Safety systems that reduce CSA violations
Safety is the top priority for motor carriers. Running a safe operation requires thorough knowledge and understanding of the Federal Motor Carrier Safety Administration (FMCSA) regulations. In addition to educating drivers on these regulations, there are specific company fleet safety policies and procedures that must be reviewed; such as the completion of roadside inspection paperwork to insure that both the fleet and drivers are in compliance with all FMCSA regulations, as well as ongoing driver training on how to operate the equipment and its added safety specifications in the proper manner.
In 2010, FMCSA launched Compliance, Safety, and Accountability (CSA) establishing a nationwide system for motor carrier road safety directed at both the vehicle operator and general public that incorporated a new measurement system for monitoring and scoring motor carriers. Within CSA stands the Safety Management System (SMS) that measures the on-road performance of carriers and drivers using the motor carrier’s two-year rolling data including its roadside inspections, all safety-based violations, reported crashes and the federal motor carrier census. The SMS considers the following five items to quantify and measure performance in the Behavior Analysis and Safety Improvement Categories (BASICs):
- The number of safety violations and inspections;
- The severity of safety violations or crashes;
- When the safety violations occurred (with recent events weighted more heavily);
- The number of trucks/buses a carrier operates as well as the number of vehicle miles traveled; and
- Serious violations uncovered during investigations.
CSA Basics
- Unsafe driving — Operation of commercial motor vehicles (CMVs) by drivers in a dangerous or careless manner.
Example violations: Speeding, reckless driving, improper lane change, and inattention. (FMCSR Parts 392 and 397). Public view. - Hours-of-service (HOS) Compliance — Operation of CMVs by drivers who are ill, fatigued, or in non-compliance with the HOS regulations. This BASIC includes violations of regulations pertaining to records of duty status (RODS) as they relate to HOS requirements and the management of CMV driver fatigue
Example violations: HOS RODS, and operating a CMV while ill or fatigued. (FMCSR Parts 392 and 395). Public view. - Driver fitness — Operation of CMVs by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualifications.
Example violations: Failure to have a valid and appropriate commercial driver’s license (CDL) and being medically unqualified to operate a CMV. (FMCSR Parts 383 and 391). Public view. - Controlled substances/alcohol — Operation of CMVs by drivers who are impaired due to alcohol, illegal drugs, and misuse of prescription or over-the-counter medications.
Example violations: Use or possession of controlled substances/alcohol. (FMCSR Parts 382 and 392). Public view. - Vehicle Maintenance — Failure to properly maintain a CMV and/or properly prevent shifting loads.Example violations: Brakes, lights, and other mechanical defects, failure to make required repairs, and improper load securement. (FMCSR Parts 392, 393 and 396). Public view.
- Hazardous materials (HM) Compliance — Unsafe handling of HM on a CMV. Example violations: Release of HM from package, no shipping papers (carrier), and no placards/markings when required. (FMCSR Part 397 and Hazardous Materials Regulations Parts 171, 172, 173, 177, 178, 179, and 180). Not public view.
- Crash Indicator — Histories or patterns of high crash involvement, including frequency and severity. It is based on information from State-reported crashes. Not public view.
The goal of the CSA program is to target safety threats of both motor carriers and their drivers to reduce CMV (Commercial Motor Vehicle) crashes and fatalities. The success of the program is dependent on the motor carriers, drivers, FMCSA, law enforcement partners, and other stakeholders including the insurance industry. The equipment manufacturers are actively involved in improving highway safety by continuously improving vehicle safety additions in the design and engineering of new equipment. Manufacturers are equipping vehicles with state-of-the-art safety features including ABS brakes, air bags, on-board computers, tire pressure monitoring, collision avoidance, roll stability, in/out side camera technology and lane departure warning systems. Fleets equipped with these technologies are experiencing a dramatic reduction in highway violations and accidents. Realizing the dramatic public safety benefits of incorporating this new technology, motor carriers are sparing no expense and are including these features in their new equipment specifications. Aside from reducing accidents, motor carriers are also realizing additional benefits. They are saving time and money on driver recruiting and training as drivers opt to sign with fleets that have newer model equipment. Newer trucks equipped with upgraded safety features reduce the chances of driver CSA violations they are subject to when driving for carriers that use older equipment requiring the driver to be vigilant on maintenance and repair item violations to protect his/her standing.
