March/April 2014
Fleet managers can monitor their CSA results and take action to keep vehicles in compliance with federal law to reduce violations—and reduce the likelihood of a crash.
By Nancy Mann Jackson
The ultimate goal of the Federal Motor Carrier Safety Administration’s Compliance, Safety, Accountability program is to ensure that drivers practice safe driving behaviors while operating safe vehicles, says Commodor Hall, ISRI’s transportation safety manager. CSA, which the Washington, D.C.-based FMCSA launched in 2010, collects data on carriers and drivers and scores them using seven behavioral analysis and safety improvement categories, or BASICs. The BASIC scores are not actual safety ratings, the FMCSA points out, but high percentile scores indicate a lack of compliance and greater exposure to potential safety problems. In other words, Hall says, the higher the score, the greater the risk of a crash. Compliance doesn’t guarantee a crash won’t occur, he adds, but faulty and poorly maintained vehicles put carriers and drivers at greater risk. Even more worrisome, he says, is that noncompliance could indicate that carriers “have subpar or nonexistent safety programs.” Making CSA a part of a company’s safety program is one more way of keeping workers safe.
Safety “requires not only complying with the regulations but incorporating them and good safety practices into [a company’s] culture,” says Steve Keppler, executive director of the Commercial Vehicle Safety Alliance (Greenbelt, Md.). “It cannot be an afterthought. Companies need to view safety and compliance as an investment and not a cost, he says, adding that “generally the safest companies also tend to be the most profitable.”
CSA scores are one more tool in a company’s transportation safety toolbox, says Steve Forystek, director of health, safety, environment, and transportation for PSC Metals (Cleveland). Safety and compliance naturally work together to keep drivers and others safe, he adds. Companies that use their CSA data effectively will strengthen the caliber of their fleets, making them and the roads on which they travel safer, these transportation professionals say.
Dissecting the Data
During the first two years of the CSA program, 71 percent of the violations were maintenance-related, according to the FMCSA, and of the 10 most frequent violations, seven were maintenance-related. Those seven involved out-of-compliance clearance identification lamps (lights that help delineate the width of the vehicle), reflective sheeting (reflective tape around the edges of the vehicle), brakes and brake hose or tubing, wheel studs/clamps, brakes out of adjustment, tires, and lighting. The remaining three of the 10 most frequent violations were driver-related: incomplete driver log, speeding, and other log violations. Those nationwide findings seem to correspond with the experience of Page Transportation. Though the company says it makes safety a priority, when its drivers have received violations, they tend to relate to hours of service—drivers putting too many consecutive hours behind the wheel—or equipment such as a burned-out light, says Chris Jorolemon, vice president of operations for the Weedsport, N.Y.-based carrier. “Just a couple of bad roadside inspections can put you over the threshold, putting you at risk of a [Department of Transportation] audit,” he says.
That top-10 list could spark a conversation among drivers, fleet managers, and maintenance workers about how to avoid those particular violations, but Annette Sandberg, CEO of TransSafe Consulting (Davenport, Wash.), a transportation safety consulting firm, and former FMCSA administrator, warns to not read too much into it. Compliance data vary significantly from state to state and don’t necessarily reflect the most serious issues, she says. Each state focuses on enforcing different regulations, she explains, which could lead to scores that don’t accurately reflect safety practices. For example, nationwide, there were about 12 light violations for every one speeding violation, but in Texas, there were about 321 light violations for every speeding violation, and in Indiana, there were about two light violations for every speeding violation, according to CSA: Assessing the New Safety Measurement System and Its Implications, a white paper published by the American Transportation Research Institute (Arlington, Va.). “We see significant state disparities,” Sandberg says. “Some states really focus on vehicle violations, and others focus on driver [violations].”
More valuable for safety and compliance purposes are an individual company’s CSA results. Transportation managers must “manage the data and make some sense about what the data mean to [their] drivers and [their] fleet,” Sandberg says. Fleet managers “must really carefully watch for trends in violations and quickly address them,” she says. “If they don’t, you suddenly will see CSA scores over the threshold. Once your scores go over threshold, it targets your trucks for even more inspections, and even more important, it may target your company for a full DOT audit to look at all your regulatory compliance, not just roadside compliance.” A fleet’s CSA data are important to outside parties as well, she says. For example, many insurance carriers view CSA scores when making decisions about insurance coverage, she notes.
Forystek says he and Dave Tarvin, PSC’s DOT compliance manager and a 30-year-veteran truck driver, monitor PSC’s CSA scores via an internally developed dashboard and respond accordingly. For example, if they notice a PSC facility’s score that’s nearing the threshold, they work with that yard to address problems contributing to the score. Likewise, if they notice a yard with scores well below threshold levels, they acknowledge it. “We regularly monitor and audit our compliance with the FMCSA regulations; we closely monitor the fleet’s condition; and [we] perform repairs promptly,” he says.
