CSA and Roadside Inspections Trooper John Sova Motor Carrier Operations Division North Dakota Highway Patrol

Roadside Inspections  Where does the inspection report go?  How are we affecting CMV safety by doing a roadside inspection?  Is the inspection simply a warning or is it something more?  Who does the inspection report affect?  What does a clean inspection report do?  Why is it so important to properly fill out the inspection report?

Objectives  CSA – What is it?  7 CSA Basics  Inspections – beyond roadside enforcement  Safety Investigations - Who receives one?  Safety Investigations - How are they influenced by roadside inspections  Future concerns

CSA What is CSA?

CSA  Compliance, Safety, and Accountability –Started as CSA2010 –Used to track safety performance of carriers and drivers (CSMS and DSMS) –Replaced Safestat 7 Basics vs. 4 Safety Evaluation areas All violations counted vs. only OOS violations –Increased importance of high quality roadside inspections

CSA  Compliance, Safety, and Accountability –Being implemented in stages Nothing changes on surface (roadside inspection) All changes behind the scenes (investigations) –Increased types of interventions available Goal was to contact more carriers and earlier Compliance Review changed to Safety Investigation NOV, NOC, Warning letter, Off Site Focused, On Site Focused, Full

CSA  Seven Basics –Unsafe Driving –Hours of Service Compliance –Driver Fitness –Controlled Substances/Alcohol –Vehicle Maintenance –Hazardous Material Compliance –Crash Indicator

CSA  Intervention Thresholds –Unsafe Driving, HOS and Crash Indicator Passenger carriers (50%) HM carriers (60%) All other carriers (65%) –Driver Fitness, Controlled Substances/Alcohol, Vehicle Passenger carriers (65%) HM carriers (75%) All other carriers (80%) –HM Compliance All carriers (80%)

CSA  Carriers subject to HM threshold –Min. 2 Placardable HM inspections in previous 24 months –Min. 1 of the 2 inspections in the last 12 months –At least 5% of total inspections are HM Placardable inspections –Level 3 inspections are not counted

CSA Questions?

Inspections  What does all this have to do with my job doing roadside inspections? –The carrier and driver scores are calculated by what is or is not listed on the roadside inspection report and the accuracy of the information –Alerts appear due to violations on roadside inspections and/or investigation history –You are determining who gets interventions including who gets safety investigations

Inspections  How do roadside inspections determine who gets interventions? –Every violation has a severity weight assigned to it Using wrong code gets wrong weight assigned 392.9a1 (1 pt) vs b (7 pts) (1 pt) vs c (7 pts) 393.9a (2 pts) vs TS (6 pts) Generic descriptions always 1 pt Extra 2 pts assessed when OOS Miss a violation (0 pts) Invalid Violation (Improper points assigned)

Inspections  Issues –Points only assessed if violation is in SMS Methodology Basic (0 points) Excessive weight violations (0 points) –Speeding violations 392.2S (1 point) (no longer available) SLLS2, 6-10 mph over limit (4 points) SLLS3, mph over limit (7 points) SLLS4, 15 or more over limit (10 points) Only violations assess points –Traffic violations

Inspections –Every violation will have a time weight 0-6 months = 3X 6-12 months = 2X months = 1X –Example- Turn signal inoperative on trailer (6 + 2) X 3 = 24 pts (0-6 months) (6 + 2) X 2 = 16 pts (6-12 months) (6 + 2) X 1 = 8 pts (12-24 months)

Inspections –Example of wrong coding on new inspection –(1 + 2) X 3 = 9 pts c on new inspection –(7 + 2) X 3 = 27 pts –Coding 50% inflated tire under wrong code a – Flat tire –(8 + 2) X 3 = 30 pts h – Underinflated tire –(3 + 2) X 3 = 15 pts

Inspections  Coding of violations –Always choose the best option for the violation Most descriptive Stay away from generic descriptions, if possible –Taking the time to do the inspection, might just as well have it counted appropriately

Inspections –Every inspection is counted Level 1,2,3 inspections count towards driver Basics Level 1,2,5 inspections count toward vehicle and HM Basics –This is why Vehicle violations and HM violations on Level 3 inspections don’t count. –Violation points are put into the corresponding Basics (max of 30 pts in any 1 Basic/inspection) –Only 1 violation code given weight (ex. Flat tires) –Total points of all violations from all inspections in a Basic are divided by the sum of time weighted inspections related to that Basic to get a Basic measure

Inspections –The carrier is then placed into a peer group based on number of relevant inspections in that Basic in the previous 24 months. –The last step is to rank that carrier by comparing its Basic measure to other carriers Basic measure in that peer group –The percentage is where the carrier falls in the peer group

Inspections  Clean inspections raise the number of inspections in a Basic, helping the carrier’s score  If only inspections with violations go on the carrier profile, it skews the data and we cannot get an accurate picture of which carriers are having a problem because according to the data, they all are  Causes Safety Investigations to be conducted on the wrong carriers

Inspections  Improper clean inspections have the opposite affect.  When clean inspections are done to get a number, we are reducing the percentages and can bring a carrier out of alert status that belongs in alert status  The scores are getting watered down and the system, once again, is giving us invalid data  Driver/Carrier Requested inspections –USDOT Memo SP RR

Inspections Garbage In = Garbage Out

Inspections Questions?

Safety Investigations  How is an investigation initiated? –Alert in Basic (Percentage or prior investigation) –Request by carrier (upgrade in safety rating) –Complaint –Fatal crash –Enforcement follow-up

Safety Investigations  How does a roadside inspection influence an investigation? –Red Flag Violations/Drivers –Sampling criteria DSMS, crashes, High violation rates

Safety Investigations  Outcome of investigation is a direct result of the quality of information put into system by roadside inspections –Exceptions Violations found as expected but didn’t rise to the level of critical (no pattern) Violations on intrastate carriers with DOT #’s –Jurisdiction only on interstate commerce

Safety Investigations Questions?

Future Concerns  Safety Rating calculated by Basic scores –Currently only from an investigation –Shippers-won’t use carrier with poor rating –Insurance companies –Carriers will scrutinize inspection reports –DataQ challenges will/may increase What can inspector do to limit these? –DataQ decisions must be correct

Summary  Roadside Inspections are the backbone of CMV safety and enforcement –Determine who gets investigations –Determine which Basics get investigated Focused or Comprehensive –Determine Red Flag investigations –Determine which drivers are selected during investigation

Summary  Safety Investigations are critical to CMV safety –allow us to bring the carrier and all its drivers into compliance Further investigation of what you found on the road Holds the carrier accountable Holds the drivers accountable Impacts many drivers with one encounter –Allows for progressive enforcement if violations are not remedied –Gives inspections the power to bring about compliance long after releasing the driver roadside

Roadside Inspections  Where does the inspection report go?  How are we affecting CMV safety by doing a roadside inspection?  Is the inspection simply a warning or is it something more?  Who does the inspection report affect?  What does a clean inspection report do?  Why is it so important to properly fill out the inspection report?

Questions?