FMCSR Brakes Parts thru Appendix G & Parts 396. CVSA BRAKE OOS CRITERIA Roadside Brake violations & CSA Brake Points

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1 CVSA Brake Safety Week September 7 13, 2014 Shelley Conklin, Landstar, Inspection Services Coordinator Captain Derek Barrs, Florida Highway Patrol - Commercial Veh Enforcement Sergeant Scott Henry, Florida Highway Patrol Compliance Investigations Unit Introduction to Brake Safety Week FMCSR Brakes Parts thru Appendix G & Parts 396 CVSA BRAKE OOS CRITERIA Roadside Brake violations & CSA Brake Points 1

2 Discussion Topics What is CVSA (Commercial Vehicle Safety Alliance) Brake Safety Awareness Week Know the FMCSA Brake Regulations NTSB warning on adjusting auto slacks What to expect during Roadside Brake Inspection Understanding the Roadside Report Brake violations & CSA Points (Vehicle Maintenance BASIC) Reducing your CSA foot print 2

3 Commercial Vehicle Safety Alliance CVSA is an not-for-profit organization comprised of local, state, provincial, territorial and federal motor carrier safety officials who perform the Roadside Inspections. Its mission is to promote commercial motor vehicle safety and security by providing leadership to enforcement, industry and policy makers. Inspections performed by state and federal law enforcement officers and are designed to stop unsafe vehicles in transit 3

4 CVSA Brake Safety Week Brake Safety Week is part of the Operation Airbrake program sponsored by CVSA in partnership with the U.S. Department of Transportation s Federal Motor Carrier Safety Administration (FMCSA). During a week in September, inspectors select vehicles for inspection and conducted either North American Standard Level I or Level IV inspections just on brake systems to verify regulatory compliance. They also helped to inform operators about the importance of proper maintenance including the distribution of educational 4 materials.

5 2013 Brake Safety Week Results at a Glance What are YOUR top brake violations? 2013 Total Brake Violations 1,010,013 Brake Violations 205,139 Out of Adjustment 150,123 Chaffing Hoses 20,067 vehicles were inspected 1,811 or 9% of vehicles were placed OOS for brake adjustment 1,434 or 7.1% of vehicles were placed OOS for brake components 2,714 or 13.5% of vehicles were placed OOS for brakes overall 5

6 Prevent Roadside Violations Know the FMCSA Regulations You and your teams are required Part INSPECTION, REPAIR, & MAINTENANCE o 396.1(a) Every motor carrier, it s officers, drivers, agents, representatives & employees directly concerned with inspections or maintenance must be knowledgeable & comply with the rules of this part o 396.3(a) Every motor carrier must systematically inspect, repair, & maintain all motor vehicles subject to its control o 396.3(a)(1) Parts & accessories shall be in safe & proper operating condition at all times. These include those specified in Part 393. APPENDIX G MINIMUM PERIODIC INSPECTION STANDARDS 6 o A Vehicle does not pass if it has one of the following defects..

7 Prevent Roadside Violations Know the FMCSA Regulations You and your teams are required Part 393 COMPONENTS NECESSARY FOR SAFE OPERATION o 393.1(b)(1) Every motor carrier & it s employees must be knowledgeable of & comply with the requirements & specifications of this part o 393.1(c) No motor carrier may operate a commercial motor vehicle unless it is equipped in accordance with the requirements & specifications of this part 7

8 FMCSA Brake Regulations Subpart C-Brakes (a) Each commercial motor vehicle must have brakes adequate to stop & hold Each commercial motor vehicle must meet the applicable service, parking, and emergency brake system requirement provide in this section Brakes required on all wheels Every commercial motor vehicle shall be equipped with brakes acting on all wheels. Exception: o Tractors having three or more axles AND manufactured before 7/25/80 are not required to have brakes on the front axle o Specialized vehicles, etc. 8