Managers need to use the CSA information “to drill down and see what the common problems are and then put corrective measures in place to combat [them],” says Lisa Merkle, DOT compliance manager for OmniSource Corp. (Fort Wayne, Ind.). Forystek agrees. “You can use your CSA data to focus your efforts on problem areas.”
The CSA data are “great stuff,” Forystek says. “To get this kind of data [otherwise], you’d have to hire a third party to follow and inspect your trucks on the road. This is an impartial third party doing your work for free. So if you understand how to use the system, you can evaluate your company based on the system’s data and make improvements accordingly.” On the other hand, he says, “if you don’t like the results, then you need to do a better job maintaining your trucks, training your drivers, or purchasing new equipment.”
Ensuring Compliance
Once you know your company’s compliance weaknesses, how can you ensure they’re remedied? Fleet safety and compliance begin with hiring practices, Sandberg says. Fleet managers should “make sure they carefully screen and monitor their drivers,” she says. “If you hire good drivers that understand the importance of proper driving techniques, following the rules, and maintaining their equipment, this goes a long way to having a safe and compliant operation.” Forystek agrees that “a solid team of transportation professionals” makes a difference when it comes to compliance. “It all starts with the right people,” he says. “The right managers hire and retain the right drivers, which makes the process much more manageable.”
Good hiring alone isn’t enough, however. Training—including training about regulatory compliance—should be ongoing, these safety professionals say. According to the results of one ATRI survey, truck drivers’ CSA compliance training has been insufficient. Each year since CSA took effect, it has asked truck drivers to complete a 14-item test to gauge their knowledge of the program. On average, drivers accurately answered 5.71 items in 2011, 6.55 items in 2012, and 5.94 items in 2013. About 34 percent of drivers surveyed say they have not received any form of CSA training, according to the report.
Page Transportation provides ongoing training that targets compliance requirements, such as working within the hours-of-service regulations, in addition to its new-driver training program, Jorolemon says. PSC Metals’ internal transportation compliance program includes a detailed transportation manual and a driver handbook. As OmniSource’s Merkle puts it, “It is important to keep the communication flowing so drivers are aware of what the requirements are. … Knowing the regulations and understanding them is part of the responsibility of owning or operating a commercial truck.”
Just as drivers should know what’s expected of them and be held accountable for their compliance and safety performance, Hall says, companies need to support drivers by making sure they’re driving well-maintained vehicles. Maintenance is “a shared responsibility” of drivers and maintenance, operations, and safety staff, Jorolemon says. The drivers’ primary role in maintenance is performing pre- and post-trip inspections. Those, when backed with regular maintenance, go a long way toward keeping companies safe and compliant, Hall says—and they’re required by federal law. As drivers become adept at conducting pre- and post-trip inspections, they shouldn’t take more than 15 to 20 minutes, he adds. OmniSource’s driver handbook outlines what its drivers must cover in the inspections, Merkle says.
Even though the inspections are required by law, some carriers say it takes an extra incentive to make sure drivers take them seriously. “We’ve implemented a program to reward our drivers for no-violation stops, which enhances the daily vehicle inspection process,” Forystek says. Drivers who undergo Level 1 or 2 roadside inspections without any violations receive a polo shirt inscribed with “Transportation Excellence.” At Page Transportation, leaders also have put more emphasis on ensuring that pre- and post-trip inspections are being performed—and performed correctly. Further, Jorolemon says, “if we have a driver who receives bad roadside inspections, we now have an internal punishment system with a series of fines they have to pay. Our internal compliance is tougher than DOT.”
After the drivers do their inspections, fleet and safety managers must ensure that the maintenance department follows through on their reports, says Kevin Speis, transportation manager for Grossman Iron & Steel Co. (St. Louis). “The most important inspection of the day is the post-trip inspection because it sets us up for success the next day,” he says. “If we’re not diagnosing and repairing the faults our drivers list on a daily post-trip inspection, then we’re failing in our preventive maintenance program. We’re sending a message to our drivers that we don’t value their safety by allowing them to operate substandard or faulty equipment.”
One more way transportation managers can boost compliance is by getting out in the field as often as possible, Speis says. “I walk our lot every day and spot-check our equipment,” he says. “I talk to our mechanics in our maintenance department and seek their input on maintenance issues and trends they may see that we’re not recognizing. Nothing beats taking a trip with the driver and observing firsthand the condition of our equipment and the condition of the environment in which they work.”
