Roadside Inspections

1. Attention Attendees: • Thank you for attending! • The presentation will start in a few minutes at 1:00 PM Central. • Please use your computer speakers to listen to the event. If you have audio issues, dial-in info is below. • You will be muted during the event. • Please use the Question feature to text questions to “Q & A”. We’ll try to answer them during the Q&A period if they are not covered in the presentation. • The slides and recording will be posted within 7 days at: http://www.jjkeller.com/nptcinfo Roadside Inspections This webcast will cover ... The selection process, Inspection levels and procedures, The use of roadside inspection data, Kellogg’s Program, and Question & Answer Moderator Dr. Gary Petty, President & CEO, NPTC Panelists Tom Bray, Sr. Editor – Transportation Management, J. J. Keller & Associates, Inc. Tom Moore,CTP, Vice President of Education, NPTC Larry Cook,CTP, Sr. Mgr., DSD Fleet Safety & Compliance, Kellogg Company

2. Dr. Gary Petty President & CEO National Private Truck Council

3. Introduction • The Selection Process, Inspection Levels and Procedures – Tom Bray • The Use of Inspection Data – Tom Moore • Kellogg’s Program – Larry Cook • Housekeeping issues: • You will be muted during the event. • Please use the Question feature to text questions to the Q&A Panelist. We’ll try to answer them during the Q&A period if they are not covered in the presentation. • If you lose sound at any point, you can dial-in by phone using the number and Pass Code listed below. • If you lose the program window and need to re-loginbe sure to enter a different e-mail address to avoid being denied access for multiple logins. Gary Petty National Private Truck Council

4. Introduction and Disclaimers • Road Check is June 5-7 • The content in this webcast is intended for information purposes only and should not be construed as providing legal advice. • This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth. • We invite you to ask questions. We will answer them throughout today’s webcast. Gary Petty National Private Truck Council

5. Tom Bray Sr. Editor, Transportation Management J. J. Keller & Associates, Inc.

6. Goals of the Roadside Inspection Program • Direct attention to rules and regulations by requiring carrier safety and compliance • Document violations that are used in subsequent enforcement actions • Obtain information regarding carriers, drivers, vehicles, and cargo relative to safety and compliance • Support on-going assessment of carrier, driver, and vehicle • Remove unsafe carriers, drivers and vehicles from the highways Tom BrayJ. J. Keller & Associates, Inc.

7. Overview of Roadside Inspection Program • Roadside Inspections are a spot-check of driver and vehicle (“mini-compliance review”) • Inspections can occur anywhere and at anytime • Specially trained and certified inspectors conduct standardized roadside inspections • Any officer can “pull over a truck,” but only trained ones can conduct roadside inspections and submit report • The Commercial Vehicle Safety Alliance is an association that establishes and disseminates roadside inspection procedures, inspector training courses, and Out-of-Service Criteria Tom BrayJ. J. Keller & Associates, Inc.

8. Selection methods: Observation of a violation/defect Inspection Selection System (ISS) and other electronic screening programs Random selection Vehicle with valid CVSA sticker normally not selected for inspection (exception is observation of violation/defect) Roadside Inspection Selection Process Tom BrayJ. J. Keller & Associates, Inc.

9. The Roadside Inspection Process Tom BrayJ. J. Keller & Associates, Inc. • Conducted at fixed and mobile sites • Selection both random and risk-based, including traffic enforcement component • 3.5 to 4 million roadside inspections conducted per year • Inspection follows standard process • Average time to conduct: 15-60 minutes depending on level and violations discovered • Enforcement – Violations, warnings, citations, fines, • OOS orders, arrests and others • Data – Hard copies and Software; entry and upload

10. Level I — North American Standard Inspection Level II — Walk-Around Driver/Vehicle Inspection (same as Level I, except…) Level III — Driver-Credential Inspection Level IV — Special Inspections Level V — Vehicle-Only Inspection Level VI — Enhanced NAS Inspection for Radioactive Shipments Level VII — Jurisdiction Mandated Inspection Seven Levels of Roadside Inspection Tom BrayJ. J. Keller & Associates, Inc.

