Conforming to FMCSA Regulations While Reducing Operating Costs with Pre and Post Trip Inspections By Paul Backers Introduction: With the Federal Motor Carrier Safety Administration s (FMCSA) recent implementation of the Compliance, Safety, Accountability (CSA) system, many commercial truck fleet managers and owners are concerned over the implications of a measurement system with guidelines that are easier to enforce. With more detailed regulations regarding owner and driver accountability, out-of-service criteria, and more FMCSA intervention, some motor carriers are having difficulty meeting these guidelines. While CSA is not really tougher than its predecessor, the SafeStat program, its regulations are more clearly defined and therefore more enforceable. Its guidelines concerning driver violations are particularly detailed. In an effort to foster a more proactive approach to public safety, CSA introduces an intensive system that classifies driver-related problems into multiple categories. This places an emphasis on driver responsibility, which was often overlooked under SafeStat. Because driver violations are now a significant factor in the calculation of a company s safety score, a motor carrier s drivers are integral in achieving success under CSA. While CSA can mean more citations for driver and equipment violations and more audits and trucks pulled out of service as a result it is important to keep in mind that the new regulations are not only designed to promote a safer system, they can help fleet managers and owners reduce operational costs as well. CSA s emphasis on preventative vehicle maintenance is particularly beneficial to motor carriers. Driver pre and post trip inspections are an indispensible aspect of preventive maintenance. Because drivers are in a position to detect vehicle deficiencies and refer them to maintenance for repairs, 1 they are instrumental in ensuring that their vehicles remain in safe operating condition. The implementation of routine pre and post trip inspections allows motor carriers to promote a culture of safety, reduce driver and company citations, maintain a satisfactory safety score, and identify maintenance problems before they become needlessly expensive. 1 "Preventive Maintenance and Inspection Procedures." Federal Motor Carrier Safety Administration. US Department of Transportation. Web. 05 May 2011. <http://www.fmcsa.dot.gov/facts-research/researchtechnology/publications/accidenthm/vehicle.htm>.
History While federal and state government regulations have dramatically decreased commercial vehicle accidents since the 1970 s, accident rates have now remained relatively level for the last decade. In an effort to continue a downward trend in accidents (and to more efficiently allocate resources that are becoming increasingly limited in the current economic climate), the FMCSA implemented the CSA program in December, 2010. CSA is designed to correct some of SafeStat s major flaws. Because SafeStat scores were based on primarily on owner/operator safety violations and took into account only selected moving violations from roadside inspections, the factors that actually contributed to accidents (e.g. poor vehicle maintenance) were largely overlooked. Furthermore, without roadside inspection data, catching owner/operator safety violations required FMCSA audits, and the FMCSA lacked the resources to effectively monitor the entire industry. So with no process for recording and tracking information that could be used for accident prevention, the FMCSA was required to take a reactionary approach to public safety under SafeStat: they focused their attention on carriers with high accident rates and serious moving violations rather than taking steps to prevent accidents and unsafe driving. Because resources could not be allocated efficiently with SafeStat, the FMCSA was often forced to focus on large motor carriers (more vehicles on the road means a greater chance of accidents) while overlooking small carriers with alarming safety issues. With the number of commercial vehicles on the road increasing, a more proactive approach to accident prevention was vital. Consequentially, the FMCSA developed CSA, which includes driver safety violations in its guidelines. Driver safety scores are based chiefly on roadside inspection data, and they dramatically affect a carrier s overall safety score. In fact, 172 of the 220 vehicle maintenance violations listed in the CSMA are counted in the Driver Safety Measurement Score. By placing a greater emphasis on driver responsibility, the FMCSA remedies a major problem with the SafeStat program. The incorporation of roadside inspection results into the Safety Measurement System allows the FMCSA to use state law enforcement as a means of data collection. This means that the FMCSA does not have to rely primarily on audit data as they did under SafeStat. Instead of using their limited resources to monitor an entire industry, they can use roadside inspection results to perform targeted audits. In short, the intention of CSA regulations is to help the FMCSA more quickly and accurately identify motor carriers with serious safety violations so that time and resources can be allocated appropriately. The ability of the FMCSA to perform targeted audits is a field leveler for motor carriers. It allows regulators to gain a wider perspective on the industry so that carriers who continue to push their hours of service, have poor maintenance practices, and place immediate cost over safety regardless of the size of their organization can be dealt with appropriately. In short, the intention of CSA regulations is to help the FMCSA more quickly and accurately identify motor carriers with serious safety violations so that time and resources can be allocated appropriately. By targeting carriers that exhibit severe and persistent violations, the FMCSA can reduce operational costs while preventing commercial vehicle accidents caused by negligence on the part of both drivers and motor carriers. BASICs The calculation of the CSA s Driver Safety Measurement Score is accomplished through the categorization of driver-related safety problems. While Safestat lumped these problems into a single group, CSA introduces Behavior Analysis and Safety Improvement Categories (BASICs). These categories quantif[y] the on-road safety performance of carriers and drivers to identify candidates for interventions, determine the specific safety problems that a carrier or driver exhibits, and monitor whether safety problems are improving or worsening. 2 In short CSA s BASICs allow the FMCSA to identify the motor carriers that exhibit the most severe and persistent violations and to intervene via warning letters and audits accordingly. 2 Ibid.
