Did you know that nearly 12,000 trucks each month are cited for running without an annual DOT inspection?
To make sure vehicles are safe to operate, the FMCSA requires an annual inspection for every commercial vehicle, including each segment of a combination vehicle, that must be performed by a qualified mechanic, according to 396.17c.
If your truck and trailer pass a Level 1 inspection or a Level 5 DOT inspection by a federal officer, or a qualified periodic state inspection, you can count that as your annual DOT inspection.
Otherwise, motor carriers may perform the annual inspection themselves with a qualified mechanic and the original or copy of the periodic inspection report must be retained by the carrier for 14 months from the report date.
Intermodal equipment providers must also inspect intermodal equipment that is interchanged or intended for interchange to motor carriers in intermodal transportation.
A completed annual inspection form or sticker decal must always be in or on your equipment.
Which state periodic inspections count?
According to the regulations, vehicles passing periodic inspections performed by a State government or equivalent jurisdiction in Canadian Provinces, Yukon Territory, and Mexico, will be considered to have met the requirements of an annual inspection for a period of 12 months commencing from the last day of the month in which the inspection was performed.
The states include:
- Alabama (only LPG Board)
- District of Columbia
- Michigan (bus inspection program only)
- New Hampshire
- New Jersey
- New York
- Ohio (church bus inspection program only)
Note that Arkansas and Oklahoma no longer carry inspection programs that are approved by FMCSA.
If a state inspector makes a mistake for citing your driver for an outside state inspection that you say meets the annual inspection requirements, you can file a DataQ challenge. CNS can help you use language that shows intent to be thoughtful, clear, and concise in describing what the error is believed to be.
Who is qualified to perform an annual inspection?
Many larger carriers have a qualified mechanic that can perform an annual inspection. However, most carriers go to a third-party mechanic.
This can include a commercial garage, fleet leasing company, truck stop, or other similar commercial business to perform the inspection, provided that the business operates and maintains facilities appropriate for commercial vehicle inspections and employs qualified inspectors, as required by 396.19.
To be a qualified inspector, they must:
- Understand Part 393 and Appendix G: This includes being able to identify defective components, and have knowledge and proficiency in methods, procedures, and tools.
- Be a qualified brake inspector
- Have qualifying brake training or experience: This includes successful completion of a State, Canadian province, Federal agency, or union training program, a State-approved training program, training that led to attainment of a State or Canadian Province qualifying certificate to perform assigned brake service or inspection tasks, including passage of CDL air brake test in the case of a brake inspection, or one year of brake-related training, experience, or combination of both.
- Maintain evidence of the brake inspector qualification: Carriers must maintain evidence of the brake inspector qualification for theperiod during which the brake inspector is employed in that capacity, and for one year thereafter at their place of business or location where the inspector works.
Which vehicles are required for annual inspection and what will they look for?
The following commercial motor vehicles require an annual periodic inspection:
- Commercial motor vehicles weighing 10,001 lbs or more (including tractor-trailers, taxi cabs, rental vehicles, public utility vehicles, delivery, and more)
- Vehicles that transport more than 8 passengers (including the driver) FOR compensation (passenger buses)
- Vehicles that transport more than 15 passengers (including the driver) NOT used to transport for compensation (passenger or school buses)
- Vehicles that transport hazardous materials
At a minimum, inspections must include all items listed in the Minimum Periodic Inspection Standards, which includes a visual inspection of the vehicle’s exterior and interior, as well as a test of its braking, steering, and lighting systems.
The full inspection list includes:
- Brake System: Service brakes, brake linings or pads, parking brake system, brake drums and rotors, brake hoses, brake tubing, low pressure warning device, tractor protection valve, air compressor, electric brakes, hydraulic brakes, vacuum systems, antilock brake system, automatic brake adjusters
- Coupling devices: Fifth wheels, pintle hooks, drawbar/towbar eye and tongue, safety devices and saddle-mountsExhaust System
- Fuel System
- Lighting Devices
- Safe Loading
- Steering Mechanism
- Wheels and Rims
- Windshield Glazing
- Windshield Wipers
- Motorcoach Seats
- Rear Impact Guard
Annual inspection form and sticker requirements
Once the inspection is completed, the inspector will give you a DOT Annual Inspection Form, which needs to be fully completed, along with the inspector’s Qualified Inspector Form. Some third-party locations have these forms included in their invoice paperwork.
If you don’t receive the qualified inspector form and are later audited by the DOT, they can call the third-party location to verify their qualification.
The completed form or annual inspection decal sticker must always be in or on your equipment.
All commercial vehicles do not require the annual DOT inspection sticker but can be helpful for your trailers. However, carriers can complete these stickers themselves and place them on the inside driver’s side windshield, the bumper near the license plate, or front left of the trailer and closer to the pigtail hookups.
If you are ever pulled in for a DOT Inspection, officers will want you to verify that the vehicles have undergone an annual inspection. They will also ask for proof for each piece of equipment in combination.
Once proof on an annual inspection has been provided, officers will verify that the inspection took place within the last 12 months. If drivers can’t provide proof of an annual inspection, or if an investigation shows the inspection didn’t occur in the last year, the officer will write a citation.
We recommend always having the last two annual inspections in the vehicle as there is a slight overlap with the retention requirement (14 months). Trailers can have a waterproof plastic pouch to keep it on the trailer, but drivers must be aware that it is there if an officer is asking for the information.
If carriers cannot track these inspections, they will get a citation for not doing the annual inspection (396.17) and may also get a citation for not tracking their inspection, repair, and maintenance process well (396.3(b)).
So, be sure to keep a good schedule, no matter if it is on a whiteboard, outlook calendar, in your ELD system, or manila envelopes.
DOT Compliance Programs (PSM)
At CNS, our DOT Compliance Programs focus on Proactive Safety Management (PSM),a mindset that will ensure your fleet’s safety and compliance is always in order and ahead of the FMCSA.
Our PSM Motor Carrier Program includes:
- ELD management
- Driver Qualification File Management
- New driver on-boarding
- Driver safety meetings
- CSA score management
- Policies and handbooks
- Vehicle maintenance
- and more