CSA 2010: Vehicle Management; Part II

Today s Webinar CSA 2010: Vehicle Management; Part II Today s Webinar CSA2010: Vehicle Management Miranda Voelz encompass /DMO Client Services Manager J. J. Keller & Associates, Inc. Our Client Service Support number is (800)327-1342 support@drivermanagement.com encompasssupport@kellerencompass.com Today s Webinar CSA2010: Vehicle Management Tory Much Sr. Client Service Specialist J. J. Keller & Associates, Inc. 1

Today s Webinar CSA2010: Vehicle Management Tom Bray Editor, Transportation Manager J. J. Keller & Associates, Inc. Motor carrier safety and operations management expert. Over 25 years of experience Today s Webinar Please don t hesitate - ask your questions! Today s Overview What is CSA 2010? What is the Vehicle Maintenance BASIC? What tools do encompass /DMO have for me? 2

FMCSA Challenges Only 12,000 out of 750,000 carriers are contacted by FMCSA annually Presently, the only formal contact is a Compliance Review SafeStat is used to locate carriers for auditing Poll Question #1 Are you in a CSA2010 pilot state? Yes No CSA 2010 Uses seven BASICs (Behavior Analysis and Safety Improvement Categories) to analyze carriers Unsafe driving Fatigued driving/hours of service Driver fitness Controlled substance and alcohol Vehicle maintenance Improper loading/cargo securement Crash indicator 3

CSA 2010 Safety Fitness Determination (SFD)/Evaluation 1. Continue to Operate (no contact) 2. Marginal (progressive interventions) 3. Unfit (correct or cease operations) (unable to enforce until regs are passed) How do BASICs work? Seven BASICs Relevant intervention, inspection, violation, and crash data assigned to the carrier Violations and crashes are classified into the correct BASIC Events are time weighted and severity weighted BASICs are totaled and normalized (BASIC Measure) Carriers are peer grouped and compared Percentile rank in peer group assigned (BASIC Score) If any BASIC Score over threshold, intervention occurs CSA 2010 Safety Fitness Determination (SFD) Each BASIC has two thresholds: Intervention required Failing (unfit) Any BASIC above threshold = Intervention If unfit in a stand alone BASIC, carrier declared unfit If unfit in more than 1 non-stand alone BASIC, carrier declared unfit (1 stand alone is marginal ) 4

CSA 2010 Poll Question #2 Do you conduct driver training on vehicle inspections? As part of orientation As ongoing training As remedial training All of the above None of the above Required by the regulations Pre-Trip ( 392.7 and 396.13) Enroute inspections ( 392.9 and 397.17) Post Trip/DVIR ( 396.11) 5

Pre-trip ( 392.7 and 396.13) Driver cannot operate the vehicle until the driver is satisfied with the condition of the vehicle. Review of previous DVIR is required. Regulations list the MINIMUM that must be checked. Many carriers require more! No required form, however, many carriers have developed mandatory forms or require flagging on the driver s log (best practice). Pre-trip ( 392.7 and 396.13) Intermodal drivers have special pre-trip requirement. Intermodal drivers must inspect a chassis provided to them before operating it on the roadway. Cannot leave provider until chassis meets the standards. Leaving certifies that the driver is satisfied. Pre-trip ( 392.7 and 396.13) Training tip: Pre-trip inspections prevent onthe-road breakdowns and out-of-service violations. Train drivers to inspect everything! 6

Enroute ( 392.9 and 397.17): Tire check required whenever the vehicle is parked, if the vehicle is hauling hazmat. Unsealed cargo must be inspected for securement: Every time the vehicle is parked. Every 3 hours/150 miles (whichever comes first). No required form. Best practice, flag on log. Enroute: Best practice: Walkaround inspection checking tires, lights, hubs, cargo securement, coupling devices, and general condition whenever parked. Try to find problems before they become big problems. No required form. Best practice, flag on log. Post-trip/DVIR ( 396.11) Driver must report condition of the vehicle at the end of the workday to the carrier in writing (DVIR form required). Regulations list the MINIMUM that must be reported on. Many carriers require more! As a best practice carriers require this inspection to be noted on the driver s log (as well as submitting the DVIR form). 7

Post trip/dvir ( 396.11) Pre-trip cannot take place of post-trip/dvir. Copy of last DVIR NOT required to be carried on the power unit anymore-retained by company for three months. Carrier must maintain original records containing: Inspecting driver s signature, and if necessary: Certification of repairs or Need not be repaired statement Certification of driver reviewing DVIR Flow-No defect Driver finds no defect Driver signs DVIR showing no defects Next driver reviews DVIR as part of pre-trip and submits DVIR to carrier (no additional signatures required) DVIR Flow-Driver reports defect Driver notes defect on form Mechanic or carrier official acts on report, then signs that repairs were completed or not necessary Next driver to pre-trip vehicle reviews previous DVIR and signs agreeing with the mechanic or carrier official DVIR with all signatures is submitted to the carrier 8

