['Enforcement - DOT', 'Electronic logging device (ELD)', 'CMV Parts and Maintenance', 'Fuel Management']
['Vehicle maintenance', 'Roadside Inspections', 'Fuel management']
07/24/2024
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Motor carriers are required to keep their commercial motor vehicles in safe operating condition at all times, so a comprehensive inspection and maintenance program is key to compliance.
Scope
The inspection and maintenance requirements apply to motor carriers, drivers, and commercial motor vehicles.
Regulatory citations
- 40 CFR 396.3 — Inspection, repair and maintenance
Key definitions
- Commercial motor vehicle (CMV): A self-propelled or towed vehicle used on a highway to transport property or passengers when the vehicle:
- Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR), or gross vehicle weight (GVW) or gross combination weight (GCW), of 10,001 pounds or more, whichever is greater; or
- Is designed or used to transport more than 8 passengers (including the driver) for compensation; or
- Is designed or used to transport more than 15 passengers (including the driver), and not used to transport passengers for compensation; or
- Is transporting hazardous materials of a type or quantity that requires placarding.
Summary of requirements
Each motor carrier is required by 396.3 to “systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles ... subject to its control.”
The time period between “systematic” vehicle inspections and the items inspected are to be determined by the motor carrier. The intervals could be established on a mileage or time basis. While the time intervals are at the discretion of the motor carrier, the program must be reasonable and systematic.
One place to start when developing a systematic inspection and maintenance program is with preventive maintenance (PM) schedules and checklists. These are generally established by the motor carrier based on the original equipment manufacturer’s (OEM) recommendations. The carrier normally reviews the OEM’s recommended inspection, lubrication, and maintenance intervals, and bases their schedules on them. Once the schedules are established it is simply a matter of documenting the schedules, performing the inspections and maintenance on time, and documenting the maintenance and any repairs.
Typical maintenance programs involve the use of a designation system to identify and describe preventive inspection and maintenance schedules. Here is an example of a schedule:
- PM A is also know as a "maintenance check-out." It involves a safety check of the vehicle and lubrication and inspection of "high wear" parts or components (brakes, belts, drive shaft, etc.) based on OEM recommendations. This is typically done at roughly half of the oil change interval. However, some carriers will use an inspection lane to perform a PM A on all vehicles entering the terminal.
- PM B involves everything done in a PM A plus an oil change and full lubrication (and any other fluid that is due for change) as well as a more in-depth inspection. Interval is set by OEM's recommendations (usually based on mileage, engine run hours, or time, depending on vehicle application).
- PM C is an "annual service." This service involves conducting a full periodic (annual) inspection as required by 396.17 as well as replacement of wear items as recommended by the OEM. A PM C must be done within 12 months of the previous PM C (new vehicle must have a periodic inspection before going into service).
- PM D is typically used to indicate a specialized service (summarization, winterization, and scheduled component rebuild are examples of PM D).
- Companies continue the lettering system based on their needs. Some companies go as far as PM L.
Remember, these are preventive maintenance inspections. They are not to be confused or combined with the driver's daily inspection requirements.
In addition to being charged with systematically inspecting, repairing, and maintaining motor vehicles subject to their control, carriers are required to maintain records on all vehicles controlled for 30 days or more. Records to be maintained are as follows:
- An identification of the vehicle, including:
- Company number (if so marked),
- Make,
- Serial number,
- Year,
- Tire size, and
- Name of the person furnishing the vehicle if it is not owned by the carrier;
- A means to indicate the nature and the due date of the various inspection and maintenance operations to be performed;
- A record of inspection, repair and maintenance indicating their date and nature; and
- A record of tests conducted on pushout windows, emergency doors, and emergency door marking lights on buses.
All records must be retained for at least one year where the vehicle is housed or maintained. However, after a vehicle leaves the motor carrier’s control, the records for that vehicle need only be kept for six months. The recordkeeping requirements do not apply to a non-business private motor carrier of passengers.
See topics on Driver vehicle inspection reports, Roadside inspections, Periodic inspection, Brake inspector requirements, and Intermodal equipment for other requirements related to maintenance.
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['Enforcement - DOT', 'Electronic logging device (ELD)', 'CMV Parts and Maintenance', 'Fuel Management']
['Vehicle maintenance', 'Roadside Inspections', 'Fuel management']
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