Roadside Inspections

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Roadside Inspections

• Attention Attendees
• Thank you for attending!
• The presentation will start in a few minutes at
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• The slides and recording will be posted within 7
  days at http//www.jjkeller.com/nptcinfo

• This webcast will cover ...
• The selection process,
• Inspection levels and procedures,
• The use of roadside inspection data,
• Kelloggs Program, and
• Question Answer
• Moderator
• Dr. Gary Petty, President CEO, NPTC
• Panelists
• Tom Bray, Sr. Editor Transportation Management,
  J. J. Keller Associates, Inc.
• Tom Moore, CTP, Vice President of Education, NPTC
• Larry Cook, CTP, Sr. Mgr., DSD Fleet Safety
  Compliance, Kellogg Company

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• Dr. Gary Petty
• President CEO
• National Private Truck Council

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Introduction

• The Selection Process, Inspection Levels and
  Procedures Tom Bray
• The Use of Inspection Data Tom Moore
• Kelloggs Program Larry Cook
• Housekeeping issues
• You will be muted during the event.
• Please use the Question feature to text questions
  to the QA Panelist. Well try to answer them
  during the QA period if they are not covered in
  the presentation.
• If you lose sound at any point, you can dial-in
  by phone using the number and Pass Code listed
  below.
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Gary Petty National Private Truck Council
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Introduction and Disclaimers

• Road Check is June 5-7
• The content in this webcast is intended for
  information purposes only and should not be
  construed as providing legal advice.
• This is an introductory course and is intended
  to highlight critical safety and compliance
  topics. Time constraints limit our ability to go
  in depth.
• We invite you to ask questions. We will answer
  them throughout todays webcast.

Gary Petty National Private Truck Council
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• Tom Bray
• Sr. Editor, Transportation Management
• J. J. Keller Associates, Inc.

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Goals of the Roadside Inspection Program

• Direct attention to rules and regulations by
  requiring carrier safety and compliance
• Document violations that are used in subsequent
  enforcement actions
• Obtain information regarding carriers, drivers,
  vehicles, and cargo relative to safety and
  compliance
• Support on-going assessment of carrier, driver,
  and vehicle
• Remove unsafe carriers, drivers and vehicles from
  the highways

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Overview of Roadside Inspection Program

• Roadside Inspections are a spot-check of driver
  and vehicle (mini-compliance review)
• Inspections can occur anywhere and at anytime
• Specially trained and certified inspectors
  conduct standardized roadside inspections
• Any officer can pull over a truck, but only
  trained ones can conduct roadside inspections and
  submit report
• The Commercial Vehicle Safety Alliance is an
  association that establishes and disseminates
  roadside inspection procedures, inspector
  training courses, and Out-of-Service Criteria

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Roadside Inspection Selection Process

• Selection methods
• Observation of a violation/defect
• Inspection Selection System (ISS) and other
  electronic screening programs
• Random selection
• Vehicle with valid CVSA sticker normally not
  selected for inspection (exception is
  observation of violation/defect)

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The Roadside Inspection Process

• Conducted at fixed and mobile sites
• Selection both random and risk-based, including
  traffic enforcement component
• 3.5 to 4 million roadside inspections conducted
  per year
• Inspection follows standard process
• Average time to conduct 15-60 minutes depending
  on level and violations discovered
• Enforcement Violations, warnings, citations,
  fines,
• OOS orders, arrests and others
• Data Hard copies and Software entry and upload

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Seven Levels of Roadside Inspection

• Level I North American Standard Inspection
• Level II Walk-Around Driver/Vehicle Inspection
  (same as Level I, except)
• Level III Driver-Credential Inspection
• Level IV Special Inspections
• Level V Vehicle-Only Inspection
• Level VI Enhanced NAS Inspection for
  Radioactive Shipments
• Level VII Jurisdiction Mandated Inspection

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Inspecting Paperwork

• Driver credentials and paperwork (DL/CDL
  logbook, supporting documents, medical
  certificate)
• Carrier and vehicle credential documents
  (markings, IEP related paperwork, lease
  agreements, proof of annual inspection, IFTA,
  IRP, etc.)
• Shipping papers (bills of lading, HM shipping
  etc.)

