How to Avoid 6 Common CSA Violations

LTL CSA violations l-tread-depth

This guest blog post comes from Daren Hansen, Senior Editor – Transportation Safety for J.J. Keller & Associates. Contact him at transporteditors@jjkeller.com.  It was first published in Heavy Duty Trucking.  

“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.

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 pre-trip 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 pre-trip 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.

Worth It or Not? The Aerodynamics Debate

truck line drawing

They’re ugly. They don’t make enough difference in fuel economy to be worth it. They won’t hold up to road abuse. They don’t produce the savings I can get just by slowing down.

Drivers and fleets have plenty of reasons they’ve generally opted out of aerodynamic add-ons, and while it’s true they’re not smart for everybody, companies are getting better at making durable, effective drag reducers. If you’ve always written the things off, it might be time to re-investigate.

Henry Albert, a trucker since 1983 and a contributor to TeamRunSmart.com, drives a 2013 Cascadia Evolution and has been on a pretty well-publicized quest to achieve 10 mpg for over five years. In a recent interview, he says he’s achieved in excess of 10 mpg on many individual driving days. His truck is completely decked out, with side skirts, nose cone, a trailer tail and wheel covers.

“I have drivers tell me all the time, ‘side skirts don’t make that much difference,’ and they’re right – they only save between 2.5% and 3% in fuel cost. But they also say the same thing about the nose cone and the wheel covers and trailer tail, but cumulatively, when I put it all together, it adds up,” Albert says. The fuel savings of adding aerodynamic modifications to his truck covered his cost in six months.

On the other side of the debate are drivers who point to the weight of the add-ons and the fact that on certain routes, crosswinds in combination with accessories like trailer side skirts can actually create drag. In the comments section of this article, a driver who travels the I-80 corridor between Milwaukee and San Francisco, a route where he’s usually rolling through 25 mph crosswinds, installed side skirts. He reports no difference in fuel mileage and concludes, “There is only one way to good fuel mileage, and that is SLOW DOWN. I went from driving the 75 mph zones to driving 60 and have saved an average of 160 gallons per trip.”

But this driver begs to differ: “I don’t subscribe to the theory that slowing down increases profits!” In the comments section of an article on the trailer Kevin Rutherford developed for owner-operators, he explains that, “when you slow down, your are also reducing your per-hour revenue.” By way of example he says that a driver averaging 70 mph and earning $2 per mile grosses $140 per hour, while someone driving an average of 60 mph at that same pay rate makes $120. Since fuel only costs $11 per hour more to run at 70 mph, the 70 mph driver is $9 per hour more profitable. His philosophy: “Revenue first, then control costs.”

One way he controls his costs is by employing an undercarriage device and nose cone to diminish aerodynamic drag. He uses an Airman undercarriage add-on, which is designed to move with the tandems, unlike the skirts that are stationary. He says, “For every slider hole you move the skirts away from the tandems, your efficiency decreases. At a certain distance, the efficiency is actually worse than no skirts at all. The 5-6% fuel savings I’m getting from skirts is only achieved at the 40-foot California setting. Utilizing both the nose cone and Airman, I am achieving 7.2-7.4 mpg running @ 75 mph in 75 to 80 mph states, usually grossing 75-80,000 lbs and am hitting 11 mpg empty.”

An option for drivers who determine trailer side skirts aren’t right for their situation are tractor wheel covers. As Mario Bravo, marketing manager for Flow Below points out in this article, one advantage of making a modification to the tractor is that you get that fuel economy benefit even when the trailer is sitting in a customer’s yard, unlike trailer side skirts. “The higher a fleet’s trailer-to-tractor ratio, the more standing time, and no aerodynamic device saves anything when the vehicle is sitting still,” he says.

His company’s AeroKit consists of panels that close the gaps between a tandem’s drive wheels, and others that guide air as it leaves the tandem area. Circular covers block wheel indentations and reduce turbulence.
The advantage of being an owner-operator vs. a fleet manager in this situation is that owner-operators many times run dedicated loads and/or routes, according to comments in this article by Mitch Greenberg with SmartTruck Systems.

He points out that they also tend “to measure their fuel mileage more consistently and run the same equipment day in and day out. Any differences that stem from aerodynamic add-on devices will more effectively and directly present themselves, Greenberg says, due to the aforementioned variables being so controlled, which is often not the case for large fleets looking to implement aero devices.”

There’s no one right answer and every driver needs to test for himself what combination of equipment, accessories and driving skills will create the best results.