CSA BASIC s include seven categories of safety measurement: Unsafe Driving Fatigued Driving (Hours-of-Service) Driver Fitness Controlled Substances/Alcohol Vehicle Maintenance Cargo-Related Crash Indicator The Vehicle Maintenance BASIC The Vehicle Maintenance BASIC places much of the responsibility for operating a safe vehicle in the hands of drivers. Regulations state that a vehicle may not be operated until the driver is satisfied that it is safe. A routine inspection would include an examination of service brakes, parking brake, steering mechanism, lighting devices, tires, horn, windshield wipers, mirrors, coupling devices, and any other system that could affect overall vehicle safety. While it seems that frequent inspections of so many systems would be time consuming, routine pre and post trip inspections will ultimately save a motor carrier both time and money. How can pre and post trip inspections save time and reduce operational costs? While adherence to all seven BASICs can prevent accidents and protect carriers from the costly lawsuits that accidents create, the Vehicle Maintenance BASIC in particular can allow carriers to reduce operational costs. By implementing mandatory pre and post trip inspections, fleet managers can: create a culture of safety that promotes driver responsibility and accountability attract quality drivers to their business minimize citations reduce the number of trucks pulled out of service for safety issues lower insurance bills improve company standing with shippers limit downtime for repairs reduce repair bills lower fuel costs Making Safety a Priority When fleet managers require inspections on vehicles pre and post trip, this communicates to drivers that safety is a company priority. If a driver s day begins and ends with an inspection that assesses vehicle safety, adherence to CSA regulations becomes part of a daily routine; furthermore, when drivers know that their company actively promotes safety, they are more inclined to follow regulations throughout the entirety of their workday. In this regard, mandatory pre and post trip inspections can not only reduce maintenance citations, but other driver citations as well. While it seems that frequent inspections of so many systems would be time consuming, routine pre and post trip inspections will ultimately save a motor carrier both time and money. Required pre and post trip inspections also facilitate driver accountability, which allows managers to pinpoint where and when problems begin. Motor carriers can both identify drivers that are causing damage by driving poorly and determine specific routes that might be problematic (for example, if tire damage is consistently reported after a particular route, this might indicate poor road maintenance, and an alternate route can be considered). When the results of pre and post trip inspections are recorded daily, carriers increase their likelihood identifying problems early and eliminating mystery damage. By combining inspections with mandatory paperwork, managers can create a paper trail that allows them to track wear and tear and any damages to vehicles. The participation of fleet managers and owners in the paperwork process is critical; mandatory driver inspections are not effective if there is no follow through. By carefully inspecting their drivers paperwork daily, managers can both ensure that safety problems are fixed quickly and remain consistently aware of the condition of their fleet. Lastly, because adherence to the seven BASICs affects not only a motor carrier s overall safety score but individual driver scores as well, drivers will be more inclined to sign on with, and continue to work for, companies that actively promote safety; after all, why would a good driver jeopardize his Driver Safety Measurement Score by working for a company that does not actively encourage preventive vehicle maintenance?
