How fleets can best prioritize compliance issues

Fleet safety teams face a complex challenge: ensuring compliance with Federal Motor Carrier Safety Administration (FMCSA) and related state regulations while juggling limited time and resources. Roadside inspection violations, Electronic Logging Device (ELD) data, audits, and accident claims all demand attention, often leaving safety teams uncertain about where to focus their attention.

Of course, not all compliance issues are equally weighted. Some have the potential to cause significant headaches for you if not addressed rapidly. Thus, in the face of limited resources and time, learning to prioritize and tackle these more serious compliance issues first is key.

In this article, we'll offer a practical roadmap for fleet safety teams to prioritize compliance issues effectively. By leveraging data from the Safety Measurement System (SMS), internal ELD reports, FMCSA's list of critical/acute violations, and proactive risk management strategies, fleets can target high-impact areas to enhance safety, reduce violations, and improve Compliance, Safety, Accountability (CSA) scores.

Below, we explore four key approaches to streamline compliance efforts and optimize your time. The idea is that by focusing on these key issues, you will first tackle the items most likely to cause you significant problems in the audit and highway-accident contexts. But once you have these items under control, you shouldn't stop there! Move on to the less pressing items as time and resources allow.

Why Prioritizing Compliance Matters

Compliance with applicable federal and/or state motor carrier safety regulations is important for a variety of reasons. Violations can elevate CSA scores, leading to more frequent roadside inspections, costly fines, higher insurance premiums, and even audits. Poor safety performance also erodes customer trust and profitability, as shippers often review key safety metrics when selecting carriers.

For resource-strapped fleet safety teams, prioritizing efforts based on data-driven insights enables them to address high-risk behaviors, reduce violations, and strengthen safety culture. This article outlines four practical approaches: analyzing and acting on SMS roadside inspection data, leveraging ELD internal reports, understanding and addressing FMCSA critical/acute violations, and adopting proactive risk management.

Analyzing Roadside Inspection Data in the Safety Measurement System (SMS)

The FMCSA’s Safety Measurement System (SMS) is a powerful tool for fleet safety teams, organizing roadside inspection and crash data from the past 24 months into seven Behavior Analysis and Safety Improvement Categories (BASICs): Unsafe Driving, HOS Compliance, Vehicle Maintenance, Controlled Substances/Alcohol, Hazardous Materials Compliance, Driver Fitness, and Crash Indicator. Accessing SMS data through the FMCSA Portal provides fleets with detailed reports, including driver-specific violations not publicly visible. For a detailed undrstanding of how carriers are scored in the CSA platform, check out our free webinar series on the topic.

First and foremost, fleets should be monitoring their BASIC scores on a monthly basis and prioritizing any categories that are in so-called "alert status," meaning in excess of the FMCSA-established "intervention thresholds." Carriers whose scores are in alert status (indicated by yellow warning triangle in SMS) are prioritized for enforcement, typically in the form of an FMCSA compliance review. Keeping your scores below the applicable intervention thresholds in each BASIC is key to keeping out of the crosshairs from both an FMCSA and plaintiffs' bar perspective. If you find yourself with one or more BASICs in alert status, you should prioritize the compliance issues that led you to this point and start to drive those scores down. Check out our prior article for a more detailed breakdown of CSA scores, intervention thresholds, and improving scores.

Another way to leverage SMS and prioritize effectively is to examine each BASIC to identify the most frequent violations, like inoperative lights in Vehicle Maintenance or log falsification in HOS Compliance. In fact, the SMS system itself shows you the most common violations impacting your various scores, including how many instances of the particular violations your fleet has incurred over the past 24 months, as well as the severity weights of those violations.

Sample SMS Violation Summary (Vehicle Maintenance)

Violations with high severity weights (1–10 scale) have a greater impact on CSA scores, so focusing on those types of violations and preventing their reoccurence will go the furthest in improving your overall safety posture. Likewise, Identifying drivers or vehicles with recurring issues, such as a driver with multiple speeding violations or a truck with persistent brake problems, enables targeted interventions. Tracking trends over time, with recent violations weighted more heavily, helps assess whether issues are escalating, such as a rise in HOS violations after adopting a new ELD system. Filtering SMS data by date, driver, or violation type simplifies analysis, and comparing scores to peer groups provides context, as high percentiles may reflect stricter state enforcement. Filing Requests for Data Review (RDR) through DataQs can correct erroneous violations. And working to retraing problematic drivers and more thoroughly inspect probelmatic equipment is the key to bucking negative trends in SMS.

For example, a mid-sized fleet with 50 trucks faced a 95% percentile in Vehicle Maintenance due to frequent brake and tire violations. Using SMS data, they identified three problematic trucks and two drivers neglecting pre-trip inspections. By prioritizing brake repairs and tire inspections, implementing a mandatory inspection checklist, and conducting driver training, the fleet reduced their Vehicle Maintenance percentile to 55% within six months, lowering enforcement risks significantly.

Levaraging roadside inspection data via SMS can be a particularly effective way to quickly get a handle on a fleet's most pressing compliance issues. That's particularly true for fleets that incur many roadside inspections and thus have a wealth of data to mine in SMS. But what about fleets that have little roadside inspection data in SMS to review? There are still plenty of other ways they too can prioritize their compliance efforts, which we address in the following sections.

Leveraging Internal Reports from Electronic Logging Devices (ELDs)

Hours of service and driver logging violations are some of the most frequently cited violations during roadside inspections and in FMCSA and state compliance reviews. They also routinely lead to downgraded safety ratings in audits.

