Suggested New Critical Inspection Item - Engine Operation

The petitioner is requesting that not being able to start a commercial motor vehicle from the seated position while at the vehicle controls be added to the CVSA out of Service Criteria under either 396.3a1 or 396.7. Currently the Federal regulations and the Out of Service Criteria do not directly address the hazard created when a commercial motor vehicle cannot be started while the driver is seated at the controls of the commercial motor vehicle.

Justification or need: During an inspection, the vehicle is required to be turned on and off to complete the inspection process and turning the vehicle on and off is included throughout the 37 step Inspection Procedures. If the vehicle is unable to be restarted it will prevent the inspector from completing a thorough inspection. Inspections are done both roadside and at fixed sites. If the vehicle is stopped roadside it would create a hazard to other motorists by being disabled roadside. It may cause the driver to get out into traffic to start his vehicle or the necessity to have a wrecker remove the vehicle which would also create a hazard to other motorists. In addition to the hazards created from being disabled roadside, having the driver out of the cab away from the controls in an attempt to “jump” the starter would create its own hazard by placing the driver between the steer axle and the frame of the truck, especially if the truck was left in gear or if it begins to move with no one at the controls.

Having a vehicle that is unable to be started while the driver is seated at the controls should immediately be added to the Out of Service Criteria using either 396.3a1, Inspection Repair and Maintenance, or 396.7, Unsafe Operation Forbidden due to the potential hazard created.