What drivers need to know about CSA: Fact or Fiction & Insurance Facts

1. What drivers need to know about CSA: Fact or Fiction& Insurance Facts 2011 Expedite Expo July 22, 2011 Wilmington, Ohio Presented by: Shelly Benish – Commercial Insurance Solutions and John Mueller, CDS – Premium Transportation Logistics LLC

4. What is CSA ? CSA is the Comprehensive Safety Analysis initiative. It is NOT a set of new rules or regulations. CSA is a methodology for tracking, measuring, and evaluating Carriers and drivers. It is simply a new way of viewing the safety data of Motor Carriers and drivers. It restructures the data previously contained in FMCSA’s Safe-stat system and assigns values to violations.

5. Why the New Initiative?

6. SaferSys Snapshot

7. How Are the Systems Changing? • New Safety Measurement System – SMS will replace SafeStat in an effort to better identify “demonstrated” safety problems. In 2010, FMCSA transferred the old SafeStat data to the new “BASICs” scoring system (Behavioral Analysis and Safety Improvement Categories) to replace the “SEAs” (Safety Evaluation Areas) previously used in SafeStat.

8. A New Intervention Process to Augment Compliance Reviews Under the old system, compliance reviews were the only real intervention that FMCSA had with Motor Carriers. In the new system, FMCSA has implemented new intervention tools to include: • Warning letters • Off-site Investigations, and • On-Site – “Focused” Investigations

9. What are the “BASICS”? • Unsafe Driving • Drug & alcohol • Fatigued driving • Driver Fitness • Vehicle Maintenance • Cargo loading/securement; and • Crash

10. More on BASICS There are 930 BASICs violations. CSA was developed around the concept that commercial motor vehicle crashes can be linked or traced back to the behavior of motor carriers and their drivers. The idea that certain “behaviors” are riskier than others was also involved in the development of CSA. Studies have proven that risky driving behaviors affect the likelihood of a driver’s involvement in a crash. Violation/Conviction/Event Increase in Crash Likelihood Reckless driving violation 325% Improper turn violation 105% Improper/erratic lane change conviction 100% Failure to yield right-of-way conviction 97% Driving too fast for conditions conviction 62% False or no logbook violation 56% Any conviction 56% Speeding excess 15 mph over limit conviction 56%

11. Rating of CarriersIn the past, FMCSA issued three “fitness ratings”, Satisfactory, Conditional and Unsatisfactory. Under CSA, carriers will be issued Safety Fitness Determinations (SFD) which links current safety performance, rather than acute and critical violations discovered in compliance reviews.FMCSA will begin to use all safety-based roadside inspection results and crash reports to identify Carrier safety deficiencies and unsafe Commercial Motor Vehicle DRIVERS.

12. What Drivers Are Subject to CSA? • If you operate a CMV as defined in 49 CFR 390.5 then you are subject to CSA. CMV means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when: • The vehicle has gross vehicle weight rating or gross combination weight rating, or gross combination weight, of 10,001 pound or more; • The vehicle is designed to transport more than 8 passengers (including the driver) for compensation; or • The vehicle is designed to transport more than 15 passengers, including the driver, and is not used to transport those passengers for compensation; or • The vehicle is used in transporting placardable quantities of Hazardous Materials.

13. PSPPre-Employment ScreeningProgram

14. Pre-Employment Screening Program What is the Pre-Employment Screening Program? The Pre-Employment Screening Program (PSP) is a screening tool that allows motor carriers and individual drivers to purchase driving records from the Federal Motor Carrier Safety Administration’s (FMCSA) Motor Carrier Management Information System (MCMIS). Records are available for 24 hours a day via Web request. What information does the Driver Information Resource record (DIR) contain? Driver Information Resource records purchased through PSP contain the most recent 5 years of crash data and 3 years of roadside inspection data from the FMCSAMCMIS system. Is information from traffic tickets going to be posted prior to the court date or will the information only be posted if there is a conviction? No. The PSP only contains MCMIS information.