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Inspection Data Systems

• ISS (Inspection Selection System) Provides
  inspection recommendation carrier snapshot
  with census and safety data
• CDLIS, NCIC, NLETS Retrieves driver status,
  conviction history, etc.
• QC (Query Central) Combines the functions of
  ISS CDLIS Access, plus more
• ASPEN (inspection software) Collects inspection
  details, prepares report, and transmits data

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Outcomes

• Three possible outcomes
• No violations discovered
• Roughly 66 of driver inspections have no
  violations
• Roughly 33 of vehicle inspections have no
  violations
• CVSA Decals are issued for passing a Level I or V
  inspection good for 90 days
• Violation(s) discovered, but driver and vehicle
  allowed to continue (corrections made ASAP)
• Violations discovered and driver and/or vehicle
  placed out of service
• 5.5 of drivers and 20.7 of vehicles inspected
  placed OOS

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2011 Top 10 Driver Violations
Tom BrayJ. J. Keller Associates, Inc.
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2011 Top 10 Vehicle Violations
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CVSA Out-of-Service Criteria

• What it is
• Safety violations that represent an imminent
  hazard
• Cannot continue to operate until repairs made
  and/or condition is fixed
• Driver, vehicle and load specific
• What it is not
• They ARE NOT maintenance or performance
  standards
• North American Standard
• Time tested process
• Legislated
• Case law established

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Vehicle Out-of-Service Items

• If violation is found, second question Is the
  vehicle OOS?
• Operating over hours or with false log
• Brake System 1 source of OOS adjustment is a
  major issue 20 of brakes defective to be OOS
• Tires 2 source of OOS wear and exposed areas
  are major issues 50 under-inflation to be OOS
• Lighting 3 source of OOS 1 stop and 2 turn
  signal

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After a Roadside Inspection

• Driver can hand deliver report to equipment owner
  if back within 24-hours, or fax/place in mail.
• If vehicle passes a roadside inspection, a decal
  will be placed on the equipment (number, color,
  and cut establish month inspection took place).
• If violations are found, equipment owner has 15
  days to correct and return the report to the
  issuing agency.
• Equipment will be tagged if found to be
  Out-Of-Service. Driver/vehicle cannot operate
  until issue corrected. Violating an OOS order
  carries severe penalties!
• Equipment owner maintains a copy of the
  inspection for 12 months
• Report data is loaded into SAFETYNET and MCMIS by
  officer

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ISS, Roadside Data, and BASICs
Inspection Program Roadside Data
ISS at Roadside Inspect Optional Pass

• BASICs
• Unsafe Driving
• Fatigued (HOS)
• Driver Fitness
• Controlled
• Substances/Alcohol
• Vehicle Maintenance
• Cargo Related
• Crash

SMS Results (percentiles)
Investigation Results (serious violations)
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• Tom Moore, CTP
• Vice President of Education
• National Private Truck Council

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Performance-Based Inspection Program ROI

• Vehicle Repairs 1 _at_ in-gate, 10 _at_ out-gate,
  100 on the road
• Typical CVSA Out-Of-Service Order for vehicle
  defects lasts 8.6 hours
• Missed delivery, repairs, towing, re-dispatch,
  driver wages, fines, violations
• Shippers becoming sensitive to carrier CSA scores
• Inserting safety performance metrics in future
  contracts, lost loads
• Good drivers becoming more selective to the score
  of their carrier employers
• Insurance underwriters paying closer attention

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Systematically Inspect, Repair and Maintain

