DOT Auditors Might Assume All Crashes On Record Were “Preventable”
posted in Alerts by Brian Gray
DOT Auditors Might Assume All Crashes On Record Were “Preventable”
Does Your Fleet Have Crashes Affecting Your CSA Score When It Shouldn’t?
Too many motor carriers do not have the time or resources to make sense of their CSA data. This is why fleets end up not knowing that non-preventable crashes are harming their CSA scores.
The FMCSA’s Comprehensive Safety Analysis (CSA) guarantees most every motor carrier will be scrutinized for safety compliance on a monthly basis. With scrutiny adds to your chances of being audited.
We at Glostone Trucking Solutions (and now our friends at CleanFleet) help hundreds of fleets with audit prep, post audit SMP and CAP plans, and work closely with official auditors. This give our staff detailed insight in what auditors are looking for, assumptions that are made, and how those assumptions might hurt many motor carriers if they are not well prepared for the audit.
Assumption: DOT Auditors Might Assume All Crashes On Record Were “Preventable”
We have heard situations during an audit where a carrier failed one of the seven BASIC categories because they failed to mention that a crash or crashes on their record were non-preventable, assuming that the auditor would bring it up in the audit.
Often the auditor does not bring it up because they assumed the crashes were preventable or that the carrier would bring up the crash detail to the auditor.
According to the FMCSA website:
All reportable accidents over the last 24 months, regardless of the role of the carrier or driver, are considered in FMCSA’s Safety Management System (SMS) and used to calculate a Crash Indicator measure.
SMS does not weight a crash differently based on the role of the carrier or driver, though it does weight crashes based on severity. The State-reported crash data used in the SMS does not list or factor in fault or preventability. In the case of the Crash Indicator measure, the carrier’s crash rates are being compared to other carriers’ crash rates. A high Crash Indicator percentile suggests that a further examination of cause is needed, and if correctable, the motor carrier should make changes to address the problem.
If a carrier believes any part of its SMS data is incorrect, including crash data, it can submit a Request for Data Review through FMCSA’s DataQs Website.
Carriers Disputing Crash Fault In CSA Scores Planned To Be Made Permanent
Under a two year pilot program, which is ending in July, the FMCSA is accepting Requests for Data Review (RDRs) in its DataQs system for certain crashes. So, if a crash is found to be not preventable, a carrier’s private Crash Indicator Behavioral Analysis Safety Improvement Category, or BASIC, score would be recalculated with the crash omitted.
Based on positive feedback from industry stakeholders, the FMCSA will propose to make this demonstration program permanent and to begin immediately after the pilot program ends.
The FMCSA will accept the following eight crash types for review:
- When a truck was struck by a driver under the influence or a related offense
- When a truck was struck by a motorist driving in the wrong direction
- When a truck was hit in the rear
- When a truck was hit while legally stopped or parked
- When a pedestrian or car drives in front of a truck in an attempt to commit suicide by truck
- When a truck sustains disabling damage after hitting an animal in the road
- When a crash is caused by an infrastructure failure or falling trees, rocks or other debris
- When a truck is hit by cargo or equipment from another vehicle
The DataQ system is used to fix incorrect or duplicated information in the Federal MCMIS database. This is the system that generates your safety measurement system scores for public viewing, as well as the database for a driver’s “Pre-Employment Screening Program” and a motor carriers audit results.
Actively managing your safety measurement system (SMS) scores is crucial to the success of Motor Carriers. The “SMS” will only become more central to the FMCSA’s enforcement strategy as we move forward and will determine your DOT safety rating based off of your SMS scores and inspection data so it is more important than ever to make sure the data in the system is accurate and appropriate for your company.
Preparing for the Audit: The DOT Accident File or Accident Register
The Federal Motor Carrier Safety Regulation 49 Part 390.15 requires that all motor carriers maintain an accident register and accident files (copies of the crash reports) on all “DOT reportable” accidents, for a period of three years from the date of each accident.
*Tip: Prepare Paperwork for the Audit: Before the auditor arrives, it’s important to have all the necessary paperwork ready to go. If you are prepared for the audit, the process will run smoother and will be less stressful.
An “accident” is defined in Part 390.5 as:
- A fatality;
- Bodily injury to a person who, as a result of the
injury, immediately receives medical treatment
away from the scene of the accident; or - One or more motor vehicles incurring disabling
damageas a result of the accident, requiring the
motor vehicle(s) to be transported away from the
scene by a tow truck or other motor vehicle.
Required information on the register:
- Date of accident
- City or town, or most near, where the accident occurred and the State where the accident occurred
- Driver Name
- Number of injuries
- Number of fatalities
- Whether hazardous materials, other than fuel spilled from the fuel tanks of motor vehicle involved in the accident were released.
Motor carriers should maintain two accident registers (for the calendar year) in order to limit information in an audit situation, yet still provide the big picture to effectively analyze all incidents and accidents:
- DOT recordable accidents only register;
- Non-DOT recordable accidents register.
Accident registers may be kept electronically— if you can print a hard copy for the FMCSA upon request.
* Tip: At least have a State Police or Highway Patrol accident report in file for each collision. The DOT may check this against your Loss Run record.
If you never had a reportable accident, then create the accident register form and write “None” on the form.
Want Help With This Whole Process?
Take advantage of the DataQ system and make sure your records are fair and accurate! Glostone can do this for you so you can focus on what you do best. Contacts our expert staff today at 503-607-1088.
To protect yourself in the future, visit the FMCSA website weekly to check for any changes in your company’s status. Requesting a certified Driving History Report (MVR) every 90 days to 6 months is another good way to stay informed and be aware of any complaints or violations moving forward.
CleanFleet provides Mock Audits, Safety Rating Upgrades and Corrective Action Plans (CAP), and complete Safety, while Glostone provides Licensing, and Fuel Tax Management.
