CVSA Brake Safety Week September 7

Transcription

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
CVSA BRAKE OOS
CRITERIA
Parts 393.40
thru 393.55
Roadside Brake
violations
Appendix G
&
&
CSA Brake Points
Parts 396
1
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
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
3
to stop unsafe vehicles in transit
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.
2013 Brake Safety Week Results at a Glance
What are YOUR top brake violations?
 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
2013 Total Brake Violations
 1,010,013 Brake Violations
 205,139 Out of Adjustment
 150,123 Chaffing Hoses
 2,714 or 13.5% of vehicles
were placed OOS for brakes
overall
5
Prevent Roadside Violations
Know the FMCSA Regulations
You and your teams are required
Part 396 - 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
o A Vehicle does not pass if it has one of the following defects6…..
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
FMCSA Brake Regulations
Subpart C-Brakes 393.40 - 393.55
393.40(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.
 393.42 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
393.43 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, 90-100 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
393.45 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 2nd color (white)? Replace**
10
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
393.47 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
393.47 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
(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
Short Stroke 20 or 24 (round air port)
steer axles
1 3/4 inch
trk drives & trl axles
2 inch
steer axles
2 inch
2 1/2 inch
Short Stroke 30
Long Stroke 20 or 24 (square air port)
Long Stroke 30
Maximum Travel Limit Allowed
14
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
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
Location
Maximum Travel Limit Allowed
Short Stroke 20 or 24 (round air port)
Short Stroke 30
Long Stroke 20 or 24 (square air port)
Long Stroke 30
steer axles
steer axles
1 3/4 inch
2 inch
2 inch
2 1/2 inch
16
1)
2)
3)
4)
5)
How to Measure Push-Rod Travel
Block/Chock wheels.
Release spring brakes (90-100 psi reservoir pressure).
Make certain spring/park brakes are fully released.
Chalk or mark each push-rod at chamber. (diagram A).
Full brake application; brake pedal fully depressed–measure push-rod
travel, (diagram B).
Mark push-rod at the
entrance of the chamber
Spring brakes released
Measure travel from the
mark to the chamber
Service brakes applied—
Full brake application
17
(g) Drums -
Thickness of the drums shall not be less than the limits
established by the drum manufacture
18
393.48 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
393.53 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
393.55 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
(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
(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
(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
Inspection Scenario
Tractor, manufactured before March 1, 1997 does not
have ABS however, is hooked to a newer Trailer with ABS:
o Tractor shall provide electrical power to operate Trailer ABS
and exterior malfunction light
o When inspecting both tractor/trailer, keep them hooked
together, to confirm tractor is supplying the power to operate
ABS malfunction light
25
What Should Drivers Expect
During Brake Safety Week?

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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

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
OOS Violation
Violation
Violations
Data
Data
Vehicles
2013
2012
2011 Drivers
2013
2012
2011 Hazardous Mat.
Brake Adjustment 19.5% 17.5%
23.0% HOS
51.8% 50.2%
52.5% Shipping Papers
Brake System
30.1% 27.8%
29.2% False Logs
13.2% 15.0%
14.9% Placards
Tires/Wheels
10.1% 12.8%
10.9% Suspended
5.2%
4.7%
5.3%
Bulk Pkging
Lights
12.6% 12.5%
12.3% Expired Lic
0.7%
N/A*
1.5%
Marking
Safe Loading
11.7% 12.3%
9.1% Cancelled Lic
1.0%
N/A*
0.2%
Loading
Steering
2.3%
2.3%
2.2% DQ'ed
10.2%
4.7%
6.1%
Pkg Integrity
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
Violations
2013
2012
17.0% 24.2%
17.7% 17.6%
2.7%
N/A*
13.9%
2.0%
37.4% 34.4%
14.6%
N/A*
2011
29.7%
28.2%
6.2%
11.0%
24.9%
14.7%
27
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.


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

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
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Brake inspections conducted during Brake Safety Week
include inspection of brake-system components to
identify:
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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.
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
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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
During Brake Safety Week

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Operation Airbrake Inspection
Procedure for the Level IV Inspection
Inspection Items

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
Driver License
Registration
Low Air Warning Device
Pushrod Travel (Adjustment)
Brake Linings/Drums
Air Loss Rate (If leak detected)
Tractor Protection System
31
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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 90 - 100 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
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

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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
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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
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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
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

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.
http://www.cvsa.org/members/documents/2012/NAS%20PBBT%20Inspection%20P
rocedure%20Revised%2006-10.pdf
38
CSA Brake Violations

