While this BASIC (Behavioral Analysis and Safety Improvememt category in the Comprehensive Safety Analysis 2010 (CSA 2010) program does track drivers that are operating while fatigued (or ill), what is more important is that the Fatigued Driving BASIC is tracking, measuring, and evaluating carrier and driver compliance with the hours-of-service regulations as well. For those of you that are not familiar with CSA 2010, it is the new driver and motor carrier monitoring system being unveiled by the FMCSA. Information on the full program is available at www.jjkeller.com.
What goes into the Fatigued Driving BASIC?
The Fatigued Driving BASIC uses hours-of-service violations noted on roadside inspection reports to calculate driver and carrier performance. This has nothing to do with the driver being placed “out-of-service” or receiving a “citation” or “ticket.” Citations are a totally different matter and involve someone paying a fine for the violation. To sum this up, if a violation of the hours-of-service regulations is noted on a roadside inspection report, the violation will be entered into the driver’s and carrier’s Fatigued Driving BASIC in the CSA 2010 data system.
Examples of violations that will be placed in the Fatigued Driving BASIC include operating a commercial vehicle when ill or fatigued, operating over hours, general form and manner violations, no log when required, false logs, log not current, and driving after being placed out of service for an hours-of-service violation.
Tracking and measuring
Whenever an hours-of-service violation is placed into the system, the violation is “valued” in the driver and carrier Safety Measurement Systems (SMS) using severity and time weighting. The severity weighting is based on the violation’s relationship to crash causation (operating a commercial vehicle when ill or fatigued has a severity weight of 10, which is the maximum, while using an automatic onboard recorder that does not display information correctly has a severity of 1, the minimum). If the violation led to the driver being placed out of service, the severity weight is increased by two.
Time weighting involves placing more value on violations that have happened recently. All violations remain in the carrier’s data for 24 months (36 months for drivers), but a violation’s “value” reduces over time due to the time weighting system. Events that occurred in the last six months are given a time weight of 3, while events that took place between 6 and 12 months ago are given a time weight of 2, and anything that happened over a year ago is given a time weight of 1.
To determine the “value” of a violation, the total severity weighting for the violation (the predetermined severity weight of the violation plus two if the driver was placed out of service) is multiplied by the time weighting to determine the “value” of the violation in the SMS.
If a carrier has more than three driver inspections or one that notes a violation of the hours-of-service regulations, the value for all violations is totaled, and then the total is divided by the “time weighted relevant inspections.” The “time weighted relevant inspections” are the driver inspections the carrier has undergone (good and bad) that have been “time weighted” using the same time weighting discussed above. This “normalizing” process generates a BASIC Measure (violation value per inspection) that allows all carriers to be compared to each other.
Once a carrier’s BASIC Measure has been determined, the carrier is then compared to other carriers in its “Peer Group.” The Peer Groups are based on the total number of driver inspections. Carriers with 3 to 10 inspections are compared to all other carriers with 3 to 10 inspections, and then “Percentile Ranked” inside their Peer Group based on their BASIC Measure. The carrier with the lowest BASIC Measure in the Peer Group is ranked at 0, while the carrier with the highest BASIC Measure is ranked at 100. All other carriers in the Peer Group fit in between based on their BASIC Measure. This percentile ranking is the carrier’s actual “BASIC Score.”
If a carrier’s BASIC Score is above a predetermined threshold, an intervention will be triggered. Interventions range from a warning letter to a full Compliance Review. The basic principle is the worse the carrier’s score, the more severe the intervention.
Drivers’ Fatigued Driving BASIC Measures are determined by the same process. First, all violation values in the Fatigued Driving BASIC are totaled and then divided by the “time weighted relevant inspections.”
The BASIC Measures are then percentile ranked in Peer Groups based on the number of driver inspections the driver has undergone. Within each Peer Group, drivers are assigned percentile rankings from 0 (representing the lowest BASIC Measure) to 100 (representing the highest BASIC Measure). This Percentile Ranking is the driver’s BASIC Score.
Two points about the driver’s BASIC Measures and Scores: First, these are going to be confidential; no one will be able to view them but FMCSA officials and investigators, and second, the driver interventions are not directly based on the driver’s score. Drivers found with high scores during other enforcement activity (such as during an audit) will be subject to interventions.
How do I keep this BASIC Score low?
The simple answer is to make sure your drivers do not receive hours-of-service violations or operating-while-fatigued violations on roadside inspection reports ─ especially the “high severity violations.” The high severity violations in this BASIC include operating after ordered out of service for an hours-of-service violation, false logs, operating over hours, log not current, not having a log when required, failing to have the previous seven days, and failing to submit logs within 13 days.
However, avoiding violations will require several actions, starting with doing initial training on the hours-of-service regulations and best practices, and emphasizing in the most straight-forward way that your company requires drivers to comply with the hours-of-service regulations (including keeping their logs current and truthful). This should then be followed up by an ongoing training and communications program to make sure the drivers do not “forget” what they need to do (and what you want them to do). Next, you must make sure that your driver supervisors know and enforce the hours-of-service regulations.
Finally, track driver and supervisor performance and take corrective action when necessary. Tracking drivers means auditing. Tracking supervisors involves aggregating the performance of their drivers to attempt to locate supervisors that may be creating an environment where noncompliance is expected, encouraged, or required. If a problem is found, the driver or supervisor should be immediately retrained. If the problems continue, the next decision needs to be “Do we want this person working for us?”
It is far better for you, as a company, to locate the problem drivers and supervisors and make corrections, rather than waiting for the FMCSA to locate your problems using CSA 2010. To sum it up, drivers and supervisors need to understand that when a decision must be made between hours-of-service compliance and anything else, they are to decide on the side of compliance.