Mobilize today for the DOT's CSA Enforcement Program. Act now with a proactive safety management philosophy. The goals of this blog are to provide information, insights and know-how on being safe, mitigating exposures and risk, and maximizing control of losses. Email me at john(at)part380(dot)com. Thank you for visiting.
On December 10, 2010, a pilot enforcement program known as Comprehensive Safety Analysis 2010 (CSA 2010) was relaunched nationally and became Compliance, Safety, Accountability or more commonly, CSA.
The heart of CSA is the Carrier Safety Measurement System (CSMS). Another part is the Driver Safety Measurement System (DSMS), which measures the safety of individual commercial motor vehicle (CMV) drivers.
The Driver Safety Measurement System is designed to identify drivers with a history of safety violations. The information is used to target enforcement when an investigator visits a motor carrier during a compliance review or other intervention. This information is not provided to the public.
The SMS is based on available roadside safety performance data. This roadside data is used to rank operational safety in six Behavior Analysis and Safety Improvement Categories (BASICs) and a crash involvement (Crash Indicator). Law enforcement may use rankings within these BASICs and the Crash Indicator to select organizations for further investigation or selection for additional roadside inspections. As this information is public (except for the Crash indication), anyone including shippers, insurance carriers, job candidates, etc., can look at the BASICs as well.
If a certain score (or threshold) is passed, the basic may be flagged.
Flagged BASICs can result in DOT Audits or investigations that can last from several hours to several days, or even weeks, depending on the size of the fleet and the scope of the investigation. If any regulatory discrepancies are discovered during an audit or investigation, the DOT can respond in a number of ways ranging from fines, to issuing a downgraded safety rating, or “orders” to comply or to develop a safety plan.
Essentially, the results of every Roadside Inspection (RI) are important because the safety performance data from the inspection can affect the BASIC or CSA score.
“I am asked over and over again, ‘how do I get my CSA scores down?’ Generally speaking, you have to control your drivers. You can’t just turn them loose and let them do whatever they want to do. Every time they get written up by the police at a scalehouse, or on the side of the road, your score goes up. You need to be in your drivers’ ears all the time. It’s not too much more complicated than that.”
In addition, I recommend that you—
1. Become aware of your CSA scores. The CSA scores can be checked at:
2. Have a process in place for immediate repair of any vehicle safety defects or faults. A successful maintenance program should be 80% proactive or preventative, and 20% reactive. Catch problems when they are small and manageable.
3. Make sure your driver(s) understand Hours of Service rules and regulations (Part 395).
4. Make sure drivers are well-rested and alert when they drive.
5. Hire well. Do good background investigations and drug and alcohol testing, if required. Road test drivers before hire and do driver check rides at least annually.
6. Have a set of written standards for your fleet. Document driver and vehicle expectations. Provide drivers with safety training, manuals, guides and training. Monitor driving performance and give feedback when necessary.
7. Learn and know the DOT regulations. Know what the regulations expect of you and your team. Then communicate your expectations, on a daily basis.
Organizations with low CSA scores do all of the above and more.
John Taratuta is an independent Risk Engineer. (989) 474-9599
The CSA Tire Inspection video starts with the now standard boilerplate legal disclaimers, followed by a musical intro of a turquoise blue Michelin truck, and self-introductions by Kevin Rolling, of the Tire Industry Association, and Doug Jones of Michelin, NA. At 2:45 there is an introduction to CSA (DOT’s regulatory enforcement methodology) and Capt. Douglas Shackelford (North Carolina State Highway Patrol) tells us he will talk about the “visual inspection components” to avoid inspections.
CSA created a new Safety Measurement System (SMS) for both driver and company. Under CSA, individual road violations are assigned a “severity rating” that ranges from one to ten, with ten being the most severe and the most likely to cause an accident.
Items that are required to be inspected under Part 393 for safe operation prior to each trip include:
– Lamps, Reflective Devices and Electrical Wiring
– Glazing & Window Construction
– Fuel Systems, including: Compressed Natural Gas Fuel Containers and Liquefied Petroleum Gas Systems
– Coupling Devices and Towing Methods
– Miscellaneous Parts and Accessories including: Tires, Windshield Wipers, and Rear Impact Guards
– Emergency Equipment
– Protection against shifting and falling cargo, including specific securement requirements by commodity type
– Frames, Cab and Body Components, Wheels, Steering and Suspension Systems
Capt. Shackelford, “For purposes of this video, we’re going to focus on tires. So let’s look at the federal regulations for tires.”
Feeling the sidewalls for bulges and defects.
Feeling the face or crown of the tire for damage by laying hand flat on tire and sliding it across the face.
