What Paper Trail Is Needed After Your Drivers Receives Roadside Inspection With A Vehicle Maintenance Issues?
The Feds only have so many checking points during an audit on your company. Their number one thing is to compare your Roadside Inspections on your SMS Report to your admin files. This is typically the equipment any auditor will start with during your Compliance Review.
When your equipment receives any kind of violation roadside rather it is a “warning” or an out of service order this provides multiple check points in your Maintenance Files.
- Driver Vehicle Inspection Report (DVIR)
- Maintenance Log
- Maintenance Schedule
Driver Vehicle Inspection Reports
With regulation change as of December 2014 carriers are no longer required to have daily Driver Vehicle Inspection Reports unless defects are found. Now we all know, no truck never has maintenance issues. However, the only time an investigator can prove when your equipment had defects and a DVIR is warranted is when they have caught it roadside. For example, if your driver receives a warning for an inoperable bulb you are now required to have the accompanying DVIR with the three required signatures verifying the repairs have been completed. The individuals who need to sign off on this report is: the driver who found the defect, the person (mechanic or driver) who repaired the defect and the driver of the equipment on the next run who has confirmed the repair. Now many people will read too deep into the regulations, don’t! If your driver found the defective bulb and replaced the bulb and then drove the truck next, he must sign in all three required locations. If an officer found the defect and it is on the Inspection report but the driver repaired it right in front of the officer the same applies. Basically, if the defect is on the SMS you must have a DVIR completed for that day!
After you have received the completed DVIR there is another step the individual who is in charge of the maintenance files must take. First off, always make sure you have your supporting documentation for the repair. This does not need to be a receipt necessarily, but is helpful. It can also be a work order completed by the driver or mechanic who replaced the bulb. They then need to take the supporting document and log the repair on your Maintenance Log. Some people choose to use the PDF supplied by the Feds or some sort of Database or software system. Personally, I prefer to use an Excel Spreadsheet because this will have the ability to keep both an electronic and hard copy for your records for the life of the equipment and it is simple to enter data even for the most technologically challenged.
Now keep in mind you are technically only required to have four things in your vehicle maintenance file for a Compliance Review; your Maintenance Log, your Maintenance Schedule, Annual Inspection, and Driver Vehicle Inspection Reports with defects in the last 90 days. Once they have checked your DVIR’s with defects they will check the maintenance log for the repair and now they will check the Annual Inspection. From here they can begin checking your Maintenance Schedule. Your Annual Inspection will always have an odometer reading this the provides the investigator with checking point on your mileage to insure your scheduled maintenance follows the program set forth in your Fleet Safety Policy.
So, anytime any of your equipment received documentation of a vehicle maintenance issue make sure a few thing completed. The DVIR needs to reflect the defect, and have the three required signatures. Then, ensure the repair has been documented on your Maintenance Log within a reasonable amount of time and before the vehicle was operated again. Lastly, make sure the equipment is current on their scheduled maintenance and Annual Inspections. If you do these few things the FMCSA will have a hard time proving vehicle maintenance violations during an FMCSA Compliance Review.
Don’t forget to submit the inspection report to the issuing state as well! This, of course, is typically only for violations where citations were received, but you must submit that within 15 days of the inspection report date. Make sure to keep all copies for 12 months for audit purposes. I keep them in a separate file not in a drivers DQ file.
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