Amidst all the minutiae that make up the Federal Motor Carrier Safety Administration’s Compliance, Safety, Accountability enforcement program, it’s easy to lose sight of the goal of your fleet’s safety program.
“Let’s forget about CSA for a minute — we’re here so your vehicle doesn’t kill somebody,” says John Seidl, a former state trooper and DOT compliance officer turned consultant. “There are vehicles on the road that are so unsafe that somebody dies. A guy waiting at a bus stop lost his life because of the brakes on the trailer were worn out.”
“In a sense this is a game for you to stay out of the focus of the federal government,” Seidl says. “The mere fact that a company doesn’t have reflective tape on a mudflap isn’t going to kill anyone, but it demonstrates to the government that you aren’t paying attention to the details of this game.
“I’m not trying to say safety’s a game — it’s not. But in this system, you have to find something before they do.”
Who’s responsible?You’ve heard about the 80/20 rule? Forget it. With CSA, it’s more like 95/5 — that is, 95% of your problems are the work of 5% of your driver pool.
“It’s all about the drivers, and it’s almost always just a few of them that will drive the carrier scores,” says Steve Bryan, CEO of Vigillo, a data mining operation that specializes in turning copious amounts of data into usable information about CSA. “It’s really lopsided.”
The problem drivers need to be identified and either brought into compliance or dismissed.
The problem for fleets is drilling down deeply enough into the Safety Management System to get a meaningful picture. There’s just not much detail in the driver data, Bryan says. He strongly recommends fleets take the time to learn how to do it, or hire a service to do it for them.
“You really have to get down to the level of the drivers to understand on a driver-by-driver basis who is contributing to the problem,” he says.
While the driver may be the one holding the smoking gun in most cases, it may not be entirely appropriate to lay all the blame at his or her feet. When you look backwards up the chain of responsibility, the larger picture tells a slightly different story. It’s fleet culture that determines a driver’s propensity for incurring violations. If the fleet allows, tolerates or even encourages malfeasance, and the drivers stand to benefit from such behavior (more miles, fewer logged hours, less paperwork, etc.), they will try to get away with whatever they can.
Vehicle inspectionsThe Vehicle Maintenance BASIC accounts for nearly two-thirds of all CSA points assessed to carriers and drivers. Of those, brakes, lights and tires make up the largest share. While drivers are required to conduct pre- and post-trip vehicle inspections, evidence suggests most of the defects are either not being detected, or if they are detected, they aren’t being repaired. We can throw in some tolerance for lights that burn out somewhere between the time the driver inspected the truck and the officer inspected it, but how does one account for tires with less than 2/32 of tread depth? Those tires didn’t go bald on the way into the inspection station.
In fact, most of the violations on FMCSA’s list of Most Frequent Vehicle Violations in Roadside Inspections are not the type likely to have just happened. That suggests fleets scoring poorly in vehicle maintenance have either a maintenance problem or a training problem — or both.
It’s hard to overstate the importance of proper vehicle inspections in your arsenal of CSA game-winning strategies.
Are the drivers trained to conduct a proper vehicle inspection, including details on how to spot defects and what constitutes a defect? Are the mechanics repairing trucks that have written reports indicating defects are present? Is there a latency problem in getting the reports to the shop? Does the fleet believe the defects are not serious enough to warrant the cost of a roadside repair?
Technology can help with vehicle inspections and maintenance reports.
Telogis, for example, offers a system with a handheld reader and QR code stickers placed strategically around the truck that the driver has to scan to complete the trip report.
“Scanning the codes gets the driver walking around the truck and looking at certain points where the codes are, and the scan proves the inspection was done rather than just pencil-whipping the DVIR,” says Kelly Frey, vice president of product marketing.
Zonar offers a similar walk-around system that uses RFID (radio frequency identification) tags; Detroit’s Virtual Technician system uses this functionality.
Of course, once a driver finds those defects, they have to be fixed. And according to Michael Riemer, vice president of product and channel marketing at Decisiv, there’s still a lot of communication that has to happen between drivers, shop and dispatch that often isn’t.
Drivers are a key part of a successful safety strategy, from their behavior to how well your company handles screening and paperwork.
“They don’t have a closed-loop process,” he says. “When an issue is identified, our application attaches the problem to the asset so everyone who comes into contact with the truck knows what’s going on.”
It’s basically an electronic DVIR that is circulated to everyone concerned, so the maintenance managers see the DVIRs the drivers complete and can see the follow up from the shop. Reimer says the issue isn’t closed until everyone involved has signed off.
The applications can also track driver inspections to see how many were done, and try to determine when the defects weren’t noted.
