Author: finaoagency

Everyone can agree that Hours of Service (HOS) management is a critical aspect of all safety sensitive operations, as fatigue has proven to be a top cause of all accidents involving a Commercial Motor Vehicle. Your truck’s Electronic Logging Device (ELD) is the best tool available to capture HOS data and measure against the HOS minimums set forth by the FMCSA in a standardized format. These devices are relied on heavily in our industry to act as the de facto hours of service clock, referred to in audits, roadside inspections, and litigations. The HOS rules are specific in writing and expected to be followed, resulting in ELD manufacturers building and implementing logic and timetables into a recordable and presentable electronic device that your organization and law enforcement can access on demand.

There are many reasons why utilizing an ELD is critical for business operations and meeting minimum regulations established by the DOT and FMCSA. But what if the ELD is not painting an actual picture of compliance or risk and instead is providing a false sense of security for your fleet? Are you depending on your ELD to manage your HOS, or are you an active participant in the process?

Successful fleet managers still need to engage with and get to know their drivers on a personal level. Is there something going on in their lives that is affecting or limiting their rest periods and creating fatigue situations? Examples may include a second job, sick family members at home, marital issues, etc. Sometimes life gets in the way and drivers should feel comfortable telling their managers they are too stressed or fatigued to drive without potential severe consequences. Managers also need to review routes for compliance and reasonableness. If the route is too long, the driver is setup to fail from the beginning.

The intentions of ELDs were to make it easier and faster to accurately track, manage, and share HOS data, as well as create a safer working environment. While there is no doubt tracking HOS data is much easier than it was with paper logs, the data still needs to be analyzed and managed by a safety professional.

According to the ‘Compliance, Safety, Accountability’ (CSA) enforcement program, HOS violations in 2022 accounted for 3 of the top 10 violations with out-of-service (OOS) orders, including #2-no logs when required and #3-false logs. The top HOS violations include exceeding the 11 or 14-hour limits, not taking 10 hours off, and false logs. These statistics reveal that management is relying too heavily on ELDs and should start manually reviewing logs daily and hold their drivers accountable for following HOS rules.

The question as to whether ELDs have improved safety as originally anticipated is hard to quantify due to factors such as the COVID-19 pandemic, which resulted in several HOS exceptions, as well as the HOS changes made in 2020. However, if you look at the most recent data (October of 2022) published by the FMCSA regarding crashes involving fatality or injury, it proves that ELDs are not as effective on their own. Accident rates for “accident by 100 million miles” have actually increased since the mandate went into effect in 2017. An increase of 10% by 2019 from 2016, the year before the ELD mandate was enforced, proves that relying strictly on ELD data is not an effective HOS management tool for your company or the public safety.

Considering the cost of implementing these devices, one would expect to have an ROI that can be pointed to, specific to reduction in accidents/injuries/fatalities while also minimizing the workload on a motor carrier. That has unfortunately proven to be the opposite of reality; whereas increases in accidents, risk and significant lawsuits have proliferated as indicated in the average size of verdicts since the ELD mandate went into effect. According to the American Transportation Research Institute’s (ATRI) “Impact of Nuclear Verdicts” study, fatigue and hours of service were the #2 and #3 reasons by cases with a 95% success rate in verdicts. In many of these cases, the driver’s hours of service were egregiously in violation with the motor carrier found to be responsible and/or negligent.

With all of the available data coming from your ELD, it can create the perception of negligence. How is your fleet managing the ELD output or reporting capabilities? What actions or trends are you as a motor carrier able to point to that ensures you’re not only employing safe hours of service practices but overall driver compliance and risk? How a motor carrier manages their ELD compliance, including reports, trends, and data output, is critical to going beyond the minimum requirements while not falling victim to complacent compliance. Are you equipped to manage all elements of HOS FMCSA compliance without assistance? If an audit is called tomorrow, how confident are you that you’d receive a satisfactory rating? Would your feeling of confidence increase knowing you had a partner in compliance that has the experience and tools needed to provide support?

