Safety & Compliance

How to avoid 6 common CSA violations

Let’s examine the top three CSA violations for both vehicles and drivers across the industry and discuss practices that can help bring the numbers down.

May 2014, TruckingInfo.com - Department

by Daren Hansen, J.J. Keller & Associates

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“A good decision is based on knowledge and not on numbers,” the Greek philosopher Plato once said.

Too bad he wasn’t around when the government was coming up with CSA.

Now four years old, the safety enforcement program known as Compliance, Safety, Accountability relies on almost nothing but numbers. And as numerous studies keep telling us — and as many trucking professionals already know — those numbers are not always reliable.

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At the top of the list are your CSA scores, perhaps flawed but visible to the world and used to decide if the DOT needs to pay you a visit, or at least send you a letter.

Pull the curtain on those scores and you can find a mass of interesting and (arguably) more reliable data: the raw numbers coming in from enforcement personnel on the front lines.

Besides giving insight into your CSA scores, the enforcement data can reveal important clues about your drivers and overall safety management. It can tell you where to focus your compliance efforts.

Let’s examine the top three CSA violations for both vehicles and drivers across the industry and discuss practices that can help bring the numbers down.

The truck

Violation: Lighting

Ironically, broken lights are among the most “visible” of all violations. Maybe that’s why a whopping 28% of all roadside vehicle violations last year, out of 2.4 million inspections, dealt with lights or reflective materials.

A broken or missing light, reflector, or reflective tape is like an “Inspect Me!” sign and can result in a loss of six severity points in CSA for each violation (Three points for reflective tape).

Prevention: Drivers and maintenance personnel need to be aware that every light and reflector listed in Sections 393.11 and 571.108, even the license-plate lamp, needs to be operational at all times. The only way to verify compliance is to inspect the vehicle on a regular basis.

By conducting adequate pretrip and post-trip inspections and reporting what they find, drivers should be able to spot violations — and get them fixed — before an inspector does. Carrying spare fuses is required, and spare bulbs can help too. Non-required lights do not have to be working, but any broken lamp can draw attention.

Violation: Brakes

One-fourth of all vehicle violations are for brakes, with over 1 million brake violations last year, each with four CSA points.

As with lights, brakes need to be inspected before and after every trip, but drivers need to be fully trained and qualified before doing any brake adjustment.

Prevention: Training is key. Make sure drivers know what to look for and when to get assistance with their brakes. The only way to find a brake adjustment problem is to carefully measure the stroke, and adjusting a brake that has an automatic adjuster won’t fix the problem (and may make it worse).

Violation: Tires

As with lights, bad tires are a sure-fire way to be stopped and inspected. The biggest culprit: tread depth. Overall, 11% of vehicle violations are for tires (half for tread depth), with a CSA severity of eight points.

Steer tires must have 4/32 inch of tread depth; other tires must have 2/32 inch.

Prevention: A comprehensive maintenance program that includes regular tire inspections is a must, including pretrip and post-trip inspections. Drivers need to know how and when to check inflation (with a gauge!) and when it’s time for a replacement.

Drivers

Violation: Logs

So-called “form & manner” and “log not current” violations make up one-fourth of all driver violations at the roadside, far and above any other violation. A form/manner violation carries just one CSA point, but a log that isn’t current is worth five.

These violations are often frustratingly obvious and easily correctable.

Drivers need to fill out all required information on their logs and keep them current to the last time their duty-status changed.

Prevention: First, make sure your drivers know what’s required and what’s not required on their logs (see Sec. 395.8), and when it has to be filled in. When a driver is stopped for an inspection, the log must be current up to the time at which the driver got behind the wheel.

Make sure your policies reinforce these requirements. Review your CSA data to find the worst offenders and re-educate them on the rules.

Finally, investigate two things that can help eliminate many of these violations: pre-printing of common log entries (address, etc.), and electronic logs (which will be mandatory soon enough).

Violation: Medical issues

One in eight driver violations is related to medical issues, often a failure to have a valid medical certificate. These carry a low CSA point value of one or two, although driving while physically ill is a 10-point violation.

Prevention: Track the expiration of your drivers’ medical cards and make sure they get updated, placed in drivers’ files, carried in the vehicle and turned in to the state licensing agency. Make sure drivers know exactly what’s required of them, and have consequences in place for those who fail to comply.

Some of these violations may go away once we have the National Registry of Medical Examiners, and once interstate CDL drivers no longer have to carry their medical cards (in Feb. 2015).

Violation: English ability

This violation has been surging in recent years, currently at 9% of all driver violations and carrying four CSA points.

Compliance is complicated because there is no yes/no standard. Key for a roadside inspection is being able to fill out paperwork, speak with officers and answer their questions, all in English.

Prevention: Your hiring practices should filter out drivers who simply cannot meet the standard. Use training and practice to help drivers know how to respond to typical questions about their logs, their trips and cargo, their insurance, registration, license and their vehicle.

Even if you don’t pull the curtain on your CSA scores, a little training on these common violations may go a long way in improving them.

