Truckers, suppliers concerned about self-certification process, compliance
Jun 23, 2016 Aaron Marsh American Trucker
With about a year and a half left before most U.S. trucks will need to have some sort of electronic logging device, or ELD, just five vendors have added their products the Federal Motor Carrier Safety Administration’s list of compliant devices. None yet are the big-name providers of electronic driver log recording instruments that conform to FMCSA’s requirements in place for Automatic On-board Recording Devices, or AOBRDs, which are the current option to paper logs and a precursor to the mandated ELDs.
Complicating matters, trucking companies and some technology vendors have expressed concern about whether the self-certified products truly will be compliant with the ELD final rule’s requirements, and Elise Chianelli, director of safety and compliance at fleet management technology company PeopleNet, spells out three things truckers should be aware of regarding where that process is now.
“In terms of the industry, I think it’s going to be year’s end or into next year before you really start to see a lot of credible names pop up” in the self-certified compliant ELD list, Chianelli says.
1. Certain FMCSA software/systems relating to ELD compliance aren’t yet available.
If the Department of Transportation (DOT) shows up after the Dec. 18, 2017 ELD compliance deadline to audit a carrier’s driver logs, either a driver will provide needed info to authorities at the roadside or the carrier will provide info from the back office to auditors. Chianelli says FMCSA will then take the information collected and run it through what the agency is calling its “ERODS,” or Electronic Record of Duty Status, system to determine compliance with federal Hours of Service regulations.
“At this point, FMCSA has not yet released access to ERODS. There’s been rumors we may not see that until the latter half of this year,” she notes. “So in terms of being able to bring a compliant product to market, we’re unsure how [an ELD provider] would know now that they are or are not compliant before they know that what they’re showing for hours of service available matches what FMCSA shows for hours of service available.”
2. Information required for one of the four ELD information transfer methods FMCSA specified also is not yet available.
FMCSA has outlined that ELDs will be able to transfer their data via web service, email, Bluetooth connectivity or USB 2.0 connection, Chianelli points out. However, for the “web services” transfer method, “FMCSA has not yet published where we would post the files to,” she says. “The web services URL has not yet been provided.”
“We at PeopleNet feel we will need to have access to these systems to ensure that when we release our ELD product, yes, it is indeed compliant with all the different specifications,” she adds.
3. FMCSA has published a 400-plus-page document of ELD test cases that is optional for vendors to use in developing their ELD products.
In terms of what is available now, FMCSA published a 440-page document in late April containing ELD test cases and procedures, Chianelli notes. FMCSA states that “although use of the ELD test procedures set forth in this document is not binding on ELD providers . . . FMCSA would use these test procedures to evaluate compliance if the Agency decides to undertake an independent evaluation of an ELD that has been certified by the provider.”
So in other words, “if there is an audit of your [ELD] solution, those test cases are what they (FMCSA) would use in order to determine compliance,” says Chianelli. “FCMSA has stated that you can use the test cases they’ve provided to ensure your product is in compliance, but you don’t have to.
“At the end of the day, this is definitely an area where we feel it’s very important for carriers to do their research and due diligence before making that purchase decision,” she continues. “They need to make sure they’re partnering with the right people who understand the complexities involved” when it comes to ELDs.
Advice for now?
Again, Chianelli emphasizes that PeopleNet and many of the company’s peers in the ELD provider community aren’t likely to self-certify their ELD products until later this year or into 2017.
“And remember, that’s when and if FMCSA grants access to these other applications or pieces of information that will be required,” she notes.
While there are five companies to date that officially claim their products are compliant with the ELD final rule, Chianelli says FMCSA is expecting perhaps four or five times that many vendors ultimately will have products on the self-certified list.
Every year, during the first week of June and usually on a Tuesday, Wednesday and Thursday, the CVSA (Commercial Vehicle Safety Alliance) holds the annual sting operation code named “Roadcheck”. During the 72-hour event approximately ten thousand federal, state, provincial and local truck and bus inspectors hold inspection operations throughout the USA, Canada and Mexico using North American Standard Level I Inspection Procedures.
