OOSC, Part II, Item 1. Brake Systems, a. Defective Brakes (7) Hydraulic and Electric Brakes - Linings
| Entry Date | August 29, 2025 |
|---|---|
| Issue Number | 25-076-VEH |
| Name | Jacob LeTourneau |
| Agency | Minnesota State Patrol |
| Address | 1110 Centre Point Curve Suite 410Mendota Heights, MINNESOTA, 55120United StatesMap It (opens in a new tab) |
| Phone | 5072592922 |
| [email protected] | |
| Committee | Vehicle Committee |
| Status | Closed |
| Summary of Issue | CVSA's Out-Of-Service criteria Part II, 1. (Brake Systems), a. (Defective brakes) 7. (Hydraulic and electric brakes), (g) currently requires inspectors to declare non-steering hydraulic or electric brake lining/pad thicknesses of exactly 1/16 inch as being 'defective' per the 20% rule. The OOS criteria reads "Lining or pad with a thickness 1/16 OR LESS for disc or drum brakes" Meaning 1/16th inch exactly IS A DEFECTIVE LINING CONDITION. The regulation itself, however, (393.47(d)(2)) which applies to non-steering axle brakes outlines that "Hydraulic or electric braked commercial motor vehicles shall not be operated with a lining/pad thickness LESS THAN 1/16 inch". Meaning 1/16th inch exactly is NOT A VIOLATION. |
| Justification or Need | The OOS criteria should not be identifying a non-steering axle hydraulic or electric brake lining of exactly 1/16th inch as a defective lining condition when the regulation itself explicitly allows for this. It would be very confusing for a carrier who receives a violation for 393.47(d)(2) lining condition being 'defective' measured at exactly 1/16th inch - when the regulation itself allows for this lining thickness. |
| Request for Action | Please align the OOS criteria with the regulation for non-steering axle hydraulic or electric brakes |