Another reason to fight traffic tickets: Convictions can now impact independents' safety ratings

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This week's edition of Overdrive Radio touches on an area of well-founded concern for owner-operators -- fighting the stains on your Motor Vehicle Record that come from tickets for moving violations of all types. Pay the fine, and it’s like pleading guilty and doing the proverbial time. A "conviction” will be paid for in a myriad of ways beyond just the cash fine: higher insurance rates, impact on your company’s CSA Safety Measurement System profile and scores, and an increased likelihood of audits. 

Overdrive Radio logoSubscribe to the podcast on your listening platform of choice for early access to the weekly Overdrive Radio series -- it drops typically every Friday to the feed and follows here at OverdriveOnline.com and in Overdrive's Youtube and Facebook feeds the following week. You can subscribe via Apple and Google podcasts, Spotify, Stitcher, most anywhere you listen.Yet there's another, relatively new way anyone with motor carrier authority could pay, too, speaking of those audits. Jeff Davis, longtime Fleet Safety Services compliance consultant who supports mostly small carriers in the event of an audit, outlines it in the podcast.

Last year, FMCSA modified its safety rating methodology, Davis said. For the first time auditors were able to include traffic-ticket convictions in a carrier's overall safety rating. That’d be the Satisfactory, Conditional, or Unsatisfactory system long in place and which the agency is set to reconsider for improvement as early as this year: A public affairs spokesperson again confirmed that with me just this week, in fact, that an Advanced Notice of Proposed Rulemaking requesting industry and public input on the safety rating remains for this year as a possibility.

Howes logoOverdrive Radio sponsor Howes wants to hear from you. If you've used Howes' fuel treatments, lubricants or other products through the years, send me an an email or leave a voicemail with your story on the podcast message line. Leave your name and address and we'll get a prize pack with Howes' Diesel Defender treatment and Multipurpose penetrating oil to your doorstep: 615-852-8530.With traffic-ticket convictions on the table for safety ratings during audits, Davis notes in the podcast, that’s even more for owner-operators and small fleet owners and managers to keep in mind. As in 2021, when a majority of safety ratings issued were of the adverse, Conditional variety, year 2022 numbers from the FMCSA's Analysis and Information System show that outlier year on a path to becoming a trend, as it were.  FMCSA and state partners conducted more audits in 2022 that resulted in a safety rating than in 2021, yet the percentages were roughly similar to those charted for 2021, when a majority were Conditional. 

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Consider new procedures around traffic-ticket convictions as further incentive to manage those citations. Recall, too, that citations adjudicated in your favor by a court can be removed from the data profile in the CSA SMS and the broader MCMIS database itself –- you use the DataQs system to do that

More on the recent-history audit-process change in the podcast: 

[Related: Fit or Unfit? FMCSA keying in on problems with 'Conditional' safety rating limbo]

Transcript

Todd DIlls: Hey, everybody. It's Todd Dills, your host for this Overdrive Radio edition, dropping to the podcast feed and subscribers Friday, June 2nd, 2023, hitting the world-famous overdriveonline.com Monday, June 5th. The subject today touches on a long area of well-founded concern for owner-operators. That's the importance of, when possible, fighting the stains on the motor vehicle record that can come in the form of tickets for moving violations of all types. Pay the fine and it's like pleading guilty and doing the proverbial time. A "conviction" will be paid for in a myriad of ways: higher insurance rates, marks on your company's CSA SMS profile and its scoring, possible audit hassles, given more violations on the record meaning greater likelihood of prioritization by federal or state investigators for an audit.

There's a relatively new way anyone with motor carrier authority could pay too. That's according to Jeff Davis, longtime fleet safety services compliance consultant, who supports mostly small carriers in the event of an audit. "Last year, FMCSA modified its safety rating methodology," Davis said, "to, for the first time, include traffic ticket convictions, potentially a carrier's overall safety rating." That'd be the satisfactory, conditional, or unsatisfactory system in which the agency is set to put up for ideas for improving this year.

FMCSA public affairs spokesperson, again, confirmed that with me just this week, in fact, noting in advance notice of proposed rulemaking crew requesting industry and public input on the safety rating remains for this year's possibility. With traffic law convictions on the table, Davis notes in what follows in this podcast, that's even more for owner-operators and small fleet owners and managers to keep in mind in case an audit is likely. A good portion of Davis' talk recorded at the annual conference of the National Association of Small Trucking Companies late last year also delved into just what the term safety culture means as it's banded about by trucking companies, by consultants like himself, indeed by FMCSA when it talks about its CSA safety measurement system, which Davis described this way.

