Safe as Truck

The Feds are Here

Episode Summary

Want to know what the investigator from the FMCSA is thinking when they come knocking on your door? Hear the tips and tricks the FMCSA won’t tell you and get better prepared for when the feds come knocking with Former FMCSA Investigator and State Police Inspector John Seidl.

Episode Notes

Highlights from the conversation:

Safe as Truck is a podcast powered by LogRock, a platform dedicated to handling all aspects of compliance for trucking companies. Learn more at www.logrock.com. 

Episode Transcription

Derek Rogers  0:05  

Welcome to Safe as Truck, the podcast focused 100% on breaking down the challenges of compliance and safety in the trucking industry. Safe as Truck is powered by LogRock, the only digital tool built exclusively to help America's trucking companies stay compliant and stand strong when the DOT or lawsuits come knocking at your door. Now, let's jump straight in with our host, Hunter Yaw.

Hunter Yaw  0:34  

Alright, so this week we have with us a trucking community celebrity. John Seidl, who we first got to know through the excellent content that he has at TruckingWinds.com and then learned that he is a part of the Reliance organization, which is a fantastic insurance company with whom we at LogRock have a great relationship, a great partnership. And we are excited to have John with us here today, not just because of his broader expertise and experience in the industry, but because he—in a past life—was an inspector (do I have that right, John?) for the Department Of Transportation.

John Seidl  1:11  

Yeah, it depends how you play it out. I was an inspector when I pulled trucks over at scales in the road, but then I was an investigator with FMCSA. That's when I came and knocked on company doors. So they both start with an "I," I guess and they both do the same thing: They make sure that we're meeting federal motor carrier safety regulations, basically an enforcement job.

Hunter Yaw  1:31  

That's it. But today, we're focused specifically on the federal piece of that. And we're going to ask John to put back on his federal hat and help us understand to get inside the mechanics, the mentality, the details of what is happening on the other side of the table when the DOT comes knocking on your door, when they ask for all of your files, when they want to break down your business, when they want to see everything you have, when you get that letter saying "we're coming tomorrow," "we're coming the day after" from the DOT, what's going on on the other side of the table? What's going on in the representative from the DOT's minds? What are they thinking? What are they looking for? And I think maybe the interesting thing to start is, how do you pick which door to knock on in the first place?

John Seidl  2:14  

Alright, so that's interesting. Like I said, I used to be an FMCSA investigator. So if you've ever undergone a new entrant safety audit, or, or an intervention from FMCSA, I was one of those guys that knocked on your door. Four ways: 1, 2, 3, 4. There are four basic ways that will get them to knock on your door. One, CSA scores. You don't want high CSA scores, the worse your CSA scores are, the more likely they're going to come knock on your door to high profile crash that hits the median and gets the attention of the Feds does that mean all fatality math, it just means some of them could result in a review. Third complaint, not just a frivolous complaint, a documented complaint with real tangible things. They're accusing you of whether it's a driver, ex-employee, another trucking company, etc. And the last thing is, it's called the PSP Driver Information Resource. Most people don't know what that is when drivers get pulled over. All the violations they have are connected to their driver's license. So then the Feds track down and find out who's the worst driver in the whole United States. And they find out where they were inspected last and they target that driver by going to the company that honestly was dumb enough to hire him. So there are four ways that we'll get you knocked on the door, you don't do those things, the likelihood of getting a visit are next to none.

Hunter Yaw  3:42  

Interesting. Which of those would you say is the most common? What's the one that's causing the most doors to get knocked on?

John Seidl  3:48  

CSA scores. CSA score. CSA scores. Absolutely number one. Number two is that complaint. Number three would be the high-profile crash. Very limited. Do they chase drivers it happens it's called Operation unsafe driver, but it's more of a special project but CSA scores, man. That'll do it.

Hunter Yaw  4:09  

Got it. And let me just double click real quick on complaints. Who's complaining?

