Nuts, bolts and printouts
Truck maintenance isn’t just smart business, it’s a requirement for truck owners and it involves a lot more than wrenching on the truck and changing oil. It means paperwork.

By Jami Jones, managing editor

If it ain’t broke, don’t fix it works only in limited scenarios. And, unless you’re willing to pay big, both monetarily and with downtime, it’s certainly no approach to truck maintenance.

Setting up a preventive maintenance plan – and sticking to it – is a must for any savvy owner-operator. The complex engines and components on trucks today simply don’t lend themselves to a “when I get around to it” or “when I have time” approach. Finally, no matter your opinion on the matter, it is a federal requirement.

If you don’t have a formal plan that’s compliant, there are key components you need to include.

J.J. Keller recently released a comprehensive White Paper on truck maintenance, titled “Putting It All Together – Components of an Effective, Compliant Vehicle Maintenance Program.” The paper points out that while you have to establish a maintenance program, you do have options. While targeted toward fleets, the advice works for owner-operators and small fleets as well.

‘Systematic’

Whether you want to or not, the Federal Motor Vehicle Safety Regulations require you set up a maintenance program.

Here’s the reg, 49 CFR 396.3(a):

“Every motor carrier and intermodal equipment provider must systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles and intermodal equipment subject to its control.”

That’s fine and dandy, but what is systematic? And what maintenance is adequate enough to say you’re compliant?

The Federal Motor Carrier Safety Administration does say that “systematic” is “a regular or scheduled program.”

J.J. Keller says the best place to start when setting up your maintenance program is to look at the original equipment manufacturer’s recommendations. Those recommendations are a general guideline for an “average” use of the truck and equipment.

That means you have to look closely at your operations and eyeball the average-ness of it. Do you often pull loads that are significantly lighter than 80,000 pounds? Heavier? Do you route through the mountains? Put another way consider the toll on the engine and transmission to move you on your average day.

The more severe duty the operation and the older the equipment, the more frequently regular maintenance needs to be built into your schedule.

Setting the standard

Back in the day, truck maintenance decided on time in between cycles. In the spring and fall were very popular choices with six months in between. While simple enough, and logical given the prep that can be done before harsh winter cold and brutal summer heat, you do have more choices than just looking at a calendar.

J.J. Keller says you can also set it by mileage or hours. The paper counters that while sticking to a time schedule is simpler, it can lead to unnecessary inspections and time off the road.

“This is due to the vehicle being scheduled into the shop after ‘x’ days or months, regardless of the use,” the paper states. “However, if the vehicles see consistent use, then this may make sense.”

Scheduling on miles driven is more efficient in most operating environments. It might not, however, be the right choice for severe duty or operations with high idle times.

Checklists

J.J. Keller recommends, strongly, developing checklists to be completed at each maintenance interval.

“A good checklist will also document the condition of the vehicle at the time of the inspection or maintenance. This will provide proof to anyone (such as investigators, auditors, or plaintiffs’ attorneys) that you have been active in inspecting and maintaining your vehicle,” the paper states.

The checklist should be a combination of the OEM recommended intervals, maintenance as required by FMCSR 393 as well as any components that have given you fits and maybe been a problem recently on inspections.

CYA

The endgame to any compliant maintenance program is making sure that you can prove you’re legal. As you may guess, in this case, your proof and defense is all in the documentation.

Compliance with a maintenance program would come up in an audit. Sure they aren’t likely for small motor carriers with squeaky clean records, but it can and has happened. And let’s not forget the mention of “attorneys” earlier. Compliance could be a huge asset if you have an equipment failure that results in a crash.

J.J. Keller points out that it all comes down to the paperwork retention and the list is lengthy.

The regulations simply require maintenance records for each vehicle. According to J.J. Keller, the maintenance recordkeeping requirements include:

  • The “informational record” on a unit, which is to be kept the entire time the vehicle is in service, plus six months after the vehicle leaves service. Identifying information includes:
    • Fleet number (if assigned one)
    • Make, model and year
    • VIN
    • Tire size
    • Owner (if not the carrier)
    • A maintenance schedule for the unit (the last time it was serviced and when it is next due for service)
  • Records of all inspection, maintenance, lubrication, repairs, and upcoming maintenance are to be kept for one year while the unit is in service, and six months after the unit leaves service (so far all this is in 396.3).
  • Copies of roadside inspections for the unit (with the carrier official signature) are to be kept for one year (396.9).
  • Driver vehicle inspection reports are to be retained for three months (with either one or three signatures – 396.11 and 396.13).
  • Copies of periodic (annual) inspections are to be kept for 14 months (396.17).

Visit JJKeller.com for the complete White Paper. LL