North American Standard Level I Commercial Vehicle Inspection Procedures
Be Proactive and inspect your vehicle thoroughly before pulling in for inspection. According to the CVSA, if you are placed “Out of Service” the cost will average $861.00, which does not include charges for fines or emergency service repairs as a result of the inspection.
- PREPARE THE VEHICLE AND DRIVER
Instruct the driver to remain at the controls, shut down the engine (allow cool down time for turbo-charged engines). Place chock blocks in position beginning on the drivers side, one in front and one behind the drive axle tires or between the axles. Advise the driver the wheels have been chocked. Have the driver place the transmission in neutral and release all brakes. Advise the driver in the use of hand signals. (Lamps and brakes).
- CHECK DRIVER’S REQUIREMENTS DRIVER LICENSE (391.11)
Check for expiration date, birth date and status check. MEDICAL CERTIFICATE (391.41) Check for expiration date, corrective lenses, hearing aid and signatures.
MEDICAL WAIVER (II applicable)(391.49) Check for expiration date, make sure form is completed. Note the stated physical limitations.
RECORD OF DUTY STATUS (395.8)(395.3) Updated to last change of duty status, today’s date, legible handwriting, past 7 days recorded, mileage, driving time, on duty time, vehicle numbers, carrier name and signature. “Remarks” section may include locations of duty status change, unusual circumstances that delay the trip and shipping document numbers or the name of the shipper. Check for written authorization for interactive electronic recording devices. If applicable.
DRIVER VEHICLE INSPECTION REPORT (396.11) Check for I.D. number(s) of vehicle(s) inspected, record of defects found, if any. Check for signatures.
SHIPPING PAPERS, BILL OF LADING – Check for listings of hazardous materials indicated by the first entry or an “X” in the H.M. column or a contrasting color. Papers must be within arms reach and visible.
SEAT BELT (392.16) – Check for condition and usage.
ALCOHOL AND DRUGS (392.4) (392.5) – Check for violations.
- CHECK FOR PRESENCE OF HAZARDOUS MATERIALS
PLACARDS – Check for the presence of placards but use caution even If none are posted.
LEAKS, SPILLS, UNSECURE CARGO. When hazardous materials are present, be especially careful with leaks, spills or unsecured cargo.
MARKINGS – Cargo tanks and portable tanks will display markings on an orange panel or placard. They should indicate the I.D. number for type of hazardous material. There are exceptions to this rule. LABELS – When containers are visible, labels will identify the hazardous materials. There are exceptions to this rule.
- INSIDE CAB
STEERING LASH – Measure amount of steering lash and compare with out-of-service criteria.
STEERING COLUMN – Check for unsecured attachment.
- FRONT OF TRACTOR
HEAD LAMPS, TURN SIGNALS, EMERGENCY FLASHERS (393.25) – Check for improper color and operation.
WINDSHIELD WIPERS (393.78) – Check for improper operation. Two wipers are required unless one can clean the drivers field of vision.
WINDSHIELD (393.60) – Check for cracks or other damage. Check for decals or stickers in field of vision.
- STEERING AXLE
INFORM THE DRIVER THAT YOU ARE GOING UNDER THE VEHICLE, AND TO LISTEN FOR YOUR INSTRUCTIONS.
STEERING SYSTEM (BOTH SIDES) – Check for loose, worn, bent, damaged or missing parts. Instruct the driver to rock the steering wheel, check key components: front axle beam, gear box, pitman arm, drag link, tie rod and tie rod ends.
FRONT SUSPENSION (BOTH SIDES) – Check for indications of misaligned, shifted or cracked springs, loosened shackles, missing bolts, spring hangers unsecured at frame and cracked or loose U-bolts. Check for unsecured axle positioning parts and signs of axle misalignment.
FRONT BRAKES (BOTH SIDES) (393.48) – Check for missing, nonfunctioning, loose, contaminated or cracked parts on the brake system, including; brake drums, brake shoes, rotors, pads, linings, brake chambers, chamber mounting brackets, push rods, and slack adjusters. Check for “S” cam flip over. Be alert for audible air leaks around brake components and air lines. With brakes released, mark the brake chamber push rod at the point where the push rod exits the brake Chamber. Mark the push rods on both sides at this time. All push rods will be measured in ITEM 17.
