On Aug. 1, 2013, the Federal Motor Carrier Safety Administration (FMCSA) proposed eliminating the requirement that pre- and post-trip driver vehicle inspection reports (DVIRs) be filed with the FMCSA when no defects are identified.
Current regulations require that DOT-regulated fleets turn in pre- and post-trip inspection reports on their trucks whether or not the truck has defects. Fleet managers have long contended that such a mandate is meaningless, time-consuming, and expensive. Under the proposed rule, fleets will only have to file a DVIR for inspections in which they find an issue with a truck. The FMCSA proposal is designed to reduce the paperwork burden on the industry, thereby saving money, while continuing to preserve the government’s safety enforcement powers. The FMSCA estimates that 95 percent of DVIRs note no defects. However, the FMCSA stressed this proposed regulatory relief doesn’t preclude drivers from the requirement to perform pre- and post-trip inspections.
Widespread Industry Support
The American Trucking Associations (ATA) applauded the move by the FMSCA to provide this modest relief against a broader and longstanding paperwork burden with which truck fleets must comply. The ATA hopes this proposal signals a willingness by the FMCSA to act on other substantive issues, such as Compliance, Safety & Accountability (CSA) reforms concerning crash accountability and changes to the hours-of-service rules.
The FMCSA estimated the truck fleet industry could save $1.7 billion per year in paperwork costs without affecting safety as a result of this proposal. While the savings from each report is modest, when you consider the proposal eliminates the need for millions of reports, it will have a large cost impact.
The FMCSA has parsed the DVIR process into two steps. The first step, filling out a DVIR, is estimated to take 2 minutes, 30 seconds. The second step, reviewing and signing a DVIR is estimated to take 20 seconds when defects are reported and 5 seconds when no defects are reported. When there are no defects to note, there is nothing to review on the DVIR and the form requires only a signature. The FMCSA also will propose rulemaking to allow fleets to use e-signatures to expedite electronic recordkeeping.
Not Everyone Agrees
Proponents say that moving to a defect-only reporting system will reduce a significant paperwork burden facing regulated truck fleets and save the industry billions of dollars without compromising safety. However, others are not convinced.
“If this proposal goes into effect, how do you differentiate between an inspection that was never done and one that has no defects? I think this seriously dilutes the strength of these required inspections,” said Chris Burgeson, CAFM, fleet manager for the City of Napa, Calif. “Plus, keeping a copy of a no-defect inspection defeats the purpose of this proposed ruling to reduce paperwork. The real answer will probably come in the form of an electronic driver vehicle inspection report(eDVIR). I have already begun implementing electronic DVIRs on my regulated equipment, which makes this a non-issue. Copies of all inspections are maintained and no paperwork is generated.”
An eDVIR is used for pre- and post-trip vehicle inspections to ensure equipment safety and CSA compliance scores. An eDVIR is designed to comply with all DOT-mandated pre- and post-trip vehicle inspection regulations. The advantage of an eDVIR is that it simplifies pre- and post-trip inspections while reducing inaccuracies and the administrative overhead associated with paper logs. Typically, electronic inspection reports are sent directly to each vehicle where a driver receives an in-cab, verbal reminder to complete a safety inspection before and after each trip. Upon completion of the report, the data is electronically sent via cellular communication to a Web-based fleet management system.
Law of Unintended Consequences
Some fleet managers feel strongly that the FMCSA’s proposal to reduce paperwork is a misguided solution, especially from an operational perspective. They view DVIRs as a critical linkage between the drivers and their equipment, and the fleet maintenance division. Weakening this connection will increase on-the-road breakdowns, which, in turn, will subsequently increase costs.
Other industry observers voiced concern about the unintended safety consequences of this proposal. By eliminating the submission of no-defect inspection reports to the FMCSA, you eliminate one level of oversight ensuring pre- and post-trip inspections have been done. While the overwhelming majority of fleets will conduct the required pre- and post-inspection trips on their trucks, what about scofflaws or companies with lax enforcement policies? Yes, these infractions ultimately will be caught, but what good is it to discover after-the-fact that a pre- and post-inspection was not performed, especially if it resulted in a tragedy?
Let me know what you think.
By Mike Antich