15. You can make mistakes, you can run, but you can’t hide…. SMS will also supply the collected data to the FMCSA Driver Pre-Employment Screening Program (PSP). PSP allows Carriers to electronically access driver inspection and crash data as part of the hiring process. Using the driver safety info during pre-employment screening, Carriers can assess potential safety risks of hiring a prospective driver/contractor. Carriers will see only the driver’s data – not the actual “scores” associated with the violations or the crashes. In addition to reviewing a driver’s application, MVR, and previous employment verifications, Carriers now have an added tool to hire only the safest drivers and only the safest, best maintained, vehicles.

17. Rating of Drivers When a roadside inspection report is generated, inspecting officers enter the inspection info into MCMIS (Motor Carrier Management Information System). Data on both the Carrier and the driver are entered, then separated into the CSMS (Carrier Safety Management System) and the DSMS (Driver Safety Management System). Carriers and drivers are scored within each of the seven BASICs (Behavioral Analysis Safety Improvement Categories) for all roadside inspections and interventions. Drivers will receive a score under SMS that accounts for the last 3 years of their (the driver) roadside inspection history. These scores remain the “property” of the driver even if he or she switches carriers or companies!

22. Data Q’s What if there are violations or crash information on my PSP that are incorrect? FMCSA has a resolution center called Data Q’s. Data Q’s has been in operational for some time and was originally used by Carriers. Now, you drivers have the ability to “contest” any roadside inspection violations and crash information that are listed on your PSP report. https://dataqs.fmcsa.dot.gov/login.asp

23. Data Q’s Info

24. More on PSP • PSP is NOT part of CSA • “Driver Profiles” from FMCSA’s Driver Information Resource (DIR) will be available to carriers through PSP • Driver Profiles will only be released with driver authorization. I would assume that most Carriers will only hire drivers that authorize release of the information. • Drivers will be able to obtain their own driver information record. • PSP is fully developed and is already implemented by Carriers. You as a driver can obtain more information on PSP at www.psp.fmcsa.dot.gov

25. Most commonly discovered violations: • Logbook not current • Failing to maintain previous 7 days logs • Lighting violations • Windshield/Window violations • Speeding • Oil or grease leaks

26. What do WE need to do? • We must update our logbook each and every time our duty status changes, or at least once every 4 hours • We must always have the previous 7 days logs with us • We must SLOW DOWN - operating at, or under posted speed limits is a company policy and the law! Read and understand your Carrier’s Drivers Manual. It is your obligation to abide by their policies – you agreed to that in your lease agreement. Speeding violations open the door to Roadside Inspections. • We must perform meticulous pre-trip inspections. Most of the lighting violations should have easily been discovered in a pre-trip inspection. • We must repair any oil or grease leaks on the vehicles. Some Carriers do work with many of you with older vehicles. You are obligated to keep those older vehicles free of oil and grease leaks. • We MUST submit to the Carrier all Monthly and/or Quarterly vehicle maintenance records along with copies of receipts for repairs or parts. These are proof to DOT (and possibly a Court of Law) that violations have been corrected. It is especially important after Roadside Inspections with vehicle violations.

27. Hours of Service Review • LOGBOOK REQUIREMENTS • The following information is required on every driver’s log: • Date • Total miles driving today • Truck or Tractor Unit Number and Trailer Number (if applicable) • Name of Carrier (Premium Transportation Logistics LLC) • Driver’s signature • 24-hour period starting time • Main office address • Remarks • Name of Co-driver (if applicable) • Recap of Hours (Far right side of most logs) • City or Town (complete name), State (abbreviated) • Shipping document numbers, or name of Shipper and Commodity • Fully completed log grid and Post trip inspection with signature • All fuel stops, Roadside and Pre-trip inspections

28. OTHER LOGBOOK REQUIREMENTS • Your Carrier and any DOT personnel must be able to read all entries and follow all lines on your log. Use a logbook ruler to help make log grid neat and legible. • Wite-Out is not allowed on logs – you must XXX the line out on any mistakes and write your initials next to the correction • If you choose to use a highway number and a mile marker as a reference you must insert the nearest city/town and state to this point. • At any duty status change please write above the city and state, what is going on. Ie… loading, unloading, fueling, break, etc… • All DOT Roadside Inspections must be logged to match the exact time of the inspection. Above are DOT mandated requirements. Listed below are two requirements that your Carrier may request: • When running empty, please write empty on the log. • May require you to log a full 15 minute period for your Pre-trip inspection to be completed before the first of each driving period in a 24 hour period.