Good drivers will understandably assume that motor carriers that tolerate less-than-professional pre and post trip inspections also engage in poor equipment maintenance habits. Because CSA places the responsibility for vehicle maintenance not only on the equipment owner but on the driver as well, drivers who sign on with companies that do not properly maintain their vehicles put their reputations at risk. By implementing mandatory pre and post trip inspections, fleet managers can demonstrate their emphasis on safety and ensure that they can attract quality drivers to their business. This is particularly important in the current job market, where the imminent retirement of Baby Boomers (as well as the loss of drivers who found other work during the economic recession and drivers who cannot meet new CSA DOT driver physicals) is already shrinking the potential employment pool. Because it is also estimated that the trucking industry will need to hire 400,000 drivers by the end of 2012 as we move out of the recession, attracting and retaining good drivers will be critical in maintaining a competitive advantage. Consequentially, carriers must focus on training their current drivers to minimize violations by performing effective pre and post trip inspections. This will allow carriers to reduce maintenance issues, achieve satisfactory safety scores, and ultimately promote future growth. Creating a Culture of Safety Since the implementation of CSA, the motor carriers that are receiving the smallest number of violations are those that are not merely following the minimum requirements outlined by the new regulations but are meeting the challenges of more stringent FMCSA guidelines with the creation of a culture of safety within their businesses. A vital aspect of implementing a culture of safety is both training drivers to perform pre and post trip inspections competently and emphasizing the seriousness of the inspection process in every aspect of a driver s interaction with the company. Guidelines for pre and post trip inspections should be outlined in a business s safety policies, and training (as well as a clear presentation of expectations) should be included in the new hire process. Motor carriers should also work with their insurance and equipment providers to ensure that their policies are up to date. Larger companies with their own truck maintenance facilities can require their drivers to spend a few days in their shops as part of training. This allows drivers to become more familiar with the equipment they operate and improves the communication between drivers and mechanics. Because both drivers and companies can be held legally liable for any losses that occur as the result of failing to adhere to CSA standards, it is in a motor carrier s best interest to foster a culture of safety. Smaller companies can work with their maintenance and equipment providers to offer the same level of training. Drivers can do a PM with a mechanic and a ride along or walk around with an equipment dealer. In addition to extensive training, motor carriers should make sure that they supply their drivers with the basic tools they need to perform adequate pre and post trip inspections. Tire pressure and depth gages, clean rags, and flashlights should be part of drivers uniforms; they should be available at all times, and drivers should be expected to keep them close at hand. Companies can reinforce their emphasis on safety by recognizing drivers that consistently conform to policies. Whether it s creating reward systems for the drivers with the fewest number of violations, posting the names and pictures of drivers with zero violations, or including safety statistics in the company newsletter, activities that emphasize the importance of safety can help a carrier succeed under CSA. Because both drivers and companies can be held legally liable for any losses that occur as the result of failing to adhere to CSA standards, it is in a motor carrier s best interest to foster a culture of safety. Citations and Their Effect on Operating Costs Failing to perform pre and post trip inspections leads to a lower quality of vehicle maintenance, and when maintenance issues are overlooked by drivers and management, citations and out of service vehicles are the result. Not only can the cost of citations and downtime quickly exceed the cost of routine maintenance, each citation is counted on a carrier s safety score.