9 FMCSA Brake Regulations Subpart C-Brakes Breakaway & emergency braking (a) Towing vehicle protection system.. For air braked towing units, the tractor protection valve (TPV) shall operate automatically when the air pressure on the towing vehicle is between 20 psi & 45 psi. **Wheels chocked, psi, engine off, brakes released, remove supply air lines to trailer, TPV pops closing off air supply from tractor to trailer Check for leaking air from the system** 9

10 FMCSA Brake Regulations Subpart C-Brakes Brake tubing & hoses. (b)(1) Be long & flexible enough to accommodate without damage (b)(2) Be secured against chaffing, kinking, or other mechanical damage **Chaffing/rubbing? Secure with zip tie or spacer** **Worn to reinforcement ply &/or 2 nd color (white)? Replace** 10

11 ROADSIDE VIOLATIONS Chaffed/Worn to reinforcement ply & reduction of diameter of hose Air Line Crimped/Restricted Air Flow Red Emergency Line is WORN to the second color white & to the re-enforcement ply 11

12 FMCSA Brake Regulations Subpart C-Brakes Brake slack adjuster, lining/pads & drums (b) Service brake & spring brake chambers on each end of an axle must be the same size (c) Effective length of the slack adjuster on each end of an axle must be the same **No violation on mixing short/long stroke chambers across an axle** 12

13 FMCSA Brake Regulations Subpart C-Brakes Brake slack adjuster, lining/pads & drums - Continued >> (d) Thickness of the brake lining/pad shall not be less than ¼ inch Cracked Brake Pad/Lining Lining Separated from the Shoe 13

14 FMCSA Brake Regulations Subpart C-Brakes Brake slack adjuster, lining/pads & drums - Continued >> (e) Clamp-Type brake chambers (1) The pushrod stroke must not be greater than the values specified in the following table: Brake Chamber Type & Size Location Maximum Travel Limit Allowed Short Stroke 20 or 24 (round air port) steer axles 1 3/4 inch Short Stroke 30 trk drives & trl axles 2 inch Long Stroke 20 or 24 (square air port) steer axles 2 inch Long Stroke 30 trk drives & trl axles 2 1/2 inch 14

15 NTSB WARNING (National Transportation Safety Board) Automatic brake slack-adjusters should not be manually adjusted in an effort to correct excessive pushrod stroke. Excessive pushrod stroke indicates that a problem exists with the automatic slack-adjuster, with the installation of the automatic brake slack-adjuster or with related foundation brake components, which manual adjustment will not fix. Manual adjustment of automatic slack-adjusters is a dangerous practice that could have serious consequences because it gives the operator a false sense of security about the effectiveness of the brakes which are likely to go out of adjustment again soon. 15

16 BRAKES OUT OF ADJUSTMENT? BRAKES INOP? WHAT IS YOUR PUSH ROD TRAVEL? Out of Adjustment: Maximum stroke allowed is based on the size of brake chamber and depending if it is a Long or Short Stroke chamber. If stroke travel is beyond measurement allowed by DOT Standards it is out of adjustment. a) Measure your push-rod travel and track changes on the movements b) If over the travel allowed, do NOT adjust, have the brakes checked for possible defects c) Remember, continuously adjusting automatic slacks is not recommended, have your brakes checked and make necessary repairs Brake Chamber Type & Size Short Stroke 20 or 24 (round air port) Short Stroke 30 Long Stroke 20 or 24 (square air port) Long Stroke 30 Location steer axles trk drives & trl axles steer axles trk drives & trl axles Maximum Travel Limit Allowed 1 3/4 inch 2 inch 2 inch 2 1/2 inch 16

17 How to Measure Push-Rod Travel 1) Block/Chock wheels. 2) Release spring brakes ( psi reservoir pressure). 3) Make certain spring/park brakes are fully released. 4) Chalk or mark each push-rod at chamber. (diagram A). 5) Full brake application; brake pedal fully depressed measure push-rod travel, (diagram B). Mark push-rod at the entrance of the chamber Measure travel from the mark to the chamber Spring brakes released Service brakes applied Full brake application 17

