Each year, the nation’s trucking fleets focus on the Commercial Vehicle Safety Alliance’s (CVSA) International Roadcheck enforcement blitz. But the reality is that the three-day event, which in 2021 inspected a little over 40,000 commercial vehicles, represents just a small portion of the nearly 3 million vehicle inspections that occur each year.
Fleets that focus only on Roadcheck or one of the other enforcement blitzes that occur during the year could be increasing the likelihood of receiving a roadside violation at other times. CVSA also conducts brake safety and driver programs as well as unannounced inspection checks.
Vehicle maintenance and driver adherence to regulations represent a 365-day effort. Brakes, tires, lights, service hours and log compliance are items that trigger violations on a daily basis for fleets. The resulting infractions impact a carrier’s Compliance, Safety, Accountability (CSA) score and lower scores can hurt the bottom line.
“CSA scores don’t ‘happen’ to you. They’re simply a reflection of how safely you’re operating,” said Rick Malchow, industry adviser for J.J. Keller & Associates. “Identify the violations that have the most significant negative impact on your CSA scores and you can quickly reverse the trend. Trending data is not a ‘one-and-done’ event. The FMCSA Safety Management Cycle is named a cycle for a reason — it never ends.”
The odds of an inspection
In fiscal year 2021, there were a total of 2.87 million inspections, 2.8 million conducted by state officials. Nearly 873,000 of those were full inspections, with another 995,000 walk-around only. Add an additional 900,000 driver-only inspections and you have a picture of the scope of reviews.
Those inspections generated a driver out of service rate of 5.89% and a vehicle out of service rate of 21.1%.
According to the Federal Motor Carrier Safety Administration’s 2021 Pocket Guide to Large Truck and Bus Statistics, there were 10.1 million single truck units (straight trucks) and 2.9 million combination trucks (tractor-trailers) registered in the U.S. in 2019. Based on the 300.1 billion miles FMCSA said commercial vehicles traveled in 2021, an inspection of a bus or truck takes place roughly every 104,000 miles. With a typical over-the-road truck traveling about 100,000 miles per year, the chances any individual driver and/or truck will be inspected once a year are pretty high.
Analyze inspection data
Customers are now using violation and fine data to decide who will haul their freight, and drivers are increasingly utilizing that same information when making employment decisions. In a competitive environment for drivers, that pushed up salaries for those fleets.
Malchow said fleets can counteract this by understanding their inspection data. Violations tend to follow the “80/20” rule, he said, which indicates 80% of violations are likely caused by 20% of the driver force. There are many reasons for this, including not performing proper pre- or post-trip inspections, not following fleet and federal regulations or even poor maintenance practices.
Violations can easily surpass $15,000 per violation. The top 10 carriers each settled with FMCSA at amounts above $40,000. In 2021, FMCSA closed 2,773 enforcement cases with carriers with an average settlement of over $6,600 and a collective total that surpassed $18 million.
How to analyze the data
FMCSA uses the Safety Measurement System (SMS) to track fleet safety and compliance performance. The SMS is organized into seven Behavior Analysis and Safety Improvement Categories (BASICs). These BASICs are:
Hazardous materials compliance
“No matter the depth of your data dive, the Safety Measurement System is updated monthly,” Malchow said. “It’s a best practice to review the data monthly and no less than quarterly. However, the deeper you dive, the more actionable your data becomes.”
Surface review: All seven BASIC measures and scores.
Medium review: All seven BASICs measure trends over a six-month period, over six quarters or over 1 1/2 years; and semiannually or over 2 1/2 years.
Deep review: Specific violations received in each BASIC to identify repeat actions. These are the areas that need to be addressed across the organization.
Very deep review: Uses weighted averages to consider the violation occurrence rate, severity weight and how often the vehicle or driver is placed out of service. To make the data more actionable, sort and score the data by terminal location, driver manager or dispatcher, maintenance shop and driver.
“Digging deep into the roadside inspection data could lead to an important discovery that most carriers never find,” Malchow said. “The violations that occur most often are not necessarily the ones hurting your scores the most. You need to consider the severity weight and out-of-service rates.”
Fleet management systems, such as J.J. Keller Encompass, allow carriers to track roadside inspections and CSA data as well as driver and vehicle records. This becomes critical data when trying to manage violations and identify fleet trends.
The collection and analysis of inspection data is only part of the solution to improving fleet CSA scores. The final aspect is making that data work for you.
“The FMCSA doesn’t need to get inside your vehicles and sit with drivers to see how safely you operate,” Malchow said. “Instead, they simply need enough inspection data points to ‘see’ your safety culture. Take your data seriously.”
FMCSA updates BASIC data on a monthly basis, so fleets should do the same. Waiting to do so quarterly or even yearly means the data the fleet is using to manage risk is outdated compared to what FMCSA is using. Malchow said carriers should train drivers on how to perform good pre- and post-trip inspections, which serve as the first line of defense against preventable maintenance issues. Drivers should also be properly trained on their requirements, such as hours-of-service and electronic logging device compliance.
“When enforcement gives you and your drivers clean inspections, you may also reap dividends with other industry stakeholders who impact your bottom line — insurance companies, brokers, shippers and drivers,” Malchow said.
Malchow noted that insurance companies will use the data in compiling a fleet’s risk profile. A poor risk profile will raise insurance premiums. Brokers also parse the data when vetting carriers, as do shippers.
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