Understanding Lubrication and Maintenance Intervals
Overview
Carriers are required to identify a schedule for the frequency each of their vehicles will be lubricated (grease and/or oil change) and receive a scheduled maintenance inspection. These intervals can vary from company to company or even from vehicle to vehicle, however, once they have been identified should never be exceeded. They form part of the company's written maintenance program which can trigger audit violations if they are not complied with.
There is a wide array of how different businesses use commercial vehicles. For example, a forestry truck operating on a regular schedule over poorly maintained service roads will likely experience more stress on the mechanical equipment than a delivery truck used occasionally within a local municipality. It's because of these differences that the requirement to define these intervals falls back on the individual company.
What needs to be included in a Scheduled Maintenance Inspection
Carriers operating with a Safety Fitness Certificate issued in Alberta are required to inspect particular items (if their vehicle is equipped with it) on a regular basis (discussed below). The Alberta Government does provide a sample of a Scheduled Maintenance Inspection Form in their Sample Safety and Maintenance Programs. Each time a Scheduled Maintenance Inspection is completed, a record must be created and placed in the individual vehicle file (and kept for at least 5 years). Each inspection form must include all of the following information (at a minimum):
- The nature of the inspection or work performed on the vehicle,
- The date on which that inspection or work took place,
- Meter Readings:
- Odometer (if equipped),
- Hubmeter (if equipped), or
- Engine Hours (if the inspection interval is set using engine hours),
- Who completed the inspection, and
- An identification (unit number, licence plate, or VIN) of the vehicle being inspected.
Nature of Inspection must include a listing of all the items included in the inspection.
Ensure that each vehicle file (including trailers) has a copy of all of their applicable inspection forms filed appropriately
In the Sample Program linked above, Alberta Transportation includes a sample form that can be used to perform the inspection (below). You'll notice that there are thirty-three (33) items listed to be included on every inspection. If the vehicle is equipped with that component, it must be inspected at every Scheduled Maintenance Inspection interval you have defined. There may be items from the list that the vehicle is not equipped with. In those cases, those items can be crossed off (or otherwise marked as Not Applicable). Additionally, each of the inspection items is followed by a Section (S.) number that refers back to Schedule 2 of the Commercial Vehicle Safety Regulation (starting on Page 46). This regulation should be referenced while completing the maintenance inspection to ensure that each component is inspected as the regulation requires.
Don't forget that all commercial vehicles require a scheduled maintenance inspection. This might require a separate form/template for different vehicle types (trucks, trailers, buses, etc.)
Each ComplianceBox customer receives an inspection form on their account that includes all the applicable items from the Commercial Vehicle Safety Regulation schedule. Read this article for more information: Creating a copy and editing an existing Maintenance Template
How to select a proper maintenance interval
First, the carrier must determine if they want the required maintenance to be conducted based off of:
- Odometer - (Kilometer or Mile Based)
- Engine Hours
- Hubmeter
- Time (# of days, weeks, months, etc. until the next service is required)
Ensure that the vehicle is capable of meeting the desired maintenance interval. For example, a trailer is still required to have regular lubrications (greasing) and scheduled maintenance inspections performed. Even if the trailer is usually attached to a truck, it cannot use the trucks engine hours or odometer to determine the interval. Additionally, if the trailer isn't equipped with a hubmeter, then that interval type cannot be selected.
Now that the interval type has been determined, the carrier must define the absolute maximum frequency between intervals that the lubrication and scheduled maintenance inspections will be performed. There is a lot that can go into calculating this duration. This can include the age, intended use, frequency of use, area of operation, and other environmental factors. If you need assistance with determining intervals, please contact support@compliancebox.ca to have a CayCan Safety Consulting expert assist you.
How to ensure effective maintenance intervals have been selected
A good preventative maintenance program is continuously monitored and improved over time. In practice, a good program will identify small issues before they grow into larger ones. In theory, when a vehicle goes in for a Periodical Maintenance Vehicle Inspection (PMVI) or a Commercial Vehicle Inspection Program (CVIP) there should be zero defects found. The PMVI/CVIP is a certified inspector providing their stamp that the company's preventative maintenance program is working effectively. Ideally, the deficiencies are caught in Daily Vehicle Inspection Reports (DVIR) or the scheduled maintenance inspections. Therefore, it's crucial for a company to monitor the results of each DVIR, scheduled maintenance inspection, repair, PMVI/CVIP, and roadside compliance inspections to identify trends. If there are frequent issues found in scheduled inspections or by roadside compliance officers corrective action should be taken. Perhaps drivers need additional training to help identify these defects, or the frequency of inspections should be increased.
A carrier that selects a lubrication and/or scheduled maintenance inspection to be completed every 1,000,000 kilometres likely doesn't have a reasonable interval defined. There will likely be both mechanical and safety-related deficiencies that can be identified well before the next lubrication or inspection.
On the other hand, the carrier should ensure that they are in compliance with their stated intervals. If they are being exceeded, even by a little bit, then the company is not following their written program and can experience negative results in a compliance audit or investigation.
A carrier that selects a lubrication and/or scheduled maintenance inspection to be completed weekly isn't likely to remain compliant with their written program. If the actual intervals of lubrications or scheduled maintenance inspections exceed what is in writing a violation will be assigned.
Effective Driver Vehicle Inspection Reports
Carriers are also be held accountable in a Compliance Audit or a New Carrier Compliance Review to ensure that their drivers are conducting and documenting adequate vehicle inspections. As such, it's a good practice to regularly review completed Scheduled Maintenance Inspections (and other repair documents) for any defects that are listed on the applicable National Safety Code Standard 13 schedule. If any of those defects are identified, the most recent Driver Vehicle Inspection Reports (DVIR's) should be cross-referenced to verify that the driver correctly identified and responded to the defect. Defects that were not properly identified or responded to on the DVIR should be treated as an incident. This allows the carrier to perform an analysis of the situation and to provide an effective solution to prevent drivers from not properly recording the applicable defects in the future.