The new CSA (Comprehensive Safety Analysis) Methodology, published in August 2010, reduced the number of violations appearing on the severity weighting tables substantially reducing the Behavior Analysis & Safety Improvement Categories (BASICs) score. But don’t let fewer violations on the tables give you a false sense of security; there are still ample opportunities to get at least one violation at a roadside inspection.
Compliance begins and ends with the pre-trip inspection. As a carrier, how your employee driver (or any other driver that you utilize) performs will have an impact on your roadside inspection results and also aid in reducing the number of crashes attributed to your company. The best way to maintain an effective safety program is to follow what the FMCSA has suggested and use what is called a “Safety Management Cycle.” It is a very simple plan where you can incorporate the best maintenance practices into your safety plan. Imagine a large wagon wheel with a hub in the middle and six spokes going from the hub out to the outer rim…
Spoke 1: Polices and Procedures. Create policies and procedures that offer practical application of the maintenance regulations. Make sure you enforce the policies in order to give them teeth. Consider including the following areas: training, recordkeeping, consequences for policy violation, and who is in charge – give name and job title. All personnel that are affected should be given a copy of the policy and sign a receipt to show that they have received it and will follow it.
Spoke 2: Roles and Responsibilities. Identify, clearly define, and document roles and responsibilities of drivers, dispatchers, mechanics and technicians related to vehicle inspection, repair and maintenance. This can be accomplished through your policies and procedures, as well as training and job descriptions. The role of senior management must also be identified, clearly defined and documented for implementing inspection, repair and maintenance policies, and for monitoring compliance with these policies.
Spoke 3: Hiring and Qualifications. Thoroughly investigate whether a potential mechanic/technician actually worked for the people they said. When interviewing for the position of mechanic, it could be beneficial to check the previous employer’s SMS score if applicable. If you’re going to use an outside garage for repairs and to perform periodic and brake inspections, ask about the tech’s qualifications. Ask for proof that they meet the minimum requirements of the rules.
Spoke 4: Training and Communications. Be sure to always use the North American Standard Out-of-Service Criteria in your driver and technician training program. All parties responsible for safety must know the regulations that the motor carrier has to follow during a roadside inspection.
Spoke 5: Monitoring and Tracking. Designate someone to monitor and track roadside inspection results in order to ensure that vehicle defects are repaired promptly. This will help prevent you from accidently using an out-of-service vehicle. Someone in your shop, or your outside fleet maintenance service facility, should be required to review the daily vehicle maintenance reports against receipts to ensure maintenance accuracy. This same person should also monitor all manufacturers’ recall notices, if applicable.
Spoke 6: Meaningful Action. Take action based on what you learned from past experiences. This will help in preventing a possible repeat violation during a future roadside inspection. You must ensure that your driving and maintenance staff is familiar with all the regulations (see Sec 390.3(e) 1 and 2). If you become aware that someone is not up to his/her responsibilities, you need to address this issue right away before it becomes a more serious problem. This may involve a progressive disciplinary program, possibly leading to termination. Try to focus on positive corrective action to ensure that drivers and technicians comply with FMCSA regulations and company policies.
Pre-trip and post-trip inspections are the two most important things that a truck driver, new or old, can do to promote safety and to insure against loss of revenue. The secret goal is to discover any problems while they are small, instead of waiting until they become a major problem. By following the subsequent three steps, you can stay out on the road making money, instead of being in the shop spending money.
Step 1: Parking your Rig. When you park your rig, if at all possible, try and park in a dry spot. If you can’t, try to put a large piece of cardboard down so that you can check for any leaks underneath.
Step 2: The Walk Around. As you walk up to your truck, look for leaks. Start your engine and turn on all your lights, heater, A/C and wipers. Also, be sure to check the horn, all dash lighting and gauges, and all external lighting. Check for missing or non-working clearance lights, wiper blades, headlamps, etc. Remember, everything that came on your truck from the factory must work, and if you added any extra lighting, it must also work. Next, walk down one side, checking the top of the door, window, mirrors, turn signals, front wheel lug nuts, and tires (look for any uneven wear or low air pressure). Check fuel tanks, fenders and mud flaps, making sure everything is in place and tight. After that, check the rear lighting, then do the same for the other side that you did on the first. Tires and leaks are the most common problems, followed by loose parts, which cause truckers the most headaches and downtime.
Step 3: Under the Hood. Check your oil, power steering fluid and coolant levels. Check your belts, hoses and water pump. If you see any leaks, try to follow the leak to see where it comes from (most of the time it is just a bolt or clamp that needs tightening). Also, check out the front brakes – make sure you have at least 16/32” or more brake shoe. If any brake shoes are 8/32” or less, this will put your truck out-of-service at the first scale. This also goes for the rear brakes.
Good maintenance is a must with CSA, so be sure to follow these guidelines. Until next month, “Drive Safe – Drive Smart!”
