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You Will Be Tested on This

Posted: December 9, 2015 by Jim Park

National Safety Code Standard 11, more commonly known as Periodic Motor Vehicle Inspections (PMVI), calls for annual inspections of trucks, tractors and trailers to ensure a vehicle’s continued safe operating condition. In 2011 Canadian regulators and industry stakeholders identified the need to update PMVI from its 2006 incarnation, so a committee was assembled to review the standard and come up with recommendations for updates. The task was begun in spring 2012 and wrapped up in 2014 with the review of “between 3,400 and 3,600 issues” following hundreds of conference calls, a few face-to-face meetings and countless hours of consultation and discussion.

“As we went through the 2006 standard, we found a lot of components that just weren’t there in the old standard; for example clevis pins on the simple side and electronic stability control systems on the more complex side,” says Committee Chair Doug MacEwen, whose real job is Registrar of Motor Vehicles, Highway Safety Division in the Department of Transportation, Infrastructure and Energy in Prince Edward Island.

“The review required an incredible amount of work from everyone involved, so we plan to conduct more frequent reviews in the future. With equipment evolving as quickly as it is we can’t allow ourselves to get that far behind the 8-ball again.”

MacEwen, who is a truck and tractor mechanic by trade, says that committees made up of equipment experts, industry stakeholders and government officials who tackled small chunks of the project, were usually chaired by people with expertise in those areas.

“It worked really well because we not only had the government people with their own expertise in vehicle standards, we had the collected knowledge and experience from the industry side as well as the manufacturers,” he says. “We got stuck on several issues, so we called on the Heavy Duty Brake Manufacturers Council for example for an opinion. Who could be better to provide insight into inspecting equipment than the people who design and manufacture it?”

In total, more than 20 technical experts participated actively in the project, representing all provinces and territories as well as a number of industry groups, including Motor Coach Canada, the Ontario Trucking Association, Pacific Western Transportation from Alberta, the Manitoba Trucking Association and the Canadian Transportation Equipment Association as well as Transport Canada. The end result, most would agree, is a standard that is considerably more comprehensive and technically up-to-date than previous iterations and most importantly, was developed with the full support and expertise of industry stakeholders.

MacEwen credits much of the success of this revision to a much higher level of stakeholder engagement than was the case in 2006. He is also proud and happy that the committees agreed to include guidelines for the technician’s safety in the new standard as well.

Most jurisdictions have committed to implementing the revised standard beginning late this year, including Manitoba, Quebec, New Brunswick, Newfoundland and Labrador and Saskatchewan. The remaining jurisdictions have pledged to start putting the new standard in place early in 2016.

Most provinces’ inspections are still on a 12-month interval and apply to all commercial vehicles registered for 4,500 kg or more. There are exceptions for certain vehicles in BC, Alberta, Saskatchewan and Yukon where weight thresholds may be higher or the inspection interval may be 6 months rather than 12. Vehicles registered in Canada must be inspected to the Canadian PMVI standards. If a vehicle has to be inspected in the U.S because of a time constraint, the inspection will not be recognized by jurisdictions other than the home province, and those vehicles will need to be re-inspected upon return to Canada in order to meet the reciprocal agreements between the provinces. 

How Much Will it Hurt?

The ultimate operational impact on fleets of the new PMVI standards will be felt, but the extent will vary. Some fleets may find fewer errors or misinterpretation in their inspection results, while others may see more defects than before.

Part of the problem with the previous standard was it had a visual inspection where you had to remove something else to do the inspection. This clarified a lot of the process.

“We have standardized definitions in this version that we didn’t have before that clearly identify specific defects and give guidance on fail conditions, which is very helpful to the technicians performing the inspections,” says MacEwen. “That was lacking in the original model.”

Take something as obtuse as a leak, for example. Previously, the guidelines might have said “some leakage is acceptable.” The new standard defines leaks as: Level 1 leak: means seepage of fluid that is not great enough to form drops; Level 2 leak: means seepage of fluid that is great enough to form drops, but not great enough to cause the drops to fall during inspection; Level 3 leak: means seepage of fluid that forms drops, and those drops fall during inspection.

That takes most of the guess work away, and few could argue with it. On another topic, there’s now a chart that illustrates hose and tube conditions by type of hose and the extent of damage that would be deemed acceptable or not. Again, the grey area of technician judgment or discretion has all but been eliminated.

This new version includes lots of illustrations to help with defect detection, such as when identifying cracks on a brake lining. The old document merely described the cracks, this one contains illustrations, which remove a lot of interpretation.

Among the changes that may cause some consternation are those pertaining to brake inspections. For example, brake stroke length and drum and brake lining thickness need to be captured and they have to go on the inspection report.

There are still requirements for wheel removal in cases where the components can’t be measured, like with backing plates or dust shields that can’t be removed.

“The way the wording was, the wheels were supposed to come off every 24 months to have the drum and brake lining thickness measured,” MacEwen says. “The wording of the standard allowed mechanics to take that out to 36 months, so we tightened up that wording so now wheels-off inspections for disc brakes can’t go beyond 12 months and drum brakes with non-removable backing plates cannot go beyond 12 months without proper documentation of a previous brake service or 24 months for a full inspection with the drum removed.” There’s also now an emissions-system inspection, and that could be a big challenge for fleets and jurisdictions. MacEwen says there was a lot of discussion among committees and regulators over how far the inspections should go, right down to being required to conduct actual emissions tests. That was deemed impractical because of the highly precise nature of the measurements required – and the expense. The big concern will come for fleets that have removed or disabled those systems because they are hard on fuel economy and very expensive to repair and maintain. Where this currently stands, in MacEwen’s words is, “if the technician can determine from a visual inspection that the DPF or the EGR valves, for example, have been tampered with or bypassed then it’s a reject situation.”

And speaking of emissions systems, that part of the standard could make it difficult to get a glider kit truck safetied, especially if someone has put say a 2013 or 2014 serial number on it, notes Eddy Tschirhart, recently retired Director of Technical Programs at the Canadian Transportation Equipment Association. “That would make it a vehicle of a particular year, and as such the vehicle would have to meet all the CMVSS standards in place “at the time of manufacture,” such as emissions systems, which are conspicuously lacking on some glider kit tractors.”

National Safety Code Standard 11 actually contains two documents, Part A is recommended standards for a commercial vehicle maintenance program and represents the minimum criteria which would be evaluated in an audit of the carrier’s operation. Part B contains the standards to which a vehicle will be inspected by authorized technicians at authorized facilities at scheduled intervals. Both should be required reading for every fleet.

“It’s a complete new document,” says Tschirhart, who was a consultant on the NSC 11 rewrite project. “There’s still some room to work on it, but I love the new format, I love the stuff we’ve added to it and I love the way we revamped it.” Hopefully the rest of the industry will feel the same way.

Today’s Trucking will be featuring several follow-ups to this story, going into more detail on some of the more substantial changes to the 2014 PMVI standard. There’s far too much to cover in one short magazine story. Watch for them.

In the meantime, here’s a link to the 2014 edition of the PMVI standard document, available free of charge for the first time ever from The Canadian Council of Motor Transport Administrators: http://ccmta.ca/en/home/item/national-safety-code-standard-11-update-2014

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