John Seidl  4:14  

Well, I'll give you an example from this morning. I have a company undergoing a review right now right before we had this podcast, I was giving him advice. He had a driver complaint. Now the driver kind of said him because the driver was starting to rumble that if he don't do certain things for him, he's gonna file a complaint. Well, the driver purposely stopped completing his el DS in a timely manner and in a consistent manner like he was supposed to. What's nice is the investigator in Wisconsin is being very reasonable to the trucking company because he has text messages and proof and other things to show. This was more of a sabotage thing, but who wants to have to open up their front door to the Feds because a driver did that now sometimes it's the company and the drivers are you know, they're basically supported by what the company was trying to do to them. But in this case, I would call it more frivolous.

Hunter Yaw  5:06  

So those complaints can come from even within your own company. from your own drivers?

John Seidl  5:11  

Yeah, drivers, safety officials, customers, other trucking companies that don't like what you're doing, basically, anybody can support it. With specifics, you can't just say I think they're unsafe. That's not enough.

Hunter Yaw  5:25  

So let's take the most common example: CSA scores. A company's CSA scores have got them onto your radar and you've made the decision—or your boss or the FMCSA, somebody made the decision—that that's it. We're sending in John, so you go knocking on that door. What are you going to do to prepare for that visit? Or do you show up and it's a blank slate from when you enter the building?

John Seidl  5:48  

Well, back in the old days, every review was a full review, they checked everything, from drug testing, to CDOs, to DQ files to our service to maintenance to hazmat, whatever you did there looking at everything, several years ago, right in the middle of my career would FMCSA they came up with focused reviews, right? So first, they're going to decide, do you have enough alerts to warn the full review CSA score alerts? Or do you just have one or two or maybe three, and they're just going to focus on those areas where you're non-compliant, say hours of service, you got a CSA alert in our service, they may come in and just look at your hours of service, not really look at drug testing, not look at a whole hazmat investing session, or even maintenance for that matter. So first, we figure out full review or focused.

Hunter Yaw  6:39  

Got it. So let's say full review, because I think that's going to give everyone a better sense of what this is like and what's going on. So you understand it's going to be a full review. Are you digging through a bunch of the company history before you show up? Or are you learning on site once you get there?

John Seidl  6:55  

That's a preference of the investigator. Some of them don't do a lot of homework. We'll call it before they get there others do. But ultimately, the way it works kind of now most of the time is they don't just show up, they send an email contact letter asking for preliminary information to be uploaded through your FMCSA portal, driver list, vehicle list, mileage questionnaire, and accident register, it's pretty, pretty standard information, that's round one, then round two, they're either going to have you send them more information when they start picking drivers trucks to check deeper into what you're doing, or they're going to show up and knock on your door. Now the COVID, a little bit behind us, we're getting more and more in-person reviews where they come knock on the door. And then they start asking for specific drivers, trucks, trailers, and program information.

Hunter Yaw  7:49  

So based on your experience, we're doing a full review, you've done some homework, you've done some preparation. You strike me as the guy who does his homework before he goes knocks on the door. So let's say you've done your homework, you've done some prep, maybe you got a sense of where the bodies are buried, where the gaps are, things you're gonna want to look harder at. You show up. What's top of your mind? Is there a way that you're filtering through what you're seeing? Or how do you structure the time that you're spending on-premise? What's your thinking from your side as you go into that?

John Seidl  8:17  

The word I want to start with this sample size, sample size, depending on how big your company is, there's something called the E photo. It's the electronic Field Operations Training Manual. It's basically a guidance document like a handbook, to the investigator telling you how many records in any given category to look at bigger companies, you look at smaller companies, you look at less than these sample sizes are set. Now, based on the sample size, we got two types of violations you need to worry about acute and critical. Okay, which one's worse, an acute is worse than critical, you do an acute ruin one time, it could hurt your rating, give you up on sadder conditional, right? Give you an adverse rating. One time you do it wrong, acute, you're starting down the path of getting a violation, or a finding penalty, right? Critical, critical, they take the sample size, you have to be in excess of a 10% violation rate. And you have to have done whatever you did wrong more than once. So doing a critical violation one time, then ain't gonna kill your rate and give you finding penalties when you have a pattern of noncompliance with acute and critical. So to start with investigators are trying to find out if you have any acute and criticals.

