Sie sind auf Seite 1von 14

N

O
TI
C
Will Your Systematic

U
D
O
R
Maintenance Program Get a

EP
R
Passing Mark?

R
O
N
O
TI
A REFERENCE GUIDE
U
IB
TR

MON DAY 2 1 S E PTEMBE R 2 0 1 5


IS
D
R
FO
T
O
N
Participants

N
O
TI
C
U
Tony Bennett Special Agent, FMCSA

D
O
R
Darrell Ruban Field Administrator, FMCSA

EP
R
Clinton Seymour GA Division Administrator, FMCSA

R
O
N
O
Paul Tamburelli Principal
TI
U
Transportation Compliance
IB
TR

and Safety Group


IS
D
R
FO
T
O
N

2
Presentation Objectives

N
O
TI
C
U
To explain industry responsibilities under the new

D
O
intermodal equipment provider (IEP) rule.

R
EP
To facilitate compliance and improve vehicle safety

R
R
O
through better understanding of these requirements.

N
O
To explain how FMCSA will investigate and enforce
TI
U
the IEP rule.
IB
TR
IS
D
R
FO
T
O
N

3
IEPs Must Establish an IRM Program

N
O
TI
C
U
Required Inspection, Repair, and Maintenance (IRM)

D
O
program elements

R
EP
Performing regular IME inspections

R
R
O
Repairing the problems you find

N
O
TI
Maintaining IME between inspections
U
IB
TR

Creating a recordkeeping system for the program


IS
D

Preventative maintenance is
R
FO

key to safety!
T
O
N

4
FMCSA Roadability Reviews

N
O
TI
C
U
In a roadability review, FMCSA investigators will

D
O
R
EP
Review the IEPs compliance with 49 CFR parts 390,

R
R
393, and 396

O
N
O
TI
There will be no safety rating issued
U
IB
TR

as a result of a roadability review.


IS
D
R
FO
T
O
N

5
Systematic Maintenance Program

N
O
TI
C
U
Required Inspection, Repair, and Maintenance (IRM)

D
O
program elements

R
EP
Policies and Procedures

R
R
O
Roles and Responsibilities

N
O
TI
Qualification and Hiring
U
IB
TR

Training and Communication


IS
D

Monitoring and Tracking


R
FO

Meaningful Action
T
O
N

6
Systematic Maintenance Program
Element: Policies and Procedures

N
O
TI
C
Develop a system of preventive maintenance for compliant, safe,

U
D
and efficient fleet operations, including a schedule for periodic

O
R
maintenance, inspection, and recordkeeping.

EP
Develop a procedure ensuring that vehicle defects that impact

R
R
safety and/or safety compliance are reported, repaired, and

O
certified before the vehicle is operated.

N
O
Develop procedures to ensure that management is notified of
TI
U
vehicle defects through the use of Driver Vehicle Inspection
IB
Records (DVIRS) and other communication channels.
TR

IS

Develop a policy ensuring that mechanics are qualified to


D

complete annual inspections according to the requirements of


R
FO

396 and appendix G.


T
O
N

7
Systematic Maintenance Program
Element: Roles and Responsibilities

N
O
TI
C
Define and document responsibilities of managers, supervisors,

U
D
mechanics, and technicians as related to vehicle inspection,

O
R
repair, and maintenance policies, including the monitoring and

EP
documentation of defects and repairs.

R
Define and document roles and responsibilities of mechanics and

O
technicians for differentiating between safety-related defects and

N
O
other defects and for taking unsafe vehicles out-of-service (OOS).
TI
U
Define and document roles and responsibilities for checking daily
IB
completion of DVIRs and certifying repair before the next
TR

assignment.
IS
D

Define and document dispatch responsibilities for planning,


R
FO

scheduling, monitoring, and adjusting fleet operations in


accordance with repair and maintenance requirements.
T
O
N

8
Systematic Maintenance Program
Element: Qualification and Hiring

N
O
TI
C
Ensure that prospective employees are qualified to inspect, repair,

U
D
and maintain the chassis by querying applicants, checking with

O
previous employers and references, and obtaining necessary

R
EP
documents regarding inspection, and maintenance responsibilities
and (for mechanics and technicians) the quality of previous work,

R
R
including whether maintenance services were systematic and well

O
documented. Create a detailed written record of each inquiry.

