So…You read the title. How much is a clean inspection worth? What do you think? Some motor carriers have driver incentive programs: Get $50 for each clean inspection, for example. That is certainly one way to measure it. I am talking about something else though. Specifically, what is the impact of a clean inspection under CSA?
Vigillo has been helping transportation professionals better understand CSA since the first methodology was published in 2010. I’ll tell you some of the misconceptions I’ve heard. More importantly, let’s really unravel it. Let’s dig deep and lay out exactly what the effect (or non-effect in some cases) that a zero-defect inspection has on a motor carrier’s CSA score. The answers may surprise you.
Misconceptions about Clean Inspections
First, clean inspections are a somewhat complicated area within CSA so it does not surprise me that there are many different answers to this question. Here is just a brief list of differing explanations I have heard:
- Clean inspections don’t count at all
- Clean inspections wipe away violations a bit at a time
- Three clean inspections cancel out one violation
- Clean inspections dilute violations
- Clean inspections only count for some BASICs
- Clean inspections don’t exist
These can’t all be true, right? So misconceptions about clean inspections abound. Let’s start at the beginning and work our way through.
What Exactly is a Clean Inspection?
Let’s keep things nice and simple. In regular conversation, a clean inspection is simply an inspection that has no violations. Other names for clean inspections include “zero-defect inspections” and “no violation inspections.” Same thing.
How Common are Clean Inspections?
In a word – very. The FMCSA Analysis & Information Online website reports that for calendar year 2011, there were a total of 3,588,020 inspections conducted. Of these, 1,351,609 of these had no violations. That’s 38% of all inspections.
Two BASIC Examples
Here’s the thing – in terms of CSA points, you need to look at inspection points one BASIC at a time. The FMCSA evaluates each of the 7 BASICs separately and differently. There are different scoring rules, different calculations, etc. So let’s start by taking a look at two BASICs and see how they handle clean inspections (hint: very differently). Below, I’ll discuss the impact of clean inspections in Unsafe Driving and Driver Fitness.
Unsafe Driving BASIC
The key calculation in the Unsafe Driving BASIC determines a carrier’s BASIC measure. For Unsafe Driving, the calculation is below:
In very simplified language, this is your CSA Points divided by your number of power units. Any reference to number or type of inspections here? None whatsoever. By the way, “utilization factor” is only concerned with vehicle miles traveled and number of power units – so no connection to inspections there either.
Example: Let’s take a simplified example. Please note that I am not getting into all the complicating factors so that this is easier to understand. Let’s say a carrier has 150 violation points in this BASIC and has 50 power units (with no utilization factor bonus), that works out to be a BASIC measure of 150 divided by 50 which equals 3. To determine the percentile score of this carrier, all carriers in this same safety event group are then arranged high to low based on their BASIC measure and given a percentile. Got it?
Questions:Would anything be different if this carrier had zero clean inspections? How about 10? How about 100? The answer to all of these questions is that the BASIC measure would be unchanged and therefore the CSA percentile score in the Unsafe Driving BASIC is unchanged as well.
Conclusion: NO EFFECT. For purposes of the Unsafe Driving BASIC, Clean Inspections have absolutely no effect on a carrier’s CSA scores, such as BASIC measure or percentile. Furthermore, inspections that have violations – but no unsafe driving violations – have the same effect on the Unsafe Driving BASIC: that is, no effect at all. Hard to believe? You would not be the first to think so.
Fatigued Driving (HOS) BASIC
A motor carrier’s Fatigued Driving (HOS) BASIC score is determined primarily from this calculation:
In other words, take the total violations points (from fatigued driving / hours of service violations) and divide them by time-weighted relevant inspections. The key question then is: What the heck is a relevant inspection?
