Roadside Inspections: How to Prevent and Survive Them

A roadside inspection is a nerve-wracking event for a driver and an event that holds significant consequences for a carrier. Therefore, a carrier and its drivers need to understand roadside inspection procedures and how to get the best possible outcome.

 

How are drivers and vehicles selected for inspections?

There are several reasons a driver and vehicle are selected for a roadside inspection, including:

• Traffic violation: The driver is pulled over for a traffic infraction and then inspected.
• Visible vehicle violation: An officer at a facility or on patrol sees a vehicle defect and stops the driver for an inspection.
• Inspection selection system (ISS) score and recommendation: The ISS is a tool that officers can use when selecting who to inspect. A carrier’s ISS score and recommendation are based on the carrier’s Compliance, Safety, Accountability (CSA) scores. If a carrier has a Behavior Analysis and Safety Improvement Category (BASIC) score over a predetermined threshold, the carrier will not have a “Pass” recommendation and will have an “Optional” or “Inspect” recommendation. Carriers with an “Optional” or “Inspect” recommendation in the ISS will see more roadside inspections.
• Post-crash: Following a serious crash involving a commercial vehicle, many jurisdictions require a roadside inspection. Pre-existing and post-crash violations will be separated on the report.
• Random selection: There is a random component to being selected. However, the situations noted above are more common reasons for an inspection.

 

Tips to reduce your chance of selection

Understanding when and why a roadside inspection occurs is the first step in reducing the chances of an inspection. To help reduce your odds of an inspection:

• Train your drivers on compliant, safe, and defensive driving using a well-established training program, such as J. J. Keller’s Principles of Defensive Driving.
• Train your drivers on vehicle inspections using either a formal in-house program or an outside training resource.
• Verify your drivers are driving compliantly, safely, and defensively (verify, for example, by using dash cameras).
• Verify your drivers are doing their inspections.
• Keep your ISS recommendation at “Pass” by keeping your CSA BASIC scores low. This involves:
  • Avoiding violations during inspections,
  • Reviewing your data and using DataQs to correct any errant data, and
  • Taking steps to reverse upward trends in your CSA data. Using an outside service, such as J. J. Keller & Associates, Inc. can help with this task.

 

The roadside inspection process

Officers use a 37-step process to conduct the inspection. Each step after the first one (select a safe location for the inspection) is designed to verify compliance with specific rules. Here are some examples:

Inspection step(s)	Regulatory citations
Steps 3 and 4: Driver condition and fact gathering	§391.11 (driver qualifications) and §392.3, .4, and .5 (ill or fatigued or under the influence)
Step 7: Carrier identification	§390.19 and §390.21 (carrier registration and vehicle marking)
Step 8: Driver’s license	§382.501 (Clearinghouse status), §383.21, .23, .25, .51, .91, .93, and .95 (valid CDL of the correct class and endorsements), and §391.11 (correct license if a non-CDL driver)
Step 9: Medical qualifications	§391.41 and .43 (medically qualified and has a valid medical card), and §383.71 (for CDL drivers – valid medical information on the MVR)
Step 10: HOS records	§395.8 (correct type of record-of-duty status and is current and not false), §395.20 to .38 (ELD regulations), and §395.3 or §395.5 (within the hours-of-service limits)
Step 12: Proof of periodic (annual) inspection	§396.17 (valid annual inspection)
Step 13: ABS	§393.55 (ABS malfunction lamps)
Step 14: Front of vehicle	§393.9, .11, .19, .22, and .24 (lights), §393.60 (windshield), §393.78 (wipers and washer), §393.81 (horn), §392.2RG (license plate), §393.203 (hood and bumper)
Step 19: Left side of trailer	§393.11, .13 (lights and conspicuity tape), 100 to 136 (cargo securement), .201 (frame/side).
Step 31: Brake adjustment	§393.47 (measurement/verification of free play for all wheels)

 

If the officer will be doing a Level I inspection, the officer will use all 37 steps. If the officer is doing a Level II inspection (driver and vehicle walkaround), the steps related to going under the vehicle will be omitted, resulting in 34 of the 37 steps being used. If the officer does a Level III inspection (driver only), the officer will only use 13 of the 37 steps (Steps 1 to 12 – the driver portion of an inspection, and Step 37 – document the inspection).

Bottom line: The carrier and driver should know the inspection process and the regulations that are being checked and always be prepared for an inspection.

 

Prepare for the inspection

Consider the following measures that a carrier can do to prepare for a roadside inspection:

Have a system in place that verifies the driver is fully qualified (such as J. J. Keller’s Encompass system or Driver Qualification File Management Service). This means having a system in place to track the various expiration dates attached to the driver’s credentials (license, medical card, hazardous materials training, etc.) and acting when one is about to expire.

• Have a method to verify that the driver’s license remains valid (such as an MVR monitoring service).
• Train drivers on the roadside inspection process and their part in it. This can involve classroom training using an outside training program (such as J. J. Keller’s roadside inspection training programs) and/or doing mock inspections. As part of the training, verify the driver:
  • Can present the required driver, vehicle, and carrier credentials;
  • Can transfer the ELD records and present the required ELD-related documents (user guide, transfer instruction and malfunction sheets, and blank logs);
  • Can locate the proof of periodic/annual inspection;
  • Knows how to activate all lights; and
  • Understands the process the officer will use to check brake adjustment.
• Make sure the vehicles are current on all maintenance inspections and preventive maintenance (and verify your maintenance program is adequate by reviewing your roadside inspection violations and repair records).
• Train drivers on conducting pretrip, enroute, and post-trip inspections. Once trained, devise a method to verify that drivers are doing the inspections (observation, tracking unreported defects, etc.).

 

Common violations

The annual list of roadside inspection violations offers insights into common problem areas for carriers. Using the information above, pay special attention to what you can do to avoid these violations.

The top vehicle violations based on 2023 data include:

1.      §393.9: Inoperative required lamp

2.      §392.2RG: State registration or license plate violation

3.      §396.17: Operating a vehicle without proof of periodic/annual inspection

4.      §393.47: Brake out of adjustment

5.      §393.95(a): No, discharged, or unsecure fire extinguisher

6.      §393.9TS: Inoperative turn signal

7.      §393.75(a)(3): Tire flat or audible leak

8.      §393.78: Inoperative or missing wiper

9.      §393.11: No required light or reflective marking

10.  §390.21TB: Carrier name or DOT number not correctly displayed

 

The top driver violations for the same year are:

1.      §392.2C: Failure to obey a traffic control device

2.      §392.2SLLS2: Speeding – 6 to 10 mph over the limit

3.      §395.8(e): False log(s)

4.      §383.23(a)(2): Operating without a valid CDL

5.      §392.16: Failing to use seat belt

6.      §391.41(a)(1)NPH: Medical card not in possession when required

7.      §392.2LV: Lane restriction violation

8.      §392.2MI: Miscellaneous traffic law violation

9.      §395.8: Log form and manner

10.  §395.8(a)ELD: No record of duty status (ELD required)

 

The entire roadside inspection process, from selection and inspection procedures to the regulations, is an officer’s attempt to verify compliance using all that can be learned during the stop.

Since inspections are methodical, there should be no surprises for the carrier or driver. Therefore, carriers and drivers should be able to be prepared and get good outcomes.