Operational Policy 15 - b(3) Air Leak Clarification

This is a continuation of Issue Number 19-035-VEH titled "Operational Policy 15 - Brake Systems b (3) Air Leaks." The issues identified by the Committee in the original Request for Action have been added to this proposed wording of Question b(3). The issue is that "unapplied air loss" is being cited even though the source of the air-loss is noted to be at an undetermined location or originating from non-safety related parts that do not affect the brake performance or safe operation of the vehicle(s). For example, a slight air leak from an air operated window or an air actuated door lock can be cited as a violation even though it has absolutely nothing to do with the safe operation of the vehicle.

A change in wording of Operational Policy Question b(3) Air Leaks is needed. Changes include the addition of the fifth assemblies in air loss violations and the separation of "applied" and "unapplied" air loss.

Amend the Q&A to instead read as follows: QUESTION: When should an air leak in the brake system be documented as a violation? ANSWER: When a vehicle has an “applied” air leak in the braking system or at an undetermined location, and the vehicle passes the CVSA OOSC air loss rate test, inspectors will record a violation for an air leak on the inspection report. When a vehicle has an “unapplied” air leak in the braking system, and the vehicle passes the CVSA OOSC air loss rate test, inspectors will record a violation for an air leak on the inspection report. NOTE: In 393.45(d), it indicates that the leak has to affect the brake performance under 393.52. Enforcement cannot determine to what extent a leak has to be to affect the brake performance; therefore, any leak in the brake system will be documented as a violation. NOTE: Leaks in the brake system, such as a leak discovered when the treadle valve is applied or a leak in a hose from an air reservoir to a relay valve will be documented under 393.45(d). Any other air leak that cannot be attributed to the brake systems, fifth wheel, or suspension systems (see 393.207(f)) shall not be documented as a violation.