Here is a very interesting set of timely questions (and answers!) about inspections, ISS scores, and related topics provided by our colleagues at the Wisconsin Motor Carriers Association and Pre-Pass – Many thanks!

Here are the questions:

1. How does PrePass evaluate a carrier’s safety information?
2. Why is PrePass using CSA?
3. What if I have questions/concerns with CSA?
4. What is my pull-in rate and ISS score?
5.  Where can I view my ISS score?
6.  How did PrePass get access to my ISS score?
7.  How long does a violation stay on “record”?
8.  What if my company just received a satisfactory compliance review (CR)? Will that affect my ISS score?
9.  If the data that is feeding my ISS score is incorrect, who do I talk to about correcting it?
10. What happens to my PrePass service if my pull-in rate is now 100%?
11. How will my inactive account status affect my billing?
12. How do I improve my percentile ranks in the Behavior Analysis and Safety Improvement Categories (BASICs)?
13. What can a motor carrier do to improve?
14. Do inspections that find no violations count?
15. How often is PrePass checking ISS?
16. What if my ISS score on the FMCSA portal is different from your records?


Read on for the answers (updated as of 7/29/2011)…

1.  Question: How does PrePass evaluate a carrier’s safety information?

Answer: Recently, the Federal Motor Carrier Safety Administration (FMCSA) launched a new safety initiative called Compliance, Safety, Accountability (CSA) to further reduce commercial motor vehicle (CMV) crashes, fatalities and injuries on our nation’s highways. As a result of this initiative, PrePass will now be evaluating a carrier’s safety eligibility using data from the seven Behavior Analysis and Safety Improvement Categories (BASICs) listed below. This data is used to produce an Inspection Selection System (ISS) score that helps roadside officers in determining whether or not to inspect a vehicle.

  • Unsafe Driving BASIC — Operation of commercial motor vehicles (CMVs) in a dangerous or careless manner. Example violations: speeding, reckless driving, improper lane change, and inattention. (FMCSR Parts 392 and 397)
  • Fatigued Driving (Hours-of-Service) BASIC — Operation of CMVs by drivers who are ill, fatigued, or in non-compliance with the Hours-of-Service (HOS) regulations. Example violations: exceeding HOS, maintaining an incomplete or inaccurate logbook, and operating a CMV while ill or fatigued. (FMCSR Parts 392 and 395)
  • Driver Fitness BASIC — Operation of CMVs by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualifications. Example violations: failing to have a valid and appropriate commercial driver’s license and being medically unqualified to operate a CMV. (FMCSR Parts 383 and 391)
  • Controlled Substances and Alcohol BASIC — Operation of CMVs by drivers who are impaired due to alcohol, illegal drugs, and misuse of prescription or over-the-counter medications. Example violations: use or possession of controlled substances or alcohol. (FMCSR Parts 382 and 392)
  • Vehicle Maintenance BASIC — Failure to properly maintain a CMV. Example violations: brakes, lights, and other mechanical defects, and failure to make required repairs. (FMCSR Parts 393 and
  • Cargo-Related BASIC — Failure to properly prevent shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials on a CMV. Example violations: improper load securement, cargo retention, and hazardous material handling. (FMCSR Parts 392, 393, 397 and applicable DOT HM regulations)
  • Crash Indicator — CSA evaluates a motor carrier’s crash history. Crash history is not specifically a behavior. Rather, it is a consequence of a behavior and may indicate a problem with the carrier that warrants intervention. It is based on information from State-reported crash reports and identifies histories or patterns of high crash involvement, including frequency and severity.

2.  Question: Why is PrePass using CSA?

Answer: The states have been directed by FMCSA to use the data from CSA. To be consistent, the states have asked PrePass to use the same criteria.

3.  Question: What if I have questions/concerns with CSA?

Answer: You should direct your concerns to your safety manager, local Trucking Association or the FMCSA. Attached is a list of each state’s trucking association and phone number. We also have a consultant, Duane Henn, who can help answer questions as well. He can be reached at 417-699-5200.

4. Question: What is my pull-in rate and ISS score?

Answer: Please reference the chart below for the pull-in rate for your vehicle(s) based on your ISS score. The pull-in rate for DE, MI, NE and WY will be in effect 8/5/11.

 

5.  Question: Where can I view my ISS score?

Answer: A carrier’s ISS score can be viewed by logging onto the FMCSA’s portal at https://portal.fmcsa.dot.gov. Here is a screenshot of what the carrier sees on thportal (PrePass does not have access to the portal; we receive the information through our CVIEW):

 

6.  Question: How did PrePass get access to my ISS score?

Answer: PrePass works on behalf of the states, and we were given permission by the states to access each carrier’s ISS score. However, we only use the data for screening purposes, and we do not sell or use the data for other purposes.

