Non-manufactured holes or cracks in the service portion of brake chambers - 49 CFR Part 396.3A1 states parts and accessories shall be in safe and proper operating conditions at all times. The regulation goes onto state it includes anything outside of Part 393 which may affect the safe operation. We are requesting CVSA amend Operational Policy 15 to include 'Non-manufactured holes or cracks in the service portion of brake chambers' as an appropriate use of 396.3A1, not out of service.

Depending on the severity and location of non-manufactured holes and cracks on the service side of an air brake chamber, it can be a serious safety issue for any inspector who happens to be near the brake chamber when the brakes are applied. Furthermore, while the brake chamber may be firmly mounted to the vehicle (and therefore "Loose air chamber, spider, or camshaft support bracket" in the OOSC is not applicable), the brake chamber may pivot on its own crack which reduces the braking force being applied to the brake drum. The measurement may be within tolerance, and the brake lining may still be making enough contact to keep the brake drum from rust, but we have photos of a brake chamber that has a crack so large it can pivot on its self which is greatly reducing the braking efficiency of the brake. CVSA currently allows any non-manufactured holes on the parking brake side of an air brake chamber to be an OOS item, but does not even allow an inspector to note some serious safety concerns related to cracks and non-manufactured holes on the service side of a chamber. The documentation we have clearly shows a brake that is not in safe and proper operating condition, and this vehicle component certainly does have the propensity to negatively affect the safe operation of the vehicle. Noting brakes in this condition (photos attached) meets the criteria of the federal regulation 396.3A1.

We are requesting CVSA amend Operational Policy 15 to include 'Non-manufactured holes or cracks in the service portion of brake chambers' as an appropriate use of 396.3A1, not out of service.

The Vehicle Committee voted to send a petition to FMCSA to create a violation in Part 393 for any non-manufactured hole in a brake chamber housing. This issue will stay open pending a response from FMCSA on the petition.