18 FMCSA Brake Regulations Subpart C-Brakes Brake slack adjuster, lining/pads & drums - Continued >> (g) Drums - Thickness of the drums shall not be less than the limits established by the drum manufacture 18

19 FMCSA Brake Regulations Subpart C-Brakes Brakes to be operative (a)..all brakes with which a motor vehicle is equipped must at all times be capable of operating. (6) Raised lift axles Brakes on lift axles need not be capable of being operated while the lift axle is raised. However, brakes on lift axles must be capable of being applied whenever the lift axle is lowered and the tires contact the roadway. 19

20 FMCSA Brake Regulations Subpart C-Brakes Automatic brake adjusters (b) (air brake systems) Each commercial motor vehicle manufactured on or after October 20, 1994, and equipped with an air brake system must meet the automatic brake adjustment system requirements.. **Semi Tractor & Trailers, manufactured after this date must be equipped with Automatic Slack Adjusters** Manual Slacks not allowed! 20

21 FMCSA Brake Regulations Subpart C-Brakes Antilock brake systems (ABS) (c) Air brake systems (1) Tractors manufactured on or after March 1, 1997 shall be equipped with ABS (2) Trailers manufactured on or after March 1, 1998 shall be equipped with ABS 21

22 FMCSA Brake Regulations Subpart C-Brakes Antilock brake systems (ABS) (d) ABS malfunction circuits & signals for air brake systems (1) Tractors manufactured on or after March 1, 1997 shall be equipped with an electrical circuit capable of signaling a malfunction on the Tractor s dash (ABS malfunction light) ABS ABS In-Cab Dash Malfunction Lamp 22

23 FMCSA Brake Regulations Subpart C-Brakes Antilock brake systems (ABS) (d) ABS malfunction circuits & signals for air brake systems (2) & (3) Tractors manufactured on or after March 1, 2001, pulling a Trailer with ABS (manufactured on or after March 1, 2001), shall be equipped with an electrical circuit capable of transmitting a malfunction signal to the Trailer s malfunction lamp in the Tractor cab (ABS trailer malfunction dash light) 23

24 FMCSA Brake Regulations Subpart C-Brakes Antilock brake systems (ABS) (e) Exterior ABS malfunction indicator lamp for trailers Trailers manufactured on or after March 1, 1998 shall be equipped with an ABS malfunction lights on the exterior of the trailer (amber light located on the driver side at the rear) Trailer Exterior Malfunction Lamp (Rear Driver Side) 24

25 FMCSA Brake Regulations Subpart C-Brakes Inspection Scenario Tractor, manufactured before March 1, 1997 does not have ABS however, is hooked to a newer Trailer with ABS: o o Tractor shall provide electrical power to operate Trailer ABS and exterior malfunction light When inspecting both tractor/trailer, keep them hooked together, to confirm tractor is supplying the power to operate ABS malfunction light 25

26 What Should Drivers Expect During Brake Safety Week? Brake Safety Week is part of the Operation Airbrake program sponsored by CVSA. During the week-long brake safety campaign, CMV inspectors will conduct brake system inspections (primarily Level IV Inspections and Level I Inspections) on trucks and buses throughout North America to identify out-of-adjustment brakes and brake-system violations. HAVE YOU CHECKED YOUR BRAKES TODAY? 26