29. (a) Report required. Every motor carrier shall require its drivers to report, and every driver shall prepare a report in writing at the completion of each day’s work on each vehicle operated and the report shall cover at least the following parts and accessories: —Service brakes including trailer brake connections —Parking (hand) brake —Steering mechanism —Lighting devices and reflectors —Tires —Horn —Windshield wipers —Rear vision mirrors —Coupling devices —Wheels and rims —Emergency equipment 396.11 Driver vehicle inspection report(s).

30. Need more help with logging? If you require even additional assistance with understanding logs, please use the link below to visit the FMCSA website and review The Interstate Truck Driver’s Guide to Hours of Service http://www.fmcsa.dot.gov/rules-regulations/truck/driver/hos/fmcsa-guide-to-hos.pdf

31. Quick Reference Hours of Service Rules HOURS-OF-SERVICE RULES 11-Hour Driving LimitMay drive a maximum of 11 hours after 10 consecutive hours off duty. 10-Hour Driving LimitMay drive a maximum of 10 hours after 8 consecutive hours off duty. 14-Hour LimitMay not drive beyond the 14th consecutive hour after coming on duty, following 10 consecutive hours off duty. Off-duty time does not extend the 14-hour period. 15-Hour On-Duty LimitMay not drive after having been on duty for 15 hours, following 8 consecutive hours off duty. Off-duty time is not included in the 15-hour period. 60/70-Hour On-Duty LimitMay not drive after 60/70 hours on duty in 7/8 consecutive days. A driver may restart a 7/8 consecutive day period after taking 34 or more consecutive hours off duty. 60/70-Hour On-Duty LimitMay not drive after 60/70 hours on duty in 7/8 consecutive days. Sleeper Berth ProvisionDrivers using the sleeper berth provision must take at least 8 consecutive hours in the sleeper berth, plus a separate 2 consecutive hours either in the sleeper berth, off duty, or any combination of the two. Sleeper Berth ProvisionDrivers 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 CMV Drivers Passenger-Carrying CMV Drivers

32. You are NOT Sammy Haggar…You are a PROFESSIONAL DRIVER and must do 55 if the sign says so!

33. Top Ten Reasons to SLOW DOWN: • It is the law. • You will get a ticket • That ticket will cost you more than you made in the last hour • The customer that wants you to speed will NOT pay your ticket • The dispatcher asking you to speed will NOT pay your ticket • That ticket will show on your MVR • You could become un-insurable (by the number of tickets or by severity – 15+ or over) • You could lose your license (Your livelihood) • If you are speeding and have an accident you could be sued and lose everything you have ever worked for • The SAFETY DIRECTOR at your Carrier may terminate you

34. How To Complete a Pre-trip Inspection Completing a CDL pre-trip inspection is an important task that drivers must do every day before the safe operation of his or her vehicle can legally take place. Many drivers worry about missing some steps on their pre-trip CDL inspection, but after time and repetition of the job, a CDL pre-trip inspection soon becomes quite easy if you take all of the following steps in order. Completing a proper pre-trip inspection will save you much headache, much money and save your PSP roadside inspection history from many unnecessary violations.

35. Inspecting the Left Side of Tractor or Power Unit Left Side of Tractor or Power Unit Step 1 Turn on the vehicles headlamps and activate the four-way flashers. Release hood if the truck has a release lever inside. Step 2 Inspect all aspects of the units steering. This should include the steering linkage and gearbox, the tie rod and cotter pin. Check all for loose or missing, cracked or broken nuts and bolts and that nothing is leaking. Step 3 Look at the front brakes. These components include the slack adjusters, pins, drums, hoses or lines, chambers and brake linings. They should not be cracked, broken, loose or have any parts missing. Adjusters cannot have more than one inch of free play when hand pulled and the brake lining should not be less that 1/4 of an inch. Hoses or lines should not be in a position to be rubbing any surfaces or frayed in any way. Step 4 See that the front wheel and tire and their components are in good shape with no broken or cracked pieces, and inflation of the tire is correct using a tire gauge. Tires need to have at least 4/32 tread remaining, and cannot be a recapped tire or have any bulges or cracks. The hub must not be leaking and all lug nuts must be present and tight. Step 5 Open the door and check for the existence of all required safety equipment. These items include a fire extinguisher with a meter that shows proper charge, three emergency triangles, cones or flares. Carry spare fuses according to the requirements. None of these safely items may be missing or broken. Step 6 Locate the fifth wheel area and inspect it along with the catwalk area behind the cab. The fifth wheel's locking jaws, platform, release arm, locking pins and bolts that mount it must be in place securely, and free from any welds. If a trailer is hooked, check that the jaws properly engage. The air hoses and electric line must be free from cracks, splits or leaks, and must be free from any rubbing against other parts of the vehicle.

