[NOTE: From time to time, Vigillo requests guest articles from recognized industry experts. We are pleased to have the following post from Annette Sandberg, former FMCSA administrator and current CEO of TransSafe Consulting LLC. ]
Now that the CSA Safety Measurement scores have been live for a month many carriers, shippers and brokers are still getting used to the new format and scoring changes. As brokers and shippers continue to grapple with the best way to use the data—many carriers are realizing the importance of the data and their scores as they relate to other motor carriers.
One of the most critical tasks a carrier should perform is a careful analysis of the data. Since CSA uses all data generated from roadside inspections it is important for carrier management to look for root causes. Careful data analysis will help a carrier find ways to improve their processes and policies and in turn address potential safety and regulatory concerns. Many carriers I have worked with are doing exactly that. They pull the data on a monthly basis and evaluate it to look for consistent issues. For many carriers the data will clearly point to one or two issues the company needs to address.
Another reason for the careful review of the data is to ensure all data uploaded to your DOT number is truly yours. Many carriers are finding incorrect or improperly reported violations. If you find that data has been reported improperly it is important to challenge the data through the DataQ process. DO NOT WAIT. The longer you wait to challenge improper data the more difficult it becomes to gather relevant facts necessary to sustain the challenge.
Another important factor to remember is to provide as much documentation as possible with the challenge. In many cases this means attaching additional letters, documents, and other relevant information to help the state data quality reviewer understand the challenge. Lastly, know how each violation is scored. Sometimes roadside officers may code a particular violation incorrectly—this may result in a higher point value being assigned to the violation. If this occurs—challenge the violation and provide in the challenge the proper violation coding. Again provide any additional documentation that may be necessary to support your claim.
Here is an example of a potential challenge: A driver is cited roadside for speeding (392.2S). This violation is a 5-point violation. The driver was given a written warning from the officer showing the driver in fact was going 1-5 miles per hour over the speed limit. The challenge should request the violation be changed to “Speeding 1” (392.2SSLS1), as this is only a 1-point violation. This would remove 4 points for this violation. Attach a copy of the written warning showing the officer’s notes to support the challenge.
Once a carrier establishes a process for reviewing data every month it becomes much easier to identify problems and trends and keep the carrier one step ahead of the problem. It is also helpful during a focused review from the FMCSA or State Enforcement officers, if the carrier can show they have a regular process for reviewing and addressing the data in a timely manner.