Increasing safety scores can prompt the FMCSA to red flag the responsible fleet, which leads to increased roadside and facility inspections. This can dramatically increase a carrier s operating cost, as lengthy inspections mean less road time and more mandated repairs. One of the biggest problems with inadequate pre and post trip inspections is vehicles being pulled out of service for easy fixes, such as a broken lighting device. In these situations, a carrier must send a mechanic on a road call for vehicle repair. Because the average road call takes, on average, three to four hours, allowing law enforcement to catch a simple maintenance problem costs a company time and money. Take the example of Company A, which received an out of service violation for a burned out headlamp. The company s fleet manager was forced to spend an hour of his time finding a mechanic who could perform an immediate road call. At a rate of $75 an hour, the mechanic spent three hours locating and picking up a new headlamp, driving to the truck s location, and installing the device. The fleet manger paid an additional $50 as a mobile service fee. In total, Company A paid $275 dollars (not including the cost of downtime) for a $6 headlamp. If Company A had encouraged its driver to perform a pre trip inspection, it would have saved $269 and four hours of time. This is a perfect example of how pre and post trip inspections can minimize downtime and save money. Other Costs of Poor Vehicle Maintenance An unsatisfactory safety score can affect a motor carrier s status with insurance companies and shippers. Insurers charge carriers with a history of safety issues significantly higher rates than carriers with satisfactory scores. Shippers may also be hesitant to do business with carriers that have a history of safety violations. In the age of the internet, maintaining a good reputation with insurers and shippers can be especially difficult. Under CSA, SMS results are easily accessible online. While this allows carriers to conveniently assess their weaknesses in various safety areas, it also allows shippers and insurers to make businesses decisions based on Safety Measurement Scores. In this way, a carrier s safety score can directly affect their volume of business. By performing routine inspections and maintenance, a motor carrier has a much greater chance of maintaining a satisfactory safety score and avoiding the costs associated with poor scores. Because SMS results affect operating costs so significantly, it is also important for carrier s to make certain that clean inspections (i.e. inspections that result in no violations) are recorded. Lowering Repair Costs While routine pre and post trip inspections may lead to more frequent vehicle maintenance, repairs will ultimately be cheaper for multiple reasons. Firstly, it is beneficial to identify safety problems early on when they are cheaper to fix. Perhaps more importantly, the paper trail created by routine driver inspections bridges the communication gap between driver and mechanic. Without a mandatory daily log, a driver might verbally communicate a problem to dispatch, who communicates the problem to a repair shop, who communicates the problem to a mechanic. Not only can misunderstandings occur as information is verbally passed from party to party, management is often unaware of the specifics of a problem, which makes it difficult to gauge the appropriateness of repair costs. When drivers log potential maintenance issues, the paperwork can be given to the mechanic so that he can gain a first hand account of the problem. In order to complete the communication loop and present satisfactory paperwork in the event of an FMCSA audit, it is important for managers to attach completed repair forms to the Daily Vehicle Inspection Report on which the problem was originally noted. This also allows fleet managers to gain insight into the speed and effectiveness of their pre and post trip inspection process. In short, daily pre and post trip inspections help assure that mechanics get the correct information pertaining to repairs. This reduces repair costs by ensuring that appropriate problems are being worked on and minimizes the amount of time a vehicle must spend in the shop. This means more on-road time and more profitability. Lowering Fuel Costs with Pre Trip Inspections An important part of any pre trip inspection is checking that tires are properly inflated with adequate tread depth. Because Fuel economy falls off sharply when tires are underinflated 3 and because gains in fuel efficiency can be obtained from the tread of the tire, 4 pre trip inspections that monitor tire wear and inflation can increase fuel economy significantly. 3 "Factors Affecting Truck Fuel Economy." Good Year Truck. Good Year. Web. 05 May 2011. <http://www.goodyeartrucktires.com/resources/factors-fueleconomy.aspx>. 4 ibid
Conclusion: By encouraging their drivers to perform daily pre and post trip inspections, fleet managers and owners can maximize the profitability of their businesses. Routine inspections create a sense of driver responsibility, reduce citations, promote as satisfactory safety score, and reduce maintenance costs. Pre and post trip inspections are not only vital in adhering to CSA regulations, they are crucial to maintaining a financially viable fleet as well. AUTHOR: Paul Backers is the Lease Account Manager with Peterson Trucks in San Leandro, Calif. Paul has over 9 years of experience providing dynamic customer service and innovative solutions for complete vehicle repair. He is a Certified Transportation Professional accredited through the National Private Truck Council, and is a certified Lean Six-Sigma Black Belt out of Villanova University. REFERENCES: "Factors Affecting Truck Fuel Economy." Good Year Truck. Good Year. Web. 05 May 2011. <http://www.goodyeartrucktires.com/resources/factors-fuel-economy.aspx>. "Preventive Maintenance and Inspection Procedures." Federal Motor Carrier Safety Administration. US Department of Transportation. Web. 05 May 2011. <http://www.fmcsa.dot.gov/facts-research/research-technology/publications/accidenthm/vehicle.htm>. "Why Is CSA Needed?" CSA - Compliance, Safety, Accountability. FMCSA. US Department of Transportation. Web. 05 May 2011. <http://csa.fmcsa.dot.gov/about/csa_why.aspx>.