DOT Safety Rating • What You Must Know
Recently we’ve been receiving questions about motor carrier DOT safety ratings that we would like to explore for the benefit of our user community. Our intention is to discuss what different levels of review are performed, and from them what information is considered when assigning the DOT safety rating; what a carrier’s safety rating can tell you about that carrier, and what steps can be taken to improve a broker’s access to safety and compliance information.
FMCSA Compliance Review
The nature of pursuing motor carrier safety is that the goal never remains static. Maintaining standards in safety management means periodic testing, inspections, and examinations are necessary to ensure safety ratings meet the expectations of the state, the Department of Transportation (DOT), and the Federal Motor Carrier Safety Administration (FMCSA). Since that is the case, it may be helpful for us to include a very basic overview of the compliance review process.
A compliance review is an onsite safety audit performed by the FMCSA looking at two main areas: regulatory compliance and safety performance. Any business that works with motor carriers should be aware that not all carriers have had a compliance review. In cases where a carrier has not had a compliance review, its safety rating will be listed as “Not Rated”. Though intimidating, this is not normally a cause for alarm as it signals that the carrier’s operating performance has not triggered a compliance review.
Data insert – Of the 280,428 active Interstate Carriers that are authorized to haul freight, only 38,312 or 13.6% have a DOT safety rating, leaving 242,115 Not Rated.
When FMCSA performs a compliance review, they will either perform a full or focused review. A compliance review is considered to be a Full Review when it involves a comprehensive investigation. A team will be sent out to perform a full review of a carrier’s facilities including equipment and management controls, and their inspection may also include employee interviews. If a carrier has a full compliance review conducted the rating results will be Satisfactory, Conditional or Unsatisfactory. Of particular note, a carrier can receive a Satisfactory safety rating only if that carrier has had a full compliance review sometime in their history.
The Factors included in a Full Compliance Review follow:
- Factor 1: General (FMCSR parts 387 and 390) includes a review of minimum levels of financial responsibility and general requirements.
- Factor 2: Driver (FMCSR parts 382, 383, 391) includes controlled substances and alcohol use and testing, Commercial driver’s license standards and driver qualifications.
- Factor 3: Operational (FMCSR parts 392 and 395) includes hours of service.
- Factor 4: Vehicle (FMCSR parts 393 and 396) correlates with the Out-of-Service rates for the motor carrier when a total of three or more inspections are recorded during the 12 months prior along with regulations related to parts and accessories for safe operation and inspection, repair and maintenance.
- Factor 5: Haz. Mat. (FMCSR part 397, HMR 171, 177, and 180) includes the rules related to the transportation of hazardous materials.
- Factor 6: Accident Factor which is the Recordable Accident Rate per Million Miles for the past 12 months.
Focused Investigation, by contrast, is an onsite intervention that targets one or more areas of compliance often based on over threshold Compliance, Safety, Accountability (CSA) BASIC percentile scores, where the CSA BASIC category will align with an associated Factor from the full compliance review model. The possible results for a focused review are: Not Rated, Conditional or Unsatisfactory.
Generally, certain events may trigger a Full or Focused Compliance Review, including:
- Poor CSA BASIC Scores
- The carrier’s own request for a Safety Rating change
- Major Accidents and severe violations
- A situation where a complaint has been filed with the FMCSA against a carrier
- Inspections resulting in Out of Service violations
- The Carrier failing a New Entrant Safety Audit
Converting Compliance Review Results into Safety Scores
You may have noticed that the results of the inspections described above do not match the way a carrier’s safety rating is displayed. This is by design. The FMCSA gathers information through an in-depth examination of the motor carrier’s compliance with identified “acute” or “critical” regulations of the Federal Motor Carrier Safety Regulations (FMCSRs) and Hazardous Materials Regulations (HMRs). For each instance of noncompliance with an acute regulation or each pattern of noncompliance with a critical regulation during the compliance review, one point will be assessed.
Data insert – A “pattern” is defined as more than one violation. When a number of documents are reviewed, the number of violations required to meet a pattern is equal to at least 10 percent of those examined.
All of the available information is considered together, and a grade of Satisfactory (0 points), Conditional (1 point), or Unsatisfactory (2 or more points) is assessed based on the number of patterns of noncompliance.
- Satisfactory – Zero (0) points, records indicate no evidence of substantial non-compliance with safety requirements. This means that a motor carrier has in place and functioning adequate safety management controls to meet the safety fitness standard
- Conditional – One (1) point, records indicate that the carrier was out of compliance with one or more safety requirements
- Unsatisfactory – Two (2) or more points, records indicate evidence of substantial noncompliance with safety requirements. Generally, a motor carrier rated unsatisfactory is prohibited from operating a commercial motor vehicle.
Ratings of Conditional or Unsatisfactory will not take effect for 45 days if a carrier transports hazardous materials, or 60 days if a carrier transports non-hazardous material, reflecting the relative danger levels posed by noncompliance. During that period a carrier can take corrective action to address violations noted during the review, and can then request an upgrade before the Safety Rating is published. If the proposed rating is Conditional and the carrier did not take corrective action or request an upgrade, they would operate with that rating. If the proposed rating is Unsatisfactory and the carrier took no corrective action and did not receive an upgrade, the carrier would be subjected to an Out of Service (OOS) order.
DOT Resources You Can Refer To
So far we’ve centered on the carrier experience in the hope of explaining how DOT safety ratings are assessed, and what they mean. You may be wondering what materials and resources are available to you to ensure you consistently choose safe carriers. Since FMCSA has created the system, it stands to reason they would offer a means of navigating it–specifically the FMCSA Company Snapshot. The Company Snapshot is a simplified online record of a company’s safety rating where available, along with their identification, size, commodity information, a roadside out-of-service inspection summary, and crash information. The Company Snapshot is available for free. The system is based on FMCSA’s Safety and Fitness Electronic Records (SAFER) system and exists to improve the clarity of expectations and transparency of practices between government, carriers, and brokers. FMCSA SAFER can be publicly accessed and functions as one centralized source for information regarding specific carriers accessible through their DOT or MC number lookup.
As far as how SaferWatch specifically can help, our motor carrier risk-management system is designed to provide exactly this kind of information in exactly this level of detail quickly and accurately to help eliminate the endless paper trails and cumbersome processes that can slow down the movement of freight. The system provides as much information as you require in one place during the hiring decision by doing the research for you automatically. In a world where time is money, any efficiencies you can build into your system are immediate savings–and efficiencies that can potentially spare you from liability later are savings long-term.
A running theme in these posts is that the best safeguard to protect your business against liabilities like negligent hiring and loss is information. At SaferWatch, we arm you with trusted and innovative solutions so that you can make the most informed choices when selecting carriers to do business with.