In our previous post, we reviewed the FMCSA’s Compliance, Safety, and Accountability (CSA) system and how your scores can affect your insurance rates. Many transportation companies have designed incentive programs to keep their CSA scores low, and often giving drivers some type of reward for clean level one inspections while being penalized for certain violations.
However, in designing an incentive program, it’s important to consider the weights for violations, as the FMCSA does not treat all violations equally. The more severe a violation is, the greater the impact on your insurance rates. The FMCSA publishes this Violations List Severity Guide, and they updated it in April 2018 to reflect new ELD-related violations. Your safety team, dispatcher, operations, and senior management should familiarize themselves with the basics of violation severity weighting so that you discourage behaviors that cause more crashes and cost your company more money. Your driver safety and compliance program should also factor violations severity.
For example, let’s take a look at two violations related to a malfunctioning ELD device that have a very different impact on your Hours of Service (HOS) score:
- 395.34A1 – Failing to note malfunction that requires us of a paper log.
- 395.22H2 – Driver failed to maintain instruction sheet for ELD malfunction reporting requirements.
Both of the above examples require a driver to work with the inspector or trooper to show they understand what needs to occur when an ELD device malfunctions. However, failure to note a malfunction that requires the use of a paper log has a severity weight of five (5) versus one (1) for the instruction sheet violation. This severity weighting should factor into your ELD training program as well as any related safety incentive or reward programs. Perhaps, a driver would not lose their safety bonus for a violation with severity weight of 1 but may lose some or all of the bonus for violations weighted 5 or higher?
No matter your thoughts on the CSA program, it doesn’t appear to be going anywhere soon. Also, most insurance companies are directly factoring CSA scores into their insurance rating system. Educate yourself on all facets of your CSA scores, especially patterns of violations that increase your scores and insurance costs.
As always, the trucking insurance professionals at The Daniel & Henry Company are here to help you understand what measures you can take to reduce risk and insurance costs. Please call us today at 1-877-406-5915 or email us at RuebsamJ@danielandhenry.com