Hunter Yaw  9:43  

And if you are a trucking company owner, how should you be staying on top of this? How should I be able to know right now, I'm listening to this conversation, I think, oh, that I'm not worried about because I know for sure exactly what constitutes an acute, what constitutes a critical, and I'm 100% confident that my company does not fall into either of those buckets. What should a trucking company owner be thinking to make sure they're on top of that?

John Seidl  10:06  

Every time I am working with a customer, and I do a mock review, I start by going to 49 CFR Part 385, Appendix B, section seven, it outlines a list of all the acute and criticals that exist. So if I'm going to do an audit prior to the Feds ever calling me, I'm going to look through all those acute and criticals. And make sure I'm not doing any of those wrong. That in itself will set you up for success. Not all there are other things which I'm sure we're going to talk about in this little time we're chatting. But that's the key that you need to do.

Hunter Yaw  10:44  

Interesting. Staying for a second on the perspective of the company owner, when you were visiting auditing a trucking company representing the FMCSA, what were you sitting there thinking, "Man, if the trucking company owner just knew this" or "if these guys had just thought about this" or their ______? I don't want to say hacks, but are there smart approaches, tactics that folks can be deploying to put themselves in a better position, which when you were sitting on the other side of the table, you were thinking, Man, I don't know why these guys don't just do X or Y, because if they did, they'd be making their lives a lot easier.

John Seidl  11:19  

Companies should want to do everything right. Would you agree with me right beside everything, right? But if you have a limited amount of resources you're falling behind work is getting on the backburner. Maybe you lost a safety person, focus on those acute and criticals. And a perfect example is a driver qualification file. Right? You should have everything in a DQ file, you should have a program where it outlines and tracks to make sure you're not missing anything. Because if you get sued, you can get in trouble. But as it relates to a knock on the door from the feds, as long as you have a file of some sort, even if you're missing some things, you got a current medical, and you ran an MVR within 30 days to hire. Those are the things that are acute and critical. Wait a minute, John, I have to fill out an application for my driver's don't I? Yes. But let's say you had none. Not one application. Are you in violation? Yes. Is it acute to critical? No. Now my advocating filling out no applications, it's not what I'm saying. What I'm saying is, if you're going to mess anything up in a DQ file, don't have it be the MDR within 30 days or higher, don't have it be in medical card and make sure you ain't running around with a guy that has nothing.

Hunter Yaw  12:37  

And you mentioned before sample size. I remember from one of our past conversations that you said that there are some smart moves that folks can be doing to make sure that their company is being put in the right bucket in terms of the number of miles that they're driving. Did I understand that right?

John Seidl  12:54  

Yeah, well, that goes into another topic. We already talked about acute and critical. I told you 385, Appendix B, go check it out and do a self audits you sleep like a baby when they call you. The other part that can get you in trouble, or a trouble during a review is your accidents per million miles driven. So 1.5 is the magic number. You cannot have more than 1.5 D O T recordable crashes per a million miles driven in the last 365 days. So if you had four crashes and 4 million miles, that's clearly one, right? If you had four crashes and 2 million miles, that's too well, that's too high. So when you're doing a review, you need to figure out okay, how many miles did I have in the last three or 65 days? How many crashes do I have, you can figure this out before they ever come? And if they do call, you can figure it out in five minutes to see if you're going to fail in that formula.

Hunter Yaw  13:56  

And I remember you telling me that you see folks sometimes miscategorize the miles driven or thinking about it the wrong way where they're actually driving more miles than they'd recorded. Tell us a little bit about that. Because that's a common mistake, right?

