CSA and truck tires
If you spend any time with fleets, you’ve probably heard about the CSA program, or Compliance, Safety, Accountability. CSA is the new initiative from the Federal Motor Carrier Safety Administration (FMCSA) to measure the on-road safety performance of carriers and drivers. Unlike the old SafeStat system that was based on out-of-service violations, crash reports and certain moving violations, CSA uses data gathered from all roadside inspections to assign a Safety Management System (SMS) score in seven different BASIC areas. BASIC stands for the following Behavior Analysis and Safety Improvement Categories:
* Unsafe driving, which is focused on things like speeding, reckless driving, improper lane change and inattention.
* Fatigued driving, which centers on hours-of-service violations and incomplete or inaccurate log books.
* Driver fitness, which addresses the lack of training, medical cards or experience.
* Controlled substances/alcohol, which covers the use or possession of drugs and/or alcohol including prescription medication.
* Vehicle maintenance, which is focused on the inspection criteria outlined by FMCSR Parts 393 and 396.
* Cargo-related, which looks at improperly secured, overloaded or spilled cargo.
* Crash indicator, which is based on the history that includes frequency and severity.
The ultimate goal of CSA, SMS and the BASIC areas is to reduce the number of commercial motor vehicle (CMV) accidents on our nation’s highways. By assigning a score in each BASIC, enforcement officials get a much clearer picture of the overall safety performance of the fleet. Additionally, the drivers are also given an SMS score, and while it cannot be used to revoke a commercial drivers license (CDL), it can have a detrimental effect on future employability if the scores are poor.
In a nutshell, there is no place for a deficient fleet or driver to hide under CSA, which means both parties have a vested interest in operating vehicles safely.
Each BASIC category includes a series of violations that are assigned a severity rating that ranges from one to 10 with 10 being the most severe. Again, it’s important to recognize that CSA is designed to reduce accidents, so the FMCSA has determined that the 10-point violations are the most likely to result in a CMV crash. Here are some examples of violations that result in 10 points:
* Reckless driving.
* Speeding 15 mph over the posted limit.
* Speeding in a construction zone.
* Operating a CMV while texting.
* Driving after being declared out-of-service.
* Driver uses or is in possession of drugs.
* Release of hazardous material from a package or container.
* Package not secured in the vehicle.
As you can see, most of the 10-point violations are directly related to and/or under the control of the driver. Under the old SafeStat system, most of these offenses would not have resulted in any penalties unless there was an accident. With CSA, every moving violation and inspection that takes place on the side of the road or at a weigh station has the potential for serious consequences for the driver/fleet that is operating a vehicle in an unsafe manner/condition or transporting cargo that is not properly secured.
While the vehicle maintenance BASIC is the only one of the seven categories that is more or less under the direct control of the carrier, drivers are still responsible for conducting the inspections using the criteria in Federal Motor Carrier Safety Regulation (FMCSR) Parts 393, 396 and Appendix G to Subchapter B which covers the Minimum Periodic Inspection Standards for new tires and retreads. For a complete listing of these inspection guidelines, visit the rules and regulations sections of the website www.fmcsa.dot.gov.
Another important point that must be made when discussing the changes that are associated with CSA is the fact that every vehicle maintenance violation stays with the fleet for a period of 24 months.
Like I said before, there is no place to hide under this new program, so a fleet that historically operates poorly maintained equipment has virtually no hope to improve its SMS scores unless it makes significant changes to its maintenance program. And since the SMS score is a percentile that ranks the fleets in comparison to other carriers of similar size, it will take months (if not years) of clean inspections for a carrier to noticeably reduce its score.
The most severe tire violations are assessed eight points because FMCSR has determined that they are more likely to lead to a CMV accident. The eight-point violations are as follows:
* Flat tire or fabric exposed.
* Ply or belt material exposed.
* Tread and/or sidewall separation.
* Flat tire and/or audible air leak.
* Cut exposing ply and/or belt material.
* Steer tire tread depth less than 4/32-inch.
* Drive, trailer, dolly tread depth less than 2/32-inch.
* Bus tire regrooved/retreaded on front axle.
Unfortunately, neither FMCSR nor CSA specifically defines any of the violations so one enforcement officer’s definition of a flat tire may differ from another. The Commercial Vehicle Safety Alliance (CVSA) is the organization that sets the North American standard out-of-service criteria and they occasionally refer to FMCSA regulations.
The 2011 handbook states, “FMCSR code references... are simply recommendations to help inspectors find an appropriate citation.” CVSA does not use the term “flat tire,” but the handbook does reference FMCSR 393.75(a)(3) which simply says, “No motor vehicle shall be operated on any tire that is flat or has an audible leak.”
