CSA: THE FIRST YEAR

In December, 2010 the Federal Motor Carrier Safety Administration unleashed CSA on motor carriers and drivers. Those of you who stay up on this sort of thing know that CSA stands for "Compliance, Safety, Accountability." It replaced the former SafeStat system. Where Safestat was primarily concerned about out of service violations, CSA is concerned with ALL violations. CSA requires inspecting officers to note all "observable defects." Each of these defects has been assigned a point value. Carriers and drivers accumulate points. These defects are sorted into seven categories, called "BASICS". These BASIC categories are: 1)Unsafe Driving; 2)Fatigued Driving; 3)Driver Fitness; 4)Drugs/Alcohol; 5)Vehicle Maintenance;
6)Cargo; and 7)Crash. The FMCSA doesn't directly grade drivers on these (yet). However, they have established threshold scores for motor carriers in each of the seven BASICS. Carriers exceeding any threshold are subject to increased scrutiny by both FMCSA and law enforcement. This scrutiny takes the form of such things as more frequent roadside inspections, warning letters, targeted audits, full audits, fines and shut downs. Carriers cannot keep drivers who rack up points on bad roadside inspections.

In the coming days, we will be looking at how Mercer has faired with CSA in 2011 and what we need to be doing (or not be doing) in 2012. I will give you my observations of each BASIC, what is good about it, what is not, how we are doing in it, and what we need to be doing differently. It is important for all drivers to understand that there are no "breaks." CSA is all about "observable defects." That is, if the officer sees a violation, he or she is required to note it.

It is also important to understand that "not getting a ticket" is not enough. CSA points can be assessed on nearly any write up. Unlike a "ticket", which can be contested in court, warnings are virtually impossible to get reversed. Drivers must be constantly aware of this. We'll discuss how to do that in the next several days.

After we review each of the seven, we will look at related topics, such as the seminar program for the Mid-America Trucking show, CARB and SmartWay, BMI, electronic logs (EOBRs), and my 2012 travelling LKY inspection schedule. We'll begin tomorrow with CSA Unsafe Driving BASIC. Remember, under CSA, everything counts. Stay tuned.


NEW CARB REPORTING REQUIREMENTS, 96-99 ENGINES

On December 14, 2011, California's Office of Administrative Law approved amendments to the Truck and Bus Regulation. Prior to the amendments, trucks with engines of model years 1996-1999 would have been banned in California on January 1, 2012. Those retro-fitted with a CARB-approved particulate matter (PM) filter would be allowed in California until January 1, 2020.

The amendment allows heavy truck owners with 1996-1999 engines but without PM filters to operate in California until January 1, 2014 providing they report their trucks to CARB through the Truck Regulations Upload and Compliance Reporting System (TRUCRS). You are eligible to report if you own three or fewer diesel trucks. You must report your vehicle by January 31, 2012. Mercer cannot do this for you.

The link to the online reporting system is: http://www.arb.ca.gov/msprog/onrdiesel/reportinginfo.htm. If you can't get on that way, go to www.arb.ca.gov and go from there. Since the actual deadline for compliance is January 1, 2012, my advice for everyone with these engines is to get them registered by the end of December. Several Mercer drivers have already done this with no problem. Good luck.


DOT BANS HAND-HELD CELL PHONE USE

As most of you are probably aware, the Department of Transportation recently issued a final rule that bans hand-held cell phone use by drivers of buses and large trucks. The rule is slated to go into effect December 30, 2011. Studies have shown that commercial drivers were at an increased risk of being involved in a safety critical event such as a crash, a near-crash or an unintended lane departure due to being distracted when using a hand-held mobile phone.

This rule defines using a hand-held mobile telephone device as:
1) using at least one hand to hold a mobile telephone to conduct voice communication;
2) dialing or answering a mobile telephone by pressing more than a single button; or
3) reaching for a mobile telephone in a manner that requires a driver to maneuver so that he or she is no longer in a seated driving position and restrained by a seat belt.

Under this criteria, it seems to many observers that if the driver is speaking on his or her cell phone through a Blue Tooth ear piece, the phone is in a shirt pocket, and the call can be terminated by touching a single button, then the driver would not be in violation of the new rule. The same appears to be true with dialing with the use of a single button. However, a problem, ie violation, would appear to occur if a driver looked at caller ID before answering the phone or scrolled through the speed dial memory before placing a call. This will become clearer after the rule goes into effect and we see how the law enforcement community deals with it. We expect pretty robust enforcement due to the high priority placed upon it by the DOT.