Jeff Davis: I believe it's not even touching the surface of what a true safety culture is. I believe it's an accumulation of violations run into an algorithm that they are trying to evaluate people, but it really doesn't show that deep down culture that we're really after.

Todd DIlls: That collection of violations, he argues, really has entrenched the management by exception, by negativity for fleets of all sizes, something he encouraged the small fleet managers and owners in attendance to get away from as much as possible in favor of more positive reinforcement.

Jeff Davis: Well, one question I'd ask you is how much time do you really dedicate to working with your drivers because they are the most important people out there as we know. They're the revenue generators. We're trying to find loads, we're trying to buy equipment, we're trying to handle things administratively, but how much time do we literally wrap our arms around that driver and tell them what a good job they did or recognize them in some way?

Todd DIlls: Too often, our drivers just get caught doing something wrong as it were. Those negative conversations then end up being the rule for contact with what fundamentally is the most important relationship any small fleet owner has at the company.

Jeff Davis: So how many times do we catch a driver doing something good? Can we catch a driver doing something good every day? Is that in our vocabulary? Is that even possible?

Todd DIlls: After the break, well, more of where that came from, and on the other side, we'll take up the safety rating methodology change directly. First off, here's a message from Overdrive Radio sponsor, Howes. Keep tuned.

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Todd DIlls: Find more information at H-O-W-E-S, howesproducts.com. You can try out the warm-weather Howes Diesel Defender fuel treatment yourself if you just drop me a message on our podcast line with your name and address, 615-852-8530. I've got a new shipment of several bottles of it capable of treating up to 160 gallons of fuel a piece. Drop your address and I'll send you a prize pack including a bottle of Defender]. That number is 615-852-8530. Okay. Here's Davis setting up the big safety rating methodology change that's mostly flown under the industry's radar in recent times.

Jeff Davis: They've added a little twist to things that we've never had to deal with before in the past and what it is is unsafe driving, and we're all aware of what unsafe driving is on our scorecard. We have unsafe driving violations. Up until about 60 days ago, those violations could never affect your safety rating. It was on the CSA scorecard. CSA scorecard is totally different than a compliance review. Okay? So up until about 60 days ago, they could walk in and you could have 50 unsafe driving violations and it would never affect your rating. Why are we concerned about protecting our rating? We protect our rating, we protect our shippers, we protect our insurance, and we do good in the courtroom or helps us do good in the courtroom.

Okay? So the change that they made now is now, unsafe driving ties into your overall safety rating. Think about what the agency's asking us to do. They're asking us to entrust a piece of equipment to a driver and we're asking that driver, whether employee, owner-operator, or whatever he is, 1,000 miles away, DOT's expecting us to control his speed, whether or not he wears a seatbelt, whether he makes a lane change, whether he's following too close. When you look at manufacturing here in town, the manufacturers can't even control the people working on the line. They show up late, they don't come back. They take smoke breaks and mess this up. Now we have to manage that driver miles away. So this is how it works in an audit.

They'll come in during an audit and they'll go back 365 days from the date of the audit and they'll count the number of unsafe driving violations and they'll determine whether the load was interstate, did it cross state lines, or was it intrastate, did the load pick up and deliver in the same state? You with me? So very first thing they do, they go through and look at all the unsafe, they determine what type of movement it was, and then they will look for convictions, interstate conviction and intrastate convictions. Depending on the state you're in, the state may take action against you for your intrastate convictions, but the federal audits, they're going to look at only interstate movements.

Okay? So this is how it works. Here's an example. This motor carrier had 10 unsafe driving violations. It actually goes back two years. It's the full unsafe driving, but normally, it would be just 365 days. We know 85% roughly, approximately of all roadside inspections of unsafe driving are no citation is given. It's usually just a warning, right? So one of the things that irritates, this driver gets a warning, driver comes back, says, "Hey, I didn't get a citation, but still hurts our CSA score." Follow me? Got all that? Okay, in this scenario, what happens? We had 10 over that period of time, two of them resulted in a citation and that citation resulted in a conviction.

