Definition
49 CFR 396.25(b) defines a brake inspector as any employee of a motor carrier or intermodal equipment provider who is responsible for ensuring that all brake inspections, maintenance, service or repairs to any commercial motor vehicle under its control meet the applicable federal standards. Section 396.25(c) says no carrier may require or permit an employee who does not meet the qualifications to be responsible for that work.
Qualifications
Under 396.25(d), the brake inspector must:
- understand the brake service or inspection task and be able to perform it;
- be knowledgeable of and have mastered the methods, procedures, tools and equipment used; and
- be capable through experience, training or both: by completing an apprenticeship program sponsored by a state, Canadian province, federal agency or labor union, or a training program approved by a state, provincial or federal agency, or holding a state or provincial certificate (including passing the CDL air brake tests, for brake inspection); or by having brake-related training or experience totaling at least one year.
Qualifying experience includes manufacturer or similar commercial brake training, and brake work in a carrier maintenance program or at a commercial garage, fleet leasing company or similar facility.
Records
The carrier keeps evidence of the brake inspector's qualifications at its principal place of business or where the inspector works, for as long as the person works in that role and one year after (396.25(e)).
Brake inspector versus annual inspector
The brake inspector rule is separate from the inspector qualification rule for periodic inspections. 49 CFR 396.19 covers the people who perform the annual inspection required by 396.17. A technician may meet one set of qualifications without meeting the other, so carriers should document both where they apply. See qualified inspector.
For repair shops
Brake work is a large share of heavy-duty repair, and brake defects are common on DVIRs and annual inspections. Even though the legal duty sits with the carrier, fleets ask outside shops to show their technicians are qualified. Keep a qualification file for every technician who touches brakes. See 49 CFR 396 explained for shops.