7.  Question: How long does a violation stay on “record”?

Answer: Violations stay on record for 24 months. Serious violations within 12 months carry more weight. These include:

  • Those violations where noncompliance is so severe that they require a motor carrier’s immediate corrective action, regardless of its overall safety posture (e.g., failing to implement an alcohol and/or controlled substance testing program).
  • Or, those violations that relate directly to the carrier’s management and/or operational controls and are indicative of breakdowns in a carrier’s management controls (pattern of violations, e.g., false reports of records of duty status).

If a driver asks about 36 months of data, this is the answer: There is another system called DSMS (Driver Safety Measurement System) which is a component of CSA. The DSMS is a tool that enables law enforcement personnel to assess individual drivers in the Behavior Analysis and Safety Improvement Categories (BASICs) using 36 months of roadside performance data across employers. At this time, the Federal Motor Carrier Safety Administration (FMCSA) does not use this system to assign formal safety ratings or Safety Fitness Determinations (SFDs) to individual drivers. FMCSA does not remove any drivers from their job; only the State can do that. DSMS does not impact a driver’s commercial driver’s license (CDL). Neither drivers nor employing motor carriers have access to the DSMS. FMCSA does not address drivers the same way it addresses carriers today, nor will it under CSA. While carriers are prioritized for intervention based on CSA, drivers are only investigated during a carrier investigation. Therefore, no Intervention Thresholds are in place for drivers.

8.  Question: What if my company just received a satisfactory compliance review (CR)? Will that affect my ISS score?

Answer: Compliance review results will help a carrier’s evaluation only if their problems were based on prior CR violations. CR results have no influence on improving prior roadside performance data.

9.  Question: If the data that is feeding my ISS score is incorrect, who do I talk to about correcting it?

Answer: You can go to https://dataqs.fmcsa.dot.gov/login.asp to challenge the data. A login and password are required.

10. Question: What happens to my PrePass service if my pull-in rate is now 100%?

Answer: If your pull-in rate is at 100%, your account will be placed in an inactive status and your drivers will receive red lights. Your account will be reactivated automatically once your safety improves and you will not be charged while it is inactive.

11. Question: How will my inactive account status affect my billing?

Answer: PrePass service is billed in arrears; you will therefore be billed next month if your account was eligible for bypassing this month.

12. Question: How do I improve my percentile ranks in the Behavior Analysis and Safety Improvement Categories (BASICs)?

Answer: Receiving new inspections that are free of violations in an applicable BASIC will improve a carrier’s percentile rank for Fatigued Driving (Hours-Of-Service), Driver Fitness, Controlled Substance/Alcohol, Vehicle Maintenance, and Cargo-Related BASICs. Carriers should also review the “What can a motor carrier do to improve?” section on the FMCSA website (http://ai.fmcsa.dot.gov/SMS/InfoCenter/ Default.aspx). This section provides tips that may help carriers who want to improve their safety performance. There are numerous tips that will help carriers improve their percentile ranks and help drivers avoid crashes and violations.

13. Question: What can a motor carrier do to improve?

Answer:

  1. Ensure compliance by being knowledgeable of the Federal Motor Carrier Safety Regulations (FMCSRs) and the Hazardous Materials (HM) Regulations, if applicable.
  2. Understand how your safety management contributes to your safety problems.
  3. Check and update your MCS—150 carrier registration information whenever there is a change to your company’s profile and at least every two years, as is required by regulation.
  4. Review your inspection and crash reports data and request corrections as needed.
  5. Educate yourself and your employees on the regulations and industry best practices.

14. Question: Do inspections that find no violations count?

Answer: Yes. All roadside safety inspection findings count, regardless of whether or not the safety inspection report contains violations. Roughly one-third of the 3.5 million inspections that are uploaded to the Federal Motor Carrier Safety Administration’s (FMCSA) database each year have zero violations. Safety inspections without regulatory violations serve to improve a motor carrier’s evaluation.

Carriers and drivers should be aware that not every law enforcement stop is a safety inspection; law enforcement may stop a vehicle to conduct a pre-inspection screening to determine if a vehicle or driver warrants closer examination. A pre-inspection screening may take many forms and may include, but not necessarily be limited to, a cursory check of the vehicle. These cursory checks are commonly confused with a complete safety inspection. If a law enforcement officer conducts only a pre-inspection screening, then a safety inspection report will not be generated. If a driver feels that a safety inspection has been conducted, FMCSA encourages the driver or motor carrier to ask for a copy of the report to document the safety inspection.

15. Question: How often is PrePass checking ISS?

Answer: We check each carrier’s ISS score monthly.

16. Question: What if my ISS score on the FMCSA portal is different from your records?

Answer: The information needs to be sent to the safety leads (Yesenia Villa, Joe Soliz and Kelley White), and they will put in a safety override. Call can be transferred or HDA ticket created by sending email to prepassaccountmanagers@acs-inc.com.