Regulation 49 CFR §396.3(a) has been a long-standing problem for some in industry and enforcement – it states that carriers must have a program to “systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles and intermodal equipment subject to its control.” However, it is subjective and there is no supporting definition of the word systematic, making it challenging for government personnel to assess compliance and can make it difficult for carriers to comply with the regulation’s intent.
A solution may finally be on the horizon.
FMCSA recently issued an Information Collection Request relating to Truck and Bus Maintenance Requirements and Their Impact on Safety. The notice outlines research the Agency is undertaking to develop an operational definition of “systematic maintenance” for trucks and buses, to examine maintenance differences between vehicle classes, and to identify typical industry maintenance practices. The research objectives are to:
- Develop an operational definition of systematic maintenance;
- Evaluate whether current regulations and the intervention process could be modified to improve compliance with vehicle maintenance requirements; and
- Gather information to assist in establishing minimum standards for inspection intervals, mechanic qualifications and training, and certification of maintenance facilities.
The output of the study will be a Recommended Practices Report that will outline minimum standards for inspection intervals, mechanic qualifications and training, and certification of maintenance facilities. We are hopeful that the results of this study can shed light on this long-standing problem and provide useful education and guidance to the industry.
This effort is being undertaken, in part, due to a previous study to assess the effectiveness of the Safety Measurement System in identifying the highest-risk motor carriers, which found that motor carriers targeted for intervention due to vehicle maintenance issues had a 65 percent higher crash rate compared to the national average.
In STC’s experience, many carriers unfortunately do not spend much time effectively managing their maintenance programs. Many believe conducting annual periodic inspections and making repairs when equipment breaks down constitutes a “systematic” program. These types of carrier programs are often accompanied by a lack of organization and documentation in their maintenance files and often include poorly executed DVIR programs. This is not preventive or systematic. These practices make it difficult for a carrier to have an effective systematic maintenance program, and it usually results in adding costs, complexity, frustration, and safety issues, including poor roadside inspection performance and breakdowns. Poor maintenance programs result in poor outcomes.
Having an organized, routinized, interval-based, accountable, data-driven maintenance program allows more proactive engagement with your suppliers, proper spec-ing of your trucks, and having proper replacement parts available for repairs; all key aspects of a successful systematic maintenance program. Lastly, it ultimately is about your people and others who interact with your equipment —not just the mechanics — making sure they are adequately trained and equipped to do the job and that they understand the condition of the equipment is vital to the company’s success.
STC is hopeful that this new research avenue and FMCSA’s interest in better defining systematic maintenance programs will provide important guidance to trucking on what should be expected in an effective program. This also will be particularly important for new entrants and less sophisticated carriers as they seek to define the basic elements of their programs.