The CVSA criteria that refers to this regulation identifies an out-of-service tire as one that, “has noticeable (e.g. can be heard or felt) leak, or has 50% or less of the maximum inflation pressure marked on the tire sidewall.”
Making matters even more complicated is the fact that this verbiage appears in the CVSA handbook immediately following the 50% rule, “NOTE: Measure tire air pressure only if there is evidence the tire is under-inflated.”
[PAGEBREAK]Of course, the guidelines for evidence of under inflation are also completely subjective, so an officer can pull out the old boot-o-meter and use it to establish probable cause for a pressure check. The bottom line is that the generally accepted definition of a flat tire is 50% or less of the maximum inflation molded on the sidewall regardless of the load being carried.
But the confusion and vague nature surrounding tire violations do not stop with the eight-point flat tire condition. Here are the three-point tire violations:
* Regrooved tire on front axle.
* Tire load weight rating /under-inflated.
* Weight carried exceeds tire load limit.
* Tire under-inflated.
Like flat tires in the eight-point category, the three-point under-inflated tires are equally undefined. This becomes particularly troublesome for fleets that run inflation pressures that are lower than the maximum limits molded on the sidewalls of the tires.
Technically, a CMV cannot carry more than 20,000 pounds on an axle and no more than 34,000 pounds on tandem axles. According to the Tire and Rim Association (TRA) Yearbook, a 295/75R22.5 Load Range G tire in a dual application can carry 4,300 pounds at 75 psi, which is sufficient to carry the maximum allowable weight of 4,250 pounds per tire in a tandem application. That same Load Range G tire has a maximum load of 5,675 pounds at 110 psi.
So using the CVSA and FMCSR definitions, a tire would be unable to support the load below 75 psi and becomes flat at 55 psi. Change the vehicle to a single axle and the minimum inflation pressure for the maximum load becomes 95 psi while the flat pressure of 55 psi does not change. Confused? You haven’t seen anything yet!
In another example, if a cut in the tire or retread does not visibly expose the ply material but after probing the cut with an awl the officer discovers that steel is still technically exposed, is that still eight points against the fleet and driver? This should ultimately result in the increase of spot and reinforcement repairs as fleets attempt to limit the number of tire-related violations.
And does a small void or crack at the edge of the bond line on a precure retread constitute a tread separation? Without specific definitions of “exposed” or “separation,” it’s reasonable to assume that some enforcement officials will just assess the eight points even though the industry would not consider something that is minor or cosmetic to be a major safety hazard. Precure retreaders will have to be more careful than ever during final inspection because even the slightest imperfection at the bond line may be enough for an officer to issue a citation.
Another issue that must be addressed is the “pencil bulge” that can occur in the sidewall as the result of a puncture repair.
While the industry is getting closer to releasing guidelines for reinforced shoulder repairs, will commercial tire dealers be creating more problems for their customers when these properly installed repairs result in a small sidewall bulge that the aggressive officer defines as a sidewall separation?
CVSA references 393.75(a)(2) when it identifies an out-of-service tire as, “Any tire with visually observable bump or knot apparently related to tread or sidewall separation.”
Then the following verbiage appears in the 2011 handbook, “EXCEPTION: A bulge (due to a repair) of up to 3/8-inch (9.5 mm) in height is allowed. The bulge may sometimes be identified by a blue triangular label in the immediate vicinity.” Vulcanizing these blue triangles on the sidewall is not commonplace in the truck tire repair industry, but I believe that they are more important than ever now that CSA has changed the rules for drivers and fleets.
Additionally, since the repair technician cannot determine if a puncture repair will result in a sidewall bulge, the best practice may be to install blue triangles on both sidewalls in the area of every repair just in case. After all, a sidewall bulge associated with a section repair is relatively easy to identify as opposed to a standard “plug and patch” that may not be visible to the average person.
Education is the solution
CSA is not necessarily going to change the procedures for retreading and repairing tires. But it is already changing the way that tires and retreads are inspected after they are placed in service.
Minor cosmetic issues that were overlooked in the past have become much more important under the new SMS.
And while FMCSA does not specifically define every BASIC, the CVSA already has out-of-service definitions in place that enforcement officials have used for years.
Education appears to be the solution and the industry is doing everything it can to get the word out to drivers and the law enforcement community. But the commercial tire dealers and retreaders must also recognize that they play a more important role in helping their fleet customers comply with CSA guidelines.
In the past, tires and retreads that were in a marginal condition posed minimal risk to the carrier.
Now that the rules have changed and the consequences have become more severe, it’s time for dealers and retreaders to step up to the plate and become solution providers rather than just another supplier.
Kevin Rohlwing is senior vice president of training for the Tire Industry Association (TIA). He can be reached via e-mail at firstname.lastname@example.org.