Inconsistent enforcement: Know your vulnerabilities
Some things are obvious: Securement violations are more likely for open-deck haulers, as well as lighting violations for any operator with an overabundance of running lights on both the truck and trailer.
Others aren’t: Consider owner-operator Mike Falesch’s leased household-goods hauling operation. “We’re really singled out on tires because we’re always in tight subdivisions,” Falesch says. “You run up on a curb and chunk a tire, and all of a sudden, you’re getting 20 points.” Most tire violations are weighted 8 out of 10 possible points in the Compliance Safety Accountability Safety Measurement System. The multiplier for the most recent violations is 3, meaning the chunked tire would net Falesch’s carrier 24 points – more if it was an out-of-service violation.
In Maryland, Falesch has heard from three fellow HHG haulers who’ve “gotten popped” for unsecured loads when the officer found out they’d unloaded recently. Common practice for the pad stacks and dollies of an HHG operation is to “stick the dolly” under the stacks of pads. That provides more than enough weight to hold it down in the van, he says, but inspectors don’t see it that way: “They will write you up for an unsecured load for that.”
With the December 2012 update to the SMS, Thomas Blake – owner of a five-truck fleet that bears his name and is based near Kansas City, Mo. – continued to show a Vehicle Maintenance BASIC (Behavioral Analysis and Safety Improvement Category) measure a fraction of a point above the intervention threshold of 80. By and large, Blake says, the score is attributable to his being an intermodal operation. Just a couple of inspections without one of several chassis violations on his fleet’s record would put him well below the threshold – if he registered a score at all.
Blake’s carrier first registered a number in maintenance after a not-at-fault crash saw inspectors put the truck out of service due to a broken leaf spring that was a direct result of the crash. Other violations he’s seen are “just nitpicky things,” he says, such as a violation for a loose strap on the fire extinguisher near the driver’s seat. “It’s right there by the door, so it’s easy to hit on your way out the door.”
In some states, that’s a commonly written violation. See the “Violation priorities” lists with the national maps on our CSA’s Data Trail site here.
Blake says other issues with intermodal chassis include tire and brake problems: Some late-model chassis are outfitted with manual slack adjusters in spite of the requirement for automatic slacks. “All the brakes were good” on a particular 1999-model chassis one of his drivers picked up, he says, referencing an inspection logged in the last two years. The driver had done his pretrip thoroughly, but he’d missed the fact that the slacks should have been adjusting automatically. It netted Blake a 4-point violation he says even he as the company’s owner – he also drives one of its five operating units – wouldn’t have noticed on a pretrip.
While Prime Inc. Safety Director Don Lacy has instituted a renewed focus on the importance of pre- and post-trip inspections before and since CSA went live, he says Prime also now recommends inter-trip inspections. “We spend a lot of time educating drivers on identifying the location of a scale in advance and pulling into a truck stop and going through that inspection again before approaching the scale,” Lacy says.
As Blake’s example suggests, intermodal operators might pay particularly close attention to chassis in such inspections given their reputation for poor maintenance. Clearly, inspectors have them in their sights.