27 What Should Drivers Expect During Brake Safety Week? Brake-related violations comprise the largest percentage (representing half 49.6 percent during Roadcheck 2013) of all out-of-service violations cited during roadside inspections. Improperly installed or poorly maintained brake systems can reduce the braking capacity and stopping distance of trucks and buses, which poses a serious risk to driver and public safety. Roadcheck 2013 OOS Violation Data Percent of Total OOS Violations OOS Violation Data Percent of Total OOS Violations OOS Violation Data Percent of Total OOS Violations Vehicles Drivers Hazardous Mat Brake Adjustment 19.5% 17.5% 23.0% HOS 51.8% 50.2% 52.5% Shipping Papers 17.0% 24.2% 29.7% Brake System 30.1% 27.8% 29.2% False Logs 13.2% 15.0% 14.9% Placards 17.7% 17.6% 28.2% Tires/Wheels 10.1% 12.8% 10.9% Suspended 5.2% 4.7% 5.3% Bulk Pkging 2.7% N/A* 6.2% Lights 12.6% 12.5% 12.3% Expired Lic 0.7% N/A* 1.5% Marking 13.9% 2.0% 11.0% Safe Loading 11.7% 12.3% 9.1% Cancelled Lic 1.0% N/A* 0.2% Loading 37.4% 34.4% 24.9% Steering 2.3% 2.3% 2.2% DQ'ed 10.2% 4.7% 6.1% Pkg Integrity 14.6% N/A* 14.7% Frame 1.5% 1.5% 1.6% Revoked Lic 0.0% N/A* 0.4% Suspension 5.8% 1.9% 4.5% Endorsement 4.9% N/A* 3.1% Coupling Devices 0.8% 0.7% 0.9% Age 0.6% N/A* 0.5% Fuel System 0.6% 0.6% 0.8% Drugs/Alcohol 1.5% N/A* 1.0% Exhaust System 0.4% 0.1% 0.4% *the Roadcheck 2012 summary included certain violation totals combined in an 'Other Violations' category 27

28 What Should Drivers Expect During Brake Safety Week? Florida will continue to partner with industry to educate commercial motor vehicle drivers on why it is so important to keep your brakes properly adjusted and take unsafe vehicles off our highways. The success of this operation will be realized through an effort to accomplish the following. Discourage the unsafe operation of commercial motor vehicles (CMV) Remove unsafe vehicles and drivers from the public roadways of this State Take enforcement action against violators of Florida State Statutes and the Code of Federal Regulations Promote Safe operations of commercial motor vehicles through education and enforcement, by educating CMV drivers and carriers 28

29 What Should Drivers Expect During Brake Safety Week? Brake inspections conducted during Brake Safety Week include inspection of brake-system components to identify: loose or missing parts air or hydraulic fluid leaks worn linings, pads, drums or rotors, and other faulty brake-system components. Antilock braking systems (ABS) malfunction indicator lamps also are checked. Inspectors will inspect brake components and measure pushrod stroke when appropriate. Defective or out-of-adjustment brakes could result in the vehicle being placed out of service if the criteria is met. 29

30 What Should Drivers Expect During Brake Safety Week? Some jurisdictions such as Florida will conduct both the CVSA Level I and IV Inspections during Brake Safety Week. Florida and nine other participating jurisdictions, will be checking the overall vehicle braking efficiency by using the performance-based brake testing (PBBT) equipment. These systems include a slow speed roller dynamometer that measure total vehicle weight and total brake force, from which braking efficiency is calculated. The minimum braking efficiency for trucks is 43.5 percent, required by U.S. federal regulation and the CVSA Out-of-Service Criteria. 30

31 What Should Drivers Expect During Brake Safety Week Operation Airbrake Inspection Procedure for the Level IV Inspection Inspection Items Driver License Registration Low Air Warning Device Pushrod Travel (Adjustment) Brake Linings/Drums Air Loss Rate (If leak detected) Tractor Protection System 31

32 What Should Drivers Expect During Brake Safety Week Operation Air Brake Inspection Procedure Choose the Inspection Site Safety Considerations Check Air Brake Mechanical Components Check Steering Axle Air Brake Mechanical Components Check Brake Adjustment Build the Air Pressure to PSI Check the Air Brake ABS System (If Applicable) Test Air Loss Rate Test Low Air Pressure Warning Device Check the Tractor Protection System Finalize paperwork, and provide the results to the driver (i.e. out-ofservice, etc.) 32

33 What Should Drivers Expect During Brake Safety Week? North American Standard LEVEL I Inspection The most thorough driver/vehicle roadside inspection. A 37-step procedure that includes an examination of both the driver and vehicle. The driver inspection includes items such as the license and endorsements, hours of service, possible use of alcohol and drugs, and seat belts. The vehicle inspection includes items such as the brake system, coupling devices, exhaust system, frame, fuel system, lights, safe loading, steering mechanism, suspension, tires, van and open-top trailer bodies, wheels and rims, windshield wipers, and emergency exits on buses. 33