John Seidl  14:12  

So during a review, now we're talking to review, you don't want to be over that 1.5 crashes per million miles driven or you're gonna fail that factor of the review. Well, let's talk trucking. A lot of companies have grown in the last few years because rates are pretty good. Right now. That's up and down in the industry. If a year ago you had 10 trucks and now you have 100 trucks. Well, if you just grabbed the miles off your last four quarters, if done give those to the feds, one of the quarters you only had 10 trucks. Now you have 100 So this quarter we're currently in you have more miles. So now you're understating your miles to the feds, but you may have more crashes because you have more trucks. So even though you have more crashes, you're telling them to Too few miles. In reality, they're looking at crashes for the last 365 days, you're given a mileage for maybe not the last two months, but the 12 months before that when you had fewer trucks. That is a misconception of what the Feds want, but you fill out that questionnaire and you write your miles in probably miss being an insurance guy Reliance partners, right? When we do submissions, we ask for the last four quarters. If does when you do a review with the feds don't give them the last four quarters do give them the last 365 days of mileage from your ELD. Or it's possible, you just drove a bad rating because you simply gave him the wrong amount of miles.

Hunter Yaw  15:43  

More miles, more miles, more miles. You got to count every mile you got.

John Seidl  15:46  

For the purposes of a review in the calculation of the 1.5. you are absolutely spot on.

Hunter Yaw  15:53  

Interesting, and I bet a lot of folks are thinking, "Listen, it's what I put on my EFTA. I don't want trouble with the feds because whatever I'm saying doesn't match my EFTA, so it's really important. I'm just gonna grab my EFTA. Hey, everybody, look: those two match." You can see why people fall into that trap because they think they're gonna get into trouble for not matching what they have on it and the feds are gonna say, "Oh, this doesn't match," but that is not the case.

John Seidl  16:13  

Not the case for this calculation. And I can tell you, I have personally seen reviews that were done two or three months ago, and then they call me up saying, Can you help me I have a bad rating. And I'm like, I could have helped you if you told me during the review, because I would have never told them the miles you put because you're only over the rate because you simply miss reported what you actually did. And you shouldn't even be in a battery. Now, sometimes that's not received real well, from the trucking company, because they wish the Feds and or their insurance agent would have advised him on this. And when you do insurance with me at reliance, you get safety as a value add right. You know, yeah, I'm providing safety through trucking wins. But at the same token, customers of reliance, get me for safety as well. So this is I mean, it's a self-inflicted wound, right? These are people shooting themselves in the foot, I think and they were doing it right, because they think it should match their effort. And they've actually just created a completely unnecessary problem for themselves. 100% Interesting. So that's like the mileage thing, is the second thing that you really need to be concerned if you got a cute and criticals tree discussed a little bit. We got this 1.5 mileage. And then the last thing is the vehicle at a service rate. There's a formula calculation for it too, that can hurt your rating. How should trucking owners or safety department directors be thinking about nailing not? Alright, so vehicle out of service rate? How do they do that, depending on the size of your company, they take a sample size of the last X number of inspections. Let's say you have a company with like, maybe 20 trucks, they're going to look at the last eight, level one and two roadside inspections that you underwent. You can't be more than 34% out of service rate. So let's do the math. If we look at the last eight inspections, and you have to where you were placed out of service for maintenance, that would be 25%. Yeah, I mean, now let's say you had three out of eight. Well, that's 37.5%. Now you're over the 34. And that's one step closer to a bad rating.

Hunter Yaw  18:21  

Hmm. So what should fleet owners, what should safety directors, what should they be doing to stay on top of this and to minimize their risk?

John Seidl  18:29  

I'll tell you, it's funny. There's something called the Federal Motor Carrier Safety regulations. That's what I assist companies with understanding the regulations, whether it's roadside, whether it's an investigation, whatever it may be, when you get pulled over to scale, and they're going to place you out of service for maintenance, you better understand the CBSA Auto Service criteria. They publish it every April, you go to the cbsa.org. It's a nonprofit organization that publishes the out-of-service that the feds recognize to shut trucks down. And you need to buy that out of service criteria, train your mechanics on it, train your drivers on it, make sure everybody understands what maintenance violations, we'll get them shut down. If you can reduce those, then no matter when the feds come, you're gonna pass the 34%.

Hunter Yaw  19:19  

Yeah, makes a lot of sense. I want to put myself in the shoes of a trucking company owner, safety director who has got that letter (or maybe there was no letter, maybe the Feds just came knocking) and at this point, I can't do any more training. I can't rethink my operations. What I can do is think through examples like the one you gave on mileage. Where else are there—I don't want to say gray areas—but parts of the process where by being smart and knowing the rules on the Fed side and the limits on the person from the federal government inspecting you, investigating you, where can you be smart and put yourself in a position where you minimize the risk of getting hit by that inspection?

