Big Changes Ahead!

Steve Bryan, CEO of Vigillo, will walk through the proposed CSA methodology changes (SMS 3.0).  These include a new Hazardous Materials BASIC, eliminating the Cargo-Related BASIC, and adjustments to violations and severity weights.  These changes impact all carriers, HAZMAT and Non-HAZMAT.  Read about the changes here (PDF).  Take an hour out of your busy day for the latest news on FMCSA’s Compliance, Safety, Accountability program.

Sign up by clicking the “Register here” link below:

Royce Brooks, an experienced tank truck driver, was hauling gasoline to Lockhart, Texas, south of Austin, when a BMW driver blew through a stop sign and a flashing red light.  The car hit the tanker truck with such force that Texas State Police said the rig went into a ditch, spun around, flipped and burst into flames, killing Brooks, 41.

The driver of the BMW in the March 28 crash has been charged with criminally negligent homicide.

Nevertheless, under the federal Compliance, Safety, Accountability program, the crash will be posted on the public CSA website as a fatal accident for the carrier, Johnson Oil Co. of Gonzales, Texas, also known as Cinco J Inc.  Missing from the posting will be anything that says the carrier and Brooks were blameless, a stark example of a situation that has the trucking industry crying foul.  “It is very unfair,” said Michael Burke, Johnson’s transportation manager. “That poor guy didn’t know what hit him,” Burke said of Brooks, whom he hired last year.

Read the full article here.  Fuetsch shares several other examples of the controversial policy and the FMCSA’s perspective in the article.  How do you feel about the current FMCSA policy on crashes?  What solutions do you  propose?  Keeping watching the Vigillo blog for further developments on how crash accountability develops in the future.

So…You read the title.  How much is a clean inspection worth? What do you think?  Some motor carriers have driver incentive programs: Get $50 for each clean inspection, for example.  That is certainly one way to measure it.  I am talking about something else though.  Specifically, what is the impact of a clean inspection under CSA?

Vigillo has been helping transportation professionals better understand CSA since the first methodology was published in 2010.  I’ll tell you some of the misconceptions I’ve heard.  More importantly, let’s really unravel it.  Let’s dig deep and lay out exactly what the effect (or non-effect in some cases) that a zero-defect inspection has on a motor carrier’s CSA score.  The answers may surprise you.

Misconceptions about Clean Inspections

First, clean inspections are a somewhat complicated area within CSA so it does not surprise me that there are many different answers to this question.  Here is just a brief list of differing explanations I have heard:

• Clean inspections don’t count at all
• Clean inspections wipe away violations a bit at a time
• Three clean inspections cancel out one violation
• Clean inspections dilute violations
• Clean inspections only count for some BASICs
• Clean inspections don’t exist

These can’t all be true, right?  So misconceptions about clean inspections abound.  Let’s start at the beginning and work our way through.

What Exactly is a Clean Inspection?

Let’s keep things nice and simple.  In regular conversation, a clean inspection is simply an inspection that has no violations.  Other names for clean inspections include “zero-defect inspections” and “no violation inspections.”  Same thing.

How Common are Clean Inspections?

In a word – very.  The FMCSA Analysis & Information Online website reports that for calendar year 2011, there were a total of 3,588,020 inspections conducted.  Of these, 1,351,609 of these had no violations.  That’s 38% of all inspections.

Two BASIC Examples

Here’s the thing – in terms of CSA points, you need to look at inspection points one BASIC at a time.  The FMCSA evaluates each of the 7 BASICs separately and differently.  There are different scoring rules, different calculations, etc.  So let’s start by taking a look at two BASICs and see how they handle clean inspections (hint: very differently).  Below, I’ll discuss the impact of clean inspections in Unsafe Driving and Driver Fitness.

Unsafe Driving BASIC

The key calculation in the Unsafe Driving BASIC determines a carrier’s BASIC measure.  For Unsafe Driving, the calculation is below:

In very simplified language, this is your CSA Points divided by your number of power units.  Any reference to number or type of inspections here?   None whatsoever.  By the way, “utilization factor” is only concerned with vehicle miles traveled and number of power units – so no connection to inspections there either.

Example: Let’s take a simplified example.  Please note that I am not getting into all the complicating factors so that this is easier to understand.  Let’s say a carrier has 150 violation points in this BASIC and has 50 power units (with no utilization factor bonus), that works out to be a BASIC measure of 150 divided by 50 which equals 3.  To determine the percentile score of this carrier, all carriers in this same safety event group are then arranged high to low based on their BASIC measure and given a percentile.  Got it?