34 What Should Drivers Expect During Brake Safety Week North American Standard Level I Inspection Procedure Choose the Inspection Site Approach the Vehicle Greet and Prepare Driver Interview Driver Collect the Driver's Documents Check for the Presence of Hazardous Materials/Transportation of Dangerous Goods Identify the Carrier Examine Driver's License Check Medical Examiner's Certificate and Skill Performance Evaluation (SPE) Certificate (If Applicable) 34

35 What Should Drivers Expect During Brake Safety Week Inspect Right Rear Trailer Wheels Inspect Right Side of Trailer Check Record of Duty Status Review Driver's Daily Inspection Report (If Applicable) Review Periodic Inspection Report(s) Prepare Driver for Vehicle Inspection Inspect Front of Tractor Inspect Left Front Side of Tractor Inspect Left Saddle Tank Area Inspect Trailer Front Inspect Left Rear Tractor Area Inspect Left Side of Trailer Inspect Left Rear Trailer Wheels Inspect Rear of Trailer Inspect Double, Triple and Full Trailers 35

36 What Should Drivers Expect During Brake Safety Week Inspect Right Rear Tractor Area Inspect Right Saddle Tank Area Inspect Right Front Side of Tractor Inspect Steering Axle(s) Inspect Axles 2 and/or 3 Inspect Axles 4 and/or 5 Prepare the Vehicle and Check Brake Adjustment Inspect Tractor Protection System Inspect Required Brake System Warning Devices Test Air Loss Rate Check Steering Wheel Lash Check Fifth Wheel Movement Complete the Inspection and required paperwork for the driver 36

37 What Should Drivers Expect During Brake Safety Week PBBT- Performance Based Brake Testing PBBTs are capable of assessing brakes in a complementary manner to visual inspection methods in that they provide a direct and objective measure of a vehicle's actual braking performance. Additionally PBBTs are able to check brakes that are otherwise difficult to inspect visually, such as those with low ground clearance and those that do not have exposed pushrods (air disc brakes, wedge brakes, hydraulic brakes, electric brakes, etc.) 37

38 What Should Drivers Expect During Brake Safety Week PBBT- Each tester type has a unique method of operation. Therefore, training and operation issues must be tailored specifically to each piece of equipment. This document sets guidelines for general operational procedures. rocedure%20revised% pdf 38

39 CSA Brake Violations In % of the inspections completed nationwide had an out of service inoperative/defective brake violation. Inoperative/Defective brake violations was the third most out of service violation listed on inspection reports. 1.3% of fatal crashes by vehicle related factors where brake systems violations. Brake violations are encompassed into the Vehicle Maintenance BASIC and most affect the drivers CSA scores 39

40 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver Inadequate brake system on a CMV 4 Y No or defective parking brake system on CMV 4 Y No brakes as required 4 Y A-BM Brake - Missing required brake. 4 Y A-BMAW Brake - All wheels not equipped with brakes as required. 4 Y A-BM-TSA Brake - Missing on a trailer steering axle. 4 Y No/improper breakaway or emergency braking 4 Y 40

41 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver (a) No/improper tractor protection valve 4 Y (d) No or defective automatic trailer brake 4 Y No/defective bus front brake line protection 4 Y Brake tubing and hose adequacy 4 N PC Brake Tubing and Hose Adequacy - Connections to Power Unit 4 N UV Brake Tubing and Hose Adequacy Under Vehicle 4 N (a)(4) Failing to secure brake hose/tubing against mechanical damage 4 N 41

42 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver (b)(2) Failing to secure brake hose/tubing against mechanical damage 4 Y B2PC Brake Hose or Tubing Chafing and/or Kinking - Connection to Power Unit 4 Y B2UV (b)(3) Brake Hose or Tubing Chafing and/or Kinking Under Vehicle Failing to secure brake hose/tubing against high temperatures 4 N 4 N (d) Brake connections with leaks/constrictions 4 N DCPC Brake Connections with Constrictions - Connection to Power Unit 4 Y DCUV Brake Connections with Constrictions Under Vehicle 4 N 42

