In the first post in this series, I talked about the benefits of a consistent, reliable driver scoring system that lets you see drivers from the FMCSA’s perspective. In this post, we’ll look at the fourth problem a CSA driver scoring system needs to get right: Shadow Violations.
What are Shadow Violations? You can search the FMCSA website up and down and you will find no mention of shadow violations. That’s because “shadow violations” is a term Vigillo coined to explain a particularly concerning combination of safety events – inspections and violations – about which a safety professional should be knowledgeable.
Backing up a step – Vigillo has been providing motor carriers condensed easy-to-understand safety information since 2007. We were the first company to provide SafeStat scorecards and the first company to provide CSA scorecards. We’ve added many other products and services since then – because our customers are not shy (thank you!) about telling us what they need to solve a problem. Shadow violations are another example of transportation safety professionals identifying a problem and Vigillo using technology to provide an answer.
I’ll give you the quick definition of a shadow violation and then explain why it is such an important indicator.
Quick Definition: A shadow violation occurs when a driver has just one or two relevant inspections with one or more violations AND that driver has insufficient data to be given a percentile score in the same BASIC.
In other words, the driver’s CSA violation is hidden (or shadowed, get it?) by a score of insufficient data in the BASIC. Believe me – I understand that this may be confusing at first read. Let me give you an example to help:
Example: Let’s say you hire new driver Elvis Johannsen. In his first month, Elvis had one inspection with one Vehicle Maintenance violation and one Driver Fitness violation. According to the Driver Safety Measurement System portion of CSA (and Vigillo Driver scorecards), Elvis would have a score of “insufficient data” in the Vehicle Maintenance BASIC and the same “insufficient data” in the Driver Fitness BASIC. Why? Because according to the CSA rules, a driver must have at least 3 relevant inspections to be given a percentile score in most BASICs. If you prioritized your drivers for review based on high percentile scores in a BASIC, you’d skip Elvis entirely.
In his second month, Elvis has a second inspection and again has some trouble – this time serious trouble! He is written up for seven vehicle maintenance violations and two HazMat violations. You’d want to know about this new driver who after two inspections, appears to be having significant problems. What are his BASIC percentile scores in Vehicle Maintenance and HazMat? That’s right – “Insufficient Data.”
It’s not until Elvis’s third inspection when he would finally have percentile scores in these BASICs – and they would likely be very high scores indeed. Surprise!
What did we learn? That for some BASICs, it surprisingly takes until the third inspection to be given a percentile score. Violations in these BASICs are hidden in the shadow of the insufficient data score. Does this make sense in the real world? The FMCSA is probably concerned with having a reasonable quantity of data before providing a score. A safety director is likely more concerned with identifying new or inexperienced drivers who are having problems as early as possible. These two ideas conflict – and this is also where the benefit of identifying shadow violations comes into play.
Which BASICs can have Shadow Violations? This situation can occur in four of the seven BASICs. These four BASICs require at least three relevant inspections to be given a percentile score:
- Vehicle Maintenance BASIC
- HOS Compliance BASIC
- HazMat Compliance BASIC
- Driver Fitness BASIC
In these BASICs, a safety professional reviewing drivers by their percentile score is absolutely unaware of their drivers’ violations if the drivers have fewer than three relevant inspections.
How common is this situation? Very, very common. It is among the most frequent misunderstandings of the CSA system that I personally have heard from safety directors, terminals managers, drivers, and even industry professionals. It is from years of experience of Vigillo team members talking directly with folks in the trenches that the problem of shadow of violations became clear. Safety professionals have told us loudly and clearly that they especially want to know when new or inexperienced drivers have problems inspections as quickly as possible. Hard to argue with that, right?
Vigillo’s Daylight Driver Index™ (DDI) is the only driver ranking system on the market that identifies and includes shadow violation information in it’s driver scoring calculations. If you are Vigillo customer you have access to Vigillo DDI information right now. I encourage you to get a fresh cup of coffee and spend a few minutes reviewing your driver ranking under DDI. Feel free to contact me with comments or questions.
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In my final article in this series (coming soon), I’ll look at the next problems with scoring drivers – FMCSA’s (Changing) Priorities. You can also watch the video of a recent webinar of me discussing these same problems HERE.