BASIC 5: VEHICLE MAINTENANCE

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1 Comprehensive Safety Analysis Initiative BASIC 5: VEHICLE MAINTENANCE Staying on top of safety and compliance under the CSA 2010 initiative will mean getting back to the BASICs. This synopsis will focus on the Vehicle Maintenance BASIC. Vehicle inspection and maintenance is a critical component of any motor carrier s safety program, and it s vital to driver and public safety on the road. Left undiscovered and unfixed, a critical safety-related defect could have dire consequences. And yet, maintenance violations are consistently among the most-cited of all violations found during audits conducted by the Federal Motor Carrier Safety Administration (FMCSA). For many years, failing to require drivers to complete a daily post-trip inspection report has been the #1 most-cited critical violation found during such audits. Companies routinely end up paying thousands of dollars in fines for the violations and taking a hit on their safety ratings. Among the top critical violations found during FMCSA audits in 2009: #1 No DVIRs #5 No annual inspections #10 No maintenance records While a paperwork violation may not seem like a critically important issue, it can be a sign of a deeper, more insidious problem: a failure to keep commercial motor vehicles (CMVs) in safe operating condition. And as we all know, unsafe vehicles can lead to crashes, injuries, and fatalities, which in turn can lead to more fines and penalties, increased inspections, expensive lawsuits, and a host of other consequences. All it takes is one missed inspection that otherwise might have caught a fluid leak or a faulty tire. Because vehicle maintenance is such an integral part of a compliant motor carrier safety program, the FMCSA is making vehicle maintenance one of seven categories on which your company and its drivers will be judged under the agency s Comprehensive Safety Analysis (CSA) 2010 program. The CSA 2010 initiative is designed to monitor driver and motor carrier safety performance and stop unsafe actions like failing to have a compliant maintenance program before they can result in a crash. Knowing exactly how vehicle maintenance fits into the CSA 2010 puzzle is a critical step in understanding how to survive under the FMCSA s new enforcement initiative. What is Included in the Vehicle Maintenance BASIC? Under CSA 2010, the FMCSA says a vehicle maintenance violation is vehicle failure due to improper or inadequate maintenance. Among the 273 distinct violations under this BASIC are: Defective brakes, lights, and other mechanical components Failure to make required repairs Failure to inspect the vehicle or prepare inspection reports Just the BASICs Vehicle Maintenance is one of seven violation categories in which your company and drivers will be graded under CSA The seven Behavioral Analysis and Safety Improvement Categories, or BASICs: Unsafe Driving Fatigued Driving Driver Fitness Drugs & Alcohol Vehicle Maintenance Cargo & Hazmat Crash History x

2 Inadequate conspicuity treatments Operating an out-of-service vehicle Your performance on vehicle maintenance is measured using violations of certain Federal Motor Carrier Safety Regulations recorded on roadside inspection reports. It s important to note that a violation can be logged even if a citation or ticket is not issued even if the violation simply appears on the inspection report and even if the driver is not placed out of service. If there are multiple violations of the same standard cited during one inspection, however, it only counts as a single violation. Vehicle maintenance violations are entered into the FMCSA s Safety Measurement System (SMS), which is the agency s replacement for the SafeStat system. The SMS is used to grade both carrier and driver performance on vehicle maintenance and the other BASICs. As discussed below, vehicle maintenance violations that may have had a minimal effect on your safety rating in SafeStat may have a detrimental effect on your rating in the new SMS, and may in turn lead to contact from the FMCSA. Keep in Mind Hiring a driver who has vehicle maintenance violations on his/her record will not affect your company s score, although each violation will affect the driver s score for 36 months. Once you hire a driver, however, that driver s violations that occur while working for you will continue to affect your company s record for 24 months, even if you later terminate the driver. How is the vehicle maintenance BASIC measured? Every 30 days, maintenance violations will be used to grade your performance in the vehicle maintenance BASIC, which contributes to your overall safety rating. Carriers and drivers with the poorest grades relative to their peers become targets of the FMCSA s intervention process, in which the agency takes action to try to correct the unsafe behaviors and prevent crashes. Here s the process used to figure out how you measure up in the vehicle maintenance BASIC: Violation severity All of a carrier s vehicle maintenance violations from the past 24 months will be assigned a severity, from 1 to 10, based on how likely each violation is to result in a crash. A severity of 1 represents the lowest crash risk, and 10 the highest, relative to other violations within each BASIC. For example, a fire extinguisher violation has a severity of 2 while using a tire with inadequate tread depth ranks an 8 (see accompanying table). The severity of a violation is increased by 2 if the violation resulted in an out-of-service order. For example, a tire-tread-depth violation that results in an OOS order has a final severity of 10 (8 + 2). A single bad inspection should not have disastrous consequences on your scores, because the sum of all violation severity weights from any one inspection is capped at a maximum of 30. Age adjustment The severity of each of a carrier s vehicle maintenance violations is multiplied by a 1, 2, or 3, depending on its age. The result is that violations recorded within the last 6 months are three times as damaging to a carrier s grade as violations recorded between 12 and 24 months ago. The older the violation, the less weight it carries. Inspections (including clean inspections) are also adjusted for age, so older inspections will not affect your scores as much as recent inspections. A time weight of 1, 2, or 3 is assigned to each relevant inspection depending on its age. An inspection performed within the last 6 months is assigned a 3, between 6 months and 12 months a 2, and older than 12 months a 1. Violations inspections The sum of all adjusted severity weights are divided by the sum of all age-adjusted inspections to arrive at a final measure for vehicle maintenance. This process results in your measure for vehicle maintenance, a raw score that can be used to compare your performance against that of other carriers, as described below. Drivers are measured in a similar way on the vehicle maintenance BASIC except that violations from the past 36 months are included x

