Roadcheck is an annual program conducted by the Commercial Vehicle Safety Alliance (CVSA), best described as a 3-day blitz held across the United States, Canada, and Mexico, taking place this year between May 4 – 6. It brings together roughly 13,000 inspectors across North America to focus on commercial vehicle inspections. The primary emphasis of this year’s Roadcheck is lighting on the vehicle side, and Hours of Service on the driver side, highlighted this year due to the fact that they topped the violation list during last year’s event.
Vehicle Focus
Drivers must remain inspection-ready on every trip. It’s the same mindset the office staff need every day– always audit ready, never knowing when something could happen to bring an investigator in. So what are some ways drivers can better prepare?
Here’s an example of a pre-trip process to refresh your drivers’ minds, and maybe help them examine their current routines. While lights are not specifically listed here, a proper inspection should include the light check as they circle around the truck and/or trailer. Remember– it doesn’t matter if it’s a pre-trip, en-route, or post-trip inspection. The driver should have one inspection routine and always follow it.
Inspectors continue their vehicle inspection on lighting, which accounted for 12% of all vehicle violations in 2020. Violations were deemed out-of-service (OOS) at a 7.66% rate. It makes sense that Hours of Service is also being emphasized this year, considering that this is the most cited vehicle violation of thus far, currently exceeding 150,000 violations just one quarter in!
Two more violations also land in the 2020 Calendar Year Roadside Inspection Vehicle Violations Top 10
Red is displayed only at the back.
Blue lights are reserved for law enforcement and are not legal on a CMV.
It used to be, in Iowa for example, that you would be violated for any light out. This has now changed. Procedures are now that you would only be cited for mandatory lights that are inoperable.
LEDs (light–emitting diodes) are longer lasting, brighter, smaller, and more efficient. However, they do not get hot like the incandescent lights, so in snowy weather, drivers have to remember to clean the lights off from snow build since it is no longer “automatic” from the light heat.
Diodes make up the lights in an odd number. The regulation requires that half plus one needs to work. Therefore, if you have a 9-diode light, 5 need to be operable.
Regulations on required lamps and reflectors can also be found in 393.11 at eCFR – Part 393.
Be sure to utilize the reference table that breaks down the allowable colors for the various lamps. White, amber, and red colors and locations are clarified along with location, positioning, and vehicle types.
Driver Focus
The driver emphasis this year is hours of service. As stated above, the topic was selected due to high violation activity. The 2020 Calendar Year Roadside Inspection Driver Violations Top 10 also include three violations here with 12% of the violations and accounting for many Out-of-Service’s.
False logs have always been a problem, and ELDs haven’t solved that… just improved and changed it. A big contributing factor to the false log violation is improper personal conveyance (PC) use. Remember that, in order to allocate time as personal conveyance, it really needs to be personal. Any activity in furtherance of business cannot legally be logged as personal conveyance. FMCSA has released a helpful section on its website that further breaks down this regulation. Be sure to reference this material as a refresher for your drivers, or to glean information for your driver orientation program.
Other false log violations during audits come in from controlled substance and alcohol violations not getting logged as on-duty time. Log audits, roadside or office, also see fueling and roadside inspections causing false log violations. Drivers need to properly allot the time they spent on various functions. Plus, remember anything an owner-operator does in the furtherance of business is on-duty time of one sort or another.
Let’s refresh what the on-duty definition is. § 395.2 Hours of Service Definitions
On-duty time encompasses all time from when a driver begins to work or is required to be in readiness to work, until the time the driver is relieved from work, as well as all responsibility for performing work. On-duty time shall include:
All time at a plant, terminal, facility, or other property of a motor carrier or shipper, or on any public property, waiting to be dispatched, unless the driver has been relieved from duty by the motor carrier;
All time inspecting, servicing, or conditioning any commercial motor vehicle at any time;
All driving time as defined in the term driving time;
All time in or on a commercial motor vehicle, other than: time spent resting in or on a parked vehicle, except as otherwise provided in §397.5 of this subchapter; Time spent resting in a sleeper berth; or up to 3 hours riding in the passenger seat of a property-carrying vehicle moving on the highway immediately before or after a period of at least 7 consecutive hours in the sleeper berth;
All time loading or unloading a commercial motor vehicle, supervising, or assisting in the loading or unloading, attending a commercial motor vehicle being loaded or unloaded, remaining in readiness to operate the commercial motor vehicle, or in giving or receiving receipts for shipments loaded or unloaded;
All time repairing, obtaining assistance, or remaining in attendance upon a disabled commercial motor vehicle;
All time spent providing a breath sample or urine specimen, including travel time to and from the collection site, to comply with the random, reasonable suspicion, post-crash, or follow-up testing required by part 382 of this subchapter when directed by a motor carrier;
Performing any other work in the capacity, employ, or service of, a motor carrier; and
Performing any compensated work for a person who is not a motor carrier.
Remember that the September 29, 2020 HOS revision didn’t change the hours rules. The 11, 14, 60/70, 30-minute break, and passenger driver rules remain as is. It merely revised four guidelines on how the particulars are evaluated. This includes:
The 30-minute break after 8 hours of driving is to be satisfied with a driver using a 30-minute on-duty break rather than the previous 30-minute off-duty period.
The sleeper berth exemption offered additional flexibility in allowing a 7/3 split along with the 8/2 split.
The Adverse Driving exception was modified by extending two hours to the maximum window during which driving is permitted.
The short–haul exemption matched for the CDL driver and the non-CDL driver short-haul rule allowing the driver to lengthen the maximum on–duty period from 12 to hours and extend the distance to 150 air miles.
Work with your drivers now. Evaluate your Hours-of-Service activity on your monthly violation statuses from your log reviews. Review your CSA HOS activity to see the kind of activity you have out there. Follow up with backup drivers that were previously coached post-violations – either roadside or in-house during your log audit reviews. Consider implementing some inspection days before Roadcheck 2021 starts on May 4th, and get the trucks in, without notice, to see what the equipment looks like as it rolls back in.
Can you and your staff find some time to do spot checks out on the road in the next couple of weeks to see how the equipment is looking en route? However, if you decide to prep for the event, make it as beneficial to your fleet and drivers as possible so you come back with clean inspections and limited infractions noted.
Stay safe out there, and happy trails!