Fleetworthy Solutions has the tools to ingest information from your ELD, identifying trends, actionable data, and able to provide recommendations to improve your overall standing within the HOS Basic. A single source of truth, providing visibility 24/7/365 into your fleet and drivers is crucial to creating a safety net around your operations. With Fleetworthy’s CPSuite, you have a driver’s HOS record at your fingertips while also providing your team with the ability to manage other safety regulated and risk minimizing requirements such as DVIR/EVIR, maintenance records and driver qualification records. Layering on Fleetworthy’s 40 years of industry experience, you’ll have an experienced team of Subject Matter Experts (SMEs) available to you for all aspects of your fleet compliance. Our team of experts are adept at interpreting the information coming from all data sources, compiling into a single dashboard that provides a C-Suite level layout while also providing the details required for effective day-to-day fleet management. Having these resources at your disposal allows you to focus on the right areas and free up time to maintain the personal interaction needed with one of your most valuable resources – your drivers. With Fleetworthy Solutions, you’ll go beyond the minimum standards of compliance. Reach out for a demo of our industry leading products and services and see for yourself what going ‘Beyond Compliant’ can do for your organization. Together, we can help minimize the number of daily accidents one driver at a time!

About Fleetworthy Solutions

Fleetworthy is the leading provider of cloud-based compliance, risk mitigation, and safety solutions for commercial fleets.  Over 1,500 commercial fleets, including some of America’s largest private fleets, for-hire carriers, and 3PLs rely on Fleetworthy to manage and identify risk, adhere to DOT, IFTA, IRP, and other regulations, and help ensure safe and compliant operations, covering a footprint of more than 210,000 drivers and over 260,000 assets.  With a 40-year-long successful track-record, deep commercial fleet experience, and a flexible delivery model that ranges from a cloud-based do-it-yourself software-as-a-service (SaaS) platform to fully outsourced, turnkey subscription-based tech-enabled managed services, Fleetworthy helps private fleets, for-hire carriers and third-party logistics companies of all sizes surpass compliance of federal, state, and local regulations and streamline processes to reduce costs, mitigate risks, and operate more safely and efficiently. 

For more information about this topic or to learn more about Fleetworthy, please visit www.fleetworthy.com or email the Fleetworthy marketing team at marketing@fleetworthy.com

Background

The Federal Motor Carrier Administration (FMCSA) is the agency tasked with developing and enforcing safety regulations to reduce crashes, injuries, and fatalities involving commercial motor vehicles. These regulations provide minimum standards for motor carriers and drivers and are believed to reduce crashes and improve safety.

In partnership with local, state, other Federal agencies, FMCSA holds motor carriers accountable to these standards, although motor carriers should have policies and procedures in place that rise above the minimum standards.

Following the Federal Motor Carrier Safety Regulations (FMCSRs) is important for several reasons. This article focuses on what can trigger selection for a DOT audit and how to reduce the likelihood of selection.

Monitoring Motor Carriers

The FMCSA measures motor carrier performance with the intent of identifying those carriers that pose a safety risk and intervening with them to correct safety deficiencies under the enforcement program called Compliance, Safety, and Accountability (CSA).

The tool that the FMCSA uses to quantify motor carrier compliance and on-road performance is the Safety Measurement System (SMS), which assesses motor carriers and groups data into seven Behavior Analysis and Safety Improvement Categories (BASICs):

• Unsafe Driving
• Crash Indicator
• Hours-of-Service Compliance
• Vehicle Maintenance
• Controlled Substances/Alcohol
• Hazardous Materials Compliance
• Driver Fitness

Several things go into the SMS scoring that we will not cover here, but the end result is a “CSA score” in each of the BASICs listed above. It is vital for motor carriers to monitor these scores because they are the main trigger for Department of Transportation (DOT) audits.

Measures and Events as Triggers for Audit

The majority of reasons for a DOT audit are related to CSA scores and violation data in the SMS. A few examples include:

• A high score in one BASIC category will be flagged in the SMS system and will trigger an intervention, which could be a warning letter, or a notice of a compliance review.
  • Scores over threshold in 2 or more BASICs will typically result in an audit.
• The severity of safety violations.
  • There are sixteen violations noted as “red flag” violations, which are considered egregious and will draw more attention than other, less severe, violations.
  • A high percentage of out-of-service violations, resulting in a ranking over the national average can also result in an audit.
• Number of DOT-recordable crashes.
  • A high accident rate will trigger an audit that will be focused on crash, unsafe driving, and management controls around preventing crashes, but as the audit progresses it can branch into other areas as well.

