06Sep
Post-Trip Inspections: Policy, Practice, and Documentation
The beginning of the school year is an appropriate time for School Bus Contractors to review post-trip inspection procedures with drivers and aides. Pennsylvania law does not expressly prescribe a specific post-trip walkthrough or child-check procedure on the bus; however, federal law imposes requirements for post-trip inspections of a school bus. In any case, the Contractor’s written policy, training, documentation, and actual practice are especially important.
A useful post-trip procedure begins with clearly assigning responsibility. The policy should identify when the inspection must occur, who must complete it, and how completion will be recorded. For post-trip inspections on the bus, the Contractor should require the driver and aide, as applicable, to physically walk through the passenger compartment and inspect each seating area before securing the bus. When both a driver and aide are assigned, the policy should designate primary responsibility so that each employee does not assume the other completed the inspection. The procedure should also identify how completion will be documented, whether through a written record, electronic log, mobile application, or child-check system. Contractors should account for applicable district policies, training requirements, and transportation-contract obligations when developing or updating their procedures regarding on-bus inspections. Post-trip inspections should not be treated as an unwritten matter of common sense. In K.M. v. Chichester School District, 152 F. Supp. 3d 412 (E.D. Pa. 2015), the federal court allowed claims based on alleged failures in policy and training to proceed after a student was allegedly left asleep on a school bus. The case did not establish liability or require a particular inspection procedure, but it illustrates why Contractors should put expectations in writing and train employees on the required process.
As also noted above, federal law requires a post-trip inspection of a school bus. 49 C.F.R. §396.11. FMCSA regulations provide that drivers must complete a written post-trip driver vehicle inspection report (DVIR) upon completion of each day’s work. 49 C.F.R. §396.11(a). The post-trip inspection cover components like brakes, lights, tires, wipers, etc....Id. DVIRs must identify the vehicle and list any defect or deficiency found during the inspection. However, no DVIR is required if no defect or deficiency is discovered. 49 C.F.R. §396.11(a)(i).
When an inspection is missed or incompletely performed, the Contractor should preserve relevant records and determine what occurred before deciding on retraining or corrective action. The review may include the written policy, prior instruction, GPS data, child-check logs, available video, and the employee’s explanation. Contractors that clearly assign responsibility, document completion, and verify actual compliance will be better positioned to reduce missed inspections and respond consistently when one occurs. If you have questions about post-trip inspection policies, employee training, or documentation, email us at help@rckelly.com or call 215-896-3846.
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