Questions:Would anything be different if this carrier had zero clean inspections?  How about 10?  How about 100? The answer to all of these questions is that the BASIC measure would be unchanged and therefore the CSA percentile score in the Unsafe Driving BASIC is unchanged as well.

Conclusion: NO EFFECT. For purposes of the Unsafe Driving BASIC, Clean Inspections have absolutely no effect on a carrier’s CSA scores, such as BASIC measure or percentile.  Furthermore, inspections that have violations – but no unsafe driving violations – have the same effect on the Unsafe Driving BASIC: that is, no effect at all.  Hard to believe?  You would not be the first to think so.

Fatigued Driving (HOS) BASIC

A motor carrier’s Fatigued Driving (HOS) BASIC score is determined primarily from this calculation:

In other words, take the total violations points (from fatigued driving / hours of service violations) and divide them by time-weighted relevant inspections.  The key question then is: What the heck is a relevant inspection?

Relevant Inspection Defined. A relevant inspection in the Fatigued Driving BASIC is, according to the SMS Methodology version 2.2:

A Relevant Inspection is any Driver Inspection (Level 1, 2, 3, or 6), including those that do not result in a violation in the BASIC, or any other inspection resulting in an applicable BASIC violation

So what does that mean – especially in terms of a clean inspection?  Well, it means that an inspection will count as long as it is either one of the following: (a) a driver inspection, meaning a level 1, 2, 3, or 6 inspection OR (b) the inspection included a fatigued driving violation.   Since part (b) is by definition not a clean inspection we can forget about that part.  However part (a) appears to include clean inspections as long as they are a level 1, 2, 3, or 6.  So, a clean inspection will count in this BASIC.  Fantastic!  Even better, because the bad violation points on the top of the calculation (in the numerator) are divided or diluted by the inspections (in the denominator), clean relevant inspections clearly will help the carrier’s BASIC measure which improves the BASIC percentile.

How Much does a Clean Inspection Matter? Wait a second…It’s great that a clean inspection is included and can help the carrier’s score.  Now the question is: how much does it count?  Let’s look at a fictional motor carrier:

Let’s say Carrier A has 100 violation points in this BASIC.  Next we divide that by time-weighted relevant inspections.  Let’s say that number is 25.  100 divided by 25 equals 4 which would be the BASIC measure.

Let’s say Carrier A has added one more clean inspection that was a level 1 inspection.  It definitely helps the carrier but by how much?  the first question we have is what is the time weighting? Here’s how the time weighting works:

• Recent inspections from 0 – 6 months are triple weighted
• Inspections from 7-12 months are double weighted
• Older Inspections from 13-24 are single weighted
• Inspections older than 24 months are not included

The best case is that a new clean inspection is recent (within the last 6 months) so it therefore counts as 3 time-weighted inspection points.  Using our example from above, this carrier would 100 violation points divided by 28 (25 +3) time-weighted inspection points, so the BASIC measure comes out to be 3.57 – better (lower) than the 4 it was previously!  That is an improvement of 11% in the BASIC measure.  Not bad, right?

The harder question is what is the percentile improvement due to this clean inspection?  Unfortunately that is tougher to answer because the change is different in each safety event group.  Remember the percentile is applied after all motor carriers are, in a sense, lined up against a wall and given a ranking best to worst.  The percentile change will depend upon how many motor carriers you passed with this change.

Conclusion: Clean inspections DO have a positive effect on a carrier’s Fatigued Driving BASIC scores. How big an effect depends upon the recency of the clean inspection and the BASIC measures of the other carriers in the safety event group.

Two Categories of BASICs

So far we’ve seen one BASIC where clean inspections have no effect (Unsafe Driving) and one BASIC where clean inspections help the carrier’s CSA score (Fatigued Driving).  It turns out that all remaining BASICs can be divided into these two categories – for exactly the reasons we saw in our two example BASICs above.

BASICs where Clean Inspections DO NOT CHANGE CSA Scores

Clean inspections have no effect on a carrier’s score in the following BASICs simply because the official calculation does not take into account any clean inspections:

• Unsafe Driving

• Crash

BASICs where Clean Inspections IMPROVE CSA Scores

For the BASICs listed below, clean inspections positively help a carrier’s score because the calculation used dilutes violation points by relevant inspections – including relevant clean inspections:

• Fatigued Driving (HOS)

• Driver Fitness

• Controlled Substances / Alcohol

• Vehicle Maintenance

• Cargo-Related

• HazMat (future)

Note that the FMCSA has announced that the Cargo-Related BASIC will be replaced by the HazMat BASIC in the last half of 2012.  The SMS Methodology March 2012 version 3.0 Motor Carrier Preview shows that the HazMat BASIC is positively affected by clean inspections as well.

