March 31, 2012
Bruce Hooker of Mattei Insurance Services
It’s now been almost six months since the Federal Motor Carrier Safety Administration’s CSA (Compliance, Safety, Accountability) system went live. In that time, many waste companies have racked up violations and seen their scores rise in several of the CSA’s “BASIC” categories. By looking at some of the most commonly cited violations, a waste hauler should be able to take proactive steps to reduce the likelihood of having CSA problems.
To review, the CSA’s Safety Measurement System (SMS) rates motor carriers in seven different categories called BASICs. These categories are: Unsafe Driving, Fatigued Driving, Driver Fitness, Controlled Substances/Alcohol, Vehicle Maintenance, Cargo-Related and Crash Indicator. With the exception of Crash Indicator, a waste company’s measurement (score) for each BASIC is based on the number, severity and date (more recent violations are weighted more heavily) of the violations.
What follows is a look at each BASIC category (with the exception of Crash Indicator) that indicates what types of violations are common for waste haulers and what can be done to avoid them.
Unsafe Driving. Obviously, having drivers cited for speeding and other moving violations is one way for a hauler to develop problems with this BASIC. Since having a truck pulled over for a moving violation provides the enforcement officer an opportunity to find other violations, having drivers obey all traffic laws is the best way to avoid issues with this BASIC as well as many of the others.
It should also be noted that many waste companies have developed problems with the Unsafe Driving BASIC for something as simple as seatbelt violations. The severity weight for a seatbelt violation is a 7 (out of 10), which is higher than most other moving violations. It is also important to remember that texting or use of a handheld cell phone has violation severity of 10 in addition to the significant fines incurred for engaging in those activities behind the wheel.
Fatigued Driving. Fortunately, most waste collection companies do not have many problems in this area because of the local scope of their operations. However, those companies involved in refuse transfer operations that travel over 100 air miles should be aware that more violations are issued to over-the-road tractor-trailer drivers based on the Fatigued Driving BASIC than any other BASIC. Violations stemming from inadequate or missing driver’s record of duty status (logbook), general logbook violations and exceeding permissible driving hours are among the most frequent violations issued to the transportation industry as a whole.
A waste company can run into problems with this BASIC for allowing someone to operate a commercial vehicle without a valid commercial driver’s license (CDL) or without the proper CDL endorsement, such as air brakes. A driver who forgets to bring his or her CDL to work can also result in this violation.
Similarly, many waste companies are getting dinged on the Driver Fitness BASIC because their drivers are failing to carry their medical cards with them or are carrying an expired medical card. Even those drivers who have submitted their medical examiner’s certificate to their state department of motor vehicles (DMV) as part of the new self-certification process should still carry their medical cards with them just to be on the safe side. Making sure that all drivers have a valid CDL and medical card with them before they hit the streets will go a long way to avoiding these two most common violations.
Another source of violations under this BASIC comes from a driver failing to wear his eyeglasses or hearing aid if it is shown as a restriction on his license. Finally, allowing someone who cannot speak English or cannot understand road signs in English to operate a commercial motor vehicle can also result in a violation under this BASIC.
Controlled Substances/Alcohol. Any driver found using or in possession of illegal drugs will result in a violation that carries a severity weight of 10 under this BASIC. Additionally, being under the influence of, being in the possession of or using alcohol within four hours of beginning work will result in a violation with a severity weight of 5. Making supervisors (who have had reasonable suspicion training) available to greet drivers as they show up for work is a good way to identify and head off potential problems in this area. Since the alcohol standard prohibits any possession of alcohol, it is important to remind both drivers and helpers not to accept any gifts of alcohol from customers.
Vehicle Maintenance. There are more than 200 separate violations relating to the maintenance of a commercial motor vehicle, and the CSA has assigned a severity weight for each one. It is no surprise that issues with tires or brakes are the most common violations within this BASIC. Most violations with brakes carry a severity weight of 4, while most violations for tires carry a severity weight of 8. Because of the high severity weight associated with tire violations and because tires are so easy for an officer to inspect, it is vital that a waste company have a strategy to ensure that all their trucks have good rubber at all times.
While there are a myriad of other maintenance violations affecting waste haulers besides brakes and tires, a couple others stand out as common problems. One is not having a fire extinguisher or having a discharged or unsecured fire extinguisher. Another relates to burned-out bulbs and lamps.
When it comes to avoiding as many violations as possible under the Vehicle Maintenance BASIC, most waste companies have found that what works best is doing quality pre-trip inspections, having a strong preventative maintenance program and keeping trucks as clean as possible.
Cargo-Related. The Cargo-Related BASIC is the most misunderstood BASIC and often the most punitive for waste haulers. Two types of these violations seem to make up the vast majority of violations for this BASIC, and both carry heavy severity weights. The first relates to the improper securement of the rear of a roll-off box, which has a severity weight of 7. Companies that operate roll-off trucks need to make sure they fully understand the requirement and have trained their drivers on what constitutes proper securement.
The second common violation in this category relates to leaking/spilling/blowing/falling cargo. This can be especially punitive and seemingly unfair to waste haulers as the discretion as to what constitutes a violation (e.g., one piece of paper flying out of a truck) is left up to the enforcement officer. To make matters worse, this violation carriers a severity weight of 10. While no company will ever be 100-percent successful in preventing any debris from blowing out of the truck, it is still vital to take precautions to reduce this from happening. Roll-off boxes and transfer trailers need to be adequately tarped. The doors on roll-off boxes and transfer trailers should be in adequate alignment so that no debris can escape. The top door on a front-load truck should be closed when not in the process of dumping a container. And the hoppers of rear-load trucks should be free of any refuse or have the blade completely covering the hopper when the truck is traveling at any appreciable speed.
Bruce Hooker works for Mattei Insurance Services Inc. based in Sacramento, Calif.