43 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver DLPC DLUV Brake Connections with Leaks - Connection to Power Unit Brake Connections with Leaks Under Vehicle 4 Y 4 Y Inadequate/contaminated brake linings 4 Y (a) Inadequate brakes for safe stopping 4 Y (b) Mismatched brake chambers on same axle 4 Y (c) Mismatched slack adjuster effective length 4 Y (d) Insufficient brake linings 4 Y 43

44 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver (e) Clamp/Roto-Chamber type brake(s) out of adjustment 4 Y (f) Wedge type brake(s) out of adjustment 4 Y (g) Insufficient drum/rotor thickness 4 Y (a) Inoperative/defective brakes 4 Y A-BCM Brakes - Hydraulic Brake Caliper movement exceeds 1/8" (0.125") (3.175 mm) 4 N A-BMBC Brakes - Missing or Broken Components 4 N A- BRMMC Brakes - Rotor (disc) metal-to-metal contact 4 N 44

45 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver A- BSRFS Brakes - Severe rusting of brake rotor (disc) 4 N (b)(1) Defective brake limiting device 4 Y Inadequate reservoir for air/vacuum brakes 4 N (a) (b) Failing to have sufficient air/vacuum reserve Failing to equip vehicle - prevent reservoir air/vacuum leak 4 N 4 N (c) No means to ensure operable check valve 4 N (d) No or defective air reservoir drain valve 4 Y 45

46 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver No or defective brake warning device 4 Y (a)(1) Insufficient braking force as percent of GVW or GCW 4 Y (a) Automatic brake adjuster CMV manufactured on or after 10/20/ hydraulic brake 4 Y (b) Automatic brake adjuster CMV manufactured on or after 10/20/ air brake 4 Y (c) Brake adjustment indicator CMV manufactured on or after 10/20/ external automatic adjustment 4 Y (a) ABS - all CMVs manufactured on or after 3/1/1999 with hydraulic brakes 4 N (b) ABS - malfunction indicators for hydraulic brake system 4 N 46

47 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver (c)(1) ABS - all tractors manufactured on or after 3/1/1997 air brake system 4 N (c)(2) ABS - all other CMVs manufactured on or after 3/1/1998 air brake system 4 N (d)(1) ABS - malfunctioning circuit/signal - truck tractor manufactured on or after 3/1/1997, single-unit CMV manufactured on or after 3/1/ N (d)(2) ABS - malfunctioning indicator to cab of towing CMV manufactured on or after 3/1/ N 47

48 CSA Brake Violations Section Violation Description Violation Severity Points Counts Against Driver (d)(3) No or Defective ABS Malfunction Indicator for towed vehicles on vehicles manufactured after February N (e) ABS - malfunctioning lamps towed CMV manufactured on or after 3/1/1998, manufactured before 3/1/ Y (c)(1) ABS - all tractors manufactured on or after 3/1/1997 air brake system 4 N (d)(3) No or Defective ABS Malfunction Indicator for towed vehicles on vehicles manufactured after February N 48

49 SMS Methodology (Point System) Maximum points for any BASIC in one inspection is 30 points prior to Time Weighting. Severity - All measurements are based on violation severity for the specific BASIC. (Inoperative/Defective Brake - 4 points). The same violation will not be counted twice. However, the one counted violation will have an additional 2 point value if it is an OOS violation (counted prior to the Time Weighting). Time Weight - New violations most heavily weighted. 0-6 Months- (Severity + OOS points) X Months- (Severity + OOS points) X Months- (Severity + OOS points) X 1 Over 24 Months- Not counted on CSMS. 49

50 Example of SMS Methodology Inoperative/Defective brake (393.48(a) (4 Points) (Additional 2 points if determined to be out of service) (4 + 2) X 3 = 24 pts (0-6 months) (4 + 2) X 2 = 16 pts (6-12 months) (4 + 2) X 1 = 8 pts (12-24 months) 50