Wrapping Up:

I am hopeful this article can clear up some of the misconceptions about clean inspections and CSA.  A few parting thoughts:

• Understand Clean Inspections: As a transportation safety professional, it makes sense to understand how this key federal safety initiative of CSA works.  Inspections, both clean and not-so-clean, are an important part of it.  Plus – you’ll look smarter, be more confident, and generally impress folks when you know what you are talking about!

• Unsafe / Crash: If your carrier is working to reduce Unsafe Driving or Crash BASIC scores, focusing on clean inspections may not be the most productive way to go about it since these BASICs do not consider clean inspections in their calculations.

• Value of Clean Inspections: One transportation safety professional I discussed this topic with put it something like this: Generally speaking, think about violations as costing you dollars while clean inspections give you back pennies.

• DataQs: Consider submitting DataQ challenges to get clean inspections counted if they did not get reported to the FMCSA.  There is very little downside to this effort – especially if you have the documentation.

• Changes ahead! In the exciting world of CSA, there are always changes – changes to the methodology, to enforcement, to reporting.  Vigillo works hard to keep our customers in the know for all of these changes.

I welcome your questions and comments.  Thanks for reading!

Review it and comment.  You have a chance to add your input.  The government is asking for YOUR thoughts.  How often does that happen?  Use the opportunity.  How do you comment?  No you don’t get to just dial up the FMCSA Administrator directly and chat.

Here’s the official process for submitting your comments from the notice:

ADDRESSES: You may submit comments identified by Federal Docket Management System Number FMCSA-2012-0074 by any of the following methods:

1.      Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting comments.

2.      Fax: 1- 202-493-2251.

3.      Mail: Docket Management Facility, (M-30), U.S. Department of Transportation (DOT), 1200 New Jersey Avenue SE., West Building, Ground Floor, Room 12-140, Washington, DC 20590-0001.

4.      Hand Delivery: Same as mail address above, between 9 a.m. and 5 p.m., ET, Monday through Friday, except Federal holidays. The telephone number is 202-366-9329.

But what if you’re okay?  What if none of your CSA scores are currently over the intervention threshold?  What do you have to worry about then?  Can’t I just stick my head in the sand and ignore CSA?  It can’t hurt me!

Well, just because you’re under the thresholds doesn’t mean your insurance company isn’t keeping an eye out on you.  Many are monitoring CSA for sudden spikes in BASIC percentiles or are keeping track of fleets that are getting close: often trying to intervene before a fleet hits that alert symbol threshold.  Having insufficient data or no inspection data for a BASIC will notify roadside inspectors that this fleet may need an inspection (see details: The New ISS: How Motor Carriers With Insufficient Data Are Treated).  So if you’re a fleet with NO inspection data, you’re still at risk for increased scrutiny by the FMCSA.

If you’re close to threshold, less than 10% below, there’s a good chance one bad inspection may be enough to push you over.  Many fleets have been on the wrong side of this; and once you’re over, it’s a tough climb back down.  Vigillo has been watching CSA trends closely and over the past few months, we’ve seen that there are approximately 50,000 fleets with alerts every month.  This has been consistent, especially for the past 5 months.  As this number has been consistent month over month, many believe that it’s the same fleets with alerts.  Well, we did a deeper analysis and found that 9% of these fleets will drop out of alert status next month.  This means, that there are roughly 4,000 fleets coming in/going out of this bucket of fleets in alert status.

That’s a steady churn of fleets coming and going every month.

Maybe you’ve got one BASIC over the intervention threshold and you’ve received your letter from the FMCSA that you should be monitoring your scores.  You’ve been keeping an eye on your BASICs and have made some changes as to how your fleet handles training and incoming inspections and driver involvement/intervention.  Your team is feeling good since you’ve been seeing some slight improvements in your OOS percentages, fewer inspections, fewer violations, etc.  But something isn’t right.  Your performance as a fleet has been improving, but your BASIC percentiles are barely shifting!

This comes to the nasty little bit of CSA.  Because you are being compared to other fleets, that benchmark of being below the intervention/alert threshold will always be shifting.  What we’ve seen is that these Safety Event Groups are improving over time, which forces fleets to constantly be improving.  So, a fleet that has not changed their performance over the past year may see their percentile ranks rise!

So, if you want to, you can stick your head in the sand and ignore CSA.  Be like the ostrich who sticks it’s head in the sand and thinks to itself, “I can’t see you so you can’t see me!”  But sadly, as 5 of your BASICs are public knowledge, they can see you.  Ignoring CSA may work for some…. for now… for the ostrich.