Since the ELD mandate in December 2017, fleets have gained real-time insights into driver behavior and HOS compliance. ELD reports complement SMS data by revealing internal issues, such as HOS violations, personal conveyance (PC) misuse, or unidentified driving events, before they become roadside inspection violations. Configuring ELD systems to generate automated reports on HOS violations, like exceeding the 11-hour driving limit, helps identify drivers with frequent or severe infractions, which significantly affect CSA scores. Personal conveyance--a very common contributor to log falsification violations--requires monitoring to prevent misuse, which can be accomplished via most ELD's reporting functionality. Unidentified driving events, where a vehicle operates without a logged-in driver, also pose risks, often due to drivers forgetting to log in or improper ELD sharing. This is yet another issue that can be addressed via ELD reporting.

Fleets can rank drivers by violation frequency or severity, prioritizing those with multiple substantive hours of service rule violations over minor log errors. Investigating root causes, such as tight schedules or inadequate training, ensures systemic solutions. Corrective actions might include retraining drivers on HOS rules, adjusting routes to ease time pressure, or putting controls in place to manage improper PC use (e.g., time or distance limitations). Monitoring violation trends post-intervention confirms progress, with declining HOS violations indicating improved compliance. User-friendly ELDs minimize errors, and integrating telematics to monitor speeding or harsh braking can preempt Unsafe Driving violations. Real-time alerts for HOS violations or unidentified driving enable swift action.

In short, fleets should be leveraging the wealth of data their ELDs are generating in order to prioritize and swiftly address HOS issues before they baloon into systemic problems that can quickly esclate your CSA scores and sink you in an audit.

Focusing on FMCSA Critical/Acute Violations and Red Flag Violations

As we've addressed in detail in other articles, FMCSA compliance reviews focus heavily on so-called "critical" and "acute" violations—serious infractions signaling systemic safety failures that can lead to safety rating downgrades in the audit context. Critical violations, like log falsifications or incomplete driver qualification files, reflect ongoing lapses, while acute violations, such as allowing a disqualified driver to operate, are severe one-time breaches. Likewise, "red flag violations," outlined in the FMCSA's Electronic Field Operations Training Manual (eFOTM), carry high crash risks, such as operating without a valid Commercial Driver’s License (CDL) or failing to secure hazardous materials. Addressing these types of regulatory violations and preventing their reoccurence helps to significantly minimize FMCSA penalties, safety rating downgrades, and other adverse consequences.

For a full list of the current critical/acute violations, click here.

Prioritizing violations with high severity weights or those triggering out-of-service orders, like falsified logbooks or defective brakes, ensures urgent action. Auditing internal processes, such as driver qualification files, HOS log accuracy, or drug and alcohol testing compliance, addresses systemic issues. Corrective measures might include stricter pre-employment screening or electronic Driver Vehicle Inspection Reports (eDVIRs) for improved inspections. FMCSA resources, like the Motor Carrier Safety Planner or the Drug and Alcohol Clearinghouse, support these efforts, as does training on these topics, such as our online DOT Compliance for Safety Managers course.

By focusing their attention on the types of violations that are most likely to cause serious problems, fleets can more quickly get a handle on their overall safety posture. And once they've tackled these more serious violations, they can start to work their way down to less serious, but still problematic, issues.

Adopting Proactive Risk Management Strategies

Proactive risk management complements reactive approaches by anticipating compliance risks and fostering a robust safety culture. Predictive analytics through telematics can forecast maintenance needs or identify risky behaviors, like frequent speeding, before violations occur. Regular driver training, tailored to high-risk areas like HOS rules or pre-trip inspections, addresses knowledge gaps. Safety incentive programs, such as bonuses for clean inspections, encourage compliance and boost morale. Conducting mock audits simulates FMCSA compliance reviews, identifying weaknesses in recordkeeping or maintenance, while staying informed on regulatory changes, like the proposed 2025 SMS reorganization, ensures adaptability.

To implement this approach, fleets can deploy technology for predictive insights, schedule quarterly training, and set compliance KPIs, such as violation-free inspection rates. Engaging leadership through regular safety meetings reinforces accountability, and comparing CSA scores to industry benchmarks provides context. Dash cams offer video evidence for DataQs disputes, and digital tools like eDVIRs reduce paperwork errors.

Integrating the Four Approaches

To maximize impact, fleet safety teams should consider integrating these approaches into a cohesive strategy. Start with SMS data to identify high-risk BASICs, then use ELD insights to address driver-specific issues. Tackle critical/acute violations to avoid significant exposure, and build a proactive culture with technology and training. A compliance calendar like the following can ensure consistency:

• Monthly: Review SMS and ELD data.

• Quarterly: Audit for critical violations and conduct training.

• Annually: Perform mock audits and update policies for regulatory changes.

In sum, challenges like limited resources can be addressed by focusing on high-impact compliance issues. Compliance dashboards simplify data analysis, and partnering with regulatory experts eases complexity. By prioritizing compliance strategically, fleets can lower CSA scores, avoid FMCSA interventions, and enhance safety, ensuring operational efficiency and long-term success.

About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a livestream podcast on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who've assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube. Or subscribe to Trucksafe's newsletter for the latest highway transportation news & analysis. Also, be sure to check out eRegs, the first app-based digital version of the federal safety regulations aimed at helping carriers and drivers better understand and comply with the regulations.