Relevant Inspection Defined. A relevant inspection in the Fatigued Driving BASIC is, according to the SMS Methodology version 2.2:
A Relevant Inspection is any Driver Inspection (Level 1, 2, 3, or 6), including those that do not result in a violation in the BASIC, or any other inspection resulting in an applicable BASIC violation
So what does that mean – especially in terms of a clean inspection? Well, it means that an inspection will count as long as it is either one of the following: (a) a driver inspection, meaning a level 1, 2, 3, or 6 inspection OR (b) the inspection included a fatigued driving violation. Since part (b) is by definition not a clean inspection we can forget about that part. However part (a) appears to include clean inspections as long as they are a level 1, 2, 3, or 6. So, a clean inspection will count in this BASIC. Fantastic! Even better, because the bad violation points on the top of the calculation (in the numerator) are divided or diluted by the inspections (in the denominator), clean relevant inspections clearly will help the carrier’s BASIC measure which improves the BASIC percentile.
How Much does a Clean Inspection Matter? Wait a second…It’s great that a clean inspection is included and can help the carrier’s score. Now the question is: how much does it count? Let’s look at a fictional motor carrier:
Let’s say Carrier A has 100 violation points in this BASIC. Next we divide that by time-weighted relevant inspections. Let’s say that number is 25. 100 divided by 25 equals 4 which would be the BASIC measure.
Let’s say Carrier A has added one more clean inspection that was a level 1 inspection. It definitely helps the carrier but by how much? the first question we have is what is the time weighting? Here’s how the time weighting works:
- Recent inspections from 0 – 6 months are triple weighted
- Inspections from 7-12 months are double weighted
- Older Inspections from 13-24 are single weighted
- Inspections older than 24 months are not included
The best case is that a new clean inspection is recent (within the last 6 months) so it therefore counts as 3 time-weighted inspection points. Using our example from above, this carrier would 100 violation points divided by 28 (25 +3) time-weighted inspection points, so the BASIC measure comes out to be 3.57 – better (lower) than the 4 it was previously! That is an improvement of 11% in the BASIC measure. Not bad, right?
The harder question is what is the percentile improvement due to this clean inspection? Unfortunately that is tougher to answer because the change is different in each safety event group. Remember the percentile is applied after all motor carriers are, in a sense, lined up against a wall and given a ranking best to worst. The percentile change will depend upon how many motor carriers you passed with this change.
Conclusion: Clean inspections DO have a positive effect on a carrier’s Fatigued Driving BASIC scores. How big an effect depends upon the recency of the clean inspection and the BASIC measures of the other carriers in the safety event group.
Two Categories of BASICs
So far we’ve seen one BASIC where clean inspections have no effect (Unsafe Driving) and one BASIC where clean inspections help the carrier’s CSA score (Fatigued Driving). It turns out that all remaining BASICs can be divided into these two categories – for exactly the reasons we saw in our two example BASICs above.
BASICs where Clean Inspections DO NOT CHANGE CSA Scores
Clean inspections have no effect on a carrier’s score in the following BASICs simply because the official calculation does not take into account any clean inspections:
-
Unsafe Driving
-
Crash
BASICs where Clean Inspections IMPROVE CSA Scores
For the BASICs listed below, clean inspections positively help a carrier’s score because the calculation used dilutes violation points by relevant inspections – including relevant clean inspections:
-
Fatigued Driving (HOS)
-
Driver Fitness
-
Controlled Substances / Alcohol
-
Vehicle Maintenance
-
Cargo-Related
-
HazMat (future)
Note that the FMCSA has announced that the Cargo-Related BASIC will be replaced by the HazMat BASIC in the last half of 2012. The SMS Methodology March 2012 version 3.0 Motor Carrier Preview shows that the HazMat BASIC is positively affected by clean inspections as well.
Wrapping Up:
I am hopeful this article can clear up some of the misconceptions about clean inspections and CSA. A few parting thoughts:
- Understand Clean Inspections: As a transportation safety professional, it makes sense to understand how this key federal safety initiative of CSA works. Inspections, both clean and not-so-clean, are an important part of it. Plus – you’ll look smarter, be more confident, and generally impress folks when you know what you are talking about!
- Unsafe / Crash: If your carrier is working to reduce Unsafe Driving or Crash BASIC scores, focusing on clean inspections may not be the most productive way to go about it since these BASICs do not consider clean inspections in their calculations.
- Value of Clean Inspections: One transportation safety professional I discussed this topic with put it something like this: Generally speaking, think about violations as costing you dollars while clean inspections give you back pennies.