Violations will have severe consequences for a commercial driver. Drivers convicted of violating this new rule face civil penalties of up to $2,750 for each offense. In addition, motor carriers that allow their drivers to violate this rule will face a maximum penalty of $11,000. Mercer drivers who read Mercer's Safety Policy know that Mercer has prohibited both texting and hand-held cell phone use since April, 2009.

An important change to note is that the new rule also now includes a hand held cell phone violation as a serious traffic violation. As most drivers know, two serious violation convictions in three years results in a 60 day CDL disqualification. Three serious violation convictions in three years results in a 120 day CDL disqualification. Mercer drivers know that a serious violation conviction at Mercer is a 100 point problem on our scoring system. Mercer drivers cannot have two serious violation convictions and remain at Mercer.

All drivers need to understand that a violation of this new rule is serious business. It will not be in Mercer's or any other motor carrier's best business interests to retain a driver who could potentially cost them an $11,000 fine for this violation. If in doubt, let it go to voice mail. Be safe.


TPA LOUISVILLE INSPECTION DATES SET

My final LKY inspection trip of 2011 will be to the TPA office, Plant City, FL on Monday November 14 and Tuesday November 15. I will be there 7:30 until 5:00 both days. If you need a Louisville inspection before the end of the year and you don't want to go to Louisville, this is your last chance to have it done in the field. It is important that either you or your truck coordinator contact my Administrative Assistant, Michelle Scott, and get put on my "guest list". I will be doing Hazmat recerts and safety briefings along with the inspections. Safety briefings earn a 10 point credit on our scoring system.

Many drivers have asked if I will again be conducting seminars for Mercer people during the Mid-America Trucking Show in March, 2012. The correct answer is "absolutely!". They were a big hit last year and we are planning on doing three new ones this year. Due to the high turnout, we are planning on offering each one twice on Wednesday. There will be a 10 point credit for each. No, Big Ron, you can't go to each one twice and double your points.

At this point, most of our folks are "getting it" about CSA. It's tough, but the majority of our drivers have no problem with it. However, if you are still getting write-ups for logs, speeding, defective tires, cargo securement or brake adjustment, you haven't quite figured it out. You need to take this stuff seriously. Warnings count. Everything counts. Carriers, including Mercer, have no other option than to part company with drivers who cannot get clean inspections. Bad inspections hurt everyone, including those who do things right. I don't like the fact that the everyone gets red PrePass lights when a small minority can't get it right, or refuse to do things right. It's not fair to the majority of our contractors. If you can't stay at or below the posted speed limit, if you can't log current and legal, I urge you to truck someplace else. Mercer is for the best of the best. We are not interested in anybody else. Be safe.


ARKANSAS INSPECTIONS SUNDAY

I will be at the HIA office in beautiful Caddo Valley (Arkadephia), Arkansas this Sunday afternoon doing LKY inspections. The party will start around 2:00pm and I will work until the last truck is done. Remember, it is this Sunday, October 2, only. I will also do Hazmat recerts for those in need.

Due to a scheduling conflict, the October Newberry South Carolina inspections have been delayed one week. The new dates are Tuesday October 25 and Wednesday October 26. My last inspection trip of 2011 will be to the TPA office in Plant City, FL in November. Those dates not yet booked. Should know by end of next week.

If you need a LKY inspection before the end of the year and coming to Louisville isn't your favorite thing to do, these are your last three chances to do it in the field. Plan accordingly. Be safe.


CHECK YOUR BRAKES

Remember that beginning this Sunday, September 11 and continuing through Saturday, September 17 will be the annual CVSA Brake Safety Week. Everyone can expect an increase in Level 1 inspections next week. According to the Commercial Vehicle Safety Alliance (CVSA), during June's Roadcheck, more than 50% of the out-of-service violations cited were for brake-related violations. That is a pretty significant number and certainly merits special attention by commercial vehicle inspectors.

It is important that all Mercer drivers take the time before they go out next week to have their brakes checked and adjusted if necessary. Expect to be inspected. Be safe.


SUNBURY, YOUNGWOOD, ARKADELPHIA, NEWBERRY INSPECTION DATES SET

I will be doing Louisville Inspections at the following field locations on the following dates:

Sunbury, PA, MSU office lot, Monday September 19 and Tue September 20, 7:30-5:00 both days.

Youngwood, PA, Firestone dedicated trucks, Firestone Plant, Wed September 21, 4:00PM til dark.

Arkadelphia, AR, HIA office lot, Sunday October 2, 3:00PM til dark.

Newberry, SC, Dowd's Diesel, Tuesday October 18 and Wed October 19, 7:30-5:00 both days.

Drivers being inspected at these locations will also receive a 10 point credit on their scores for a safety briefing. Anyone needing Hazmat recertification will be able to receive that, as well.