John Seidl  20:03  

When you say "hit" you mean you don't want a bad rating?

Hunter Yaw  20:06  

Yep.

John Seidl  20:07  

You don't want to find you don't want a bad rating. So less acute and criticals control that accident rate control the out of service rate, but the cute and criticals knowing nuances of the photos and how the review works by surrounding yourself with people that experienced it. That's what you need example, faults, logbooks are probably the worst thing you can do. That would be using personal conveyance wrong, driving while logged off of your ELD. Recording the wrong duty status, too many false logs will get you over that 10% and put you in a critical situation giving you a bad rating. Here's one thing people don't understand. I think it's kind of funny. During a review, if you're logged as false by less than 50 miles or an hour, they consider that a non-critical type false. What do you mean job. If I'm driving back to my terminal, with a low, I just loaded, I'm on my hours of driving back and I'm 20 minutes away from my terminal. And I don't want to wait and take a full 10-hour break or split my log or whatever, right? So I pushed PC to drive back to my terminal with the load for example, right? Well, you can't drive to your terminal with a load given circumstances in the personal conveyance. So that's a false slog by 20 minutes, maybe 30 miles, is that less than 50 miles or an hour? Yes. So no matter how many of those you have, during a compliance, review, knock knock knock, you won't end up critical because they put those in a non-critical false log category. Conversely, you got a guide that 78 miles from his terminal with a low knee runs out hours and he wants to go back to his term. Is that more than 50 miles an hour? Yes. That's a critical type too many of those, and you will end up with a bad rating and a finding penalty. I thought False or false, John, not during your review. 50 miles or an hour is a magic line in the sand that almost nobody knows. Unless you're an investigator when they come in to tell you about false logs? They don't tell you about that. Nope. So there's a nugget for our listeners.

Hunter Yaw  22:23  

There we go. That's what we come to you for, John. We know that wisdom is all there. All right, so let's shift gears for a second.

You think a lot about, not just in the context of federal investigations, but also in the context of folks getting sued. What are the most common mistakes that you think folks make from a safety and compliance perspective? Whether it's process, whether it's hiring, whether it's investment. What are the big mistakes that you see out there all the time?

John Seidl  22:51  

I'll tell you, that's a loaded question. Depending on what actual topic we're talking about, if I want to increase revenue, I think people misunderstand the hours of service, personal conveyance yard, mood slips, sleeper, adverse conditions, the agricultural exemption, the short-haul exemption, your big day, you want to make more money, they misunderstand that. They don't understand the out-of-service criteria. So then their truck gets shut down at scales and they can't make money. Have you just known when you get shut down? And what causes that maybe you wouldn't have the problem. When it comes to lawsuits, we talked about a DQ file, it's only a couple items in there that when they knock on the door, you'll get a bad rating. I said, Who cares about an application? Well, during the review, you could make that argument because you don't get fines and penalties and it doesn't hurt your rating. However, if you get sued because of a bad crash and you have no application, you don't do your annual reviews, you're not verifying the medical doctor in the registry (all part of the DQ file), well guess what? They will string you up for that. They will really rake you over the coals with that one. They're going to make it look like you're the most unsafe company in the world because you didn't do an annual review. You understand? Even one thing in a DQ file, it says that you can have a copy of the CDL or do a road test. As an expert witness, I've had attorneys question us as to why did you just take a copy of their CDL instead of doing a road test? Well, it's not required, but they try to make you look unsafe even by doing things or not doing things that are outside of the regulation. So there are a lot of different things that I discuss with my customers at Reliance and try to help them keep themselves out of lawsuit, make more money, pay less money, reduce their insurance costs, pass a review, or maybe not even have one in the first place.