O
Verify prospective brake inspectors understanding of job

TI
requirements and their applicable training and apprenticeship
U
credentials.
IB
TR

Ensure that the employment application captures all information


IS

required by Federal Motor Carrier Safety Regulations for mechanics


D

and technicians, with regard to certification of the ability to perform


R

repairs.
FO
T
O
N

9
Systematic Maintenance Program
Element: Training and Communication

N
O
TI
C
Convey expectations to all applicable staff for adhering to vehicle

U
D
inspection, repairing, and maintenance regulations and company

O
policies and procedures, and for executing responsibilities by

R
EP
providing new hire and refresher training, and establish
communication channels such as meetings focused on conflicts

R
R
between vehicle availability and repair requirements

O
Verify prospective brake inspectors understanding of job

N
O
requirements and their applicable training and apprenticeship

TI
credentials. U

IB
Ensure that all managers, mechanics, and technicians receive training,
TR

including methods and tools, and appropriate certifications to fulfill


IS

their responsibilities and documentation requirements regarding


D

vehicle inspection, repair, and maintenance, as required by


R

regulations and company policies.


FO
T
O
N

10
Systematic Maintenance Program
Element: Monitoring and Tracking

N
O
TI
C
Check all inspections and relevant records, such as DVIRs, pre-trip and annual

U
D
inspections, and maintenance and repair records, to ensure that company

O
inspection, repairing, and maintenance policies and procedures are adhered

R
EP
to and properly documented.

R
Monitor and track roadside inspection results to ensure that vehicle defects

R
are repaired and documented promptly and to prevent OOS vehicles from

O
operating prior to being repaired.

N
O
Maintain inspection, repair, maintenance, vehicle identification, and
TI
communication records to help evaluate the performance of all staff
U
IB
(mechanics and managers) involved in fleet maintenance and the
TR

effectiveness of compliance with vehicle maintenance policies, procedures,


IS

and regulations.
D

When monitoring and tracking vehicle maintenance issues, always assess


R

whether an issue is individual or represents a systemic breakdown in one of


FO

the SMPs (Policies and Procedures, Roles and Responsibilities, etc.).


T
O
N

11
Systematic Maintenance Program
Element: Meaningful Action

N
O
TI
C
Design and implement incentives and/or recognition programs

U
D
in order to reward and encourage effective performance related

O
R
to compliance with vehicle inspection, repair, and maintenance

EP
regulations and company policies.

R
R

O
Give employees immediate feedback, and require corrective

N
action as soon as the company is aware that vehicle inspection,

O
TI
repair, and maintenance responsibilities are not being fulfilled.
IB
U
Provide remedial training to employees with performance issues
TR

related to vehicle inspection, repair, and maintenance that can


IS
D

be addressed by enhancing their knowledge and skills.


R
FO
T
O
N

12
FMCSA Information Line

N
1-800-832-5660

O
General questions, registration using Form MCS-150C, USDOT

TI
Numbers, and the status of USDOT Numbers.

C
U
D
O
R
FMCSA Data Qs System

EP
https://dataqs.fmcsa.dot.gov

R
R
Questions or concerns about safety records.

O
N
O
TI
DOT Safety Violation Hotline
IB
U
1-888-DOT-SAFT
TR

http://nccdb.fmcsa.dot.gov
IS

Report safety violations.


D
R
FO
T
O
N

13
Questions

N
O
TI
C
U
D
O
R
Tony Bennett

EP
R
Special Agent GA Division

R
O
678-284-5157

N
O
TI
tony.bennett@dot.gov
IB
U
TR
IS
D
R
FO
T
O
N

14