So here, we had a speed 15 over and a seatbelt, and then we had another 15 over and the seatbelt. So that means we had two out of 10 convictions out of 10 safety events, which equals 20%. Anything 10% and above, you fail unsafe driving in an audit. Now what if we had one? So we'll assume this first one didn't happen, it was a warning. We had this one. One out of 10 is what percent? 10%. We fail the unsafe driving portion of our audit. The question is, how can they expect any company not to have at least 10%?

I don't know the answer to that. I really don't. Again, remember our scenario of being on the road up to 14 hours a day, five days a week, 48 weeks a year. Look at the exposure out there and if you make a mistake, 15 over, I'd grant it, I got some issues with that, but a six to 10 over, which in this room has not gone six to 10 over in the last week? I want your ECM, I'll find out [inaudible 00:10:36]. So another thing that we need to manage in light of our recruiting and retention.

Todd DIlls: Plenty to keep in mind there in terms of basic management of those convictions too. For any violation for which you or one of your drivers receive a citation. Recall too, that citations successfully adjudicated by a court can be removed from the data profile in the CSA SMS and the broader MCMIS database itself. You use the data queue system to do that. We've got plenty of the way of data queues filing resources at overdriveonline.com, search how to data queue. I'll post a couple links in the show notes and in a Monday, June 5th post that will house this Overdrive radio edition. Speaking of recruiting and retention, that was the broader subject of what Davis led NATSA conference attendees through with this talk, a bit of a new subject in some ways for him as he illustrates here in the introduction of the talk.

Jeff Davis: The topic I was given this year was utilizing safety in the recruiting and retention process, and I believe safety is one of the last great resources in a trucking company that is untapped in light of motor carriers working with recruiting and retaining drivers. I think we've used safety pretty much as a tool, as a hammer, as a let's not do this type situation over the years, and I think we need to take a completely different look of how safety works within our organization and how we can use safety to our advantage. It is obvious with all the regulation, all the compliance, all the rules that we have to follow, we cannot hide from it. We have to embrace it in some way.

So how do we embrace this compliant segment, this compliance that we've been forced upon or we've been asked to do? How do we move that within our corporation to help recruit and retain drivers? So we're going to cover just a couple topics today that might help you in that area, but the main purpose of the presentation is to get you to think about safety and compliance in a different vein. Think how we can get our arms around our drivers. I said this on the radio this morning. If the large carriers ever learn the advantage we have of small carriers, of being able to get our arms around drivers, no matter how bad they smell, no matter how many violations they have, we can get our arms around them and work with them.

I think we can really help ourselves out both in recruiting and retention and compliance. It's all got to work together. Safety is part of the whole system that we've been dealt with, so how do we work that in this operation that we're trying to do day to day? Stanford is really doing some great work right now on is the glass half full or is the glass half empty, and what they're seeing in their studies, and these are pretty simple studies, they're peer reviewed, but what they're seeing is once an individual experiences something or perceives something as a negative, it's much more difficult to get that individual to move that same concept over to the positive side.

Or vice versa, if the initial implication or perception of a situation is positive, it's a lot easier to keep that individual positive at that point in time. We've talked about this for a year. You have a negative thought about something, you're told, hey, you got to replace it with two positives. So I think we've done that with our safety and compliance in some ways. What we've done is we tend to focus on the negative, we tend to look at things of where there's violations, we tend to look at our troubled drivers or our borderline drivers and that's where we spend our time and effort, and therefore, we come up with maybe a negative perception of our, I'll call it our safety culture for lack of a better word. So we have to start thinking in terms of what we're doing right.

Things that are really working for us. We'll come back to this a little later in the presentation, but some of the major keys to recruiting and retention in your safety culture, the two areas that we'll take a look at today are driver performance and drive to data safety management. I think those two areas are really critical, although policy implementation is very important, and staff and driver training is very important also. Let's just talk about policies for a second. You know what? If I walk into one more motor carrier and I have to blow the dust off that policy manual that they copied from the company they used to work for, all right, I think I'm going to throw up.

All right, and then you don't dare ask the question, well, have you conceived or have you thought about doing anything? By the way, here's a key. If DOT comes into your office for an audit and they say do you have a regulation book, make sure you blow the dust off of it before you hand it to them. Okay? That's a great key, and also make sure it's not from 1916 because that's another problem that happens, but anyway, side point there. It's very, very important that if we have a policy, if we have a guideline, that we do what we say and say what we do. Many times, I believe less said, the better. Now most insurance companies will want you to have a 500-page policy on everything that ever moved.