Any driver planning on being at one of those locations should have their coordinator contact my Administrative Assistant, Michelle Scott, to be placed on the inspection list. The final field inspection date, at the TPA office in Plant City, FL in November, has not yet been set. It will be booked in mid to late September.

I am looking forward to seeing a bunch of you guys at these locations. Make me work.


MERCER SAFETY SCORES

I'm going to try to get Jason off the hook regarding the driver safety scores. His comment section had a bunch of good questions. I was impressed with Big Ron's score....WOW! Here's how it works:

Every carrier uses their own scoring system. At Mercer, a driver's score is based upon DOT inspections (CSA points), moving violation convictions, preventable accidents, cargo claims and bad road surveys. Each of these have point values. A driver is allowed up to 200 points in any current three year period. Reaching the 200 point threshold qualifies a driver for the Mercer Alumni Society. I am the membership chairman of that group.

On our system, it is possible to get credit points to reduce a driver's score. Credit points are given for clean DOT inspections, good road surveys, Alabama coil certificate/New York coil endorsement, attendence at safety seminars, other additional training and safety briefings given by me around the country when I do LKY inspections in the field. For that reason, not only is it possible to get a zero score, it is possible to get a negative (credit) score. I let drivers bank points. We have folks that have -40 scores, which is really fantastic. Then there is Big Ron. Whatever.

Scoring is done by both me and Michelle Scott, my Administrative Assistant. Scoring is triggered by a number of items: A DOT inspection, a moving violation conviction, a preventable accident, a road survey or a cargo claim will put a driver in the scoring stack. We get a daily electronic feed of DOT inspections, so many times that scoring is done before we ever receive a driver's DOT inspection sheet. To date, more than 1,200 drivers have been scored. Quite a few have been scored several times as they get more DOT inspections. There are at least 300 drivers here who have none of the above, nada, zip, goose egg, thus a zero score. There is no team score, each driver is looked at individually. We do have a number of teams where one drive has a score and the other does not (yet).

Either Michelle or I will be happy to answer questions about a driver's score. The best way to improve a score at Mercer is to get clean DOT inspections. The quickest way to get a bad score is to have a preventable accident, get caught speeding or have a log violation. Our system is designed to be especially harsh on those three specific areas. Defective brakes, tires and cargo securement violations are close behind. At least half of Mercer drivers have figured this out and are running low scores (49 or less), zero scores or credit (negative) scores. The other half need to do it better. It can be done.

Remember, under CSA, carriers are given thresholds that they must stay below in seven categories. These are based upon DOT inspections and are updated monthly. If a carrier gets over a threshold, it gets more inspections the next month. More red Prepass lights. On our system, more inspections are great for the folks who know how to get clean ones and, frankly, they weed out those that don't.

As I've said many times, CSA is not rocket science. Don't go over a posted speed limit, keep the log book absolutely legal and current, secure cargo properly and keep brakes/tires within requirements. Always wear your seatbelt properly. Drivers that do these things don't have problems. Drivers that don't, or won't, do these things have problems. When drivers don't have problems, carriers don't have problems. Everyone is happy and the world is a better place. Be safe.


INSPECTIONS, INSPECTIONS, INSPECTIONS

Tonight at midnight begins the 72 hour CVSA Roadcheck. On June 7,8 and 9 officers throughout North America will be inspecting as many commercial vehicles as possible. There will be a huge emphasis this year on logs. It is not the time to have any problems with the log book. Drivers operating during the 72 hour Roadcheck should expect to be inspected thoroughly and often. Drivers should pay particular attention to brake adjustment, cargo securement, lights, logs, tires and the general cleanliness of the unit. Drivers should be particularly careful with following distance and adherence to posted speed limits. Mercer drivers will earn double credit points for a clean Roadcheck inspection.

Next Monday, June 13, I will be doing Louisville inspections at the WKS office in Wichita, KS. I start early and stay late Monday only. If you are planning on being inspected there, call Michelle in my office and get added to the list.

The LKY California inspection dates will be July 18,19 (Monday and Tuesday) in Stockton. If you are going to be there, call Michelle and get on the California list. I start early and stay late on both days.

I hope everyone has a safe and enjoyable Roadcheck.


NEVER FORGET

As everyone gets set to enjoy the long Memorial Day weekend, it is important that each of us remember what it is for. The freedom each of us enjoys has been paid for by the blood of many generations of brave American men and women. If you served in the military, thank you. If you have family or friends currently serving, be sure to give them a special thanks. While many of us think there are some problems in our country, I'll take a bad day in the good old USA over a good day anyplace else. God Bless America. Never Forget.