the certification requirements of §396.25(d) since he/she is not employed by a motor carrier.