Other Triggers Resulting in Audit

While the main reasons for a DOT audit come from CSA scores within the SMS, other events can also trigger DOT audits.

Safety Complaints

Complaints can come from various sources and will trigger audits if DOT deems them credible.

• Disgruntled drivers
  • Reroutes or other changes in work schedule or pay can cause frustration, and even if regulations are being followed, a complaint call to DOT may be the result.
  • Drivers being asked to ignore regulatory requirements often call DOT – they do not want to lose their license or be flagged in the CSA system as an unsafe driver because of their employer’s actions.
• Other company employees
  • Dispatchers, supervisors, and any others that are concerned about lack of management controls may ask DOT to investigate.
• Motoring public
  • Citizens that observe perceived or real unsafe behavior on the road by commercial drivers may register a complaint that triggers contact from DOT.

Serious Accidents

Fatalities are typically the type of accident that will trigger an audit, but a serious accident without a fatality can also be a trigger.

• These audits may be focused initially but may branch into other areas as the auditor reviews the carrier data and safety management controls.

Previous Audits

Unsatisfactory results of a prior audit may trigger the next audit.

• Failing a new entrant audit
  • The motor carrier will be required to show that deficiencies have been resolved to be allowed to maintain operating authority.
• Conditional rating on a compliance audit
  • The motor carrier will have a specified amount of time to resolve issues or operating authority will be revoked.
• Lack of improvement since the last audit
  • If a Satisfactory rating is granted on an audit, but CSA scores remain high over time, another audit can be triggered to ensure improvement since the last audit.

How to Reduce the Likelihood of an Audit

Some ways to reduce audit exposure are to:

• Have policies and procedures in place that exceed the minimum regulatory requirements and consistently follow them;
• Maintain best practices and be a leader in the industry;
• Keep good safety management controls in place that train and hold everyone accountable (drivers, supervisors, and managers);
• Continuous monitoring of systems and data that comes from those systems to identify breakdowns that need to be addressed before a crash or violation occurs.

Even if you do everything right, you may still be selected for an audit, but if you maintain a high level of accountability to the FMCSRs and company policies and practices, it will ensure that you are poised to pass the audit and keep your operating authority.

Fleetworthy Solutions provides services to help you meet and go beyond the minimum regulatory requirements and be prepared for any audit that may come your way. We can also help assess your current audit-readiness by conducting a Mock DOT Audit, conducted according to the DOT audit criteria, which will determine how you would fair in an audit conducted by DOT.

About Fleetworthy Solutions

Fleetworthy Solutions, Inc. provides DOT safety and regulatory compliance services to commercial fleets that take them Beyond Compliant. Fleetworthy combines exceptional client service, advanced technologies, and more than 35 years of transportation industry expertise to make sure that drivers and assets are truly fleet worthy. The company helps private fleets, for-hire carriers and third-party logistics companies of all sizes surpass compliance of federal, state, and local regulations and streamline processes to reduce costs and mitigate risks.

Contact Fleetworthy Solutions with any questions at (608) 230-8200 or email us at info@fleetworthy.com

The Federal Motor Carrier Safety Administration (FMCSA), a stand-alone Department of Transportation (DOT) agency, has developed a detailed set of rules designed to keep roads safe by ensuring drivers limit the long hours they spend behind the wheel. These Hours of Service regulations apply to all DOT regulated commercial motor vehicle operators in the US.  If you are worried about navigating FMCSA’s regulations and ensuring you are taking the right exemptions, you are not alone; let us help you easily adhere to DOT Regulations.

Why Does the DOT Regulate Hours of Service?