36. Inspecting the Front and Left Side of Trailer Front and Left Side of Trailer Step 1 Watch for holes or loose material on the front of the trailer walls or rails and header board. Check the trailers registration in the bill box located on the nose of the trailer, as well as its annual inspection sticker to assure that it is not expired. Step 2 Grab air and electric connections and gently check that they are secure and undamaged. Step 3 Turn landing gear to appropriate position for travel and secure them. Step 4 Glance up and down the entire length of the vehicle checking all lights are operating or flashing properly. Forward and side facing lights should only be amber in color and rear-facing lights must be red in color.

37. Inspecting the Rear and Right Side of Vehicle Rear and Right Side of Vehicle Step 1 Open the trailer doors and check its contents are secure. The doors must also close tightly and securely with latches. Step 2 Match the license plates with the vehicles registration, and confirm that they are not expired. Step 3 Push on the ICC bar with foot to check that it is not loose and inspect for loose, missing, cracked or broken nuts or bolts. Step 4 Find the marker lights, taillights, brake lights and turn signals and assure that all properly light up or flash. Step 5 Repeat inspection techniques on entire length of the right side of the vehicle as done on the left side.

38. Inspecting the Front of the Tractor or Truck Front of Tractor Step 1 Close the hood and secure it with the hood straps, making sure they are undamaged and secure. Step 2 See that all lights are properly working, and look at the exterior body parts to see that no parts are loose or missing. Step 3 Ensure that the windshield has no cracks or damage.

39. Inside of Cab Inspection Inside of cab Step 1 Enter cab and check that all lights on dash are operating properly including signal indicators. Step 2 Press clutch pedal to ensure one and a half to two inches of free travel and see that the steering has no more than two inches of play on a standard 20-inch steering wheel. Step 3 Start the engine with gearshift in neutral and watch for proper gauge operation, including the oil pressure, water temperature, air pressure and voltmeter. Step 4 Honk the city and air horn to check good operation, as well as the wipers and heater and defroster. All must be in proper working order. Step 5 Aim mirrors and check that they are not cracked or broken. Step 6 Perform all required brake checks including, hold down, pump down, trailer tug and tractor service brake roll-ahead test.

40. Oil and Grease Leaks • Many trucks are continually found with oil or grease leaks • Want to keep an “older” truck? THEN REPAIR THE OIL AND GREASE LEAKS!

41. Monthly Maintenance Report Must give brief synopsis of all repairs done to vehicle that month Must include copies of all receipts for repairs or parts. Quarterly Maintenance Report Perform Inspection yourself on designated form and submit every 3 months, or Carrier may require you to have “Annual” vehicle inspection performed every three months in lieu of. Required Maintenance Records

42. THE ROADSIDE INSPECTIONS Roadside inspection and traffic enforcement are two of the Federal Motor Carrier Safety Administration's (FMCSA) key safety programs. The roadside inspection program consists of roadside inspections performed by qualified safety inspectors following the guidelines of the North American Standard, which were developed by FMCSA and the Commercial Vehicle Safety Alliance (CVSA). Most roadside inspections are conducted by the States under a grant program (MCSAP) administered by FMCSA. There are five levels of inspections that include a vehicle component, a driver component, or both. The traffic enforcement program is based on the enforcement of 21 moving violations noted in conjunction with a roadside inspection. Violations are included in the driver violation portion of the roadside inspection checklist.

