CVSA Enhanced CMV Inspection Standard - Hoses

The CVSA Enhanced CMV Inspection Standard identifies defective conditions of hose, tubing and lines at the beginning of the standard. Specific sections of the standard reference back to this table to identify when defects exist for that specific component. Within the table, the defective conditions are identified for different types of hose and tubing. The defective conditions for all the different types of hoses are “Wear or damage resulting in reduction in the diameter of the air line”. CVSA Vehicle Committee has discussed at what level a defect exists on air lines and has that guidance published in Operational Policy 15, Part II – Vehicle, 1.b(2) [below]. This guidance tells roadside inspectors that the integrity of the hose is not compromised, and a violation does not exist until damage extends to or through the outer reinforcement ply. NSC Standard 11B was used to develop the enhanced standard and the latest version of NSC Standard 11B identifies the defective condition the same as Operational Policy 15. Reference: Operational Policy 15 – Regulatory Guidance “b.(2) When should air hoses and tubing not be documented as a violation for chafing? ANSWER: A violation should not be recorded until a reduction of the hose diameter is observed. It is not a violation if the hoses/lines rest on or lightly rub against vehicle components. A hose that is found to have a reduction in diameter but is no longer chafing does not constitute a violation unless damage extending to or through the outer reinforcement ply is observable. When damage extends to or through the outer reinforcement ply, a violation will be recorded (thermoplastic nylon tubing that is discolored or faded but not damaged, is not a violation). NOTE: If inspectors observe air hoses/lines that appear to be resting on or lightly rubbing against vehicle components, but no observable reduction is present, inspectors should educate the driver that this is a condition that, while not in violation, could lead to a violation/out-of-service condition in the future and make comments in the notes, only if so inclined.”

The integrity of the air hose or tube is not compromised until damage is to or through the reinforcement ply. Also, a hose that is found to have a reduction in diameter but is no longer chafing does not constitute a defect unless the outer reinforcement ply is observable. The Vehicle Committee has provided this guidance to roadside inspectors, and it should be the same standard that vehicles subject to the enhanced standard are held to. Replacing hoses that have been determined to not be a safety hazard can be costly with no safety benefit. As ADS developers partner with carriers to move their trailers, it is hard to justify the expenditure to repair items on trailers that do not pose a safety concern.

Request for Action: An edit be made to the CVSA Enhanced CMV Inspection Standard table for Defective Conditions of Hose, Tubing and Lines to bring the defective condition in line with NSC Standard 11B and Operational Policy 15.