DVIR form DVIR If on back of the driver s record of duty status (log), the driver(s) must guide the DVIR thru the process-the requirements are the same. The log must be filed and available by equipment number in case of audit. Retention changes to six months! Audit Point Common violations: Failure to submit Failure to act on reported defects (can lead to claims of knowingly operating unsafe equipment) Failure to have certifying signatures Failure to retain 9

IEP DVIR Intermodal drivers have a unique DVIR requirement, they must provide the equipment provider with an IEP DVIR reporting the condition of the chassis when the chassis is returned. This IEP DVIR does NOT take the place of the daily DVIR the driver must do for the carrier. Make sure drivers have necessary tools: Training that includes defect recognition, timing of inspections, and developing a routine Tire gauge Hammer Flashlight Gloves Inspection checklist Contact number and name for questions Care and feeding of vehicles by drivers is a training and policy issue!!! Roadside and maintenance inspections best gauge of driver performance. 10

On-road repairs Call first policy Mechanic-to-mechanic authorization policy (driver cannot authorize repairs) Decision matrix on continuing operation Contract shops or repair network Return all parts policy Payment procedures Primary tool used to check the condition of a carrier s equipment (and therefore its maintenance program and driver inspections) are roadside inspections. Level 1 Full and complete Level 2 Walk-around Level 3 Driver only Level 4 Special purpose Level 5 Vehicle only Level 6 Enhanced inspection for radioactive material carrying vehicles 11

Poll Question #3 If a driver is placed out of service for vehicle violation, do you: Counsel the driver Retrain the driver Discipline the driver We don t have a policy in place for this Audit Point When auditing vehicles the auditor will first verify that your out-of-service rate is below 34 percent. The auditor will then verify that you are performing the inspections, maintenance, and lubrication on the systematic schedule you have established for yourself. Audit Point CSA 2010 investigations: Violations of the regulations examination of carriers safety management controls 12

What was the reason for the roadside inspection? Failed sight and sound. Traffic violation/driver error. ISS-D score. Post accident/incident. Random selection. Out-of-Service Vehicles: DO NOT MOVE until repaired. Document repairs. Penalties for drivers and carriers who violate. Prescribed Inspection Report Form used (MCS-63 or ASPEN report). Inspection Report Form: Submitted by driver within 24 hours. Any noted defects must be corrected. Carrier signs and returns report to state within 15 days. 13

Best practices: Track ALL roadside inspections for trending as they are turned in. Review FMCSA s data monthly. Compare your data to FMCSA data to locate problems. Possible problems: Inspection in your tracking, but not FMCSA s. Inspection in FMCSA s but not in your tracking: Verify inspection is yours locate driver and get inspection report. Verify inspection is not yours use DataQs to remove it from your data. 14

Possible problems: Tracking showing violation trend: Address problem by improving driver training, technician training, increasing inspections or maintenance schedule or procedures on problem components, or change pull or cut points. Do not do nothing and hope for the best. Proof of Training Copyright 2010 J. J. Keller & Associates, Inc. All rights reserved. Poll Question #4 According to FMCSA, what percentage of DataQs challenges are successful? 15 % 35 % 40 % 65 % What is DataQs? 15

CSA 2010 will change how roadside inspection reports are used. Divides data into 7 BASICs rather than 4 SEAs, one of which is the Vehicle Maintenance BASIC CSA 2010 uses ALL violations discovered during roadside inspections, not just out-of-service violations. One intervention in CSA 2010 is Targeted Roadside Inspections (ISS Inspect recommendation). BASIC Violations Violation Severity Violating a vehicle out-of-service order 10 Violating the tire standards 8 Suspension-related violations 7 Violating the lighting standards 6 Steering-related violations 6 No pre-trip inspection 4 Brake-related violations 4 Failing to be knowledgeable of Part 396 4 Inspection-related violations 4 Where do you go to check FMCSA s data? SafeStat (all carriers): http://ai.fmcsa.dot.gov/safestat/safestatmain.asp CSA 2010 Data Review (all carriers): http://csa2010.fmcsa.dot.gov/ CSA 2010 s CSI (carriers in CSA 2010 pilot states only): http://ai.fmcsa.dot.gov/cms/login.aspx All require DOT number and Carrier PIN (provided by FMCSA) to view full data 16

Questions? Use the Q&A function to ask questions. Thank you for joining us. encompass / DMO Support (800)327-1342 17