3 For Helpful Guidance on CSA 2010 Preparation, call J. J. Keller Business Services Which inspections count? When calculating your score on vehicle maintenance, the FMCSA uses only relevant inspections from the past 24 months. A relevant inspection is either: Any vehicle inspection (Level 1, 2, 5, or 6) Any other inspection (including driver inspections) that resulted in a vehicle maintenance violation. The scoring process Your measure on the vehicle maintenance BASIC is not your final grade. Rather, your vehicle maintenance measure is held up against the records of other carriers of similar size to determine whether your safety performance is better or worse than your peers. The FMCSA expresses this relationship by assigning you a percentile in terms of vehicle maintenance. For example, if your vehicle maintenance performance is worse than that of 70% of your peers, your percentile for vehicle maintenance will x 2010 FLEET TECHNOLOGY OUTSOURCE SERVICES ADVISEMENT & TRAINING Don t wait for FMCSA enforcement. Getting your records organized now will make a difference. We can help. PERFORMANCE GRADING EXAMPLE Write Trucking started operations six months ago and has already had eight inspections in that time. After adjusting the severity for any out-of-service violations, the total severity of all vehicle maintenance violations is 145. Because the violations all fell within the past six months, the severity is multiplied by a factor of three to become 435. The eight inspections are also multiplied by three, for a total time-weighted number of inspections at 24. The vehicle maintenance measure, therefore, is , which is By itself, this raw score means little until it is compared to the scores of other carriers (see below). be 70. The worst-performing carrier within each peer group, for each BASIC, is assigned a percentile of 100, and the best is assigned a zero (0). If in the past 24 months you ve had fewer than five relevant inspections OR no inspections that resulted in at least one vehicle maintenance violation, then you will not be assigned a percentile for this BASIC. Consequences A high percentile in vehicle maintenance could have two consequences: 1 Example of Vehicle Maintenance Violations by Severity VIOLATION SECTION SEVERITY Operating an out-of-service vehicle 396.9(c) 10 Tire violations Suspension violations Steering mechanism violations Lamp violations , Brake violations Daily inspection report violations 396.9,.11,.13 4 Annual inspection violations ,.21 4 Coupling device violations Emergency equipment violations Cab, body, or frame violations , Fuel system violations ,.67 1 You may be subject to an intervention If your rank is above the threshold for an intervention, then you will likely be targeted by the FMCSA in some manner. Depending on x

