OOSC, Part II, Item 1. Brake Systems, d. Trailer Breakaway and Emergency Braking

During the NAS Level 1 Light Duty Hydraulic Vehicle and Trailer Inspection Procedure, the driver is directed to activate the trailer breakaway system to confirm its functionality. This is accomplished by having the driver simulate an unintended separation of the trailer from the power unit by removing the breakaway switch pin. During roadside inspections there have been situations that the device testing has created issues not outlined in the procedure. One issue is if the breakaway switch pin cannot be physically removed by the driver. The other issue is the driver refusing to remove the breakaway switch pin. In both of these situations the functionality of the breakaway system cannot be verified as required by the Inspection Procedure.

If the Inspection Procedure can not be completed due to either of the issues referenced above, the Inspector would be unable to verify the functionality of a critical component in the Level I inspection. There is currently no guidance as to whether the trailer should be placed out of service or whether the breakaway system should be classified as a hidden component, given that the system was not fully tested.

I request that language be included in the Inspection Procedure to address the potential circumstances. The first option, document the device as inoperative, cite the violation and place the trailer Out of Service if the committee determines this is an imminent hazard. The second option would be to document in the note section of the inspection report that the breakaway switch pin was not removed. A CVSA decal would not be issued to the trailer due to the lack of verification and allow the vehicles to proceed. If it is determined to be a violation, Operational Policies 14 and 15 should be revised accordingly to reflect such determination, in conjunction with Inspection Bulletin No. 2012-04, Hydraulic/Electric/Surge Brake System and Light-Duty Trailer Inspection Procedure.