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
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In 2013 25.51% 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
Section
Violation Description
Violation Severity
Points
Counts Against Driver
393.40
Inadequate brake system on a CMV
4
Y
393.41
No or defective parking brake system on
CMV
4
Y
393.42
No brakes as required
4
Y
393.42A-BM
Brake - Missing required brake.
4
Y
393.42A-BMAW
Brake - All wheels not equipped with
brakes as required.
4
Y
4
Y
4
Y
393.42A-BM-TSA Brake - Missing on a trailer steering axle.
393.43
No/improper breakaway or emergency
braking
40
Section
Violation Severity
Points
393.43(a)
No/improper tractor protection valve
4
Y
393.43(d)
No or defective automatic trailer brake
4
Y
393.44
No/defective bus front brake line
protection
4
Y
393.45
Brake tubing and hose adequacy
4
N
393.45PC
Brake Tubing and Hose Adequacy Connections to Power Unit
4
N
393.45UV
Brake Tubing and Hose Adequacy Under
Vehicle
4
N
393.45(a)(4)
Failing to secure brake hose/tubing
against mechanical damage
4
N
41
Violation Severity
Points
Section
393.45(b)(2)
Failing to secure brake hose/tubing against
4
mechanical damage
Y
393.45B2PC
Brake Hose or Tubing Chafing and/or
Kinking - Connection to Power Unit
4
Y
393.45B2UV
Brake Hose or Tubing Chafing and/or
Kinking Under Vehicle
4
N
393.45(b)(3)
Failing to secure brake hose/tubing against
4
high temperatures
N
393.45(d)
Brake connections with leaks/constrictions
4
N
393.45DCPC
Brake Connections with Constrictions Connection to Power Unit
4
Y
393.45DCUV
Brake Connections with Constrictions
Under Vehicle
4
N
42
Violation Severity
Points
Section
393.45DLPC
Brake Connections with Leaks - Connection
4
to Power Unit
Y
393.45DLUV
Brake Connections with Leaks Under
Vehicle
4
Y
393.47
Inadequate/contaminated brake linings
4
Y
393.47(a)
Inadequate brakes for safe stopping
4
Y
393.47(b)
Mismatched brake chambers on same axle
4
Y
393.47(c)
Mismatched slack adjuster effective length
4
Y
393.47(d)
Insufficient brake linings
4
Y
43
Section
Violation Severity
Points
393.47(e)
Clamp/Roto-Chamber type brake(s) out of
adjustment
4
Y
393.47(f)
Wedge type brake(s) out of adjustment
4
Y
393.47(g)
Insufficient drum/rotor thickness
4
Y
393.48(a)
Inoperative/defective brakes
4
Y
393.48A-BCM
Brakes - Hydraulic Brake Caliper movement
exceeds 1/8" (0.125") (3.175 mm)
4
N
393.48A-BMBC
Brakes - Missing or Broken Components
4
N
393.48ABRMMC
Brakes - Rotor (disc) metal-to-metal contact
4
N
44
Violation Severity
Points
Section
393.48ABSRFS
Brakes - Severe rusting of brake rotor (disc) 4
N
393.48(b)(1)
Defective brake limiting device
4
Y
393.50
Inadequate reservoir for air/vacuum brakes
4
N
393.50(a)
Failing to have sufficient air/vacuum
reserve
4
N
393.50(b)
Failing to equip vehicle - prevent reservoir
air/vacuum leak
4
N
393.50(c)
No means to ensure operable check valve
4
N
393.50(d)
No or defective air reservoir drain valve
4
Y
45
Section
Violation Severity
Points
393.51
No or defective brake warning device
4
Y
393.52(a)(1)
Insufficient braking force as percent of
GVW or GCW
4
Y
393.53(a)
Automatic brake adjuster CMV
manufactured on or after 10/20/1993 hydraulic brake
4
Y
393.53(b)
Automatic brake adjuster CMV
manufactured on or after 10/20/1994 - air
brake
4
Y
393.53(c)
Brake adjustment indicator CMV
manufactured on or after 10/20/1994 external automatic adjustment
4
Y
393.55(a)
ABS - all CMVs manufactured on or after
3/1/1999 with hydraulic brakes
4
N
393.55(b)
ABS - malfunction indicators for hydraulic
brake system
4
N
46
Section
Violation Severity
Points
393.55(c)(1)
ABS - all tractors manufactured on or after
3/1/1997 air brake system
4
N
393.55(c)(2)
ABS - all other CMVs manufactured on or
after 3/1/1998 air brake system
4
N
393.55(d)(1)
ABS - malfunctioning circuit/signal - truck
tractor manufactured on or after 3/1/1997,
single-unit CMV manufactured on or after
3/1/1998
4
N
393.55(d)(2)
ABS - malfunctioning indicator to cab of
towing CMV manufactured on or after
3/1/2001
4
N
47
Section
Violation Severity
Points
393.55(d)(3)
No or Defective ABS Malfunction
Indicator for towed vehicles on vehicles
manufactured after February 2001
4
N
393.55(e)
ABS - malfunctioning lamps towed CMV
manufactured on or after 3/1/1998,
manufactured before 3/1/2009
4
Y
393.55(c)(1)
ABS - all tractors manufactured on or
after 3/1/1997 air brake system
4
N
393.55(d)(3)
No or Defective ABS Malfunction
Indicator for towed vehicles on vehicles
manufactured after February 2001
4
N
48
SMS Methodology
(Point System)

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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.

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0-6 Months- (Severity + OOS points) X 3
Over 24 Months- Not counted on CSMS.
49
Example of SMS
Methodology

Inoperative/Defective brake (393.48(a)

(4 Points) (Additional 2 points if determined to be out of
service)
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(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
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
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
The Carrier Sees
Something Like This
53
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
Warning Letters

Advises carriers
 Roadside deficiencies
 Consequences of noncompliance

Sent when carrier exceeds
threshold ≥ 1 BASICs
55
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
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
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
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
8/28/2014
700,200
L STEER R STEER L F DRIVE R F DRIVE L R DRIVE R R DRIVE
1¼
1½
2 in
2 in
1¾
L R TRL
R R TRL
1½
TRAILER
DATE
HUB OD
L F TRL
R F TRL
59
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
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
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

CVSA Brake Safety Week September 7

Transcription

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