Daren Hansen is a Senior Editor – Transportation Safety for J.J. Keller & Associates. Contact him at [email protected]

Comments

  1. 1. Jason [ May 13, 2014 @ 09:36AM ]

    Great read, with simple solutions to simple problems. All we need to do is the basic, and the rest will follow. Nothing on this list is too complex, it is the basics. If we can incorporate doing these little things, we can cut insurance costs, save time by reducing repairs and sitting though inspections, and keep our roads safe.

  2. 2. Tim [ May 14, 2014 @ 05:02AM ]

    "Non-required lights do not have to be working, but any broken lamp can draw attention. " This is not true in NY. All lights have to work even the added on chicken lights.

  3. 3. Arnold C [ May 18, 2014 @ 04:02AM ]

    Non English speaking violators??? Your hiring practices should filter out drivers that simply cannot meet this standard??? What happened to the concept of trusting our government to stop the flood of Unqualified people who couldn't care less about truly taking pride in our country??? In my many encounters with said individuals, they seem to harbor an extreme dislike for America rather than a desire to become proud Americans. But hey, as long as they vote Democrat????? Isn't that the real agenda? Homeland security out the window!! Soon we won't qualify unless we can also speak Spanish or Russian etc etc. crazy

  4. 4. keith [ May 18, 2014 @ 11:26AM ]

    I get a kick out of non professionals making laws to affect professionals. Lets see, start the driving clock and you are obligated to drive like heck because you can't stop it. Even if circumstances are beyond your control. Punished before the fact. Many 4 wheelers get a total free ride. Drop their phone and crash into, at 55 mph, and total another persons car. This is all free according to law enforcement. Public road? Not any more. Morons rule.

  5. 5. KKK [ May 20, 2014 @ 11:35AM ]

    A.C. your true colors show with your ignorant political comments. No, not red, white and blue), but a white sheet and a conehead. However, I agree with you on one thing, some immigrants are not proud of becoming americans, but that's a small segment, and we can thank our goverment for catering to them in their native language (rememeber, taking CDL test in their native language). Remember, a nation without a common language becomes divided...

  6. 6. Peter D. Ohmart [ May 24, 2014 @ 10:02PM ]

    Tim, thanks, you are completely accurate about the lights. I have for the last 20 years gone by the premise, if the lights are on the vehicles, no matter how they got there, the must be working no matter what state I am in. This way my work load is lightened as I do not have remember what state forgives for certain lights out & which do not.

  7. 7. Peter D. Ohmart [ May 24, 2014 @ 10:30PM ]

    Arnold,
    I understand that you are "Madder than a mule with a mouth full of bees", but do not blame the drivers who come from some place other than America for that. Keep in mind some 2-legged Jackass allowed an individual to take the test while having a translator. Yet the driver is required to speak "English" fluently. No that is "Dumber than a pound of Rocks", needing a translator and being required to speak English. Or the other one I like, the driver being tested needs someone to read the questions for them. Wait, I have a question, what does that driver do when he/she are driving on the road. Are there two people in all of those trucks? I do not know. I do not think so!!!

    Now, as for the democrat affiliation, I am a registered Republican, but I will vote for the best of anything when it comes to party, or laws, and that comes from researching, and that includes voting across party lines, not just listening to people with verbal diarrhea, commercials, party speakers, etc. who try to convince me what I should do. I understand that you may have a dislike, but please, I ask, do not categorize people in the way you did.

    The United States worldwide is known for English being our main language. It should stay that way, the same as French is primarily spoken in France, or German in Germany. I have no problem of a second language being recognized in this country. Hell's Bells, Switzerland has at 3, and Italy has at least 2, plus the ones I already mentioned have more than one. So there is no problem having more than one language, but do not ask me or any nation to change their primary language.

    I do agree with you on the point, if you are calling America your home, there should be extreme pride, not a dislike. If you do not like America, as the saying goes, “there is the border, please cross it as quickly as you can”. America has its problems, and it does, but we are much better off than other countries in the world. I am proud to be an American!

  8. 8. Bob Harrigan [ May 30, 2014 @ 06:55AM ]

    Non-English speaking drivers that have in whatever way obtained a CDL in the U.S. also know their rights that were granted to them when we gave them U.S. citizenship. Can you say EEOC? We are functioning in a catch-22 system.

  9. 9. Khloe Andirsen [ June 19, 2014 @ 10:23PM ]

    This CSA has ruined the moral of every trucker I know. My husbands a trucker & his co-workers are stressed out to the max...with the avalanche of regulations & the constant worrying about getting on the bad side of your boss with every inspection. You get stressed at every station you pass or get pulled into. Some things out of your control but are counted against you anyway. I wanna see these inspectors get inspected & get points when they violate something !!! See how they like it !! EXAMPLE: My hubby had a clean truck...not 1 thing wrong, he gets pulled over for inspection on his trip back to yard. He inadvertantly picked up a nail in his tire. OOS !! of course its a safety thing BUT it wasn't in his control. Tire was only a couple mths old, had new tread on it!! Still is counted as tho he neglected the tire !! BOGUS !! JUST HORRIBLE- Looking for ways to get out of this ridiculously over regulated career !!

 

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