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A REFERENCE GUIDE
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Will Your Systematic
Maintenance Program Get a
Passing Mark?
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MON DAY 2 1 S E PTEMBE R 2 0 1 5
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Participants
Special Agent, FMCSA
Darrell Ruban
Field Administrator, FMCSA
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Tony Bennett
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Clinton Seymour GA Division Administrator, FMCSA
Principal
Transportation Compliance
and Safety Group
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Paul Tamburelli
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Presentation Objectives
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• To explain industry responsibilities under the new
intermodal equipment provider (IEP) rule.
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• To facilitate compliance and improve vehicle safety
through better understanding of these requirements.
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• To explain how FMCSA will investigate and enforce
the IEP rule.
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IEPs Must Establish an IRM Program
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Required Inspection, Repair, and Maintenance (IRM)
program elements –
• Performing regular IME inspections
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• Repairing the problems you find
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• Maintaining IME between inspections
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• Creating a recordkeeping system for the program
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Preventative maintenance is
key to safety!
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FMCSA Roadability Reviews
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In a roadability review, FMCSA investigators will –
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• Review the IEP’s compliance with 49 CFR parts 390,
393, and 396
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There will be no safety rating issued
as a result of a roadability review.
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Systematic Maintenance Program
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Required Inspection, Repair, and Maintenance (IRM)
program elements –
• Policies and Procedures
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• Roles and Responsibilities
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• Qualification and Hiring
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• Training and Communication
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• Monitoring and Tracking
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• Meaningful Action
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Develop a system of preventive maintenance for compliant, safe,
and efficient fleet operations, including a schedule for periodic
maintenance, inspection, and recordkeeping.
Develop a procedure ensuring that vehicle defects that impact
safety and/or safety compliance are reported, repaired, and
certified before the vehicle is operated.
Develop procedures to ensure that management is notified of
vehicle defects through the use of Driver Vehicle Inspection
Records (DVIRS) and other communication channels.
Develop a policy ensuring that mechanics are qualified to
complete annual inspections according to the requirements of
396 and appendix G.
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Element: Policies and Procedures
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Systematic Maintenance Program
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Define and document responsibilities of managers, supervisors,
mechanics, and technicians as related to vehicle inspection,
repair, and maintenance policies, including the monitoring and
documentation of defects and repairs.
Define and document roles and responsibilities of mechanics and
technicians for differentiating between safety-related defects and
other defects and for taking unsafe vehicles out-of-service (OOS).
Define and document roles and responsibilities for checking daily
completion of DVIR’s and certifying repair before the next
assignment.
Define and document dispatch responsibilities for planning,
scheduling, monitoring, and adjusting fleet operations in
accordance with repair and maintenance requirements.
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Element: Roles and Responsibilities
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Systematic Maintenance Program
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Ensure that prospective employees are qualified to inspect, repair,
and maintain the chassis by querying applicants, checking with
previous employers and references, and obtaining necessary
documents regarding inspection, and maintenance responsibilities
and (for mechanics and technicians) the quality of previous work,
including whether maintenance services were systematic and well
documented. Create a detailed written record of each inquiry.
Verify prospective brake inspectors’ understanding of job
requirements and their applicable training and apprenticeship
credentials.
Ensure that the employment application captures all information
required by Federal Motor Carrier Safety Regulations for mechanics
and technicians, with regard to certification of the ability to perform
repairs.
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Element: Qualification and Hiring
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Systematic Maintenance Program
Systematic Maintenance Program
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Convey expectations to all applicable staff for adhering to vehicle
inspection, repairing, and maintenance regulations and company
policies and procedures, and for executing responsibilities by
providing new hire and refresher training, and establish
communication channels such as meetings focused on conflicts
between vehicle availability and repair requirements
Verify prospective brake inspectors’ understanding of job
requirements and their applicable training and apprenticeship
credentials.
Ensure that all managers, mechanics, and technicians receive training,
including methods and tools, and appropriate certifications to fulfill
their responsibilities and documentation requirements regarding
vehicle inspection, repair, and maintenance, as required by
regulations and company policies.
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Element: Training and Communication
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Check all inspections and relevant records, such as DVIRs, pre-trip and annual
inspections, and maintenance and repair records, to ensure that company
inspection, repairing, and maintenance policies and procedures are adhered
to and properly documented.
Monitor and track roadside inspection results to ensure that vehicle defects
are repaired and documented promptly and to prevent OOS vehicles from
operating prior to being repaired.
Maintain inspection, repair, maintenance, vehicle identification, and
communication records to help evaluate the performance of all staff
(mechanics and managers) involved in fleet maintenance and the
effectiveness of compliance with vehicle maintenance policies, procedures,
and regulations.
When monitoring and tracking vehicle maintenance issues, always assess
whether an issue is individual or represents a systemic breakdown in one of
the SMPs (Policies and Procedures, Roles and Responsibilities, etc.).
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Element: Monitoring and Tracking
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Systematic Maintenance Program
Systematic Maintenance Program
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Element: Meaningful Action
Design and implement incentives and/or recognition programs
in order to reward and encourage effective performance related
to compliance with vehicle inspection, repair, and maintenance
regulations and company policies.
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Give employees immediate feedback, and require corrective
action as soon as the company is aware that vehicle inspection,
repair, and maintenance responsibilities are not being fulfilled.
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Provide remedial training to employees with performance issues
related to vehicle inspection, repair, and maintenance that can
be addressed by enhancing their knowledge and skills.
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FMCSA Information Line
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1-800-832-5660
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General questions, registration using Form MCS-150C, USDOT
Numbers, and the status of USDOT Numbers.
FMCSA Data Qs System
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https://dataqs.fmcsa.dot.gov
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Questions or concerns about safety records.
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DOT Safety Violation Hotline
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1-888-DOT-SAFT
http://nccdb.fmcsa.dot.gov
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Report safety violations.
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Questions
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Tony Bennett
Special Agent GA Division
678-284-5157
[email protected]
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