Facts on Brake Inspection Requirements, Reporting For MTO’s New Annual Safety Inspection Standards

As previously reported by OTA, MTO introduced revised annual inspection standards for trucks and trailers in October 2014. This is part of an ongoing multi-year effort to bring MTO’s annual inspection standards in line with National Safety Code Standard 11B

As requested by OTA, MTO will be taking a practical approach to the introduction of these changes by providing an educational period until December 31, 2015 to provide time for commercial vehicle operators and drivers to update their annual inspection programs.

One of the key elements of the new inspection standard is the inspection of brake components. As a result of the new requirements, there has been a significant amount of confusion about what is actually required. In some cases this confusion has led many in the industry to believe that inspections will take longer, become more expensive and, in order to comply with the brake inspection requirements, the wheels on the vehicle must be removed in all inspections. This is simply not the case.

The information below outlines the facts about what is required and what is not. This information is being provided to ensure carriers have a full understanding of all of the compliance options available.

  1. First carriers need to be aware of the types of brake inspections included in MTO’s new standard (known as PMVI – Periodic Mandatory Vehicle Inspections).

There are three types of inspection for drum brakes:

A) Full inspection with drum removed (This is a detailed inspection of all internal components and includes measuring drums and shoe lining.)

B) Wheel-on full inspection (This is only available for cam-type drum brakes with removable dust shields. This type of inspection requires removal of the dust shields to inspect the internal brake components, and includes measuring drums and shoe lining.

C) Limited brake inspection of drum brake (This is only permitted when there is proper and valid documentation. See below. This type of inspection is conducted using inspection holes and involves a measurement of brake lining on one shoe only.)

There are two types of inspections for disc brakes:

D) Full inspection with wheel(s) removed (This is a detailed inspection of all internal components and includes measuring rotor and pad friction material thickness)

E) Limited brake inspection of disc brake (This is only permitted when there is proper and valid documentation. This type of inspection includes measuring one of the brake disc pads.)

2. Carriers need to be aware of the documentation that is required to allow a limited brake inspection to be conducted. Without the required documentation, a limited brake inspection is prohibited.

The required brake inspection report can only be completed by a qualified technician at a Motor Vehicle Inspection Station (MVIS) when a full inspection with drum and wheel removed (inspection type A or D above) is conducted. This can be during a brake overhaul or any type of work where the wheel is removed. All of the information listed in Section 3.C of the PMVI standard (pages 78-79) must be on a Proof of Brake Inspection Report. The report can cover one, several or all of the brakes on a vehicle. A report is valid for 19 months for a drum brake and 7 months for a disc brake. (there is no standard format for the form, however forms will be available from the OTA Store.)

3. Carriers need to be aware that when any defect is found on a brake, the wheel and drum must be removed for a full inspection in every case. The list of defective conditions that requires wheel removal is listed in Section 3.A.2 of the PMVI standard.

4. There are always options to do more than the minimum required inspection. Given the information above, carriers will be able to determine what inspection options are available and choose what is most appropriate.

For example:

  • A vehicle with drum brakes and no inspection documentation requires removal of either the drums or the dust shields.
  • A brake with removable dust shields can be inspected after removing dust shields at each inspection.
  • In the case of a disc brake, the wheel would have to be removed if no inspection documentation is available.

Notes and Additional Resources:

This memo is intended to help with understanding of Section 3 of the PMVI standard. For full details refer directly to Section 3 of the Standard: CCMTA-PMVI-Section 3 Brakes_public

MTO has also provided a slide deck concerning this issue (pages 16 thru 25) that can be accessed here: MTO PMVI Presentation_public

Required brake measurement referred to above must be recorded on the inspection report. Drum brake lining measurements are to be taken at the side of a brake shoe near the center (approximately where the inspection hole would be located). When there is a difference between the adjacent brake lining or brake pad thicknesses, record the thinner of the two.

MTO will be providing an educational period until December 31, 2015.

OTA has several compliance products available to assist carriers in the transition to the new annual inspection standard.

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