January 13, 2023
One of the keys to controlling your costs is CSA Scores! How are CSA scores linked so intricately with cost control? Elevated CSA scores can increase insurance rates, prompt an FMCSA intervention – thus resulting in a potential Conditional or Unsatisfactory rating, adversely affect shipper, receiver & freight broker relationships, and also give any plaintiff unneeded ammunition for a punitive damage claim.
HOW DO YOU CONTROL YOUR CSA SCORES?
Given this, the next question is, how do you control your CSA Scores? Interestingly, you control your CSA scores in the same manner in which you would control insurance costs,
- Prevention – You cannot add CSA points if you have no adverse roadside violations & DOT crashes, just like you cannot have insurance losses without claims.
- Time – CSA points remain for two years, just like insurance claims remain until they are closed.
- Management – You can mitigate the severity of adverse inspections via DataQs whereas you can also manage insurance claims, thus reducing the overall severity over time.
DID YOU KNOW?
- 49 CFR 395.15 is the regulation for Automatic On-Board Recorders (AOBRDs) and 49 CFR 395.20 to 49 CFR 395.38 are the regulations for Electronic Logging Devices (ELDs).
- Many Inspectors are improperly enforcing AOBRDs as ELDs
- Two key guidance questions have been published to assist in fighting ELD cited violations when you actually have ABORDs
Question: May a motor carrier that installed and required its drivers to use an AOBRD before December 18, 2017, install and use a registered ELD-capable device that runs compliant AOBRD software after that date?
Answer: Yes, until December 16, 2019
Question: What will be the enforcement procedures for “grandfathered” automatic onboard recording devices (AOBRDs) and electronic logging devices (ELD) during the two-year period following the compliance date of the ELD rule?
Answer: During the period when both “grandfathered” AOBRDs and ELDs will be used (December 18, 2017 to December 16, 2019), authorized safety officials will enforce ELD rule requirements for ELDs and the requirements in 49 CFR 395.15 for “grandfathered” AOBRDs …
Basically, this means you should not be cited for 49 CFR 395.20 to 395.38 until December 16, 2019 if you are legally “grandfathered” operating AOBRDs and should be using the DataQ option to challenge these. When collecting evidence to prove you are “grandfathered” make sure you have a copy of an AOBRD log dated prior to December 18, 2017 to show you installed AOBRDs and used them before this date.
This is one example of when a DataQ can be used, but there are MANY more!
John Seidl, VP of Risk Management (262-672-0986) at Reliance Partners is the author of this article can be contacted if you wish to have more guidance on DataQs, insurance, or any other DOT related matter. You can also complete the form above.