1. Training for drivers so they understand how CSA can
affect their careers (78.1 percent)

2. Changing how sub-performing driving is monitored (63.2 percent)

3. Investing in technology to help monitor CSA (55.3 percent)

Other methods used are:

• Have an on-staff CSA manager
• Hire retired state police
• Invest in electronic on-board recorders (EOBRs)

Click HERE to see article in TheTrucker.com for more details.

1. Migrating non-HAZMAT cargo violations to the Vehicle Maintenance BASIC essentially dissolves them in a vast ocean of Maintenance violations and not only removes the unfair bias against Flatbed’s, but virtually eliminates Cargo violations as an issue. (Period)

Recently, I have heard the argument that while Flatbed operators may have gone “off-radar” when it comes to Cargo, they will go “on-radar” under Maintenance and HAZMAT.

Today, I ran the HAZMAT numbers for Flatbed Carriers.  Problem number 2:

2. Only 3,671 Flatbed Carriers are also HAZMAT.   3,671/24,023 = 15.28%.  Read as 84.72% of Flatbed Carriers are not HAZMAT and wil have no scores at all in the new HAZMAT BASIC

Conclusion: Flatbed/Open Deck Carriers are largely immune to HAZMAT and unless their Vehicle Maintenance scores are right at threshold already, there will not be enough Cargo violations to move them to Alert status.

Now, before you go and pooh-pooh my hypothesis, hear me out…

Everything in the Vigillo system is designed to keep your fleet in shape and give you the tools to stay that way.  Now it is very true that not everyone needs a gym membership.  Some lucky people have the crazy fast metabolism and have always been skinny…

Yeah.  Not me either…

Now, only 12% of fleets have enough data to generate CSA scores.

But of that 12%, 55% have an alert in at least 1 public BASIC.

Now the 88% fleets that don’t have enough inspection data are like those naturally skinny people, they don’t need to go to the gym… but for the rest of us… We’ve got to figure out some kind of plan to stay in shape….

Say you go to the gym regularly, maybe, once a week; you’ll probably do a pretty good job of maintaining your weight.  If you go once a day, you will keep it off and most likely stay pretty trim and lose a few pounds.  This is your every-day, I look pretty good and want to stay there maintenance.  This is what you get with the Vigillo CSA Carrier and Driver Scorecard subscription.  We give you all the tools to go in and keep a good handle on your CSA Scores.  Keep those points down and your management team happy….

Daily Updates and the Driver Data Manager are the additional tools we have to get you in the doors every day.  Like the pool, sauna, and classes, these keep you coming back.  They may cost a little bit more, but they make membership more valuable.  (Because who doesn’t like a little steam after spin class!?)

Now, if you want to up your game a little bit… Maybe get a size smaller or tone your arms/legs a bit.  You know, prepare for swim season, you can get yourself a personal trainer!  Now our personal trainers come in the form of the Inspection Management System (IMS) and Point Reduction Analysis.  Personal trainers are there to help you focus on exactly what your issues are, design a training schedule, keep you coming back every day, and keep you on track.

That’s what the IMS and Point Reduction Analysis are doing!  Know where your problem areas, what “weight” you need to lose, and how to get there with a Point Reduction Analysis- aka get ready for bathing suit season.  Now the IMS is more like a personal trainer who you meet with regularly.  These guys keep you on track and help monitor your performance over time: ability to perform the exercises, help you correct bad form, or learn new techniques.  The IMS does something similar for fleets.  You can track your inspections, make sure what you’re getting from the Feds is what you’re getting from the drivers, know when information needs to be corrected, and keep track of DataQ’s.

So for the rest of you… who have more will power than I do… Feel free to work out at home, hit the track, walk around the park, buy a Nordic Track.  I’m going to go to the gym and Zumba my way to bathing suit ready.

• PART 1: What is ISS?  Why does it matter? What changed?  How does it work?
• PART 2: The Seven Main ISS Groupings – what they are and how they work
• PART 3: How carriers with “Insufficient Data” are treated under the new ISS

In this final post, I will discuss how to lower your ISS score.

How To Improve Your ISS Score

In a nutshell, to lower your ISS score, simply do the following:

Have sufficient data,
don’t have serious violations, and
keep your BASICs below threshold.

In other words, simply reverse engineer the ISS methodology.  Now, is that advice particularly helpful?  I didn’t think so.  It’s similar to encouraging a student to get better grades by getting better test scores.  A response from a typical teenager to that advice would no doubt be “duh!”  So let’s get to the real question…How best to ensure (1) I have sufficient data, (2) avoid serious violations, and (3) keep my BASICs below threshold? Now you’re talking!  (I said to myself)  Let’s take it piece by piece.

