Both shippers and carriers of hazardous materials (hazmat) in transportation send the vehicles and drivers off, confident in the arrival of the hazmat to its final destination without incident. However, your driver may be pulled over by a roadside inspector who may uncover any number of hazmat violations. What are these roadside inspectors looking for, and what are they finding?
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Today we will look at how roadside inspectors conduct their inspections and what they are looking for. Tomorrow we will review the hazmat violations they have found so far this year.
Roadside inspections are examinations of commercial motor vehicles and/or drivers by Motor Carrier Safety Assistance Program (MCSAP) inspectors. MCSAP inspectors conduct roadside inspections on commercial motor vehicles and drivers to check that they are in compliance with the Federal Motor Carrier Safety Regulations (FMCSRs) and Hazardous Materials Regulations (HMRs). If an inspection results in serious violations, the driver will be issued a driver or vehicle out-of-service (OOS) order. These violations must be corrected before the driver or vehicle can return to service. OOS orders can be costly for both shippers and carriers. So far in fiscal year 2017, almost 4% of hazmat inspections resulted in an OOS order.
Note: Traffic enforcement violations may also be recorded in conjunction with a roadside inspection.
What Can Your Driver Expect? 6 Levels of Inspections
All drivers who transport hazardous materials should know what to expect when they are pulled over for an inspection. They should be familiar with the procedures for the six levels of roadside inspections.
Level 1—Full. A full inspection includes an examination of both the driver’s qualification and status and an inspection of the vehicle.
For the driver, the inspection includes:
- Examination of driver’s license;
- Medical examiner’s certificate and Skill Performance Evaluation (SPE) Certificate (if applicable);
- Seat belt use;
- Evidence of alcohol and/or drug use;
- Vehicle inspection reports; and
- Record of duty status for the past 7 days;
- Driver’s record of hours of service (as of December 18, 2017, most commercial motor carriers will be required to install and have drivers use electronic logging devices).
The vehicle inspection includes:
- Brake systems;
- Coupling devices;
- Exhaust systems;
- Frames;
- Fuel systems;
- Lighting devices (headlamps, tail lamps, stop lamps, turn signals, and lamps/flags on projecting loads);
- Securement of cargo (top the list of hazmat violations the last few years);
- Steering mechanisms;
- Suspensions;
- Tires;
- Van and open-top trailer bodies;
- Wheels, rims, and hubs;
- Windshield wipers;
- Emergency exits and/or electrical cables and systems in engine and battery compartments (buses); and
- Hazardous materials/dangerous goods (HM/DG) requirements (inspected by certified HM/DG inspectors), as applicable.
Level 2—Walk-around. At a minimum, the Level 2 inspection includes all the driver and vehicle elements of the Level 1 inspection. As a rule, the walk-around inspection includes only those items that can be inspected without physically getting under the vehicle.
Level 3—Driver only. Level 3 inspections are for the driver, not the vehicle. At a minimum, the inspection must include, where applicable:
- Examination of driver’s license;
- Medical examiner’s certificate and Skill Performance Evaluation (SPE) Certificate (if applicable);
- Seat belt use;
- Evidence of alcohol and/or drug use;
- Vehicle inspection reports;
- Record of duty status for the past 7 days;
- Driver’s record of hours of service (as of December 18, 2017, most commercial motor carriers will be required to install and have drivers use electronic logging devices); and
- HM/DG requirements.
Level 4—Special study. Level 4 inspections typically include a one-time examination of a particular item. These inspections are usually made in support of a study or to verify or refute a suspected trend. For instance, since unsecured packages are consistently at the top of the hazmat violations list, if you are carrying hazardous materials, you can likely expect at least a Level 4 inspection for that.
Level 5—Terminal. A Level 5 inspection includes all of the vehicle inspection items in a Level 1 inspection. The Level 5 inspection is conducted without the driver present and can be conducted at any location.
Level 6—Radioactive material. A Level 6 inspection is a higher or stricter inspection standard than the regular Level 1 inspection. It is intended for use only on select shipments of radioactive material. One example of the stricter standard is that under the Level 1 full inspection, if 20% or more of the brakes on the vehicle or combination are out of adjustment, the vehicle is placed out-of-service. Under a Level 6 inspection, if any brakes are out of adjustment, the vehicle is placed out-of-service.
What are hazmat roadside inspectors finding? Check tomorrow’s Advisor for the top 10 hazmat violations uncovered so far this year.