FRONT AXLE – Check for cracks, welds, and obvious misalignment.
FRAME and FRAME ASSEMBLY – Check for cracks, or any defect that may lead to the collapse of the frame.
- LEFT FRONT SIDE OF TRACTOR
LEFT FRONT WHEEL AND RIM – Check for cracks, unseated locking rings, broken or missing lugs, studs or clamps. Bent or cracked rims, “bleeding” rust stains, loose or damaged lug nuts and elongated stud holes.
LEFT FRONT TIRE (393.75) – Check for improper inflation, serious cuts and bulges. Check tread wear and measure major tread groove depth. Inspect sidewall for defects. Check for exposed fabric or cord. Radial and bias-ply tires should not be mixed on the steering axle.
- LEFT SADDLE TANK AREA
LEFT FUEL TANK(S) (393.65) – Check for unsecured mounting, leaks or other damage. Verify that the fuel crossover line is secure. Check for unsecured cap(s). Check ground below tank for signs of leaking fuel.
TRACTOR FRAME (393.201) – Check frame rails and cross members on the tractor just behind the cab, look for cracks, bends or excessive corrosion.
EXHAUST SYSTEM (393.83) – Check for unsecured mounting, leaks (under the cab), exhaust contacted by fuel lines, air lines or electrical wires. Check for carbon deposits around seams and clamps.
- TRAILER FRONT
AIR AND ELECTRICAL LINES (393.28) – Lines between tractor and trailer should be suspended and free of tangles and crimps. They should have sufficient slack to allow the vehicle to turn. Inspect line connections for proper seating. Listen for audible air leaks.
FRONT END PROTECTION (393.106) – Check for height requirements. (Note exceptions).
- LEFT REAR TRACTOR AREA
WHEELS, RIMS AND TIRES – Inspect as described in ITEM 7. Check inside tire of dual for inflation and general condition. Tires should be evenly matched (same circumference) on dual wheels. Without placing yourself between the tires on tandem axles, check for debris between the tires.
LOWER FIFTH WHEEL (393.70) – Check for unsecured mounting to the frame or any missing or damaged parts. Check for any visible space between the upper and lower fifth wheel plates. Verify the locking jaws are around the shank and not the head of the kingpin. Verify the release lever is seated properly and that the safety latch is engaged.
UPPER FIFTH WHEEL – Check for any damage to the weight bearing plate and its supports on the trailer. Check king-pin condition.
SLIDING FIFTH WHEEL – Check for proper engagement of the locking mechanism (teeth fully engaged on rail). Check for worn or missing parts, making sure that the position does not allow the tractor frame rails to contact the landing gear during turns.
INFORM THE DRIVER THAT YOU ARE GOING UNDER THE VEHICLE. ENTER THE UNDERCARRIAGE IN VIEW OF THE DRIVER.
SUSPENSION (BOTH SIDES) – Inspect as described in ITEM 6. Check for deflated or leaking air suspension systems.
BRAKES (BOTH SIDES) – Inspect as described in ITEM 6. With brakes released, mark the push rods.
- LEFT SIDE OF TRAILER
FRAME AND BODY – Check for cracks and any indication leading to the collapse of the frame.
CARGO SECUREMENT (393.100) – Check for improper blocking or bracing, unsecured chains or straps. Verify end gates are secured in stake pockets. Check tarp or canvas.
WHEELS, RIMS AND TIRES – Inspect as described in ITEM 7.
SLIDING TANDEM – Check for misalignment and position. Look for damaged, worn or missing parts. Check locking mechanism. Teeth of locking mechanism must fully mesh with those of the rail secured to the frame.
INFORM THE DRIVER THAT YOU ARE GOING UNDER THE VEHICLE. ENTER THE UNDERCARRIAGE IN VIEW OF THE DRIVER.
SUSPENSION (BOTH SIDES) – Inspect as described in ITEM 6.
BRAKES (BOTH SIDES) – Inspect as described in ITEM 6. With brakes released, mark the push rods.
- REAR OF TRAILER
TAIL, STOP, TURN LAMPS AND EMERGENCY FLASHERS – Check for improper color and operation.