Tires Part 393.75: No motor vehicle can be operated if any tire exhibits the following conditions:
– Exposed body ply or belt material through the tread or side wall
– Tread or sidewall separation
– Flat tire or a tire with an audible air leak
– A cut where the ply or belt material is exposed
These are generally cited as Out-of-Service (OOS) conditions.
Exception: An under 3/8 inch bulge on the sidewall, if accompanied by a blue repair triangle (no more than two repair patches) is acceptable. Use a “bulge gage” to measure the height of the bulge, if in doubt.
Lead tires (steering tires, converter dollies for semi-trailers and steer axles on full trailers ) must have at least 4/32s tread depth at any point on any major groove expect where tread wear indicators or stone ejectors are located. All other tires must have 2/32s inch in every major groove of the tire.
If tread depth is under the limit as established by Part 393.75, then the driver will be cited for a violation and assessed points under CSA. However, the vehicle will be placed out of service if the tread depth is below the limit set by the Commercial Vehicle Safety Alliance (CVSA).
The vehicle is OOS, if tread depth is under specification at any two adjacent grooves.
The decoupling groove at the shoulder is not a major groove. Other terms for this tire feature include: “shoulder wear protector” or “defense groove” or “pressure distribution groove,” depending on the manufacturer.
If a tire is out of specification, then this is a citable violation (ticket-able) but not an out-of-service (OOS) condition.
Insufficient tread in a decoupling groove is not a violation or an OOS condition, if all the major grooves have sufficient tread depth.
Irregular wear (example: tire “cupping” from dry steering) is not a violation or an OOS condition, if all the major grooves have sufficient tread depth.
Missing tread chucks are not a violation or an OOS condition, if all the major grooves have sufficient tread depth and the missing tread material does not expose the ply materials.
Weather checking is not a violation or an OOS condition, if the checking does not expose the underlying material.
FMCSR 393.75(4)(d) says, “No bus shall be operated with regrooved, recapped or retreaded tires on the front wheels.” This is an OOS condition.
A “regroovable” tire is allowed, but not a regrooved tire.
FMCSR 393.75(4)(d) says, “A regrooved tire with a load-carrying capacity equal to or greater than 4,920 pounds shall not be used on the front wheels of any truck or truck tractor.”
Almost all of these conditions carry a “severity rating” of eight points if found during a roadside inspection.
Example: a tire is found during a roadside inspection with less than 50% of inflation as marked on the sidewall. As such an OOS condition exists (as the tire is considered flat and may have sustained hidden “run-flat” damage).
Under CSA, eight points are given for the flat and two additional points for an OOS condition – multiplied three fold for the 0-6 months multiplier resulting an a total of thirty CSA points (the max allowed for any single violation within a CSA BASIC). This in turn, affects the fleet’s CSA “SMS score” and could later result in additional “targeted inspections.”
“Enforcement officers are now equipped with a valuable tool for any fleet we inspect. And since the CSA “Snapshot” is based on real time inspections and data, we know exactly where to look and have complete confidence when identifying violations, improving safety on our nation’s highways.”
Kevin Rolling, “Perform a thorough pretrip and posttrip inspection.”
Doug Jones: “Thanks for watching.”
The inspections performed by a US DOT certified roadside inspector under CVSA guidelines are focused on CRITICAL items. A driver has a duty to thoroughly inspect (and document) not just the aforementioned “critical items,” but all items (as specified by the regulations) on a vehicle and its load.
The “window of opportunity” is the period of time when a part or accessory begins to exhibit poor performance, prior to a repair being made. This is a period of time and/or of deteriorating performance when the part or freight is in a sub-critical condition that will require service or repair.
For example, when laying a hand flat on tire and sliding it across the face or crown of the tire, if one direction feels smooth and the other has sharp edges, then there is a lateral drag problem (edges of the tire are feathering away from the direction of the push), possibly due to excessive, unequal camber, resulting in decreased MPGs.
Irregular wear is an indicator of future trouble.
“Heavy, spotty, cupped or irregular tire wear
are signs of components (king pins, bushings, tie rod ends, steering gear, pitman arms, idler arm, spring sag, shock leakage, or wheel bearings) that are out of specification.”
Always try to always stay out of the tire’s trajectory areas and know when use a tire cage when working around tires. Several years ago, a small child was killed in Michigan watching his father inflate a truck tire.
Learning how to properly read a tire can prevent later breakdowns in critical items, saving time and money, honor and lives.
FINAL TIRE SAFETY WARNINGS
“Flat tires,” according to OSHA, are any tires under 20% of proper inflation. DO NOT re-inflate any flat tires unless you are a properly trained tire technician. Tires over 80 percent of the recommended pressure may be inflated on the vehicle if proper precautions are taken. Flats should be properly inspected to find the cause of the leak. (See OSHA 29 CFR Part 1910.177)
Stay out of the tire's trajectory areas and know when to use a tire cage when working around tires.