11. Inspecting Paperwork • Driver credentials and paperwork (DL/CDL logbook, supporting documents, medical certificate) • Carrier and vehicle credential documents (markings, IEP related paperwork, lease agreements, proof of annual inspection, IFTA, IRP, etc.) • Shipping papers (bills of lading, HM shipping etc.) Tom BrayJ. J. Keller & Associates, Inc.

12. Inspection Data Systems • ISS (Inspection Selection System) – Provides inspection recommendation & carrier snapshot with census and safety data • CDLIS, NCIC, NLETS – Retrieves driver status, conviction history, etc. • QC (Query Central) – Combines the functions of ISS & CDLIS Access, plus more • ASPEN (inspection software) – Collects inspection details, prepares report, and transmits data Tom BrayJ. J. Keller & Associates, Inc.

13. Outcomes • Three possible outcomes • No violations discovered • Roughly 66% of driver inspections have no violations • Roughly 33% of vehicle inspections have no violations • CVSA Decals are issued for passing a Level I or V inspection; good for 90 days • Violation(s) discovered, but driver and vehicle allowed to continue (corrections made ASAP) • Violations discovered and driver and/or vehicle placed out of service • 5.5% of drivers and 20.7% of vehicles inspected placed OOS Tom BrayJ. J. Keller & Associates, Inc.

14. 2011 “Top 10” Driver Violations Tom BrayJ. J. Keller & Associates, Inc.

15. 2011 “Top 10” Vehicle Violations Tom BrayJ. J. Keller & Associates, Inc.

16. What it is Safety violations that represent an imminent hazard Cannot continue to operate until repairs made and/or condition is fixed Driver, vehicle and load specific What it is not They ARE NOT maintenance or performance standards North American Standard Time tested process Legislated Case law established CVSA Out-of-Service Criteria Tom BrayJ. J. Keller & Associates, Inc.

17. Vehicle Out-of-Service Items • If violation is found, second question: Is the vehicle OOS? • Operating over hours or with false log • Brake System – #1 source of OOS; adjustment is a major issue; 20% of brakes defective to be OOS • Tires – #2 source of OOS; wear and exposed areas are major issues; 50% under-inflation to be OOS • Lighting – #3 source of OOS; #1 stop and #2 turn signal Tom BrayJ. J. Keller & Associates, Inc.

18. After a Roadside Inspection • Driver can hand deliver report to equipment owner if back within 24-hours, or fax/place in mail. • If vehicle passes a roadside inspection, a decal will be placed on the equipment (number, color, and cut establish month inspection took place). • If violations are found, equipment owner has 15 days to correct and return the report to the issuing agency. • Equipment will be tagged if found to be Out-Of-Service. Driver/vehicle cannot operate until issue corrected. Violating an OOS order carries severe penalties! • Equipment owner maintains a copy of the inspection for 12 months • Report data is loaded into SAFETYNET and MCMIS by officer Tom BrayJ. J. Keller & Associates, Inc.

19. ISS, Roadside Data, and BASICs Inspection Program: Roadside Data Tom BrayJ. J. Keller & Associates, Inc. ISS at Roadside Inspect Optional Pass • BASICs • Unsafe Driving • Fatigued (HOS) • Driver Fitness • Controlled • Substances/Alcohol • Vehicle Maintenance • Cargo Related • Crash SMS Results (percentiles) Investigation Results (serious violations)

20. Tom Moore, CTP Vice President of Education National Private Truck Council

21. Vehicle Repairs: $1 @ in-gate, $10 @ out-gate, $100 on the road Typical CVSA Out-Of-Service Order for vehicle defects lasts 8.6 hours Missed delivery, repairs, towing, re-dispatch, driver wages, fines, violations Shippers becoming sensitive to carrier CSA scores Inserting safety performance metrics in future contracts, lost loads Good drivers becoming more selective to the score of their carrier employers Insurance underwriters paying closer attention Performance-Based Inspection Program ROI Tom MooreNational Private Truck Council

22. §396.3 – “Every motor carrier and intermodal equipment provider must systematically inspect, repair, and maintain or cause to be systematically inspected, repaired, and maintained, all motor vehicles and intermodal equipment subject to their control” §396.17 – Periodic Inspection Requirement Minimum criteria set forth in Appendix G At least once a year, but is that often enough? §396.19 & 25 – Inspector Qualifications What are they? Carrier must have documentation for all internal staff and external vendors and their maintenance staff that work on your equipment §396. 21 – Period Inspection Recordkeeping Requirements “Systematically Inspect, Repair and Maintain” Tom MooreNational Private Truck Council