And which of us in this room by moving brake, fixing trucks, finding loads, do we have time to do everything that we ever wrote? So think about that in lining your policies. Maybe in this case, less is more. I'm a real advocate of that and whatever it is, that's what we want to do. The other thing with policies is that don't tie yourself down with policies. You want policies to guide, you want policies to point people and drivers in the right direction, but you don't want your policies to handcuff you in what you're doing because it will be used against you. So we'll look at mainly those two areas. It's a whole picture, a culture takes care of a whole picture of things. Safety culture in essence is everybody's on the same page and they internalize the safety message. All right.

It's not only about safe, about being driving the truck. It's safe about being around the trucks, it's about staff, it's about leadership, everybody has internalized the safety message. It takes a will and it takes work. It takes those two things really to get a safety culture to move. It can't just be slogans, it just can't be videos, it just can't be cameras, it just can't be telematics. It's got to reach a little deeper into what people really until they internalize that whole safety message. It doesn't have to run the whole company, you don't have to change your operations. In most cases, you just have to motivate or you have to move that culture throughout your organization.

That's where it gets a little difficult with people from time to time. I've got this saying I use all the time. Everything is safe until it isn't. Safety's like magic. If everything's going good, it's like magic and you're trying to figure out what safety really is, but once we have an exception, once we have a violation, once we have a crash, then safety, we're no longer safe. So everything is safe until it isn't. Where I'm going with this is that cultural, that internalization of the safety message, when everything is safe, we're still being safe. Does that make sense? Pretty simple stuff, but when we look at safety, we're measuring it by exception. All right. We look at what's the exception.

We look at the violations, we look at the crashes, we look at the breakdowns, we look at this, we look at that, but we fail to look sometimes at what we're really doing correctly. My opinion is we have to look at that glass that is no longer half empty, but that glass is half full because look at all the great things that we do with safety. How many in this room can tell me how many accident-free miles your company had last week, last month, last year? Anybody? Can anybody tell me how many accidents you had last week, last month, last year, right? See the difference? And on top of that, if we had no accidents for the last week, last year, last month, how did we reward our drivers in that situation?

I'm not saying monetarily. How did we recognize our drivers? How did we recognize the things that went right? The databases that the agency has pushed on us and we need to manage in order to stay in compliance, keep our insurance rates down to keep our shippers happy, that's all based on the exception, it's all based on violations, and we tend to, over a period of time, focus on that. So let's think about that. How do we do? How do we present? How do we display the things that we do right? Think about it. You're a single owner-operator and you ran 80,000 miles last year and you had no collisions. That is an amazing task.

So if you have four or five drivers that do that, how do we really recognize that? How do we reward that? How do we motivate that driver to do that again because I think what we do is we wait till the driver gets a roadside inspection and his log book's not bright and his light's out and the tire's flat and on and on and on and on, and then we're off on the exception. I'm not saying not manage the exceptions. I'm just saying we need to look at this glass a little different because over the years, I believe we're getting a little tainted in the other direction. Here's a carrier that's got a few problems possibly, right?

Todd DIlls: Davis showed an anonymous carrier's internal SMS profile on his screen here, showing six of the seven CSA SMS categories of measurement and "alert status," or over the percentile ranking threshold where FMCSA and state auditing partners prioritize that carrier for investigation. Carriers might be experiencing issues in that regard, but Davis also pointed out this carrier when it comes to the safety rating, however, is …

Jeff Davis: …Satisfactory rated. Motor carrier has six alerts and they've got a satisfactory, see? So what we learn is CSA has nothing to do with your safety rating. We learn from that. So this carrier appears to be totally out of control, and in some cases, they are totally out of control. All right? What I'm alluding to is the way we manage our drivers, all right, and it ties into recruiting and it ties into retention, the way we manage our driver performance has become our public perception. We all looked at this. I saw half of you cringe, I saw half of you look down and you're trying to figure out, oh my God, is this carrier out there?

Actually, not a bad carrier. Got a few crashes, a few hours of service problems, a couple other things, but they've got a lot of drivers doing a lot of right things. My point being the agency has developed this safe stat scorecard, a CSA scorecard. They've tied numbers to it, they've tied thresholds to it, and from there, over a period of 10 years now, we're starting to draw perception about the whole safety and compliance of a company, which hopefully, in a few slides, I'll show you it doesn't always appear to be what we're looking at. I know all of you have had to deal with any of you that have CSA scorecards with data on it.

