OOSC, Part II, Item 1. e. Parking Brake

Inspection Bulletin 2012-04 – Hydraulic Brake System and Trailer Brake Inspection Procedure, utilizes roadside testing conditions for Parking Brakes, that do not match those listed in FMVSS 105, S5.2, which can lead to violations and subsequent OOS being cited in error.

Asking roadside enforcement to conduct parking brake inspection procedures that are not equivalent to or same as those required per FMVSS 105, S5.2, S6 & S7, would be an inappropriate application of 393.41, FMVSS 105 and the OOS. Additionally, FMVSS 105 testing is on 20 or 30% grades with the transmission in neutral and the engine idle is at mfg. recommendations. Testing as currently noted in the Inspection Bulletin can put forces on the park brake system, beyond those required in the FMVSS. Inappropriate application of the noted regulations can lead to unjustly cited violations and OOS, which would then adversely affect a carrier's SMS Vehicle Maintenance BASIC. Incorrectly cited violations and OOS which adversely affect a carrier's SMS scores, can affect a carrier's ability to maintain existing and/or new customers, not to mention the potential for higher insurance rates.

Change inspection procedure to read "Park brake inspections should be done on grades not exceeding 20% and with the transmission in neutral. If the parking brake does not hold the vehicle, whether on an uphill or downhill grade, cite the violation of 393.41." "Note: Do not inspect park brakes with the transmission engaged, doing so is outside the requirements of FMVSS 105."