CCJ

January 2018

Fleet Management News & Business Info | Commercial Carrier Journal

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commercial carrier journal | january 2018 35 BUSINESS | CSA More clean inspections: Is it changing enforcement or improved compliance? The growth in clean inspections shows "a trend toward inspectors starting to complete the violation report" when it shows no violations, says Colin Mooney, executive director of the Commercial Vehicle Safety Alliance. Mooney and no doubt many drivers view that trend, somewhat reflective of a change in enforcement practices, as certainly "something that we want to continue to encourage" since clean inspections help a carrier's Compliance Safety Accountability scores. From the perspective of an active enforcement depart- ment, however, it's not that black and white. Arizona Capt. Brian Preston says incentivizing clean inspections as a general rule isn't something he wants to actively encourage among his state's Department of Public Safety officers. While he also doesn't want to encourage officers to not turn in inspections where they don't find a violation, he views his department's priority to be finding problems that need correction. He makes an analogy to driving-under-the-influence enforcement. "Send a guy out on a Friday night and tell him to go out there and look for DUIs, and he doesn't come up with any – I'm only really concerned if there were in fact DUIs happening somewhere, and we didn't find them." The same concept applies to truck enforcement, he says. "If you did 20 inspections and didn't find a violation, maybe we need you to work different locations or go through some new training." Targeted, effective enforcement are the watchwords there, and Arizona's no slouch. It ranks No. 4 in violations per inspec- tion found, and its clean inspections percentage is the 14th lowest in the nation. However, that percentage is moving higher at a rate that beats most states. The prevalence of clean inspections in Arizona increased by almost 20 percent in 2016 over the previous year. Preston says the national nature of that rise in prevalence across many jurisdictions may well indicate more about drivers' practices than about the nature of enforcement. Attitudes toward compliance are changing fast, he sug- gests, as more businesses large and small are buttoning up their operations. cumbersome process. Most drivers with fleets using e-logs, Preston argues, have become less concerned with roadside officers inspecting logs than with "some safety manager's phone going off " to report that the driver is over his hours. In short, Preston and Mooney believe ELDs will continue to lead a falloff in HOS violations. With vehicle-related vio- lations also falling off – the 2016 vehicle violation total was 8 percentage points less than that recorded in 2014 – and with increasing focus on improving the data well for CSA to score carriers, expect attention to continue to focus on moving violations. ose violations had been rising as a share of the total for years, even though the number of the violations kept dropping, and 2016 was no exception. But for the first time in the last few years, the raw numbers of moving violations recorded increased in 2016 by 2 percent. Mooney says a lot of ticket-writing activity at roadside isn't captured in these numbers today because many state jurisdictions employ people who are outside the CMV-en- forcement umbrella. A citation for speeding from a trooper who is not CVSA-certified won't be accompanied by any inspection and thus "does not make its way to CSA." Not so for CVSA-certified inspectors, but depending on the time available, they may not complete an inspection report themselves. e congressionally mandated National Academy of Sciences report on CSA, issued last year, recommended identification and use of new sources of data for the system that underpins carrier scores. One of those sources, says Mooney, could well be local court systems' records of adju- dicated citations, perhaps to contribute to the Unsafe Driv- ing category in CSA post-adjudication. is could mean the carrier and/or driver will be held accountable in scoring for the infraction only if a conviction occurs. It's "something we're actively trying to troubleshoot and work on with the court systems," Mooney says, calling it a "long-term strategy with FMCSA and state partners. It's one thing to know the ticket is written, and quite another to know that it's been adjudicated." He believes including post-adjudication citations in CSA would be a significant "enhancement of the program – you're capturing more data in a category that's incredibly important. If you do it on the post-adjudication side," then the cumbersome DataQs process to deal with adjudicated citations in the CSA system is "irrelevant." Difficult though it may be to make the change, Mooney notes that it's human behavior, not mechanical fitness or driver credentials, that contributes most clearly to the cause and severity of most crashes. "e biggest thing we've seen a change in over the few years is distracted driving as a result of the introduction of smartphones – it's clearly a health hazard for all of us," he says. With more enforcement of such moving violations committed by both drivers and the motoring public, "we hope we'll see the crash rates decline over time. But right now, they're increasing."

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