You've either, if you've got some violations or some defects, you're going to hear it from brokers, you may hear it from insurance companies, different places like that, that they're wondering about what's going on with your safety and compliance. Hank Seton got displaced on the website years and years ago when it was made public, and basically, what this disclaimer says, and it's on every CSA scorecard that you pull up, readers should not draw conclusions about a carrier's overall safety condition simply based on the data displayed to this system. So it says as long as you're not unsatisfactory, you're fit to use. So I think we've taken this data and we've developed a perception.

Not only us, not only our drivers in recruiting and retention, but also the plaintiff bar, also the shipping public, and also the insurance company. All insurance companies have all utilized this data for and against us moving forward, and therefore, it's become our perception, our public perception of our safety culture. I believe it's not even touching the surface of what a true safety culture is. I believe it's a accumulation of violations run into an algorithm that they are trying to evaluate people, but it really doesn't show that deep down culture that we're really after, if that makes sense. Nowadays in trucking, here's a carrier with four alerts, that's a little better than six.

Nowadays, we have all this big data that we have to manage, all right, and you look at this, there is so much data flowing through a safety department or through your company now that all has to be managed. Look at a couple of big ones. You got EROADs or the ELDs, that's huge. Telematics, critical event monitoring, all those types of things have to be managed, have to be monitored because they will be used against you. The public, shippers, brokers, all the rest use this data that they can get their hands on and they develop that perception about that company. Let me ask you a question. That CSA scorecard that we showed was six alerts. Would you ever consider if you looked at the scorecard of 10 motor carriers and they were the worst, would you ever consider looking at them to work for them?

Todd DIlls: Here, someone in the audience noted she pulled a lot of these profiles in a role with NASTC itself and that she'd never seen a carrier with more than one category in "alert status."

Jeff Davis: And that's why the small trucking companies, I believe they can recruit much better. Their retention rates are much better, and I think a lot of that has to do with the ability of us to permeate our safety culture among our drivers. We're small enough in many cases to, like I say, to get arms around it. As you get a little larger, you start seeing all these things, but good point, your data out there still needs to be managed in each one of those situations. The way I look at this is each one of these is a potential system coaching situation, and each one of these coaching situations is what I call a driver touch.

You're able to touch the driver and when you're touching the driver, not necessarily in a discipline way or progressive discipline, but every touch with the driver can become a recruiting and retention tool. So are we using this data? In a lot of ways, we've got to manage all that. We're required to manage that. Our hours of service, everybody has hours of service. We, by regulation, are required to manage it. So when we have situations come up with hours of service, how do we initiate that touch? I think the way we do that is use this data as potential coaching. We're going to talk about a couple of keys to coach drivers. That's what I'm talking about it's an untapped resources.

I think we throw bonuses, I think we do things operationally to entice drivers, and we have safety over to the side and we're trying to figure out how to move this safety in and keep these violations down, and we don't really use these safety events and really take the time and resources to make it happen. Now, I know a lot of you are single owners, I know a lot of you don't have large staffs. I realize all that, but one question I'd ask you is how much time do you really dedicate to working with your drivers because they are the most important people out there as we know. They're the revenue generators.

We're trying to find loads, we're trying to buy equipment, we're trying to handle things administratively, but how much time do we literally wrap our arms around that driver and tell them what a good job they did or recognizing in some way because we're always focusing on the problems. It's the violators, the ones that get our attention, and the times a driver is touched by a corporate entity, a company, a trucking company. Obviously, the majority of the time is dispatched and obviously, the majority of the time, it is when to pick up, when to deliver, how to get the bills signed, so on and so forth.

So when safety touches, when does safety touch? When we've got the roadside inspection, when we've got the accident, when we've got the log violations. So what does that teach our driver? All right. They know this is absolutely required. If they're going to make money, they definitely want to talk to Homer and his group because that's going to keep his truck running, but when they come to safety, what does safety want to do with it? They want to talk about the exception. Now I'm here saying we got to talk about the exception. I just want to hopefully put out an idea to have you thinking from a different perspective than what we've done before.

