Operational Policy 14 - Lighting Violations due to a Trailer Power Failure

An OOS issue arises when there is a power failure from the power unit to the trailer which prevents the trailer unit lights from operating. We believe that a new OOS violation needs to be created to cover conditions where the lights on the trailer are unable to be checked due to this lack of power. The OOS condition would provide for putting the trailer OOS and provide for not listing each individual light on the trailer as being defective. Similar to not being able to check brakes when a inspection is stopped due to a serious OOS condition such as a non-manufactured hole in a spring brake chamber. If the lights cannot be checked due to a power failure then a carrier should not have to be violated on each individual light, however, it still needs to be OOS and corrected. Additionally, this brings up the issue of OPS Policy 14 not addressing the new specific violation codes added by the FMCSA to provide for CSA, example 393.25F. Operational Policy 14 needs to be updated and modified to cover these issues.

Violations are being documented and carriers being assessed violations that need to be accounted for in a consistent and proper manner and allow for the trailer to be placed OOS properly with the proper violation. If Operational Policy 14 is followed as written, CSA points will not accrue, as would be if derived from the recently new and specific violation codes issued by the FMCSA.

Creation of new OOS condition and modification of Operational Policy 14.