The Department of Transportation (DOT) regulates hours of service to help reduce the number of traffic accidents that result from driver fatigue. These regulations apply to long-haul and short-haul commercial drivers, as well as city and school bus drivers. HOS regulations limit the number of driving hours per day and the number of driving and working hours per week. These regulations are meant to facilitate a 21 to a 24-hour schedule, allowing drivers to maintain a regular sleep schedule and avoid fatigue. Drivers must take breaks and go off-duty for extended rest periods to counteract the cumulative effects of fatigue.

How do Current Regulations Ensure Better Safety for Drivers?

The current FMCSA guidelines for hours of service tracking allow drivers to be “on-duty” for up to 14 hours a day, with 11 hours spent driving the vehicle. The remaining three on-duty hours can be used for vehicle maintenance and inspection, any time spent at a plant, terminal, or facility operated by the motor carrier or waiting for dispatch, crossing a border, loading or unloading a vehicle, or attending the same. It is being loaded or unloaded; any time spent providing samples for drug testing, or for performing any other work required by the motor carrier. Drivers are permitted a maximum driving time per week of either 60 hours over seven days or 70 hours over eight days, which they can reset by taking a 34-hour rest period (usually taken on weekends).

The HOS guidelines have changed over time, and they may be subject to change in the future, but, as of right now, they exist as they are to prevent fatigued drivers from operating CMVs.

Some exceptions to the 16-hour rule are universal. For one example, in emergencies or dangerous weather conditions, drivers can exceed the 11-hour maximum daily driving time, provided they stay within the 14 hours of duty time allotted per day. Other exceptions only apply to specific drivers, like the 100 and 150-air mile rules, which lets some drivers who venture less than 100 or 150 air miles from their reporting location remain exempt from keeping record-of-duty logs.

Who Must Comply?

If your business operates Commercial Motor Vehicles (CMVs), you could be required to complete Hours of Service (HOS) per the Federal Motor Carrier Safety Administration (FMCSA). Generally, you are mandated to track your driver’s HOS if your business employs the use of a CMV that is used to engage in interstate commerce and fits any of the following:

• Weighs 10,001 pounds or more.
• Is designed or used to transport, without compensation, 16 or more passengers (including the driver).
• Is designed or used to transport nine or more passengers (including the driver) for compensation.
• Is transporting hazardous materials in quantity requiring placards.

The Hours of Service requirement is the culmination of increased government regulations to promote safety and environmental accountability on the roads. The Hours of Service of Drivers Final Rule became effective on February 27, 2012, but was initially published on December 27, 2011. The official compliance date was July 1, 2013. While there have been minor modifications along the way, the ELD mandate added a level of compliance for completing HOS. The use of telematics software designed to automatically record HOS has become the standard and rule for fleet managers across industries. 

How to Legally Document Hours of Service for Fleets

When your drivers document their HOS, per FMCSA guidelines, depending on the cargo they are carrying; there are differences in the requirements for reporting. The difference lies in whether they are carrying passengers or property. Drivers are required to log their status as on duty, off duty driving, or Sleeper Berth.

• Off Duty – the driver is not performing work duties.
• Sleeper Berth -the driver is resting or sleeping inside their cab. 
• On Duty – the driver is performing work duties but is not driving; for example, they may be fueling, inspecting, or unloading.
• Driving – the driver is driving to perform work duties.

Take note of the following rules for documenting HOS for both CMV operators carrying passengers and those carrying property:

Passenger-Carrying Drivers

• Can drive a maximum of 10 hours after eight consecutive hours off duty.
• May not drive after having been on duty for 15 hours, following eight consecutive hours off duty. Off-duty time is not included in the 15 hours.
• May not drive after 60/70 hours on duty in 7/8 consecutive days.
• Drivers using a sleeper berth must take at least 8 hours in the sleeper berth, and may split the sleeper berth time into two periods provided neither is less than 2 hours.

Property-Carrying Drivers

• There is an 11-Hour Driving Limit. Drivers are only permitted to drive 11 hours at a time, with a minimum of 10 consecutive hours at off-duty status.
• Drivers are not to operate the CMV beyond the 14th consecutive hour, following the ten consecutive hours off duty after returning to on-duty status. Off-duty time does not extend the 14 hours.
• Operators may drive only if 8 hours or less have passed since their last off-duty or sleeper-berth period of at least 30 minutes.
• Operators are not to drive after 60/70 hours on duty in 7/8 consecutive days. A driver also may restart a 7/8 consecutive day period after taking 34 or more consecutive hours off duty. 
• Drivers can use the sleeper berth status to take at least eight consecutive hours in an off-duty status. They can also get an additional two consecutive hours either in the sleeper berth, off duty, or any combination of the two.