- DataQs: Consider submitting DataQ challenges to get clean inspections counted if they did not get reported to the FMCSA. There is very little downside to this effort – especially if you have the documentation.
- Changes ahead! In the exciting world of CSA, there are always changes – changes to the methodology, to enforcement, to reporting. Vigillo works hard to keep our customers in the know for all of these changes.
I welcome your questions and comments. Thanks for reading!
Dear Sloan,
Nicely assembled and explained. Does CSA have an area about tire infractions? I have seen vehicle maintenance and nothing within that category.
Regards,
Noorez
Hi Noorez – Thanks! There are indeed tire-related violations in the CSA methodology. Below are several examples of tire-related violations in the SMS Methodology version 2.2. The last number listed is the severity weight of the violation.
VEHICLE MAINTENANCE
393.75 Tires/tubes (general) 8
393.75(a) Flat tire or fabric exposed 8
393.75(a)(1) Tire—ply or belt material exposed 8
393.75(a)(2) Tire—tread and/or sidewall separation 8
393.75(a)(3) Tire—flat and/or audible air leak 8
393.75(a)(4) Tire—cut exposing ply and/or belt material 8
393.75(b) Tire—front tread depth less than 4/32 of inch 8
393.75(c) Tire—other tread depth less than 2/32 of inch 8
393.75(d) Tire-bus regrooved/recap on front wheel 8
393.75(e) Tire – regrooved on front wheel of truck/truck-tractor 3
393.75(f) Tire-load weight rating/under inflated 3
393.75(f)(1) Weight carried exceeds tire load limit 3
393.75(f)(2) Tire underinflated 3
393.75(h) Tire underinflated 3
396.3A1T Tires (general) 8
CARGO
397.17 No tire examination on HM vehicle 2
I hope that is helpful.
Thanks – your article did clear some things up. But you didn’t touch on the level of inspection and how that has a effect on your score. Could you please comment on that or send me a email? We can’t seem to get any major inspections to offset our bad ones..
Robert- good question. I may be misunderstanding but I’ll do my best to answer the question I think you are asking. Here goes: Let’s start with violations and then move on to inspections.
Violations: A violations counts in a BASIC or it does not. If it does count, then the violation has both a severity weight and time weight. The worst possible violation is a 10 (in some case an out-of-service is an additional 2 points meaning 12 points total) multiplied by time weight which, at worst, is a 3. 3 X 12 = 36. This is the top number (numerator) in determining the BASIC measure.
Inspections: An Inspection either counts or does not count for a BASIC. This is based on either the inspection level (different for different BASICs) or the fact that a violation in the BASIC occurred. An inspection that does count is then time-weighted with recent inspections (last 6 months) given a 3. Time-weighted inspections are the bottom number (denominator) in the BASIC measure equation.
One of my points in the article is that clean inspections are helpful in many BASICs, but that violations far outweigh the impact of a clean inspection. I hope this is helpful. Let me know if there are more clarifying questions.
Thanks for your explanation of the impact of “Clean Inspections”. Is the impact of a “clean inspection” the same in the Vehicle Maintenance Basic as the Fatigued Driving Basic?
Thanks
Good question! The answer is that the impact of a clean inspection is different in different BASICs where a clean inspection has any impact at all. These BASICs are the five I mention in the blog post. Vehicle Maintenance and Fatigued Driving are both on this list.
On the one hand, if the clean inspection is of the inspection level that would make it a “relevant inspection” (defined in the article) then the clean inspections would benefit the carrier by adding to the bottom (denominator) of the BASIC measure equation. Remember, this is total of time- and severity-weighted points divided by time-weighted relevant inspections. So a recent clean inspection counts as 3 time-weighted relevant inspection points. This would improve both BASIC measures by the same amount (in one sense) but it would not necessarily improve both BASIC measure in terms of percentage change.
I know that is a bit complicated. The bottom line is to treat each BASIC completely separately. Remember that each BASIC is calculated completely independently of the other BASICs – they rely on different violations, severity weights, calculation, relevant inspections, etc.
