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Will Your Systematic

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Maintenance Program Get a

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Passing Mark?

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N
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A REFERENCE GUIDE
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MON DAY 2 1 S E PTEMBE R 2 0 1 5

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Participants

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Tony Bennett Special Agent, FMCSA

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Darrell Ruban Field Administrator, FMCSA

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Clinton Seymour GA Division Administrator, FMCSA

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N
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Paul Tamburelli Principal
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Transportation Compliance
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and Safety Group

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T
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N

2
Presentation Objectives

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To explain industry responsibilities under the new

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O
intermodal equipment provider (IEP) rule.

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EP
To facilitate compliance and improve vehicle safety

R
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O
through better understanding of these requirements.

N
O
To explain how FMCSA will investigate and enforce
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the IEP rule.
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FO
T
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N

3
IEPs Must Establish an IRM Program

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C
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Required Inspection, Repair, and Maintenance (IRM)

D
O
program elements

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EP
Performing regular IME inspections

R
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O
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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D

Preventative maintenance is
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key to safety!
T
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N

4
FMCSA Roadability Reviews

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C
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In a roadability review, FMCSA investigators will

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EP
Review the IEPs compliance with 49 CFR parts 390,

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393, and 396

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N
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There will be no safety rating issued
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as a result of a roadability review.

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N

5
Systematic Maintenance Program

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C
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Required Inspection, Repair, and Maintenance (IRM)

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O
program elements

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Policies and Procedures

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O
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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N

6
Systematic Maintenance Program
Element: Policies and Procedures

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C
Develop a system of preventive maintenance for compliant, safe,

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and efficient fleet operations, including a schedule for periodic

O
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maintenance, inspection, and recordkeeping.

EP
Develop a procedure ensuring that vehicle defects that impact

R
R
safety and/or safety compliance are reported, repaired, and

O
certified before the vehicle is operated.

N
O
Develop procedures to ensure that management is notified of
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vehicle defects through the use of Driver Vehicle Inspection
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Records (DVIRS) and other communication channels.
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Develop a policy ensuring that mechanics are qualified to

D

complete annual inspections according to the requirements of

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396 and appendix G.

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N

7
Systematic Maintenance Program
Element: Roles and Responsibilities

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Define and document responsibilities of managers, supervisors,

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mechanics, and technicians as related to vehicle inspection,

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repair, and maintenance policies, including the monitoring and

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documentation of defects and repairs.

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Define and document roles and responsibilities of mechanics and

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technicians for differentiating between safety-related defects and

N
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other defects and for taking unsafe vehicles out-of-service (OOS).
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Define and document roles and responsibilities for checking daily
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completion of DVIRs and certifying repair before the next
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assignment.
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Define and document dispatch responsibilities for planning,

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scheduling, monitoring, and adjusting fleet operations in

accordance with repair and maintenance requirements.
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N

8
Systematic Maintenance Program
Element: Qualification and Hiring

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Ensure that prospective employees are qualified to inspect, repair,

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and maintain the chassis by querying applicants, checking with

O
previous employers and references, and obtaining necessary

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EP
documents regarding inspection, and maintenance responsibilities
and (for mechanics and technicians) the quality of previous work,

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including whether maintenance services were systematic and well

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documented. Create a detailed written record of each inquiry.

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Verify prospective brake inspectors understanding of job

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requirements and their applicable training and apprenticeship
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credentials.
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Ensure that the employment application captures all information

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required by Federal Motor Carrier Safety Regulations for mechanics

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and technicians, with regard to certification of the ability to perform

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repairs.
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N

9
Systematic Maintenance Program
Element: Training and Communication

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Convey expectations to all applicable staff for adhering to vehicle

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inspection, repairing, and maintenance regulations and company

O
policies and procedures, and for executing responsibilities by

R
EP
providing new hire and refresher training, and establish
communication channels such as meetings focused on conflicts

R
R
between vehicle availability and repair requirements

O
Verify prospective brake inspectors understanding of job

N
O
requirements and their applicable training and apprenticeship

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credentials. U

IB
Ensure that all managers, mechanics, and technicians receive training,
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including methods and tools, and appropriate certifications to fulfill

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their responsibilities and documentation requirements regarding

D

vehicle inspection, repair, and maintenance, as required by

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regulations and company policies.

FO
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N

10
Systematic Maintenance Program
Element: Monitoring and Tracking

N
O
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Check all inspections and relevant records, such as DVIRs, pre-trip and annual

U
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inspections, and maintenance and repair records, to ensure that company

O
inspection, repairing, and maintenance policies and procedures are adhered

R
EP
to and properly documented.

R
Monitor and track roadside inspection results to ensure that vehicle defects

R
are repaired and documented promptly and to prevent OOS vehicles from

O
operating prior to being repaired.

N
O
Maintain inspection, repair, maintenance, vehicle identification, and
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communication records to help evaluate the performance of all staff
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IB
(mechanics and managers) involved in fleet maintenance and the
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effectiveness of compliance with vehicle maintenance policies, procedures,

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and regulations.
D

When monitoring and tracking vehicle maintenance issues, always assess

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whether an issue is individual or represents a systemic breakdown in one of

FO

the SMPs (Policies and Procedures, Roles and Responsibilities, etc.).

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N

11
Systematic Maintenance Program
Element: Meaningful Action

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O
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Design and implement incentives and/or recognition programs

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in order to reward and encourage effective performance related

O
R
to compliance with vehicle inspection, repair, and maintenance

EP
regulations and company policies.

R
R

O
Give employees immediate feedback, and require corrective

N
action as soon as the company is aware that vehicle inspection,

O
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repair, and maintenance responsibilities are not being fulfilled.
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Provide remedial training to employees with performance issues
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related to vehicle inspection, repair, and maintenance that can

IS
D

be addressed by enhancing their knowledge and skills.

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T
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N

12
 FMCSA Information Line

N
1-800-832-5660

O
General questions, registration using Form MCS-150C, USDOT

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Numbers, and the status of USDOT Numbers.

C
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FMCSA Data Qs System

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https://dataqs.fmcsa.dot.gov

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Questions or concerns about safety records.

O
N
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DOT Safety Violation Hotline
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1-888-DOT-SAFT
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http://nccdb.fmcsa.dot.gov
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Report safety violations.

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N

13
Questions

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Tony Bennett

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Special Agent GA Division

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678-284-5157

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tony.bennett@dot.gov
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