34-Hour Driver Restart Rule

The hours-of-service regulations allow you to “restart” your 60- or 70-hour clock calculations by taking 34 or more consecutive hours off duty (or in the sleeper berth) or some combination of both. After taking at least 34 consecutive hours off duty, you have the full 60 or 70 hours available again. The use of a “valid” 34-hour restart resets a driver’s “weekly” hours back to zero. Also, an individual may perform other on-duty tasks, such as loading or unloading and paperwork, after reaching the 60/7- or 70/8-hour limits. They may not legally drive a commercial motor vehicle (CMV) on a public road when the limit has been reached. The 34-hour restart is an optional, not a mandatory regulatory provision.

30 Minute Break Requirement

Company Name driver of a CMV requires a 30-minute break only when a driver has driven for 8 hours without at least a 30-minute interruption.  If required, the break may be satisfied by any non-driving period of 30-minutes (i.e., on-duty, off-duty, or sleeper berth time)

The 30-minute break period does not have to be spent resting. Meal breaks or any other non-driving time qualifies as a break period if it is at least 30 minutes long. These break periods cannot be used to extend the 14-hour on-duty window.

Exceptions to HOS Regulation Rules

Understanding HOS rules and regulations are essential, but there are also exceptions to consider when managing and tracking your drivers. The intricacies of this process require intelligent technology built to handle both your driver statuses and track CMV diagnostics. Some important exceptions to the basic rules of HOS are included below. 

16-Hour Short-Haul Exception

The 16- Hour exception is a consideration meant to allow for an extension of on-duty hours for a round trip route. The 16-Hour Rule states that a driver on a one-day work schedule can be on duty for 16 hours if the driver begins and ends at the same terminal. However, there are further rules to these exceptions; they specify that:

• Time in ‘Driving’ status may not exceed 11 hours.
• If the driver has a layover on any workday, the 16-hour exception cannot be used—this includes any layovers.
• Drivers cannot employ the 16-hour exception and the Adverse Driving Conditions Exception together.
• After using the 16-hour exception, drivers may not use it until they have had a 34-hour reset.
• Drivers may not drive past the 16th hour when moving to on-duty status.

The DOT 16-Hour Rule: When and How Does It Apply?

The 16-hour rule is a special exemption that allows specific drivers to remain on-duty for 16 hours instead of 14, but without extending the allowed 11 hours per day of driving. This exemption applies to drivers that have started and stopped their workdays at the same location for the previous five workdays. These drivers can be described as short-haul drivers because they return to the same work location each day.

Under the 16-hour rule, the driver can remain on-duty for an extra two hours but must be relieved from duty immediately after the 16th hour. This exception can be invoked once in each 34-hour reset cycle once the 5-day pattern has been established.

The reason for this exemption is relatively straightforward once the requirements are understood. Drivers who report to the same location every day may still experience delays from time to time and should not be prevented from returning home due to restrictions on their duty hours. The 16-hour rule helps avoid situations where a driver takes a 5-hour trip, experiences a 5-hour delay when delivering a load, and still needs to return to the reporting location. Without the 16-hour rule, the driver might reach the 14-hour on-duty limit when just an hour away from home and having driven for just 9 hours that day.

Without the DOT 16-hour rule, drivers might speed or drive recklessly to try to get home without violating HOS, essentially substituting one unsafe practice with another. The 16-hour rule is a common-sense regulation that ensures drivers do not get stuck sleeping in the berth or at a hotel when the home is just around the corner.

The DOT has done a decent job of including exemptions to HOS regulations that allow truckers the flexibility to act reasonably and safely in the ordinary course of job performance. While the 16-hour rule can only be applied once weekly, it acts as an excellent option for drivers on the same regular route and needs to get home at the end of each day.

