OOSC, Part II, Item 1 - 20% Criterion

Currently there is no visual indicator throughout the 20% defective service brake section to identify which sections are part of the 20% defective service brake criterion. The only locations the OOSC identifies 20% defective service brakes is 1. Brake Systems a. Defective Brakes on page 18 and b. Front Steering Axle(s) Brakes on page 24 of the Handbook and Pictorial version of the OOSC. There is then an indication of the end of the 20% defective brake criterion on page 26 before c. Spring Brake Chambers. The lack of a visual identifier for 20% defective service brakes throughout the 20% criterion sections 1.a.and b. can result in an inspector making an error not identifying a defect as part of the 20% criterion and calling the defect out of service on its own.

Often during CVSA NASI training, participants make errors identifying brake violations as part of the 20% criterion. Participants look in the table of contents to identify a brake defect and go straight to the page and section number to determine if the defect is an OOS defect. The table of contents does not direct the participant to section "1. a." where it identifies all defects after that point up to the end of "2. g." as part of the 20% defective service brake criterion. This situation may not limited to training course participants and could result in a roadside inspector placing a vehicle OOS incorrectly.

I would like to request a visual identifier be added to each page/section of the OOS criteria that is part of the 20% defective service brake criterion. I have attached an example of a visual identifier that could be added to the OOSC to easily identify items included in the 20% defective service brake criterion and those included in 20% defective service brake criterion and OOS on their own (Steering Axle(s) Brakes).