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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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CSA - Sample 5 Why's for No/Defective Lighting or Reflective Devices

Violation

A roadside inspection report for a motor carrier showed the following violation: §393.11 - No/defective lighting devices/reflective devices/projected. The motor carrier will want to find out the root cause of this Vehicle Maintenance BASIC violation.

Question 1: Why did this event take place?

Answer: A broken wire kept a light from working.

Question 2: Why was this not discovered prior to operating the commercial motor vehicle?

Answer: The driver did not conduct a pre-trip inspection.

Question 3: Why didn’t the driver conduct a pre-trip inspection?

Answer: He was in the habit of not regularly performing pre- or post-trip inspections. He knows the rules, but he does not always follow them.

Question 4: Why was this allowed to happen?

Answer: No one was monitoring the driver’s daily vehicle inspection reports (DVIRs) or logs that closely.

Question 5: Why was no one monitoring if drivers were completing DVIRs and conducting pre-trip inspections?

Answer: No one was assigned the role or responsibility.

Possible Solutions

What might be some solution(s) based on the safety management cycle and the root cause(s)?

  • Assign the role of reviewing the DVIRs. It does not have to be safety, maintenance, or operations. A clerical personnel might assume the task if need be. Check both the post-trip documentation and the driver’s review during the pre-trip (if a defect was noted).
  • Require log-auditors to look for the flagging of both pre-trip and post-trip inspections on the record of duty status.
  • Draft a policy indicating the consequences if the driver does not complete the DVIR or conduct a pre-trip inspection. Be consistent in enforcement.
  • Train on DVIRs during new hire orientation, safety meetings, and refresher training.
  • Review applicants’ roadside inspection histories in the Vehicle Maintenance BASIC while working for other USDOT numbers. Use the Federal Motor Carrier Safety Administration’s (FMCSA’s) Pre-employment Screening Program (PSP) driver reports. Develop hiring standards in your company policies based on these reports.