Tires rank as key component of CSA inspections

Tires have always been a big piece of the puzzle in construction fleets, ranking among the biggest non-labor expense items business owners grapple with daily.

The importance of careful tire maintenance was reinforced with the 2010 launch of the Federal Motor Carrier Safety Administration’s (FMCSA) Compliance, Safety, Accountability (CSA) program, which was designed to improve safety and reduce highway crashes involving commercial vehicles. CSA applies to any interstate carrier that has a U.S. Department of Transportation (DOT) number with all on-road vehicles weighing 10,000 lbs. or more, no matter the type or size of the operation.

“Many construction fleets have always paid attention to their tires,” says Will Schaefer, director of vehicle programs at the Commercial Vehicle Safety Alliance (CVSA), a national organization of state and local enforcement authorities that performs vehicle inspections. CSA has captured owners’ attention in an even bigger way, he adds.

What separates CSA from previous vehicle inspection programs is the involvement of drivers. Previously, a tire violation would be the responsibility of the truck owner. Now a violation affects a driver’s CSA score for 36 months and the owner/company’s score for 24 months, even if the driver leaves. Scores are updated every 30 days.

“It’s top of mind for both contractors and drivers,” says Steve Wilton, vice president of fleet solutions for Goodyear’s Wingfoot Commercial Tire Systems subsidiary, which operates more than 200 Wingfoot Truck Care Centers nationwide. “Drivers are becoming more particular about the tires on their vehicles because they have a shared responsibility under CSA.”

CSA measures company operation and driver safety performance under its Safety Measurement System (SMS), which replaced the FMCSA’s old SafeStat system to identify companies for safety audits. SMS groups operations according to size and ranks them based on their safety performance with their peer group. Drivers are compared with one another, although FMCSA doesn’t rate drivers as it does companies.

Under SafeStat, FMCSA mainly focused on out-of-service violations. Now SMS tracks many more violations based on vehicle inspections. Inspectors evaluate not only inspections but also maintenance records. Tire violation points are posted to a company’s safety score under Vehicle Maintenance, one of CSA’s seven Behavioral Analysis and Safety Improvement Categories, or BASICs. According to U.S. DOT, 17 different tire and wheel related violations accounted for roughly 10 percent of the total inspection violations that took place during a 12-month period that ended last April. Ten percent of out-of-service violations specifically involved tires.

Under CSA’s enforcement program, company safety rankings are penalized for all violations, with points—ranging from 1 to 10, with 10 being the most serious—assigned for each violation. The most severe tire violations carry eight-point weightings and include:

  •  Drive or trailer tire tread depth less than 2/32 of an inch.
  • Steer tire tread depth less than 4/32 of an inch.
  • Flat tire or audible tire leak.
  • Tread and/or sidewall separation.
  • Fabric exposed.
  • Sidewall cut that exposes tire ply or belt material.

For under-inflated tires and loads that exceed the tire’s weight ratings, violations are assessed three points under CSA. In addition to individual violation points, how recent a violation happened makes a difference under FMCSA’s time-weighting formula. For the first six months after a citation, the point score is tripled. From seven to 12 months afterward, the point score is reduced to double, and from 12 to 24 months, the point score reverts to the violation’s original point weighting. For example, an eight-point violation for a steer tire tread depth less than 4/32 of an inch would actually be posted as 24 points for the first six months after it was written up in an inspection. An FMCSA document says recent violations are more relevant.

A dilemma facing construction companies and drivers under CSA is the lack of clear definitions of violations. An example is what passes as a flat tire. CVSA doesn’t use the term “flat tire” but refers to a tire that has a “noticeable leak or has 50 percent or less of the pressure marked on the tire sidewall,” according to the 2012 CVSA handbook. FMCSA’s 393 regulation covering tires states that a vehicle shouldn’t be operated with a tire “that is flat or has an audible leak.”

The absence of precise definitions may result in variations in inspections. Regulations simply provide recommendations for inspectors on how to determine citations. CVSA inspectors use inspection guidelines that are updated annually. “Tires and wheels are often the reason vehicles fail inspections,” explains Tim Miller, Goodyear customer marketing manager. “Tires are sometimes overlooked as construction contractors and drivers get in a hurry to travel to the job site or cut back on inspections. Tire and wheel maintenance is key to avoiding many violations.”

Miller recommends four areas construction fleets can follow to stay on top of tire maintenance:

Inspection. It’s especially important for contractors to look for damage to the tread and sidewall area that may expose belt or ply material. This is another visual item that will trigger an official inspection. Take the time to look for rocks, caked mud and other debris that could cause trouble. If wear is uneven, an alignment may be in order.

Tread depth. Is there adequate tread depth for the wheel position? Many truck owners maintain tread depth minimums that vary depending on wheel position. Use a tread depth gauge to measure depths. If an inspection reveals that a tire is getting close to a federal minimum, change out the tire before heading to the job.

Inflation pressure. This is the key part of a pre-trip inspection and the best way to head off roadside inspections in the first place. Check to see if the tire’s inflation pressure matches the minimum pressure that is required to handle the load. Use a calibrated pressure gauge to get an accurate reading and check the calibration periodically for accuracy.

Wheel inspection. Look for cracked and broken wheel rims, elongated bolt holes, and loose or missing wheel fasteners. Also make sure you clean and maintain studs. Remove rust and corrosion, as well as any burrs around the bolt and center holes. For a hub-piloted wheel system, apply an SAE 30 weight or equivalent lubricant on the outer two-thirds of the stud and between the nut body and flange. If a stud is broken, replace it and the stud on the opposite side.

“It’s a team approach to help ensure that a truck or trailer is road-worthy, with the maintenance manager performing maintenance at the shop or plant and the driver doing his walk-around inspections to check inflation pressure and tread depth,” says Miller. “Most companies require drivers to do periodic inspections, whether it’s daily, weekly or monthly.”

Goodyear commercial tire dealers offer services that could head off inspections and help produce top CSA scores. For example, Wingfoot Truck Care Centers offer mechanical services, from repairs and DOT checks to fleetHQ Trailer Readiness checks. “The fleetHQ Trailer-Readiness Program is an inspection program organized around what the DOT would check,” adds Steve Wilton. “Goodyear dealers can do an overall safety check around the vehicle to help fleets avoid getting fined.”

Goodyear’s TVTrack tire management program gives fleets an up-to-date analysis of their tire readiness. “We go out to the customer and provide reports on the condition of their tires—tracking it by the tire, by the truck, and by the overall condition of inflation and tread depth within the fleet,” Wilton explains. “We can give fleet operators snapshots on where they are at any given time. That information is called in by the technician in the field and then compiled and emailed to the customer within minutes. It’s as close to real time as you can get.” —;