“We have cause and effect now,” says Riemer. “Were the defects not noticed? Maybe that becomes a training issue. If I know that 100% of my drivers are doing pre- and post-trip inspections, but five of the trucks are consistently getting all the CSA vehicle violations, I can conclude those five drivers probably need some additional training in vehicle inspections.”
Don’t rely solely on drivers to keep an eye on trucks, Seidl says. Mechanics and supervisors are a second and third line of defense — and even higher up in the company.
“Who’s the most important person to change safety culture at a company?” he asks. “The owner. If you’re a company owner, when’s the last time you inspected your own equipment?” If the company owner makes a practice of spot-inspecting trucks with drivers when they’re in the home yard, that sends a powerful message.
And speaking of inspections, don’t forget about the federally required yearly inspection. “I have seen a gazillion companies in trouble with annuals, because these are critical violations,” Seidl says. He suggests doing them twice a year to avoid possible problems with last-minute scheduling to meet the yearly deadline. And make sure the inspection report is in the truck and the sticker is clearly visible to the roadside inspector.
“If that sticker wears off where inspector can’t see it, that’s not going to cause a crash, but it will annihilate your [CSA] score if your mechanics are using a wipe-off board marker instead of a Sharpie.”
Driver violationsKeeping an eye on equipment isn’t the only area where drivers are an important component of your CSA strategy.
FMCSA’s Most Frequent Driver Violations list tells an interesting story. Six of the Top 20 are hours-of-service related. Seven are moving violations, such as speeding.
That leaves seven violations in the driver screening and qualification category, which is entirely the fleet’s responsibility. How did a non-English-speaking driver get hired? How does a driver without a valid medical certificate stay on the road? A good driver screening process should prevent those types of violations.
“When we look at companies with great CSA scores, they have a very effective hiring and screening processes, and an effective onboarding/orientation program, that lasts for three or four or six or seven days,” says John Simms with HNI, a non-traditional insurance broker and consulting company.
These days, speed to hire is critical for fleets. They have to grab the first good driver they see before someone else does, says Mark Carlson, senior director of sales at First Advantage Fleet Services, “Sometimes that can lead to gaps or incomplete screening.”
Outsourcing some of the compliance requirements can provide a level of expertise that’s not always available to a fleet.
“The larger the fleet, the harder it is to track on a spreadsheet,” Carlson notes. “Small fleets sometimes fall down here as they grow and the size and complexity of the files increase. Online digital compliance services provided by our company and others can remove most of that worry.”
On the other end, fleets with driver compliance problems can benefit from data collection now available through various telematics-based resources, and use that information to train and rehabilitate drivers rather than dismissing them and starting over.
“Fleets that use such applications just for enforcement are missing an opportunity to encourage change in behavior through rewards rather than punishment,” Carlson points out. “They are only using half of the tool’s capabilities.”
Obvious defects are an invitation to an inspection. Equipment that’s clean and apparently well maintained will often pass visual triage by the DOT.
Sticks and carrotsRewards work, but unless the process is fair and transparent, you could be setting yourself up for more problems. Jim Burg, president and CEO of James Burg Trucking, a 90-truck high-GVW flatdeck fleet based in Michigan, has seen success in changing driver behavior with rewards and penalties.
“We financially reward good behavior and punish poor behavior,” he explains. “A key element of our safety bonus is directly tied to CSA. A driver is given a certain amount of money per week. CSA violations or other company safety/performance issues reduce the amount allotted to them.”
For example, Burg told us for every CSA point drivers incur while they are with the company they lose a dollar a week, and that stays with them for the life of the points, based on the company’s two-year point cycle.
“A five-point ‘Log Not Current” violation would cost the driver about a thousand dollars over the two-year life of the points,” he says. “That may not sound like a lot, but it’s often enough to get the driver’s spouse’s attention too.”
Burg also uses a DriveCam video monitoring system. The company sets the intervention thresholds, so not everything that happens makes it to his desk. Significant incidents do, and the first step is a review with the driver.
“The reviewing allows the company to evaluate what the driver can do to improve their skills,” he says — although he notes that nearly all events they review were initially caused by another motorist driving poorly. For those times where a driver’s skills or attitude do need some work, driver training is another important strategy.
Like any game, winning at CSA takes a lot of effort and expense, but it’s quickly becoming part of the cost of doing business. And if you make sure those strategies also reinforce a culture of safety that reduces crashes, it should pay for itself in savings in lives, injuries, repairs, downtime, litigation, insurance costs and more.
“When a shipper comes to me and says their legal team will no longer allow them to use my competitor, and they ask how much capacity I can spare and at what price, then I will be convinced that it’s working,” Burg says.