CARGO SECUREMENT – Inspect as described in ITEM 11. Also check tailboard security. Verify end gates are secured in stake pockets and rear doors are closed. Check both sides of trailer to insure protection of cargo from shifting or falling.
- RIGHT SIDE OF TRAILER
Check all Items as on the left side.
- RIGHT REAR TRACTOR AREA
Check all Items as on the left side.
- RIGHT SADDLE TANK AREA
Check all Items as on the left side.
- RIGHT FRONT SIDE OF TRACTOR
Check all Items as on the left side.
- BRAKE ADJUSTMENT CHECK
INFORM THE DRIVER THAT YOU ARE GOING UNDER THE VEHICLE. ENTER THE UNDERCARRIAGE IN VIEW OF THE DRIVER.
MEASURE PUSH ROD TRAVEL (ALL BRAKES) – While the brakes are applied, move around the vehicle and measure the distance of push rod travel at each chamber. Write down each push rod measurement and compare them to the out-of-service criteria for the appropriate size and type of brake chamber. Again, listen for leaks as you move around the vehicle.
- FIFTH WHEEL MOVEMENT CHECK
USE CAUTION – If conducted improperly, this method of checking for fifth wheel movement can result in serious damage to the vehicle. Use caution and instruct the driver carefully.
PREPARE THE VEHICLE AND DRIVER – Have the driver put the vehicle in gear, release the service brakes and apply the trailer brakes. Remove the wheel chocks and have the driver start the vehicle. Carefully explain the procedure to the driver. Tell the driver to GENTLY rock the tractor as you watch the fifth wheel.
CONDUCT THE PROCEDURE – As the tractor rocks, watch for movement between the mounting components and frame, pivot pin, bracket and upper and lower fifth wheel halves.
- AIR LOSS RATE
WHEN TO CONDUCT THE TEST – If you heard an air leak at any point in the inspection, you should now check the vehicle’s air loss rate.
CONDUCT THE PROCEDURE – Have the driver run the engine at idle, then apply and hold the service brake. Observe the air reservoir pressure gauge on the dash. Have driver pump the pressure down to 80 psi. Compressors do not activate until system pressure drops below a certain level. At about 80 lbs most compressors should be operating. Air pressure should be maintained or increase. A drop in pressure indicates a serious air leak in the brake system and the vehicle should be placed out of service.
- LOW AIR PRESSURE WARNING DEVICE
TEST THE WARNING DEVICE – Instruct the driver to pump the air down until the low air pressure warning device activates. Observe the gauges on the dash. The low air pressure warning must activate at a minimum of ½ the compressor governor cut out pressure, approximately 55 psi.
- TRACTOR PROTECTION VALVE
This procedure will test both the tractor protection valve and the trailer emergency brakes.
CONDUCT THE TEST – Instruct the driver to release the emergency brakes by pushing in the dash valves. Break the supply emergency line at the hose couplers between the tractor and trailer. When the line is disconnected a blast of air will be noticed. At this point, the emergency brakes on the trailer should set up.
OBSERVE THE DASH GAUGE – Air will leak from the tractor side of the line until the pressure in the tractor’s system drops to the 20-45 psi range. At this point, the air loss should stop, isolating the tractor air system. A loss of air in the tractor system below the 20-45 psi range indicates a malfunctioning tractor protection valve. If the trailer brakes do not set up when the line is disconnected, there is a problem with the trailer emergency brakes.
- SPEED LIMITERS
CANADA – ONTARIO, QUEBEC ONLY. Check Electronic Truck Speed limiters and Cruise Control. Must be set no higher than 65mph (105kph). Tire size, transmission gear ratio and rearend gear ratio must also be programmed properly to match truck specifications as listed on the ID plate, usually located on the driver’s door jamb.
- COMPLETE THE INSPECTION
COMPLETE PAPER WORK – Complete inspection forms and other paperwork as required.
CONCLUDE WITH THE DRIVER – Explain any violations or warnings to the driver. Take appropriate enforcement if necessary.
APPLY C.V.S.A. DECAL – Apply a C.V.S.A. decal on all vehicles that qualify