Hunter Yaw  24:46  

Very helpful. So we're in a hot market right now. You mentioned that in the context of your advice on tracking mileage and making sure that if your fleet is growing as a lot of folks are that you're not shooting yourself in the foot by reporting fewer miles than you actually drove. Having said that the hot market can stay forever, right? Sooner or later, it's got to cool down. And one of the things I've heard folks talking about recently, on the shipper side on the customer side, whether it's brokers or the shipper directly, is they're looking for ways to stand out and to talk about what they're doing at the moment to save money. But as the market cools down, their focus is going to be less on saving money and more on finding other ways for brokers to tell their customers or for the head of transportation at a big shipper to be able to tell their boss, what are they doing to be better to be smarter. And one of the things I hear people talking about is an interest in checking beyond just, hey, does this carrier have insurance? Hey, just does this carrier have CSA scores that are valid and actually want to go a little bit deeper? And to understand that, is that something you're seeing or hearing out in the industry brokers and shippers being more interested in understanding the safety of the profile of the carrier? And potentially that being a limiting factor of a company being able to really access that premium freight?

John Seidl  26:00  

Yeah, well, I say 100% Maybe not in this market. But people that just got in this business in the last year and a half. They're a little skewed in their mindset, those that have been doing it a while. They understand the ups and downs of the freight over time. I can tell you a story that I had an intermodal carrier, right. They did rail yard. And because of the big entity, I won't say their name on a podcast was a big entity that gives a lot of rail yard carriers, some freight. Well, the rail was a little bit on the downside because there were enough trucks out there looking for freight and the rate was low enough that rail started to disappear a little bit. Now they had all these trucking companies. Well, if you ended up with a conditional rating, they automatically said we don't care. We're not giving you freight. No. Why would they do that? Because they had too many trucking companies and not enough Intermodal Freight. And if you're going to give X amount of loads to whatever companies are out there, why wouldn't you give the loads to the ones that would give you the least likelihood of being pulled into a lawsuit due to unsafe activity? And one way to do that? Is your rating, satisfactory or non-rated? That's the rating you want if you're conditional in a bad market. Good luck.

Hunter Yaw  27:17  

I'd said, and I think to your point, folks who've only ever known crazy rate per miles, you know, truck to load ratios that make you wonder how anything gets moved. For them. That's, that's an afterthought. Because it's true brokers and shippers right now are not asking those questions any more than they have to at least at the same time. There's a lot of pressure to retain drivers. And you got a lot of folks saying, Listen, I got to find a way to make it work with this guy, because where am I gonna go to replace him? But as the market softens, those realities are gonna change. And I think it's interesting to see how some folks are ready for that and some, to your point, who have that conditional rating, but it's been okay because there was just so much freight to move that right. That wasn't an issue. That's as the weather changes, that becomes a risk for these guys.

John Seidl  28:01  

Yep, 100%, because there have been lawsuits where brokers have been brought into lawsuits. Because the company that they hired and gave a load to was unsafe, shippers get brought into lawsuits. But when you don't have enough trucks, you're willing to look the other way with CSA, things like that. Now, another part about it is the insurance carriers themselves. There are some insurance carriers that are not as good as others. If I was a trucking company, there are a select handful of insurance markets, I wouldn't let them insure me. There are other ones that I would set a goal to have them insure me. Well, in a bad market. brokers and shippers are leaning more towards those markets that are going to take care of them when a loss occurs. Less likely to scrutinize the market, you're placed within a good mark, and a good freight market.

Hunter Yaw  28:52  

Yep, that makes sense. So last thing we want to ask you, as someone representing Reliance Partners (which is one of the good guys on the insurance side), help us understand, what do you wish that trucking company owners knew or thought more about when it comes to building their selecting an insurance carrier? And when it comes to building their partnership and their relationship with their insurance carrier or if their insurance broker depending on how they have that setup?

