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Originally Posted by polonus
That is exactly why I ask. Just to be safe, I always marked 15 min after each 8, or later 10 hrs break. It was different, when I drove 5 on 5 off, but now it is no option. However I recently heard what jiptwoo said, so I?m checking with smarter then I. But I am getting confusing answers. So what is it? Any straight answers? Thx.
Okay - I'm gonna spell this out for you, and make it real simple - disregard anyone who says that they MUST be right because they never got cited in a DOT inspection.
There are several FMCSA rules that govern pre trip and post trip inspections. Here they are, with links to their location:
PRE TRIP INSPECTIONS:
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?396.13 Driver inspection.
Before driving a motor vehicle, the driver shall:
(a) Be satisfied that the motor vehicle is in safe operating condition;
(b) Review the last driver vehicle inspection report; and
(c) Sign the report, only if defects or deficiencies were noted by the driver who prepared the report, to acknowledge that the driver has reviewed it and that there is a certification that the required repairs have been performed. The signature requirement does not apply to listed defects on a towed unit which is no longer part of the vehicle combination.
This regulation says that you must perform an inspection of the vehicle BEFORE driving it, and review the prior post trip inspection from the day before.
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?383.113 Required skills.
(c)(1) Pre-trip inspection skills. Applicants shall demonstrate the skills necessary to conduct a pre-trip inspection which includes the ability to:
(c)(1)(i) Locate and verbally identify air brake operating controls and monitoring devices;
(c)(1)(ii) Determine the motor vehicle's brake system condition for proper adjustments and that air system connections between motor vehicles have been properly made and secured;
(c)(1)(iii) Inspect the low pressure warning device(s) to ensure that they will activate in emergency situations;
(c)(1)(iv) Ascertain, with the engine running, that the system maintains an adequate supply of compressed air;
(c)(1)(v) Determine that required minimum air pressure build up time is within acceptable limits and that required alarms and emergency devices automatically deactivate at the proper pressure level; and
(c)(1)(vi) Operationally check the brake system for proper performance.
This regulation specifically states what items must be inspected during a pre trip inspection, and that the driver must be qualified to perform such an inspection.
POST TRIP INSPECTIONS:
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?396.11 Driver vehicle inspection report(s).
(a) Report required. Every motor carrier shall require its drivers to report, and every driver shall prepare a report in writing at the completion of each day's work on each vehicle operated and the report shall cover at least the following parts and accessories:
Service brakes including trailer brake connections
Parking (hand) brake
Steering mechanism
Lighting devices and reflectors
Tires
Horn
Windshield wipers
Rear vision mirrors
Coupling devices
Wheels and rims
Emergency equipment
This regulation states that at the END of the day, you must complete the daily vehicle inspection report, and certify that all the items listed are in proper running order, and if they aren't, it must be noted and repaired, with all repairs noted and signed off on BEFORE the vehicle is driven again.
DEFINITON OF ON DUTY TIME:
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?395.2 Definitions.
As used in this part, the following words and terms are construed to mean:
On duty time means all time from the time a driver begins to work or is required to be in readiness to work until the time the driver is relieved from work and all responsibility for performing work. On duty time shall include:
(1) 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;
(2) All time inspecting, servicing, or conditioning any commercial motor vehicle at any time;
This means that all time spent performing inspections is considered ON DUTY TIME, and must be logged as such.
Here is some clarification taken from the
interpretations:
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Question 11: Must nontransportation-related work for a motor carrier be recorded as on-duty time?
Guidance: Yes. All work for a motor carrier, whether compensated or not, must be recorded as on-duty time. The term "work" as used in the definition of "on-duty time" in ?395.2 of the FMCSRs is not limited to driving or other nontransportation-related employment.
As far as the rules for flagging increments less than 15 minutes, here they are:
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Question 1: How should a change of duty status for a short period of time be shown on the driver's record of duty status?
Guidance: Short periods of time (less than 15 minutes) may be identified by drawing a line from the appropriate on-duty (not driving) or driving line to the remarks section and entering the amount of time, such as "6 minutes," and the geographic location of the duty status change.
As you can see, FMCSA requires that an inspection be done before driving, an inspection be done after driving (at which time you fill out the daily vehicle inspection report), and that any time spent inspecting is considered ON DUTY time.
Plain and simple, log a pre trip, and do the pre trip at the beginning of the day. Log a post trip, and do the post trip at the end of the day.
If you are speedy gonzalez, and you can manage to inspect all those items in less than 15 minutes, then you can flag the pre trip or post trip, and not drop down to "On Duty, Not Driving".
But I challenge anyone to inspect all those items listed on the pre trip in less than 15 minutes, and I challenge anyone to inspect all the items listed on your "Daily Vehicle Inspection Report" in less than 15 minutes.