|Title:||United States top 10 most common Compliance Safety Accountability motor carrier roadside inspection equipment violations in percentages for 2011|
|Source:||Commercial Carrier Journal|
Start of full article - but without data
MOST COMMON CSA ROADSIDE INSPECTION VIOLATIONS
TOP XX EQUIPMENT VIOLATIONS
(BASIC SEVERITY WEIGHT IN PARENTHESES)
X. INOPERATIVE REQUIRED LAMPS (X) XXX,XXX XX.X%
X. NO/DEFECTIVE LIGHTING DEVICES/ REFLECTIVE X.X% DEVICES/PROJECTED (X) XXX,XXX
X. TIRE - OTHER TREAD DEPTH LESS THAN X.X% X/XX-INCH (X) XXX,XXX
X. INSPECTION/REPAIR AND MAINTENANCE PARTS X% AND ACCESSORIES (X) XXX,XXX
X. FAILING TO SECURE BRAKE HOSE/TUBING X.X% AGAINST DAMAGE (X) XXX,XXX
X. OIL AND/OR GREASE LEAK (X) XXX,XXX X.X%
X. CLAMP/ROTO-CHAMBER TYPE BRAKE(S) OUT X.X% OF ADJUSTMENT (X) XXX,XXX
X. OPERATING A CMV WITHOUT PERIODIC X.X% INSPECTION (X) XXX,XXX
X. NO/DISCHARGED/UNSECURED FIRE X.X% EXTINGUISHER (X) XXX.XXX
XX. STOP LAMP VIOLATIONS (X) XX,XXX X.X%
XX. OTHER X,XXX,XXXX X.X%
ALL TRUCKS, 2011 YEAR-TO-DATE AS OF OCT. XX
Note: Table made from pie chart.
Dec. XX marks one year since the Federal Motor Carrier Safety Administration launched its Compliance Safety Accountability (CSA) program, replacing the decade-old Motor Carrier Safety Status Measurement System (SafeStat) with a more comprehensive Safety Measurement System (SMS) designed to contact more carriers, identify those with serious violations and intervene to correct carrier-specific safety problems.
While recent research shows CSA has had a positive impact on carrier safety performance, the program has drawn plenty of criticism for not meeting its initial enforcement goals and for being implemented before it was ready. The program remains incomplete and has left many carriers wondering if they are required to focus on compliance efforts that don't necessarily correlate to safety performance.
Push and pull
Trucking industry groups and carriers have raised a number of issues with CSA in the last year. As CSA data continues to accumulate and carriers gain experience with the new program, many are questioning the validity of some of the severity weights assigned to violations in the SMS methodology. For example, in the Driver Fitness Behavior Analysis and Safety Improvement Category (BASIC), operating a commercial motor vehicle with more than one driver's license has a violation severity weight of X.
"I don't know anyone who crashed because they had an old CDL in their pocket" says Brett Sant, vice president of safety and risk management for Phoenix-based Knight Transportation. "Meanwhile, following too closely only has a severity weight of X. If I'm trying to get my drivers to be safe, there are two things I focus on - a safe following distance and proper speed for conditions."
Another shortcoming is CSA's scope. Although the program improved on SafeStat's narrower enforcement capabilities, it still isn't able to monitor and inspect a large population of fleets. According to CSA analysis from Randall-Reilly Trucklntel, less than XX,XXX motor carriers out of a total population of more than XXX,XXX have accumulated XX or more roadside inspections over the last XX months, and more than two-thirds of the carrier population tallied two or fewer inspections in the same period.
To its credit FMCSA has been a willing partner with the industry to improve data quality and fairness issues within CSA.
For example, the agency responded to industry and law enforcement requests in August by amending the criteria that determines which motor carriers are subject to the more stringent Hazardous Materials intervention threshold, basing it on operational evidence of carriers that transport placarded quantities of hazardous materials. Previously, the threshold was applied based only on a carrier's registration information indicating it transported any quantity of hazardous materials.
Industry concerns including Driver Fitness ratings, potential changes to the Cargo-Related BASIC and carriers' ability to challenge crash causation remain on the horizon. Until these issues are resolved, it's unlikely that the last remaining component of CSA - a Safety Fitness Determination (SFD) - will be settled.