CDL Driver Short-Haul Exception

This exception is for drivers of vehicles that require a CDL, stay within a 150-air-mile radius, and return home each day. It is NOT an exemption from all safety regulations or hours-of-service regulations, and only exempts drivers from logs, supporting documents, and (for truck drivers) 30-minute breaks. Drivers must still follow daily and weekly driving and on-duty limits and all safety regulations.

Under the 150 Air-Mile Radius Exception, specific drivers are exempt from the logbook requirements discussed in Driver Logbook Rules. In order to qualify under the exception, a driver must:

• operate within a 150 air-mile radius (the 150 air miles are equivalent to 172.6 statute miles) of their regular work reporting the location.
• Also, the driver must return to his or her regular work reporting location within 14 hours and be released from work.
• To qualify for the exception, a driver of a commercial motor vehicle (CMV) cannot drive for more than 11 hours and must have at least ten consecutive hours off duty separating every 14 hours on duty.

To take advantage of this exemption, the motor carrier must keep time records of the times a driver reports for and is released from work each day, and the total hours on duty each day.

A driver does not have to have these records in your truck or to surrender to a safety official at the roadside.

Another critical point is that many truckers are not aware that this exemption is optional. Many fleets and their drivers have elected to use a logbook even though they are within the 150 air-mile radius.  The main reason for this is that a driver is no longer required to be released from work within 14 hours on that day.

Again, the motor carrier that employs the driver and utilizes this exemption must maintain and retain for six months accurate and real-time records showing the following:

• The time the driver reports for duty each day;
• The total number of hours the driver is on duty each day;
• The time the driver is released from duty each day; and
• The total time for the preceding seven days for drivers used for the first time or intermittently.

This regulation is found in Section 395.1(e)(1).

Non-CDL Short-Haul Exception

Non-CDL drivers who operate within a 150 air-mile (a nautical mile that measures distance in a straight line) radius of their daily starting location, end their shift at the same location, and do not drive after the 14^th hour of coming on duty in 7 consecutive days do not need to complete an ELD log and are exempt from the 30-minute break rule.

A driver is not required to fill out a log with a graph grid if you come under the non-CDL short-haul exception. The non-CDL short-haul exception applies on days when a driver:

• Drive a truck that does not require a CDL,
• Work within a 150 air-mile radius of your regular work reporting location and return there each day.
• Follow the 10-hour off duty and 11-hour driving requirements,
• Do not drive after the 14th hour after coming on duty on five days of any period of 7 consecutive days, and
• Do not drive after the 16th hour after coming on duty on two days of any period of 7 consecutive days.

The motor carrier must keep time records of the times you report for and are released from work each day, and the total hours on duty each day.

The motor carrier that employs the driver and utilizes this exemption must maintain and retain for six months accurate and real-time records showing the following:

• The time the driver reports for duty each day;
• The total number of hours the driver is on duty each day;
• The time the driver is released from duty each day; and
• The total time for the preceding seven days for drivers used for the first time or intermittently.

This regulation is found in Section 395.1(e)(2). 2

Less Than Eight Day RODS Exemption

Drivers who maintain RODS (Record of Duty Status) for fewer than eight days within 30 days are exempt from completing ELDs. This applies to drivers who meet all requirements of the short-haul exemption but sometimes drive outside of the designated radius. 

The Adverse Driving Condition Exception 

This consideration gives drivers the option to extend their drive time by two hours in the event of adverse weather conditions. Conditions related to weather like heavy snow and dense fog are formidable reasons to use the Adverse Driving Condition exception to prevent safety issues en route. This consideration is also to document significant traffic delays due to traffic incidents or construction that can impact the driver’s commute.

• If a driver cannot safely complete their duties within the maximum allowed driving time of 13 hours, they may drive up to an additional two hours to reach their destination. Drivers are still subject to a maximum of 16 hours in on-duty status.
• If a driver can complete their duties within the 13-hour drive time, they must do so, only if they cannot make it back to their home terminal within 16 hours.