John Seidl  29:18  

Well, I'll say this, there's a lot of free right now. Not a lot of carriers. But I'll tell you this, there are plenty of insurance agents, anybody that's going into their renewal knows their phone rings, non-stop saying I can get you better grades, I can get you better pricing can get you a better price, tried to find an agent that's going to do more than just give you insurance. Everybody has the markets for the most part. Everybody can get you a quote everybody can put a submission together. But line yourself up with someone that's going to help you increase revenue. Drive down your costs, including your insurance costs. help you make good business decisions to grow your business. Look at a good agent as a business consultant. Not just an insurance agent. And that's what we strive ourselves to do here at reliance, especially our large fleet team, where these larger companies need extra subject matter expertise. And what do we do? If you're an agent of ours, and you undergo a compliance review? I mean, if you're a trucking company of ours, you undergo a compliance review with me, I'm helping you right before this call, I help the guy with the complaint. No lie. Right after this call, I got another company out of Virginia, undergoing a review right now they got their second round of information requests for going through all that information so there are no surprises.

Hunter Yaw  30:40  

I said last question, I was lying. You raise a point there that I think is one that fleet owners think about. I haven't heard a good way of giving them an answer yet, which is, how much should I be spending on safety and compliance? How should I mean, am I how do I know if I'm throwing good money after bad, I want to be safe, I want to be compliant, I want to reduce my risk with the DOT, I want to reduce my risk of an ambulance-chasing lawyer coming after me and trying to sue me. I want to do it right. And I've got some cash right now, the last couple years have been good but I'm not just going to throw money at this without knowing where it's going and without knowing what is the right amount, how much should I be spending? So if you were a fleet owner, how do you think people should be thinking about that?

John Seidl  31:19  

I would analyze your current company position. Let's look at all your current CSA scores and see where they're trending. If they're good and trending, well, well, then you're in a good position as it relates to controlling those. Now let's look at your losses. How often do you crash? are we educating drivers? Are we doing a good orientation to reduce the crashes if your loss ratio is low, your CSA scores are in great shape. Those are two major areas that cost a lot of money. Now do a mock review. Because your CSA scores are good. You're not getting a lot of losses, you might not have a fatality but anybody complaint against you, right? So if you do get a complaint, and they come in, are you going to have a restless night's sleep? Are you sweat on late? Are you going to sleep like a baby, if you have made sure you're going to sleep like a baby for review, your CSA scores are good, you're controlling losses and you're paying drivers well, so you can recruit the best ones, then you're spending the right amount for safety. If you lack in any of those areas, you need the up your safety amount, or you're just spinning your wheels in the mud. You're never going to catch up with these insurance costs, with the CSA scores, etc.

Hunter Yaw  32:34  

And that's the trick, right? The folks who don't invest and think that they're saving money in the long run, it's always going to catch up with you, right?

John Seidl  32:42  

Yep, I would say 100% yes, and it could be in the form of a bad rating. I know we started this with ratings, we went down a couple of paths. But there's one last thing I absolutely want to say about ratings. You want a satisfactory rating or non-rated. There's a misconception in the industry that satisfactory is better than non-rated. And that's not the case, the only time you can get a satisfactory rating is having a full review. If you are non-rated and you do a focus review, or they only check a couple areas, it is impossible to be satisfactory. If you're a trucking company that started up 15 years ago, and you've never had a review because you have zero complaints, great CSA, no crashes and you hire the best drivers and they never visited you. You are non-rated. Now you're a company with a bunch of alerts, they come into a full review, you happen to pass all the acute criticals the accident, the vehicle rate, and your satisfactory, so to me, non rated could be looked at as better than satisfactory.

Hunter Yaw  33:46  

That's interesting. A lot of folks think that the opposite is true, right?

John Seidl  33:49  

100%. There are shippers out there that won't even give you a contract unless you're satisfactory. What I say to those shippers is man you have no idea what you're talking about. Satisfactory in my mind is not as good as non-rated.

Hunter Yaw  34:05  

Yet another nugget of wisdom from the great John Seidl who joins us representing Reliance partners. John, we really appreciate you hopping on with us here today. As always, this has been super informative. And your perspective is something that we think every trucking company owner needs to be listening to needs to be thinking about because there are just too many ways to get yourself into trouble that can be avoided. And with this kind of insight, it is possible to stay above that wherever the market is. So thank you, John.

John Seidl  34:32  

Yep. And thank you for giving me the opportunity to share some of this information. All I want to do is help truckers and help drivers and information like this is how we do so, so thank you.