(1) How Do I Ensure My Motor Carrier has Sufficient Data?

As a quick reminder, if your motor carrier has insufficient data, your carrier will automatically be in the yellow zone (50-74) or red zone (75-100).  See Part 3 for more details.  With insufficient data, an ISS score in the desired green zone (1-49) is not even possible.

So, to have a chance at an ISS in the 1-49 range, you would need more inspections.  Generally speaking, it is difficult for a carrier to initiate additional inspections – especially clean inspections.  I have had a few fascinating conversations with safety directors about how to increase inspections – since so much of the conventional safety wisdom is focused on reducing inspections.   Before we leave this item, there is one other point to consider:

Maybe a high ISS score due to insufficient data is not such a problem.

First, a carrier’s ISS score is private.  Second, the basis for recommendation is listed, meaning a high ISS score due to insufficient data simply indicates that the carrier has not had a lot of inspections.  It indicates very little if anything about safety.  Moving on…

(2) How Does My Motor Carrier Avoid Serious Violations?

See Part 2 of this series for the technical definition and list of these serious violations.  A serious violation, in this specific sense, can only be found by a Safety Inspector during an FMCSA investigation.  So, the ways to avoid getting marked for a serious violation are twofold: (a) do your best to ensure your carrier is not committing any of the 100+ possible serious violations, and (b) avoid triggering an FMCSA investigation.  Let’s take these both in turn:

• Make sure your carrier is not committing serious violations

Review the list of 100+ serious violations and do your best to ensure that your carrier is not committing these offenses.  One serious violation example: Failing to implement an alcohol and/or controlled substance testing program.  Due to the definitions, however, the Safety Inspector has a lot of leeway in his or her subjective judgment.  That being the case, you also want to pursue the second piece of strategy…

• Avoid triggering an FMCSA investigation

You see, a serious violation, by definition, can only be detected during an FMCSA investigation by a Safety Inspector.  So, if you don’t have an FMCSA inspection, you cannot have serious violations.  Seems simple enough, right?  Well, the good news is that one of the main triggers of FMCSA investigations is CSA BASICs over threshold – which is the last piece of the puzzle discussed below.

By the way – what to do if your carrier is marked with a serious violation?  Unfortunately, only time will take care of it because once a carrier is marked with a serious violation, they are stuck with that designation for a full 12 months – which is why you strongly want to avoid them in the first place.

(3) How Does My Motor Carrier Keep Our BASICs Below Threshold?

This is really the key question of the bunch.  There are 7 BASICs under the CSA Methodology – each calculated differently from the others.  What each BASIC has in common is that a BASIC measure is computed using points accumulated from past violations or, in the case of the Crash BASIC, crashes.  So, again, the simple answer is reduce your points and your BASIC percentile score, which triggers the alert when over threshold, will also fall.  Unfortunately, the simple answer is also simply not helpful.

Since points take 24 months to roll off, you can’t do much about the points already accumulated.  Much of this blog – and Vigillo’s products and service – are dedicated to helping carriers identify, analyze, monitor, and correct situations that are detrimental to a carrier’s safety rating.  Here is a starter list of actions a carrier can take:

• Monitor your ISS score from the FMCSA Portal
• Review your MCS-150 for instant improvements
• Understand your current CSA situation with Vigillo CSA Scorecards
• Review the Vigillo blog regularly for news and information about the current state of trucking safety & CSA.
• Encourage your drivers to get their free CSA score through RoadsideResume.com
• Use Vigillo’s Points Reduction Analysis for a clear, step-by-step approach to reducing the score for any BASICs already in alert status.

Ultimately, the ISS is based on driver safety and roadside performance – so safe, professional drivers are the key to avoiding trouble with CSA and your ISS score.  Good luck and keep safe!

I hope this information about the ISS-2010 is helpful to motor carriers, drivers, and safety professionals.  Please let me know what you’ve seen out there on the road or have questions or advice for readers.

From ATRI: The American Transportation Research Institute (ATRI) today launched its second annual truck driver survey to identify CSA impacts on trucking operations, as well as commercial driver perceptions and attitudes toward the maturing regulatory program. This survey, which will expand upon the truck driver research that ATRI undertook at last month’s Mid-America Trucking Show (MATS), will be compared and contrasted with last year’s CSA research – which included data from more than 5,000 drivers (report available online at www.atri-online.org).

Read more here.

Truck Drivers:  Take the survey here.

Interesting to see what the results will be!  Stay tuned – we’ll let you know when they are released.