Inspection & Maintenance: Property-Carrying-Specific FAQs

The Federal Motor Carrier Safety Administration (FMCSA) published a final rule revising the requirement for operators of property-carrying vehicles to complete a driver’s daily vehicle inspection report (DVIR). The rule has created some confusion and questions.

Are pretrip and post-trip inspections required?

The FMCSA emphasized in the final rule that “Drivers will still be required to perform pre-trip evaluations of equipment condition.” When addressing previous drivers not leaving a DVIR, the FMCSA responded “it certainly does not indicate that the driver may skip a post-trip inspection that would form the basis for a driver-vehicle inspection report required under §396.11(a).”

How are pretrip and post-trip inspections to be logged?

According to §395.2, “All time inspecting, servicing, or conditioning any commercial motor vehicle at any time” is considered on-duty and logged as such. If a DVIR is completed, the time used to complete the form is also considered on-duty.”

How does this rule affect passenger carriers?

Passenger carriers are unaffected. Daily vehicle inspection reports (DVIRs) are required when equipment problems or safety concerns are identified and when there are none to report.

Does a United States driver still need to document daily inspections in Canada?

This question was addressed by the FMCSA within the final rule: “Motor carriers operating in Canada will need to comply with Canadian national, Provincial and Territorial requirements that require the previous post-trip DVIR. Drivers will need to prepare and to carry a copy of their previous day’s post-trip DVIR, regardless of whether there are defects to report.

What about electronic versions of DVIRs or eDVIRs?

The FMCSA’s policy has been to encourage carriers to use electronic means for information collection and retention since the 1990s. One of the first reasons to do so involved the handling of DVIRs.

Since there is no requirement to complete no-defect DVIRs for property carriers, is there any case to be made for carriers to require daily vehicle condition reports from drivers?

Many motor carriers are continuing to require drivers to complete the DVIR for all post-trip inspections as a best practice and safety management control, in order to minimize the risk of operating unsafe vehicles and to protect their Vehicle Maintenance BASIC score.