Safety is important to the transportation industry and CSA continues to be a hot topic. However, motor carriers, drivers, transportation industry organizations and congress continue to challenge both the integrity of CSA data received from roadside inspections and how it is being measured. Of course, FMCSA uses this data for prioritizing interventions, but the transportation industry questions the other uses of the data. In many instances, the data does not portray an accurate picture of the motor carrier’s record and shippers, insurers and courts are using this data to support decisions made about them, leading to lost income and lost wages.
Many industry organizations are asking FMCSA to keep motor carrier scores from public view as they deem the data is unreliable and five of the BASIC scores in CSA are in public view. In opposition are safety advocates who find it important to have access to this information to monitor poor performing motor carriers. While it is beneficial to have public access of safety information data, its integrity is paramount and can be the difference between a thriving business and one that is forced to close its doors.
Even though the crash indicator BASIC scores are not public, they factor into the motor carrier scores and are visible to both law enforcement and the motor carrier. The concern over how FMCSA reports and calculates crash data is growing.
It has been cited in discussions that crash “exposure” (high traffic vs. low traffic) should be taken into account along with vehicle miles traveled (VMT) when determining the crash indicator BASIC score, as high traffic areas such as major metro areas have a greater crash risk than rural areas. And while crash ‘fault’ or ‘preventability’ is not accounted for in BASIC, the information needed to determine fault is readily available in 9 out of 10 police accident reports, and a recent FMCSA study concluded that adding preventability determination would be too time-consuming and expensive, and would not improve the agency’s ability to identify carriers most at risk for future crashes. Currently, the BASIC score includes crashes that are assigned to the Motor Carrier US DOT #, even though the driver or equipment may not have been at fault and FMCSA considers preventability only during a compliance review with regard to the motor carrier’s safety rating.
The data that comprises the CSA BASIC scores follows the motor carrier’s US DOT # for a rolling two year period and all violations and crashes are recorded on the driver’s Pre-Employment Screening Program (PSP) report and follow the driver for a rolling three year period for violations and a five year period for crashes. Since PSP reports are used by many motor carriers as a screening tool for driver applicants, it is essential that information contained therein is accurate. To insure data accuracy, both the motor carrier and drivers must review their CSA and PSP monthly. If incorrect violations are charged, they can request a FMCSA DataQ review online. DataQ was formed by the FMCSA so motor carriers and drivers may dispute inspection violation and crash data that they deem incomplete or incorrect. DataQ automatically forwards the Request for Data Review (RDR) to the appropriate office for resolution and gathers updates and responses. If, in fact, the violation or crash data was recorded incorrectly, the driver or motor carrier will be notified and the entry will be removed on the following update. For example, if an incorrect US DOT # was entered while logging a maintenance violation, that violation would be corrected.
While there are ways to correct inaccurate information, drivers and carriers must be vigilant about monitoring their monthly scores and annual updates of VMT. DataQ should be used as necessary to ensure any incorrect roadside inspection violations are revised in a timely manner to keep information current and accurate.
It is important that motor carriers foster a culture of safety and compliance within their company by learning and understanding FMCSA regulations, disposing of older, maintenance intensive equipment and specifying new equipment with the latest technologies and safety features, as well as training drivers to use the equipment properly and rewarding those with impeccable safety records. Doing so will improve driver retention and satisfaction and overall highway safety—saving lives, time and money.
About the author
Sandy Rosenfeld has more than 25 years of experience in private fleet management. Sandy is a Certified Transportation Professional and an expert on Department of Transportation (DOT) regulations and Compliance Safety Accountability (CSA) compliance. In addition, she adds a customer-based perspective to fleet management analytical reporting, one of the foundations of Fleet Advantage’s lifecycle management philosophy. For more information visit www.FleetAdvantage.net.