So how many times do we catch a driver doing something good? Can we catch a driver doing something good every day? Is that in our vocabulary? Is that even possible? I don't know. It's a struggle, isn't it? How do we catch a driver doing something good? There's Fred, he was late yesterday. I wonder if he's going to be on time today. He called me at 10:00 last night and he's in advance and now he's stuck. Don't shake your head like this ever happened to you before. Okay. So how do we catch Fred doing something good?

All right. We need to deal with what we feel is the bad. What we got to do is good. I know you guys think I'm crazy back there. It's just a totally different angle than what we normally go. Here's another one. Let's look at this one in detail. This is the one with three alerts and look at your unsafe driving, 84th percentile. What does that mean? Does that mean anything to anybody? First of all, what's an alert? Anybody know what an alert is? Pardon?

Speaker 4: Above the threshold.

Jeff Davis: Above the threshold. All right, and what causes an alert?

Speaker 4: Violations.

Jeff Davis: What?

Speaker 4: Violations.

Jeff Davis: Violations. All right. So this carrier's had some violations and according to the formula, they're over threshold. Okay. All right. Now we're going to look at their unsafe driving, their 84th percentile. So what we did when we analyzed this, we went through all their unsafe driving violations on their scorecard, and what we found is roughly 75% of their 219 drivers, about 205 drivers had zero or one. They had 151 drivers that had no unsafe driving events whatsoever. Then we went on to look about 4.6% had two unsafe driving, three and four hits within a 24-month period.

When we look at the unsafe driving points from there, what we see is almost 42% of all that 84 percentile, that alert was caused by these very few drivers. Point being what have we done for the 151? So we looked at the score, the score says they're alert. So the concept I'm trying to get through is, yes, they're alert according to this formula, good, bad, or indifferent, but at the same token, we have a ton of drivers, 151 that have had nothing. How'd we touch it? How'd we touch it, and this worked for 10, it worked for 15 trucks. I didn't really realize some of this until we started analyzing some of this data.

And that's what got me thinking about whether the glass is half full or the glass is half empty because I think if we spend more time working on the good, doesn't mean we can't work on the bad, more time catching drivers doing good, I think that's going to bring great results. Some people do the bonuses, I get that, but just a simple touch every day. So I challenge you, if you have drivers in your fleet and if you have any data to look at or your own internal data, no matter what that is, the way you calculate your safety bonus, whatever that may be, think and try to determine how many times you've touched that driver. That, to me, is part of building a safety culture.

And that, to me, is what recruits drivers and that, to me, is what retains drivers. Now obviously, you're going to run into some knuckleheads. All right. That's what the two before is for there. I'm all for that. I can play that game too, but I think this whole data management issue has pushed us into looking and spending our time with the bad guys. This is a perfect example. All right. When you really look at this motor carrier, 84 alert, 20 points, whatever that means over the threshold, they should be banned from hauling freight, but at the same time, they have 151, or actually, 75% of their drivers have one or less. Hey, a driver drives 14 hours a day or is a available 14 hours a day, five days a week, 48 weeks out of the year.

If that driver drives that much, shouldn't they be allowed one violation in a 24-month period? Yeah. Well, it happens to anybody. Any of you so perfect, I'll download your ECM in your car and we'll see what you're made of. That's not so much fun thinking about that, is it? All right. So can we live with one? Maybe we can, but when we get to two, three, four, and five, that's where the trend is. That's where the trends happen. So reward these guys, get our arms around these drivers. Really simple stuff. Sandwich the coaching, the touch in between a couple positives. Well, you're going to bring Fred in here and he hasn't done anything right in six months. Trust me, you got to find a couple positives in there to add the coaching to it.

You don't utilize telematics and visual wherever possible and why this is so important is if you're using performance metrics from an ELD or from a software system or from a camera, they don't lie in theory. Hey, Jeff, you've been speeding versus, hey, help me interpret this. What are we seeing here with the telematics? See the difference in that, and you're touching that driver with that data. So I think it's very important to get it away from personal observation into something they can put their hands on and then follow up and monitor after the coaching event. We have this big coaching event with the driver and then we throw them back in and we never check and see what's going on from there and repeat as required.

Todd DIlls: Search Jeff Davis' name at overdriveonline.com for more insights on audits and managing compliance generally, or get in touch with him directly via the website for his fleet safety services business. That's fleetsafetyservices.com.