Heavy Duty Trucking, March 2020
SAFETY COMPLIANCE for failing to require a driver to prepare a record of duty status using the appropriate method Their crime Drivers were using paper logbooks because their trucks engines were built prior to 2000 The compliance review said the drivers were using paper logs but had no documentation to show engine is manufactured prior to 2000 He had a glider kit but nothing to tie the engine to the paperwork Seidl says FMCSA didnt like that there was just a piece of paper saying it was a glider with a pre 2000 engine They wanted a physical tie to the engine to support the paperwork he said although theres nothing in the law spelling out that requirement That 49 CFR Part 279 Appendix A simply says records of motor and engine changes So Seidl worked with the small fleet to gather documentation for all its trucks with pre 2000 engines such as Printed paperwork from glider kit model year in the trucks VIN number So whether youre driving a 1998 truck with the original engine or you have a 2018 glider kit with a 1998 engine you arent required to use an ELD According to an FMCSA FAQ While the driver is not required to possess documentation that confirms the vehicle engine model year 49 CFR Part 379 Appendix A requires motor carriers to maintain all documentation on motor and engine changes at the principal place of business However just what that documentation should consist of may be subject to interpretation by the particular investigator doing a compliance review says John Seidl who provides DOT transportation consulting to motor carriers as vice president of risk services for insurance provider Reliance Partners One of Seidls clients last year received a conditional safety rating and a 15000 fine manufacturers and engine rebuilders showing the pre 2000 original engine build dates ECM download from the trucks showing the engine serial number and the truck VIN linking that engine build date to the VIN Registration cards showing the corresponding VIN for the truck If youre running a glider youd better not only have paperwork but try to tie that pre 2000 engine to the paperwork you have Seidl advises Get pictures of the engine serial numbers that match the paperwork ECM downloads that match the paperwork If youre running a 1996 truck a registration card will usually do But if the registration card says its a 2015 Freightliner and youre trying to say you have a 99 engine this particular investigator in this state would not accept mere paperwork HDT MARCH 2020 32 WWW TRUCKINGINFO COM C M Y CM MY CY CMY K HDT Safety March 2020 pdf 1 2 3 20 10 56 AM
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