51 SMS Methodology The carrier is then placed into a peer group based on number of relevant inspections in that Basic in the previous 24 months. The last step is to rank that carrier by comparing its Basic measure to other carriers Basic measure in that peer group. (e.g., other carriers with similar numbers of inspections). The percentage is where the carrier falls in the peer group Clean inspections raise the number of inspections in a Basic, helping the carrier s score 51

52 CSMS BASICs Scores and Intervention Thresholds Carriers points accumulate for 24 months To be ranked, a carrier normally needs to have: 3 to 5 relevant inspections (Level 1 or 2 for equipment) OR A violation in the BASIC category BASIC INTERVENTION THRESHOLDS Unsafe Driving 60% Hours-of-Service (HOS) Compliance 60% Driver Fitness 75% Controlled Substances/Alcohol 75% Vehicle Maintenance 75% Hazardous Material (HM) Compliance 80% Crash Indicator 60% 52

53 The Carrier Sees Something Like This 53

54 Comprehensive Intervention Process Warning Letters Investigations On-site comprehensive investigations (enhanced compliance review) On-site focused investigations Off-site investigations Follow-on corrective actions Notice of Claim Out-of-Service (OOS) orders 54

55 Warning Letters Advises carriers Roadside deficiencies Consequences of noncompliance Sent when carrier exceeds threshold 1 BASICs 55

56 Investigations Offsite Investigation Evaluate the safety problems identified through the SMS and to determine their root causes. Types of documents requested may include third-party documents such as toll receipts, border crossing records, or drug testing records. The goal is to identify issues responsible for may be subject to an onsite investigation or to subpoena records. 56

57 Investigations Onsite Focused Investigation To evaluate the safety problems identified through the SMS and their root causes. An onsite focused investigation may be selected when alerts in one or two BASICs exist. Onsite "focused" investigations target specific problem areas Onsite Comprehensive Investigation Takes place at the carrier s place of business. It is used when the carrier exhibits broad and complex safety problems through continually alerted BASICs, worsening multiple BASICs (three or more), or a fatal crash or complaint. 57

58 Investigation Ramifications Notice of Claim (NOC) An NOC is issued in cases where the regulatory violations are severe enough to warrant assessment and issuance of civil penalties. Operations Out-of-Service Order (OOS) An OOS order is an order requiring the carrier to cease all motor vehicle operations. 58

59 Reduce your CSA Foot Print Regular PM s Systematic Lube / Maintenance Measure, Document, & Track Push-Rod Travel Inspect each brake use measuring tool Don t adjust for purpose of inspection or repairs PUSH ROD TRAVEL MEASUREMENT CHART TRACTOR DATE ODOMETER L STEER R STEER L F DRIVE R F DRIVE L R DRIVE R R DRIVE 8/28/ ,200 1 ¼ 1 ½ 2 in 2 in 1 ¾ 1 ½ TRAILER DATE HUB OD L F TRL R F TRL L R TRL R R TRL 59

60 Reduce your CSA Foot Print Perform required inspections Inform/educate Driver meetings Pre/Post/In-Route driver inspections Report issues Repair before getting back on road Open dialogue with your shops Know the FMCSA Brake Regulation Standards 60

61 Encourage to review FMCSR 393, Appendix G, & 396 Regulations Build on these foundations along with your compliance/safety departments, maintenance programs, shop personnel, and third-party shops. Be diligent Remember to check your brakes Allow proper time to perform pre/post/in-route inspections Keep records of your push-rod travel measurements to be aware of any issues Establish a regular brake maintenance routine Safety is your first priority BRAKES 61

62 Review Brake Regulations FMCSA.DOT.GOV Click on Vehicles under Rules & Regulations CSA Information csa.fmcsa.dot.gov Check out CVSA s OAB Web Site OperationAirBrake.com Info on Out-Of-Service Criteria CVSA.ORG 62