There is a limited exception to the 13-Hour rule for a driver of a CMV who encounters adverse driving conditions, such as snow, sleet, fog, other adverse weather conditions, a highway covered with snow or ice, or unusual road and traffic conditions. To be considered an adverse diving condition under this exception, the condition cannot have been apparent based on information known to the person dispatching the run when the run began. Drivers who are dispatched after the Company Name has been notified or should have known of adverse driving conditions are not eligible for this exception.

The exception applies to a driver who encounters adverse driving conditions and cannot, because of those conditions, safely complete the run-in compliance with the 11-Hour rule. Such a driver may drive and be permitted or required to drive for up to two additional hours in order to complete that run or to reach a place offering safety for the occupants of the CMV  and security for the CMV and its cargo.

Penalties for Violating HOS Regulations

Violations for fleet management companies and their drivers for not correctly documenting HOS can be quite severe. Ignoring the rules can cost you and your driver’s money and tarnish your business reputation. Common penalties include:

• Drivers without mandated HOS documentation can be placed on shutting down (at roadside) until they have logged enough off-duty time to comply.
• Local and state enforcement officials may impose fines.
• The Federal Motor Carrier Safety Administration can issue civil penalties on a driver or carrier, ranging from $1,000 to $11,000 per violation.
• Your safety rating can be downgraded for repeat violations.
• Federal criminal penalties can be issued against carriers who knowingly and willfully allow or require violations; or against drivers who knowingly and willfully violate the regulations.

HOS Regulation Rules to Remember

Managing the HOS regulations surrounding your drivers and their workweek can be quite daunting. This is why smart fleet managers and owners are employing telematics software to manage their drivers. Here are some rules to guide you on the essential points to track per HOS regulations:

• Each driver shift must begin with at least 10 hours off-duty.
• Drivers can only perform 60 hours on-duty over seven consecutive days or 70 hours over eight days. It is mandatory to maintain a driver’s log for seven days and eight days after, respectively.
• Drivers can only be on duty for up to 14 hours following 10 hours off duty and are limited to 11 hours of driving time.
• A mandatory 30-minute break must be taken by their eighth hour of coming on duty.
• The 14-hour duty period may not be extended with off-duty time for breaks, meals, fuel stops, etc.

Getting the Most Out of HOS Tracking 

Using quality technology to track your driver’s HOS is essential in several ways for your fleet. From the CMVs your drivers operate to the fuel used to power their engines, everything impacts the bottom line of your business. Fleet management technology helps you track and manage your business from a convenient dashboard with plenty of tools to keep your fleet running smoothly. Using fleet management technology can help you to:

• Accurately track your driver’s statuses in real-time.
• Plan routes and dispatch drivers to avoid violations.
• Collect CMV diagnostic information with real-time insights on vehicle performance.
• Improve HOS tracking with real-time insights into your drivers’ statuses.

The ELD mandate requires fleet managers and owners to record HOS via certified telematics software. Partnering with an industry leader in fleet telematics is your responsibility as you manage the operations of your fleet.

Compliance, Safety, Accountability (CSA)

What is the CSA Program and its Purpose?

The Compliance, Safety, Accountability (CSA) program is run by the Federal Motor Carrier Safety Administration (FMCSA).  It is designed to hold motorists, including owner-operators, accountable for their role in road safety.  The FMCSA groups carriers with those who have a similar number of safety events and assigns each carrier a percentile risk.  The safety data is held online in the FMCSA’s Safety Measurement System (SMS) and is updated monthly with new data from roadside inspections.  The SMS data is organized into seven Behavior Analysis and Safety Improvement Categories (BASICs).

What Goes Into a CSA Score?

CSA scores are calculated with roadside inspection and crash report data from the SMS from the last 24 months.  The calculations consider factors like crash severity, how long ago the event occurred, and annual vehicle miles traveled.  Carriers receive a CSA score for each of the seven BASICs:

• Unsafe Driving BASIC – Operating a commercial vehicle in a dangerous manner, such as speeding, not wearing a seatbelt, or improper lane changing.
• Crash Indicator BASIC – Based on state-reported crash data, this BASIC contains historical patterns of frequency and severity of crash involvement.
• HOS Compliance BASIC – Operating a commercial vehicle when sick or fatigued and not maintaining records of duty status for six months.
• Vehicle Maintenance BASIC – Failing to properly maintain the commercial vehicle, such as improper load securement or faulty brakes or lights.
• Controlled Substance BASIC –

Operating a commercial vehicle under the influence of alcohol or illegal drugs.

