The Federal Motor Carrier Safety Administration has submitted an Information Collection Request to the Office of Management and Budget seeking approval to conduct a study on truck and bus maintenance requirements and their impact on safety.
The FMCSA notice states the goal of the study is to determine what improvements, ranging from better compliance interventions to better vehicle maintenance requirements, would enhance motor carrier safety. A 2014 study by the DOT’s Volpe National Transportation Systems Center on the effectiveness of the FMCSA’s Safety Measurement System in identifying the highest risk motor carriers to be targeted for interventions found that motor carriers targeted for intervention due to “vehicle maintenance” issues (i.e., violations) had a 65 percent higher crash rate compared to the national average. The study objectives are as follows:
- Develop an operational definition of “systematic maintenance” as required in 49 CFR 396.3(a).
- Evaluate whether current regulations and the intervention process could be modified to improve compliance with vehicle maintenance requirements. Examples of such requirements include: (i) Preventative maintenance intervals, (ii) preventative maintenance inspections with adequately trained/equipped mechanics, and (iii) adequacy of motor carriers’ maintenance facilities.
- Gather information to assist in establishing minimum standards for inspection intervals, mechanic qualifications and training and certification of maintenance facilities.
If the study is completed, the results of the analysis might be used to develop new areas of policy guidance and training and potentially new regulatory standards for motor carriers (although the Trump administration is committed to reducing the regulatory burden on companies).
Although the regulations state that every carrier must have a program to “systematically inspect, repair, maintain or cause to be systematically inspected, repaired and maintained, all motor vehicles … subject to its control,” there is no definition or guidance on what constitutes a “systematic” program that meets this requirement. The FMCSA notice states that this lack of specificity regarding standard intervals for preventive maintenance makes it difficult for safety enforcement personnel, and for carriers themselves, to evaluate effectiveness and compliance with a carrier’s maintenance program.
If conducted, the study will be in two phases. First, the agency will recruit study participants using a voluntary, seven-question online survey. For those carriers selected to participate, phase two will involve a 106-question Carrier Maintenance Management Survey about demographics, maintenance practices, intervals, personnel and facilities.
The results of this information collection will be documented in a technical report to be delivered to and published by FMCSA. In addition, the results will be used to create a “recommended best practices” report that will outline minimum standards for inspection intervals, mechanic qualifications and training and certification of maintenance facilities.
Regardless of whether the study is conducted, GAWDA members would be well advised to review their vehicle maintenance and inspection practices. According to a report recently released by Motus, a vehicle management and reimbursement platform, motor vehicle accidents cost employers nearly $57 billion in 2017. These costs include medical expenses for employees and others involved in an accident, insurance increases, leave wage replacement and property damage costs. Ensuring that your company vehicles are properly maintained and serviced is critical in mitigating the risk of an equipment-based accident.
Additional findings in the 2018 Motus Report include:
- U.S. collision insurance claims remain at the highest levels of the past 10 years and have steadily increased over the past five years.
- 53 percent of vehicle crash injuries cause employees to miss work.
- When an employee has an accident that includes damage to both a person and a vehicle, their annual insurance rates typically increase by about 33 percent. Accidents without any injuries increase insurance annual rates by about 23 percent. That means that an accident could increase an employee’s average auto insurance costs by $350 to $515 a year.