Fleet Safety Management Accountability

Rick Flores, Senior Safety Manager, Hathaway Dinwiddie

The Importance of Fleet Safety Management and Compliance

Fleet safety management is crucial for companies that own vehicles and entrust them to their employees for daily use. It is an added department within safety management that holds considerable risk for the company. Compliance with vehicle transportation laws, programs, and regulations becomes the cornerstone of risk control affecting the company’s bottom line. The Compliance, Safety, Accountability (CSA) Program, managed and implemented by the Federal Motor Carrier Safety Administration (FMCSA) holds transport companies and drivers accountable for their safety performance (CSA, 2016). The FMCSA is a branch of the US Department of Transportation (DOT) and manages the online Safety Measurement System (SMS) database. This would include notifying owner-operators by tagging or naming those with questionable driving records through enforcement and written correspondence. The goal is to alert drivers of their compliance and safety performance records and to illicit improvement.

Behavior Analysis and Safety Improvement Categories (BASIC)

The FMCSA controls the online SMS database using a matrix based on compiled information from various sources (CSA, 2016). The SMS updates once a month with information from roadside inspections, violations, and accident investigation reports for the two previous years. The “FMCSA organizes the data into seven Behavior Analysis and Safety Improvement Categories (BASICs)” (CSA, 2016, p. 8). These are the seven BASICs:

● Unsafe Driving

● Crash Indicator

● Hours-of-Service Compliance

● Vehicle Maintenance

● Controlled Substances/ Alcohol

● Hazardous Materials Compliance

Driver Fitness

                                 Total of time and severity weighted applicable violations
BASIC Measure = ________________________________________________

                                    Total time weight of relevant inspections

Fleet Management

A newly hired fleet manager of a small distribution company in the Midwest would be concerned with a score of 81 but would not consider it a hopeless situation. The scores are not like most sports where the higher score wins, but more like golf scores, the lower the score, the better they are. In other the words, the fewest mistakes show better performance (CSA, 2016). If the previous month was a score of 77, a score of 81 is about a 5 percent delta in the wrong direction.

Federal Motor Carrier Safety Administration’s

In theory, the FMCSA online SMS would seem to be a reliable source for checking a driver’s record for compliance. An article in the Journal of Transportation Law, Logistics & Policy criticized the entire program citing unreliable SMS data to support a driver’s score (Galas & Lucca, 2016). In time, the FMCSA had to add disclaimers to their system that they were in no way encouraging employers to use the scores as a basis for hiring drivers. The data presented on the SMS database made no correlation between a low score and an unsafe driver. The FMCSA recognized the need to conceal certain information from the public so as not to bias a perspective employer. The program was, as of recent years, updated to improve driver performance through the Entry-Level Driver Training (ELDT) regulation and the Employer Notification System (ENS) (FMCSA, 2022).

Entry-Level Driver Training

Developed through years of work on the issue of improving motor carrier performance, in 2022 the FMCSA introduced the ELDT regulation, which provides training standards for inexperienced drivers (FMCSA, 2022). The regulations outline training inexperienced drivers must complete before receiving a Commercial Driver’s License (CDL). Employers have the option to register in their state’s ENS which allows them access to the FMCSA ENS Best Practices and Recommendations for new licensed driver training.

"Fleet safety management is essential for companies, ensuring compliance with transportation laws and minimizing risks. Effective benchmarking, training, and safety protocols are key to reducing accidents and improving overall fleet performance"

Safety Measurement System

In the 3.16, October 2023, version of the SMS the BASIC prioritization status was re-tooled and added category, to include Insurance (CSA, 2023). In Section 1, the document states the core mission of the FMCSA, by way of the SMS, as an accident, fatality, and crash prevention catalyst related to large trucks and buses. Section 1 goes on to explain how the FMCSA identifies and prioritizes interventions of motor carriers and the prioritization status process reiterating the seven BASICs. In Section 2 of the document, it explains where it gets its data, and how they use prior violations from past investigations in the BASIC prioritization standings. In Section 3, it explains how the number (percentile) results affect the carriers’ BASC prioritization position. Then in Section 4, it goes into what process the agency uses to improve the SMS system. The three BASIC Prioritization Status Assessments no longer available to the public are the Crash Indicator, Hazardous Materials Compliance, and Insurance. The others remain visible to the public as they were previously. Noticeably the list has not changed apart from the category of Insurance:

● Unsafe Driving BASIC Prioritization Status Assessment

● Crash Indicator BASIC Prioritization Status Assessment – Not Publicly Available

● HOS Compliance BASIC Prioritization Status Assessment

● Vehicle Maintenance BASIC Prioritization Status Assessment

● Controlled Substances/Alcohol BASIC Prioritization Status Assessment

● HM Compliance BASIC Prioritization Status Assessment – Not Publicly Available

● Driver Fitness BASIC Prioritization Status Assessment

●  Insurance/Other Indicator Prioritization Status Assessment – Not Publicly Available

Litigation

With all its improvements, the SMS would not be the only source of information I would use to evaluate new hires, fleet status, or current employee performance. When there is litigation involving the use of this information in a case by a plaintiff, it may not be prudent to base a decision solely on the SMS (Galas & Lucca, 2016). Even though such information is not readily admissible in court, an employer on the defense may want to introduce hedging information to offset that possibility.

Benchmarking

This leaves fleet safety managers with the prime alternative to improving their safety record or SMS rating, which would be their own fleet safety management plan. Benchmarking is an important part of any management strategy as it is a method to diminish or eliminate problems, or in this case, accidents (Haight, 2015). Anything tracked, evaluated, and rewarded, gets managed. It is a common evaluation tool used in business for quality control purposes.

Incentives

For example, tracking accidents per one million miles and evaluating what effect they have on a fleet’s SMS ratings and insurance rates (Haight, 2015). A fleet manager may then reward fleet personnel for improvements at the million-mile benchmark. Personnel are understandably apprehensive about reporting accidents but rewarding fleet personnel for reporting accidents without fear of reprisal, accurately, and within specified time parameters would improve the reporting process. As an example,

accidents per million miles = accidents × 1,000,000     = 3 × 1,000,000 = 60 accidents per million miles.

                                                        Miles traveled                 50,000      

Program Implementation

Tagging accidents with distinct categories would help to understand if there are trends that indicate the need for specialized training or added visibility equipment on the fleet vehicles. After a root cause analysis, findings may indicate that there is a need for better blind spot visibility or added lighting for those areas. Vehicle inspections at the dispatch center should be like roadside inspections to simulate a government inspection.

Hazard Analysis

The incentive for completing correct, detailed inspections would be based on completing a leading indicator document which may prevent a better SMS score. In this case, incentives implemented for finding improvements to enhance safe fleet drivability would be helpful. These documents would include the completion of pre-task or job hazard analysis by the drivers for truck loading activities.

Conclusion

Anything that is tracked, evaluated, and rewarded, gets managed, but in the end, management must first buy into a plan for making improvements. This is sometimes the hardest hurdle to get over. A safety manager may have the best program in mind, but it does no good if we are not able to implement it. Involvement by the personnel on the road is key to having an effective safety management plan. Unfortunately, an organization will want better safety, if it does not cost any money and does not take time away from the production line. As safety managers, we must be prepared to illustrate what an organization will be saving in terms of dollars and cents by the mitigation of accidents through improved safety protocols and management.