23. Inspector Qualifications Critical To High Quality, Uniform Inspections • Sourcing, recruiting, screening candidates • Pre-requisites for truck familiarityand operations, regulations and inspection procedures • Classroom and hands-on training • Proctored test to confirm knowledge • Inspector certification • Continuing education and re-certification • Inspection alerts and bulletins • Two-person inspection teams for quality control, safety and redundancy Tom MooreNational Private Truck Council

24. Prioritize Defects to Guide Maintenance & Repair • System, subsystem, component breakdown with predetermined defects • Brake stroke, tread depth measurements • ATA VMRS coding, digital photo, comments • CVSA OOS Criteria • Capture diagnostics codes from J-Bus/ECM • Recall for re-inspection Tom MooreNational Private Truck Council

25. How to Reduce Violations During Roadside Inspections • Train all drivers upon hire how to pre- and post-trip inspect their units and the roadside inspection process. • Expect what you can inspect. • Cross reference MCMIS data with DVIR’s, HOS and roadside inspection documents. • Present CSA SMS data to drivers, technicians and managers. • Audit DVIR’s to make sure service department is repairing defects and placing units back into service. • Provide drivers with repair kits and teach them how to use them Tom MooreNational Private Truck Council

26. Larry Cook, CTP Sr. Mgr., DSD Fleet Safety & Compliance Kellogg Company

27. Kellogg Fleet Operations • Fleet consists of : • 800 Power Units • 1,200 Trailers • 1,200 CDL Drivers • 42 Distribution Centers • 35 million miles Larry CookKellogg Company

28. How Roadside Inspections are Used by FMCSA • Date/Time stamp of activity • Supporting document to check against yours • They know the answer to the question before they ask it Larry CookKellogg Company

29. Results of a Poor Pre/Post Trip • Operating with defective equipment • Endangering public and employee • Increased CSA scores and scrutiny • Subject to citation • Subject to litigation Larry CookKellogg Company

30. Crash Investigation Larry CookKellogg Company

31. Prevention Begins • Maintenance Vendor/In-house • FMCSA compliant • CSA knowledge • Mechanic qualifications and performance checks • Yearly review Larry CookKellogg Company

32. Management Training • Hiring CTP’s • Vehicle nomenclature • How to perform proper pre- and post-trip inspections • Understanding the North American Standard Out-of-Service Criteria--give them the book! Larry CookKellogg Company

33. Driver Training • DVIR Training – Is documentation complete? • Training Video – Yearly training to include on-the-job training • Work with and ride along • Gate Check • CSA Knowledge Larry CookKellogg Company

34. Company Vehicle Inspection Video • In-house • Our employees • Our equipment • Peer-to-peer instruction • Minimal investment Larry CookKellogg Company

35. Interventions and Coaching • Build a culture of safety by engaging drivers/repair techs in the process of defect identification and hazard perception • Routine training and follow-up coaching • Process • Take pictures of defects • Ask drivers/maintenance techs to identify defects • If identified, ask driver/maintenance why it wasn’t noted on DVIR Larry CookKellogg Company

36. Brake Lining Failure Larry CookKellogg Company

37. Tread Depth and Uneven Wear Larry CookKellogg Company

38. Air Hose Chafing Larry CookKellogg Company

39. Improper Frame Crack Repair Larry CookKellogg Company

40. Driver Gate Checks Larry CookKellogg Company

41. Keys to Reducing Our CSA Score • Vendor certification • Management training • Driver training • Roadside inspection follow-up • Root cause analysis • Coaching • Ride-alongs Larry CookKellogg Company

42. Question & Answer Please submit questions to“QA” using the Questions tool Larry CookKellogg Company Tom BrayJ. J. Keller & Associates, Inc. Tom MooreNational Private Truck Council Gary Petty National Private Truck Council

43. Closing Remarks • Checkout the archive of past topics at: http://www.jjkeller.com/nptcinfo • PowerPoint slides and recording up in 1 week • Topics for 2012: • July 11 – Improving Fleet Productivity Through Quality and Lean Initiatives • October 3 – Effective Motor Carrier Safety Training Programs Gary Petty National Private Truck Council