43. Inspection Levels and Inspection Items LEVEL I -- North American Standard Inspection An inspection that includes examination of driver's license, medical examiner's certificate and waiver, if applicable, alcohol and drugs, driver's record of duty status as required, hours of service, seat belt, vehicle inspection report, brake system, coupling devices, exhaust system, frame, fuel system, turn signals, brake lamps, tail lamps, head lamps, lamps on projecting loads, safe loading, steering mechanism, suspension, tires, van and open-top trailer bodies, wheels and rims, windshield wipers, emergency exits on buses and HM requirements, as applicable.

44. Level II Inspections LEVEL II -- Walk-Around Driver/Vehicle Inspection An examination that includes each of the items specified under the North American Standard Inspection. As a minimum, Level II inspections must include examination of: driver's license, medical examinees certificate and waiver, if applicable, alcohol and drugs, driver's record of duty status as required, hours of service, seat belt, vehicle inspection report, brake system, coupling devices, exhaust system, frame, fuel system, turn signals, brake lamps, tail lamps, head lamps, lamps on projecting loads, safe loading, steering mechanism, suspension, tires, van and open-top trailer bodies, wheels and rims, windshield wipers, emergency exits on buses, and HM requirements, as applicable. It is contemplated that the walk-around driver/vehicle inspection will include only those items which can be inspected without physically getting under the vehicle.

45. Level III, Level IV and Level V Inspections LEVEL III -- Driver-Only Inspection A roadside examination of the driver's license, medical certification and waiver, if applicable, driver's record of duty status as required, hours of service, seat belt, vehicle inspection report, and HM requirements, as applicable. LEVEL IV -- Special Inspections Inspections under this heading typically include a one-time examination of a particular item. These examinations are normally made in support of a study or to verify or refute a suspected trend. LEVEL V -- Vehicle-Only Inspection An inspection that includes each of the vehicle inspection items specified under the North American Standard Inspection (Level I), without a driver present, conducted at any location.

46. Level VI Inspections LEVEL VI -- Enhanced NAS Inspection for Radioactive Shipments An inspection for select radiological shipments, which include inspection procedures, enhancements to the Level I inspection, radiological requirements, and the enhanced out-of-service criteria. Select radiological shipments include only highway route controlled quantities as defined by Title 49 Section 173.403 and all transuranics.

47. Violation Severity by BASIC Overview The tables in this Appendix contain a breakdown of all FMCSRs and HMRs that can lead to roadside violations, with each table representing a unique BASIC. A severity weight is assigned to each regulation and reflects its relevance to crash risk. Within each BASIC, the regulations are grouped based on their attributes so that similar violations can be assigned the same severity weights. Severity weights, discussed in more detail below, are not comparable across the BASICs. Interpretation of the Severity Weights The violation severity weights in the tables that follow have been converted into a scale from 1 to 10, where 1 represents the lowest crash risk and 10 represents the highest crash risk relative to the other violations in the BASIC. Because the weights reflect the relative importance of each violation only within each particular BASIC, they cannot be compared meaningfully across the various BASICs. Therefore, a 5 in one BASIC is not equivalent to a 5 in another BASIC, but the 5 does represent the midpoint between a crash risk of 1 and 10 within the same BASIC. The Violation Group column in each table identifies the group to which each violation has been assigned. Each violation within a violation group is assigned the same severity weight.

48. What happens with all this data from the violations and the weighted data? The SMS uses the measures to assign a percentile ranking for all entities within each BASIC and the Crash Indicator. Each measure is a quantifiable determination of safety behavior. Percentile ranking allows the safety behavior of an entity to be compared with the safety behavior of its peers. Within each peer group, a percentile is computed on a 0 –100 scale for each entity that receives a non-zero measure, with 100 indicating the worst performance. Entities with percentiles above a certain threshold and meeting minimum data sufficiency requirements in a BASIC or Crash Indicator can be deemed poor safety performers. These entities will be identified for CSA 2010‘s Intervention process.

49. For Weighted Values by Violation, please visit the following FMCSA website: http://csa2010.fmcsa.dot.gov/documents/SMSMethodology.pdf The table of violations with their corresponding weighted vales begins on page 41 (41 of 95 pages)