4 2 your percentile, you might be subjected to: A warning letter, informing you of a poor score in vehicle maintenance and what you need to do better (you would also be instructed on how to challenge any incorrect data) Increased roadside inspections that target vehicle maintenance An on-site audit that targets your problems with vehicle maintenance The FMCSA has at least eight intervention tools at its disposal, ranging from warning letters to suspension. You may be deemed unfit If your percentile places you into the failing category for vehicle maintenance and one or more other BASIC(s), OR an audit reveals that you are violating certain critical vehicle maintenance regulations, you may automatically be deemed unfit to continue operating commercial motor vehicles. The failure to comply with certain critical vehicle maintenance regulations appears on a proposed list of 15 fundamental violations that will result in an automatic unfit status after an audit. INTERVENTION REVIEW Intervention #5: The Notice A Notice of Violation is used to put a carrier on notice of specific regulatory violations. The carrier would then have to provide evidence the problems were fixed (and thereby avoid a fine) or successfully challenge the violations. A Notice of Claim includes a fine and is used to deter severe or persistent unsafe behavior. ARE YOU PREPARED? Time is of the essence, because your on-road safety performance today could affect your scores on the BASICs for many months to come. Now is the time to put safety management controls in place that will help prevent vehicle maintenance violations. Keep these key points in mind: All vehicle maintenance violations noted on roadside inspection reports will count, not just the ones that place a driver out of service. Figure out where your drivers and company stand on the vehicle mainteinance BASIC, using inspection reports from the past months. Focus on the violations that could hurt the most (i.e., those with the highest severity), both for the company and for individual drivers. Keep in mind that violations will affect drivers scores for 36 months and the company s for 24 months. Only the passage of time will reduce the impact of those violations. Verify that the vehicle maintenance violations assigned to your company are actually yours. Review the FMCSA s data on your company regularly and contest any violations that do not belong to you. Create and communicate safety standards with comprehensive policies and procedures related to vehicle maintenance. If you have written policies and procedures, review them to make sure you re covering all the bases, and enforce them consistently. Vehicle maintenance is a shared responsibility between your drivers, the company, and your maintenance personnel. Make sure the maintenance department is aware of the consequences of vehicle maintenance violations under CSA The fewer the violations and the more clean inspections you have, the better your score and/or the better the chance that you won t be graded at all. Have your drivers ask for documentation of all clean inspections, to ensure that they get recorded. Make sure drivers are performing all required daily inspections and are reporting all maintenance issues as required. Be proactive! Use the right tools and resources to understand your exposure to risk and unsafe practices x

5 Comprehensive Safety Analysis Initiative The BASICs Unsafe Driving The operation of CMVs in a dangerous or careless manner. Examples: speeding, reckless driving, improper lane change, inattention. Fatigued Driving The operation of CMVs by drivers in non-compliance with the hours of service regulations. Examples: violation of the driving limit, driving while fatigued, failing to maintain complete and accurate logs. Driver Fitness The operation of CMVs by drivers who are unfit to operate a CMV due to lack of training or medical qualifications. Examples: failure to have a valid license, being medically unqualified. Drugs and Alcohol The operation of CMVs by drivers who are in possession of alcohol or illegal drugs, or impaired due to alcohol, illegal drugs, or misuse of prescription or over-thecounter medications. Examples: the use or possession of drugs or alcohol. Vehicle Maintenance CMV failure due to improper or inadequate maintenance. Examples: defective brakes or lights, failure to make required repairs. Improper Loading/Cargo Securement CMV incidents resulting from shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. Examples: improper load securement, cargo retention, and hazardous material handling. Crash Histories or patterns of crash involvement, including frequency and severity, based on information from state-reported crashes. A Strong Maintenance Program Limits Exposure Get your vehicle maintenance program in place with J. J. Keller encompass an online system used to manage all vehicle work. Set up preventive maintenance, schedule mechanics, monitor your parts inventory, and run reports to track all work. The online dashboard gives a quick view of upcoming work, and allows you to drill down into detail about a specific vehicle. Manage maintenance for any number of terminals or locations. Custom user settings let you limit access to features for authorized users. In addition to maintenance, J. J. Keller encompass delivers an integrated system to manage all aspects of driver & vehicle compliance and safety from driver qualification files, background checks, and accident tracking, to fuel tax reporting. When you re ready to implement onboard technology and automate hours-of-service, J. J. Keller encompass is ready to integrate with our in-cab recorder, J. J. Keller Mobile. Go to jjkellerencompass.com to learn more x x