8 Oregon Trucking Associations, Inc. Oregon Truck Dispatch What’s Changed in Required USDOT Annual Inspections in 2022? By Gregg Dal Ponte, OTA’s Director of Regulatory Compliance REGULATORY COMPLIANCE FIRST OF ALL, for a little review of what the annual inspection is, recall that §396.17 requires that every commercial vehicle, including each segment of a combination vehicle, requires periodic inspection that must be performed at least once every 12 months. At a minimum, inspections must include all items enumerated in the Minimum Periodic Inspection Standards, Appendix G to Subchapter B of the Federal Motor Carrier Safety Regulations. Motor carriers may perform required annual inspection themselves. The original or a copy of the periodic inspection report must be retained by the motor carrier for 14 months from the report date. Who is qualified to perform these annual inspections? Inspector Qualifications ` Inspectors Must Understand Part 393 and Appendix G—Motor carriers must ensure that persons performing annual inspections are qualified. Inspectors must understand the inspection standards of Part 393 and Appendix G and be able to identify defective components, and have knowledge and proficiency in methods, procedures, and tools. ` Brake Inspector Qualification— The motor carrier is responsible for ensuring that all inspections, maintenance, repairs, and service to brakes of commercial motor vehicles comply with these regulations. The carrier must ensure that the employees responsible for brake inspection, maintenance, service, or repairs meet minimum brake inspector qualifications. ` Qualifying Brake Training or Experience—Qualifying brake training or experience 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. ` Maintaining Evidence of Brake Inspector Qualifications—Motor carriers must maintain evidence of brake inspector qualification at the principal place of business or the location where the inspector works. Evidence must be retained for the period during which the brake inspector is employed in that capacity, and for one year thereafter. So, what changed effective December 9, 2021, and how does the change affect the completion of the Annual Inspection Report? The FMCSA has issued a new rule that adds rear impact guards to the list of criteria for passing an annual vehicle inspection. The criteria include details on the condition, placement, and size of the bumper, depending on vehicle type and year of manufacture. This means your inspectors and technicians will need to become familiar with the bumper inspection standards, and your annual inspection forms will need to be updated to include “rear impact guard” as one of the items inspected. You can find the bumper inspection standards in Appendix A to Part 396. A vehicle does not pass an inspection if it has one of the following defects or deficiencies: 15. Rear Impact Guard a. Trailers and semitrailers with a GVWR of 4,536 kg (10,001 lbs.) or more, manufactured on or after January 26, 1998 (see exceptions in § 393.86(a)(1)). 1. Missing guard. 2. Guard is not securely attached to trailer, including broken or missing fasteners, any welds or parent metal cracked, or other damage that compromises secure attachment of the guard. 3. Guard horizontal member does not extend to within 100 mm (4 inches) of each, or extends beyond either, side extremity of the vehicle. 4. Guard horizontal member is more than 560 mm (22 inches) above the ground. 5. Guard horizontal member is more than 305 mm (12 inches) forward of the rear extremity of the vehicle. 6. Guard horizontal member does not have a cross sectional vertical height of at least 100 mm (4 inches) across its entire width. b. Commercial motor vehicles manufactured after December 31, 1952 (except trailers and semitrailers manufactured on or after January 26,
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