Thank you for always providing helpful data and statistics. Is there a way to break down the 38% of clean inspections to show which segments of transportation are getting the most clean inspections? Dry van, flatbed, tanker, intermodal, straight trucks etc?
You are quite welcome. I wish there were an easy way to break down the 38% of clean inspection by segment – I can see how useful that would be! Indeed, if the FMCSA provided segment data along with its monthly census data, there is a lot of very interesting, very useful analysis we could do. Sadly, there is no easy way that I know of to do a further drill-down using segment data because the segment data is not something provided by the FMCSA. I’ll keep my eyes and ears open though. Suggestions from other readers?
Hi we are a small carrier with 3 trucks/trailers. We have a couple of alerts on our CSA some due to erroneous inspections that I have challenged but since the challenge was sent back to the issuing CMV inspector it was not reversed. (Had pictures to even back up our challenge) But now the inspector makes it frequent to step up on the truck while crossing the scale and ask to see logbook while checking seatbelt. Having no violations he sends the truck on down the road (We cross a local set of scales multiple times a day and same officer is asking for logs) having no documentation from the officer but clearly a driver inspection it is not helping our CSA score this has happen 7 times in the last year. Once he pulled driver up and called him back to scale did driver inspection released him with NO clean inspection, nothing even though no violations!
Hi Amber – Good for you for challenging erroneous information. In the current DataQs system, that’s nearly all you can do. On the topic of of inspectors not giving clean inspections – I can tell you that this is a hot topic. I was recently in Seattle at a CVSA conference where the law enforcement folks also expressed some frustration about inconsistent enforcement among states, including agreeing that additional training for law enforcement on actually writing up a clean inspection. There appears to be a lesser standard where an inspector can briefly review a vehicle (something short of a full official inspection) and send it on its way. It seemed to be that the gray area between a short review and an actual inspection is significant. I’ll keep my eyes and ears posted on this topic. Look for a post on this itme in the future.
Any updated numbers on the reasonable cause states number of violations versus other states? I recall reading a couple years ago about Vigillo noting the huge disparity between Indiana and Illinois.
Good question! Historically, we have indeed seen major differences between Indiana, the king of the reasonable cause states, and neighboring states such as Illinois. I don’t have updated information currently but I will keep my eyes and ears open for the future.
This is the most helpful article I have ever read as far as transportation links go. Thanks so much for actually putting it in terms that non CSA officials can understand.
I really appreciate your article as it does more to explain the scoring system than anything I have seen yet. I am in a world of trouble as we have practically zero in all fields but HOS and Veh Maintenance. HOS is borderline at 75% (with 75 pts too) and I just had a new driver get 3 bad write-ups on HOS. They are going to be high points because he was placed OOS on 2 of them and cited for one. I have ordered all drivers to get 5 good write-ups so we can try to keep our company. We are small, so I am not sure if that will cover it. If we go over 80% we will most likely have to go out of business. If a driver gets a good inspection and it is less than 6 months it is multiplied by 3? This confuses me, because we are at 75 points with 29 relevant inspections. If I multiple 29 by either 1, 2, or 3 depending on time then I get 48. 75 pts divided by 48 is 1.56. If the bad inspections we are waiting on equals 60 that takes us to 135 (75 + 60). If I got 13 good inspections and multiplied by 3 that is 39. So 135 divided by 87 (48 + 39) is 1.55. That means 13 good recent inspections gets me back to about the same number 1.56. Does that mean that I would stay at 75%? I am sure that it depends on other companies inspection info at that time, but shouldn’t it keep me close? I just am not sure I am doing this right. The confusing part is the amount of inspections. Also the other confusing part is levels of inspection. I am not sure which inspections were level 1, level 2, etc. When I came up with the number 48 I assumed that every inspection we have had involved a driver inspection making it relevant to our driver. I assumed this because I called all of my drivers to ensure that every time they were inspected logbooks were looked over. I hope I haven’t made this more confusing. I have even had other fairly smart people look over csa info and they could not figure the system out. You have been the most helpful, but I want to make sure I understand right because if I get 13 inspections and needed 20 then it was all for nothing as I watch my company fall.
Fantastic article. Thank you!