FMCSA was expected to announce a SFD Notice of Proposed Rulemaking by the end of this year or early next year, with a final rule to be published in 2013. Unlike the existing SFD, the planned rule isn't tied to onsite investigations and compliance reviews, and will be based on violations of all safety regulations.
Despite CSA's drawbacks, it is an improvement in identifying and correcting more high-risk carriers than SafeStat, according to the University of Michigan Transportation Research Institute's study of FMCSA's XX-month Operational Model Test in nine pilot states. CSA's new intervention tools - including warning letters, targeted roadside inspections and onsite focused investigations - have helped the agency stretch its resources and affect carrier safety performance better. The study showed that XX percent of carriers resolved identified safety problems XX months after receiving warning letters, and XX percent fewer carriers had safety problems XX months after an onsite focused investigation.
However, UMTRI's study also echoed industry concerns that some BASICs, particularly Cargo-Related and Driver Fitness, show a weaker relationship to crash risk. Additionally, improvement rates among carriers with the worst safety performance were similar to the study's control group.
Larger carriers are at an inherent disadvantage under CSA. The more vehicle miles a carrier travels, the greater their exposure becomes for roadside inspections and risks of receiving violations.
A CSA survey of XXX motor carriers published last month by the American Transportation Research Institute revealed that larger carriers were more likely to be above the threshold in at least one BASIC. According to the study> small and medium-sized carriers with XXX or fewer power units self-reported less than one BASIC alert on average, while large fleets with more than XXX power units self-reported ! more than one BASIC alert X on average. Fleets with XXX to X,XXX power units self-reported X.X BASIC alerts on average. The data also indicated truckload, specialized and flatbed haulers were more likely to have at least one alert, while private fleets self-reported only X.X BASIC alerts on average. (To obtain a copy of the survey results, go to www.atri-online.org.)
"What we see is the larger motor carriers are the ones that have enough data to actually trigger CSA," says Jeff Davis, principal for Fleet Safety Services. "The rest of the motor carriers are flying under the radar at this point in time."
Customers, insurance companies take notice
Before CSA's rollout, shippers and brokers relied largely on SafeStafs safety ratings when selecting carriers to haul freight. With public SMS performance results now published on a monthly basis with CSA, these groups are taking a closer look at the data for fear of vicarious liability in the event that a carrier they selected that exceeds one or more BASIC thresholds is involved in a crash.
Shortly before CSA's launch, three industry groups filed suit against FMCSA to block public data release over fears that shippers and brokers would misinterpret the "Alert" symbol in one or more BASICs as a de facto negative safety fitness determination. In March, the two sides settled on replacing the "Alert" symbol with an exclamation point inside a gold triangle and a disclaimer stating the new symbol does not imply a federal safety rating.
However, shipper and broker use of SMS data in the carrier selection process remains an unintended but largely unavoidable quence of carriers' readily available CSA performance data.
"We've taken a brand new system that has been on the street for a year, and shippers and brokers are literally using that data to decide whether or not they will give you freight or whether they will remove it" says Davis.
Insurance companies also are beginning to take notice. According to the ATRI survey, insurance costs for carriers with clean BASIC scores largely were unchanged. However, XX.X percent of carriers with one or more BASICs above the intervention threshold saw insurance costs rise.
"Carriers with conditional ratings or BASICs above intervention thresholds are beginning to run into insurance problems for the first time" says Davis.
Avoiding high-frequency violations
Perhaps the best lesson to be learned by carriers in the last year is identifying the most common roadside inspection violations and employing technology and driver training procedures to mitigate damage to CSA scores.
Davis estimates X percent of roadside inspections currently are generated randomly Of the remaining factors that trigger inspections, roughly one-third are for speeding, one-third for observable defects and one-third determined by a carrier's Inspection Selection System score.
"If we can control our speed and our lights, we are controlling two-thirds of the pie," he says. "That is the magic bullet to CSA."
According to JJ. Keller, more than half of all driver violations cited during roadside inspections are related to hours of service. It's no surprise more carriers are adopting electronic onboard recorders as a means to reduce or eliminate many hours-related violations altogether. (See "Demand grows for low-cost EOBRs" p. XX.)