Knowing the Rules
Because FMCSA regulations change frequently, staying current can be challenging, Sandberg says. “You cannot wait for when DOT shows up in your operation to find out a rule has changed and you were not aware of it,” she says. Transportation managers should stay up to date on the latest regulations, but so should senior managers and drivers, Keppler says.
Scrap companies that don’t have their own trucks or drivers also should pay attention to FMCSA regulations and monitor the scores of their carriers, Jorolemon says, because when they understand the regulations, it can help transportation companies serve them better. For instance, when a recycler needs a load delivered immediately but the driver has to wait several hours for the truck to be loaded, the hours-of-service regulation might make it impossible for that driver to meet the recycler’s demands. “Our drivers have a federally mandated 14-hour workday, and once they start working, we can’t stop the clock, regardless of weather issues, traffic, or waiting times to load or unload,” Jorolemon says. “If they have to wait four hours to get loaded, that cuts down on their driving time, and we can’t make an exception or we will receive an hours-of-service violation. The best service requires coordination between us and the scrap companies.”
Companies that hire outside transportation vendors still have to pay attention to compliance, Keppler points out. “If an independent transportation company is working or being leased to another motor carrier, the motor carrier who hires them is responsible and accountable for their safety performance and will affect their CSA scores,” he says. “Also, FMCSA is in the process of promulgating a series of regulations that will provide [the agency] with more authority to take enforcement action against companies and individuals who affect compliance.”
The Bottom Line
These transportation professionals can only speculate about why so many vehicles are being found out of compliance. Sometimes trucks or containers spend more time on the road or in customers’ yards than in their own yard for regular maintenance, says PSC’s Forystek. “It can be a challenge to maintain a fleet of boxes when they may be at a customer site for extended periods.” Also, unfortunately, some companies might view vehicle maintenance as a place to cut the budget when money is tight, Speis says. “For example, running tires below the minimum operating standards of tread depth is a clear indication of deferring cost,” he says, “but it increases the risk of bad things happening,” such as a tire blowout due to excessive tire wear. Trying to balance economic challenges and compliance requirements could lead some companies closer to the violation line. “Companies are trying to extend the life cycles of these components rather than replacing them as regularly as they might have in a better economy,” Merkle says.
These safety professionals point out that compliance can have a positive effect on a company’s bottom line. Motor carriers that operate with few violations will attract more business, Keppler says. Conversely, carriers with multiple violations could see their insurance rates go up or the caliber of drivers they attract or retain go down. Also, the safer and more compliant a carrier is, the greater the potential it has to be productive, he says, because well-maintained vehicles keep drivers and trucks on the road. Compliance “helps maintain delivery schedules and manage costs.” Not complying, on the other hand, could result in businesses not operating or drivers losing their jobs, Sandberg says.
Beyond the monetary costs of noncompliance and benefits of compliance, keep in mind why the CSA program was created: for the safety of the commercial vehicle drivers and others on the roadways. “Everyone has a stake in this game,” Sandberg says. “Highway safety is really everyone’s responsibility. So the recyclers have an interest in making sure they are partnering with safe independent transportation companies. We still have a significant number of highway deaths in this country, and it is everyone’s job to do their part to improve safety and make sure their operations and partnerships foster safe behavior.” Ultimately, working together to promote safe commercial vehicle operation translates into better business and saving lives, Speis says. “Our drivers aren’t only concerned about their own safety but also the safety of every motorist around them. It’s more than following regulations. It’s about completing the day incident- free and coming home alive to our families.”
Nancy Mann Jackson is a writer based in Huntsville, Ala.
CSA Basics
Unsafe driving, including speeding, reckless driving, improper lane change, or inattention.
Hours-of-service compliance, including drivers who are ill, fatigued, or in noncompliance with hours-of-service regulations, as well as violations of regulations pertaining to records of duty status as they relate to HOS requirements and the management of commercial-motor-vehicle driver fatigue.
Driver fitness, including lack of training, experience, medical qualifications, or failure to have a valid and appropriate commercial driver’s license.
Controlled substances/alcohol, including drivers who are impaired due to alcohol, illegal drugs, or misuse of prescription or over-the-counter medications.
Vehicle maintenance, including failing to properly maintain a commercial motor vehicle and/or properly prevent shifting loads; brakes, lights, or other mechanical defects; failure to make required repairs; and improper load securement.
Hazardous materials compliance, including the unsafe handling of hazardous materials on a commercial motor vehicle, including the release of hazardous materials from package, no shipping papers (carrier), and no placards/markings when required.
Crash indicator, including histories or patterns of high crash involvement, including frequency and severity based on information from state-reported crashes.
Source: Federal Motor Carrier Safety Administration
Fleet managers can monitor their CSA results and take action to keep vehicles in compliance with federal law to reduce violations—and reduce the likelihood of a crash.