Opinion: CSA 2010 and Preventive Maintenance
By Charles Arsenault
Chief Executive Officer
Arsenault Associates
This Opinion piece appears in the March 22 print edition of Transport Topics. Click here to subscribe today.
If your fleet has been operating without a well-organized, carefully documented preventive maintenance program, you’ll need one soon: The Federal Motor Carrier Safety Administration’s new Comprehensive Safety Analysis initiative — CSA 2010 — will see to it.
To meet the requirements of CSA 2010, which goes into effect in July, annual vehicle inspections and regular PM services will need to be performed on time and with good historical documentation — including driver-reported complaints and whether they have been addressed in a proper and timely manner.
The new regulations will snare less-than-compliant fleets and remove their equipment from the highways. Not only will lack of good maintenance management increase fleets’ Safety Measurement System ratings — higher numbers are bad — and increase operating costs, it also will red-flag their fleets, making them a target for more time-consuming roadside inspections as well as more frequent and more thorough on-site inspections, which now will be called “interventions.”
CSA 2010 is intended to reduce accidents, injuries and fatalities. Motor carriers and their drivers will be rated on safety fitness and operating conditions with what FMCSA says is the agency’s better use of data.
The new safety ratings are based on what the agency calls BASICS: Behavior Analysis and Safety Improvement Categories. These are seven categories of safety behaviors measured by SMS points. While most of the new regulations focus on drivers, they also include 275 maintenance items. A driver can be found in violation for any of 202 of these items during a roadside inspection.
The driver is responsible for the safe operation of those 202 items or reporting those that are not safe, but he can’t make most of the repairs or adjustments himself.
For example, regulation 393:207(d) — coil spring cracked and/or broken, or 393:207(f) — air suspension pressure loss, are items for which the driver can be fined. But a proactive, scheduled PM service can catch and address these problems.
In the CSA 2010 violation points system, vehicle maintenance and its administration carry significant value. Because fleets have more direct control over vehicle maintenance than over driver behavior, it will be very important to maintain a low maintenance score, something a proactive maintenance program can ensure.
There’s a lot more involved here than just oil changes. For instance, a good CSA 2010 inspection service is scheduled annually, performed on time and documented. It includes a bumper-to-tailgate inspection of the required items listed in parts 393 to 396 to identify any items that could lead to a violation, to ensure a unit is safe before it leaves your yard.
The documents for this inspection service should include a completed repair order certifying that the unit has passed inspection, where the inspection was performed, the vehicle’s identification number, plus the date and mileage readings at the time of service.
The repair order should include a detailed checklist of the items inspected and serviced. Ideally, the servicing mechanic should sign the completed checklist. Finally, this documentation must be maintained and made available for inspection for at least 14 months.
Similarly, if the repair work performed resulted from an issue mentioned on a driver’s vehicle inspection report, it’s a good habit to attach a copy of the DVIR to the completed repair order and for the driver who reported the issue to sign it, confirming that the work reported was addressed.
The regulation requires neither the attachment nor the driver signature, but it can only enhance a fleet’s standing with inspectors and help to build a rapport between drivers and the maintenance shop.
As any fleet maintenance manager will attest, it is extremely difficult to manually maintain a schedule of regular preventive maintenance services and inspections, track maintenance histories, cross-reference driver complaints with repair orders and produce documentation on demand. The regulations don’t mandate the use of maintenance management software, but it certainly may make CSA 2010 compliance less arduous.
A fleet maintenance management software application simplifies this process and makes it much easier to comply with CSA 2010.
Best-of-breed fleets already have automated maintenance operations and documentation; low safety ratings and operating costs per mile reflect this process. Of course, in SMS, as in golf, the lower the score, the better.
For these well-managed fleets, as much as 80% of the maintenance work is planned, which allows them to focus on their most troublesome units to further reduce downtime and increase the productivity of maintenance staff, drivers and equipment. They also reduce operating costs and cost per mile, while extending the useful life of the company’s capital investments.
As you plan to address the new CSA 2010 regulations, consider how a sound maintenance management program can help you attain a lower SMS safety score and all but eliminate fines and downtime.
When you consider that the cost ratio of breakdown maintenance compared with preventive maintenance is at a minimum of 4-to-1, that alone should drive you to develop good maintenance management habits with supporting documentation.
An effective maintenance program will help lower your safety inspection score, and it will be far less expensive than being fined, or worse — having your equipment placed out of service.
Arsenault Associates is a fleet management software firm located in Burlington, N.J.
