DOT and OSHA Training

Don't forget your company's management and maintenance personnel. The regulations require training of all motor carrier employees.

When we discuss training in the transportation industry, most of us think of driver training. While driver training is an important aspect of all motor carrier safety programs, there's another group of employees that are often overlooked that also need to be trained: your management and maintenance personnel.

In this discussion, we will focus on training required by the Federal Motor Carrier Safety Regulations (FMCSRs) as well as the Occupational Safety and Health Administration (OSHA) for supervisors and maintenance personnel.

FMCSR-Required Training
The FMCSRs have a few specific training requirements for those who work at a motor carrier’s facility in management positions or as maintenance professionals. In addition, Section 390.3(e) of the FMCSRs states that:

  • Every employer must be knowledgeable of and comply with all regulations contained in the FMCSRs that are applicable to that motor carrier's operations;
  • Every driver and employee must be instructed regarding, and must comply with, all applicable regulations contained in the FMCSRs; and
  • All motor vehicle equipment and accessories required by the FMCSRs must be maintained in compliance with all applicable performance and design criteria set forth in the FMCSRs.

When it comes to meeting these requirements, the regulation goes no further than what is stated above. Having a comprehensive training program that includes the required training as well as training that meets the criteria of Section 390.3(e) can go a long way in meeting these requirements.

Drug and Alcohol Reasonable Suspicion (49 CFR 382.603)
In addition to meeting the requirements in Section 390.3(e), all individuals who supervise drivers must receive reasonable suspicion training. This training must include 60 minutes of training on alcohol abuse and an additional 60 minutes of training on controlled substances use. This training must include the physical, behavioral, speech, and performance indicators of probable misuse of alcohol and use of controlled substances.

The regulation refers to "all persons designated to supervise drivers." This means that any individual, no matter the job title, who has responsibilities that include any aspect of supervising drivers should receive this training. This could include dispatchers, lead workers or foremen, and managers with various responsibilities.

Training of Maintenance Personnel
The amount of training required for your maintenance personnel will depend on their level of responsibility, as well as the degree of services performed within your facility. This training includes both motor carrier and workplace safety issues.

In addition to meeting the requirements in Section 390.3(e), the FMCSRs require specific training for those individuals who perform periodic (annual) and brake inspections.

Those who work within your maintenance facility are also subject to the workplace safety regulations administered by OSHA. At a minimum, they should be trained on the hazard communication standard ("Right to Know" requirements), tire mounting and dismounting, and other workplace safety issues that fall under OSHA’s General Duty Clause.

Periodic Inspector (49 CFR 396.19)
Commercial motor vehicles operated in interstate or foreign commerce must pass an inspection annually. Intermodal equipment that is interchanged or intended for interchange to motor carriers in intermodal transportation also must be inspected.

In some cases, these inspections are performed under a state inspection program that meets federal standards. About two dozen states have this type of program that is recognized as meeting the federal requirements. In the balance of the states, commercial motor vehicles must be inspected per the federal requirements by a qualified inspector who meets specific regulatory requirements.

The individual conducting the periodic (annual) inspection must understand the inspection criteria in Part 393 and Appendix G of the FMCSRs and must be able to identify defective components.

He/she must be knowledgeable of and have mastered the methods, procedures, tools, and equipment used when performing the inspection and must be trained and/or have a certain amount of experience. This training includes:

  • Successful completion of a state- or federal-sponsored training program or possession of a certificate from a state or Canadian province that qualifies the person to perform inspections; or
  • A combination of training and/or experience totaling at least one year. The training or experience may consist of: Participation in a truck manufacturer-sponsored training program or similar training program; Experience as a mechanic or inspector in a motor carrier maintenance program; Experience as a mechanic or inspector at a commercial garage, fleet leasing company, or similar facility; or Experience as a commercial vehicle inspector for a state, provincial, or federal government.

Evidence of each inspector's qualifications must be retained for the entire time the individual is performing periodic inspections and for an additional year after.

Brake Inspector (49 CFR 396.25)
A brake inspector is responsible for ensuring that all brake inspections, maintenance, repairs, and service meet applicable safety standards.

An individual can meet the qualification requirements by completing an officially approved apprentice or training program or through relevant training and/or experience totaling at least one year.

An officially approved apprentice program includes an apprenticeship program sponsored by a state, Canadian province, federal agency, or labor union.

An officially approved training program includes a training program approved by a state, provincial, or federal agency.

Relevant training and/or experience includes:

  • Participation in a training program sponsored by a brake or vehicle manufacturer or a similar commercial training program designed to train students in brake maintenance or inspection similar to the assigned brake service or inspection tasks; or
  • Experience performing brake maintenance or inspection similar to the assigned brake service or inspection task in a motor carrier maintenance program, at a commercial garage, fleet leasing company, or similar facility.

The carrier must maintain evidence of an inspector's qualifications at its principal place of business or where the inspector is employed.

The documentation must be retained for as long as the inspector is employed in that capacity and for one additional year after the inspector leaves the motor carrier’s employment.

Right to Know Training (29 CFR 1910.1200)
OSHA’s Hazard Communication Standard (HCS), also referred to as the "Right to Know Law," covers all employees who may be exposed to hazardous chemicals under normal working conditions or where chemical emergencies could occur. One of the areas specifically addressed under this standard is employee information and training.

Employers must provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. The training must include:

  • Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;
  • The hazards of chemicals in the work area;
  • The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals; and
  • The details of the hazard communication program developed by the employer.

Tire Mounting and Dismounting (29 CFR 1910.177)
The servicing of a multi-piece or single-piece rim wheel can be a dangerous task. Because of its dangers, OSHA requires training of all employees who service any rim wheel.

The employer must assure that each employee demonstrates and maintains the ability to service rim wheels safely, including performance of the following tasks:

  • Demounting of tires (including deflation);
  • Inspection and identification of the rim wheel components;
  • Mounting of tires (including inflation with a restraining device or other safeguard);
  • Use of the restraining device or barrier and other equipment;
  • Handling of rim wheels;
  • Inflation of the tire when a single-piece rim wheel is mounted on a vehicle;
  • An understanding of the necessity of standing outside the trajectory both during inflation of the tire and during inspection of the rim wheel following inflation; and
  • Installation and removal of rim wheels.

The employer must evaluate each employee’s ability to perform these tasks and to service rim wheels safely, as well as provide additional training as necessary to ensure that each employee maintains his/her proficiency.

Other OSHA Requirements
Use of personal protective equipment (gloves, footwear, etc.) and safe lifting techniques/back safety are additional issues that need to be trained on, either under specific regulation or by OSHA's General Duty Clause.

In Conclusion . . . Why Train?
So why should training of management and maintenance personnel be a component of a motor carrier's safety program?

There are specific requirements that must be met under the FMCSRs, as well as OSHA regulations. There are also general provisions listed in Section 390.3(e) and OSHA’s General Duty Clause that apply.

Finally, providing training shows that as an employer, you care about safety. It enables your employees to follow safe practices, which in turn contributes to a safe and productive work environment.

This article originally appeared in the September 2015 issue of Occupational Health & Safety.

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