• 396.3 Every motor carrier and intermodal
  equipment provider must systematically inspect,
  repair, and maintain or cause to be
  systematically inspected, repaired, and
  maintained, all motor vehicles and intermodal
  equipment subject to their control
• 396.17 Periodic Inspection Requirement
• Minimum criteria set forth in Appendix G
• At least once a year, but is that often enough?
• 396.19 25 Inspector Qualifications
• What are they?
• Carrier must have documentation for all internal
  staff and external vendors and their maintenance
  staff that work on your equipment
• 396. 21 Period Inspection Recordkeeping
  Requirements

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Inspector Qualifications Critical To High
Quality, Uniform Inspections

• Sourcing, recruiting, screening candidates
• Pre-requisites for truck familiarityand
  operations, regulations and inspection procedures
• Classroom and hands-on training
• Proctored test to confirm knowledge

• Inspector certification
• Continuing education and re-certification
• Inspection alerts and bulletins
• Two-person inspection teams for quality control,
  safety and redundancy

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Prioritize Defects to Guide Maintenance Repair

• System, subsystem, component breakdown with
  predetermined defects
• Brake stroke, tread depth measurements
• ATA VMRS coding, digital photo, comments
• CVSA OOS Criteria
• Capture diagnostics codes from J-Bus/ECM
• Recall for re-inspection

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How to Reduce Violations During Roadside
Inspections

• Train all drivers upon hire how to pre- and
  post-trip inspect their units and the roadside
  inspection process.
• Expect what you can inspect.
• Cross reference MCMIS data with DVIRs, HOS and
  roadside inspection documents.
• Present CSA SMS data to drivers, technicians and
  managers.
• Audit DVIRs to make sure service department is
  repairing defects and placing units back into
  service.
• Provide drivers with repair kits and teach them
  how to use them

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• Larry Cook, CTP
• Sr. Mgr., DSD Fleet Safety Compliance
• Kellogg Company

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Kellogg Fleet Operations

• Fleet consists of
• 800 Power Units
• 1,200 Trailers
• 1,200 CDL Drivers
• 42 Distribution Centers
• 35 million miles

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How Roadside Inspections are Used by FMCSA

• Date/Time stamp of activity
• Supporting document to check against yours
• They know the answer to the question before they
  ask it

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Results of a Poor Pre/Post Trip

• Operating with defective equipment
• Endangering public and employee
• Increased CSA scores and scrutiny
• Subject to citation
• Subject to litigation

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Crash Investigation
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Prevention Begins

• Maintenance Vendor/In-house
• FMCSA compliant
• CSA knowledge
• Mechanic qualifications and performance checks
• Yearly review

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Management Training

• Hiring CTPs
• Vehicle nomenclature
• How to perform proper pre- and post-trip
  inspections
• Understanding the North American Standard
  Out-of-Service Criteria--give them the book!

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Driver Training

• DVIR Training Is documentation complete?
• Training Video Yearly training to include
  on-the-job training
• Work with and ride along
• Gate Check
• CSA Knowledge

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Company Vehicle Inspection Video

• In-house
• Our employees
• Our equipment
• Peer-to-peer instruction
• Minimal investment

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Interventions and Coaching

• Build a culture of safety by engaging
  drivers/repair techs in the process of defect
  identification and hazard perception
• Routine training and follow-up coaching
• Process
• Take pictures of defects
• Ask drivers/maintenance techs to identify defects
• If identified, ask driver/maintenance why it
  wasnt noted on DVIR

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Brake Lining Failure
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Tread Depth and Uneven Wear
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Air Hose Chafing
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Improper Frame Crack Repair
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Driver Gate Checks
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Keys to Reducing Our CSA Score

• Vendor certification
• Management training
• Driver training
• Roadside inspection follow-up
• Root cause analysis
• Coaching
• Ride-alongs

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Question Answer

• Please submit questions toQA using the
  Questions tool

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Closing Remarks

• Checkout the archive of past topics at
  http//www.jjkeller.com/nptcinfo
• PowerPoint slides and recording up in 1 week
• Topics for 2012
• July 11 Improving Fleet Productivity Through
  Quality and Lean Initiatives
• October 3 Effective Motor Carrier Safety
  Training Programs

Gary Petty National Private Truck Council