Hazardous Material BASIC –

Handling hazardous materials in an unsafe manner, such as having leaking containers and failing to label hazardous materials as such.

Driver Fitness BASIC – Operating a commercial vehicle by an unfit driver, such as lack of a valid CDL, and failing to maintain driver qualification files.

Do Drivers Have CSA Scores?

Drivers do not have their own CSA scores.  CSA scores are assigned to carriers based on their DOT number.  If a driver receives a violation, it is assigned to the carrier and not the driver.  Drivers do have unique Pre-employment Screening Program (PSP) records with the FMCSA.  A good practice for maintaining CSA scores is to check driver PSP records prior to hiring them and to only hire drivers who are honest about their driving records and have a track record of low-risk and responsible driving.

Where Can Carriers Check Their CSA Scores?

CSA scores for trucking companies can be checked online at  https://www.fmcsa.dot.gov/.  All that is needed is a DOT number. Scores are between 0 and 100, the lower the better – each violation adds points to your score.  Some violations are a cut and dry point system, while others are calculated by the severity of or volume of the violation.  After two years, violations are removed from you record.

To view additional data, including data not available to the public such as the Crash Indicator and Hazardous Materials Compliance BASICs, a carrier will need to login with their FMCSA-provided PIN.  If you don’t have it, then you can request it at – https://cms8.fmcsa.dot.gov/registration/request-pin-number.

How Does a CSA Score Affect Your Business?

There are several ways that your CSA score can positively and negatively affect your business.  Here are a few of the main ones:

Investigation and Intervention Risk – A poor CSA score may put you at a higher risk for FMCSA intervention and investigations. In extreme cases, this can result in an out-of-service order for your business.

Revenue – Shippers often look at the available data to help choose safe, reliable carriers.  Poor scores can prevent a carrier from getting the most profitable loads.

Insurance – Insurance companies use BASIC scores in their evaluation of a carrier’s risk profile.  Often, higher CSA scores lead to higher premiums and deductibles.

How to Improve the CSA Score?

If compliance, safety, and accountability are a genuine concern, then your trucking company will already have a system in place for checks and balances.  This includes initial training, recurrent training, scheduled in-house inspections, preventative maintenance, checklists, and consequences for violations.  The best way to improve your CSA score is to implement and maintain a system of checks and balances and use your current score as one of the ways in which you update your internal operations.  Track which violations are most common – or which ones are on the rise.  This will help you to determine the areas in which you need to improve, so that you can adjust your training accordingly. Once you understand how to answer the question – “What is the CSA Program?” you can begin to work on improving yours.

More useful tips to improve the CSA score –

1. Use PSP Reports in your hiring. By using these reports, you can make intelligent hiring decisions and lower your crash rate by 8% and driver out-of-service rates by 17%, according to FMCSA data.
2. Implement dual-facing dashcam solutions. Dashcams have a proven impact on accident reduction.  They may prevent about 15% of accidents involving heavy duty trucks each year according to a recent study.
3. Get proactive about vehicle maintenance. By using a pre and post-trip inspection tool that’s mobile, you can significantly improve the effectiveness of your inspections.
4. Challenge incorrect violations. It is possible that incorrect or incomplete violations will be added to a CSA score at some point, so if this happens then challenge it.
5. Use a weigh station bypass solution. Fewer weigh station pull ins means fewer inspections, and potentially fewer violations.
6. Choose the right ELD solution. Many of the most common and costly violations are Hours of Service related.  Choose ELDs that are easy to use, reliable and include document management.

Additional information regarding CSA Score Frequently Asked Questions can be found on the following sources:

Fleet Safety, “A Guide to Understanding and Improving Your CSA Score”, Elizabeth Vather, July 10, 2019.

FMCSA website – fmcsa.com

Thank you for reading “What is the CSA Program?”