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Deciphering the Motor Carrier Rating: What Does It All Mean?

Motor Carriers can often find themselves in a frustrating scenario trying to defend why they do not have a current “SATISFACTORY” safety rating. It is understandable to question a motor carrier’s safety rating when they are currently “CONDITIONAL” or even “UNSATISFACTORY.” However, a non-rated motor carrier is often put in a position of defense when questioned by a variety of entities, such as shippers, receivers, brokers, and even insurance providers.

John Seidl

The current rating process is outlined in 49 CFR Part 385. This rating process has been in existence before CSA was ever developed by the Federal Motor Carrier Safety Administration (FMCSA). It dates back to the SAFESTAT days (for those of you that have been in the brokerage/motor carrier space that long). We then found our way to the Safety Measurement System (SMS) and CSA.

In moving to SMS – CSA, there was an attempt to replace the current rating process with the Carrier Safety Fitness Determination, but that has gone by the wayside. This would have eliminated an antiquated rating process and replaced it with one that would have included roadside inspection data as well as results of compliance reviews.

What we are left with is an often misunderstood process. Here is an attempt at explaining each of these ratings:

NON-RATED: Simply stated, this a carrier that has either never undergone a “FULL” FMCSA compliance review in which all parts of compliance were checked, or a “FOCUSED” review in which some parts, but not all were checked for compliance. Additionally, they could have undergone a FOCUSED review whereas nothing was found that would have resulted in a proposed Unsatisfactory or Conditional rating, as outlined in Part 385, thus resulting in being non-rated.

UNSATISFACTORY: Simply stated, this carrier would have undergone a FULL or a FOCUSED review, and the findings of that review for the carrier would have resulted in a UNSATISFACTORY rating, as outlined in Part 385. It should be noted that ratings are proposed and do not take affect for 45 days if you transport hazardous materials and 60 days if you do not transport hazardous material. Proposed UNSATISFACORY carriers must complete a 49 CFR 385.17 upgrade request prior to the 45/60 day time frame or be subject to a FMCSA Out-of-Service Order.

CONDITIONAL: Simply stated, this carrier would have undergone a FULL or a FOCUSED review, and the findings of that review for the Carrier would have resulted in a CONDITIONAL rating, as outlined in Part 385. Proposed Conditional carriers can complete a 49 CFR 385.17 upgrade request during the aforementioned timeframes, or they simply attempt to operate with this rating until which time they feel corrections have been made to warrant an upgrade.

SATISFACTORY:  Simply stated, this carrier has undergone a FULL review at some point in their history. You cannot be a SATISFACTORY carrier without having undergone a FULL review. FOCUSED reviews do not result in SATISFACTORY ratings. You can maintain a previous issued SATISFACTORY rating if you pass a FOCUSED review, but cannot be issued a new SATISFACTORY rating without a FULL review.

Let’s summarize this:

  • Carrier A has been so good that they have never undergone any FMCSA review – NON-RATED.
  • Carrier B underwent a FULL review that resulted in a Conditional Rating, completed a 385.17 upgrade request, which was subsequently approved by FMCSA – SATISFACTORY.
  • Carrier C underwent a FULL review that resulted in a UNSATISFACTORY Rating, completed a 385.17 upgrade request, subsequently approved to CONDITIONAL, then completed another 385.17 upgrade request over time, which was subsequently approved – SATISFACTORY.
  • Carrier D was Satisfactory and underwent a FOCUSED review that resulted in a CONDITIONAL Rating, completed a 385.17 upgrade request, which was subsequently approved by FMCSA – SATISFACTORY .
  • Carrier E was Non-Rated and underwent a FOCUSED review that resulted in a CONDITIONAL Rating, completed a 385.17 upgrade request, which was subsequently approved by FMCSA – NON-RATED.

Since SMS – CSA, there has been a substantial move in the types of reviews that are completed. Under SAFESTAT, the majority of the reviews were primarily FULL reviews. Under SMS – CSA, the majority of the reviews are FOCUSED. This has resulted in far fewer SATISFACTORY ratings being issued since SAFESTAT went away.

Shippers, receivers, brokers, and insurance providers have to understand that in many cases a NON-RATED motor carrier is actually better than SATISFACTORY motor carrier.

When applying this information it is important to not confuse a New Entrant Safety Audit with any of these ratings because ratings are only assigned for FULL or FOCUSED reviews as noted here, not for New Entrant Safety Audits. New Entrant Safety Audits result in Pass/Fail.

Entry Level Driver Training Program

The following is a brief overview of the Entry Level Driver Training program.  For complete information click on the link below.

https://tpr.fmcsa.dot.gov/

Interested in ELDT?

Select a scenario below to determine if you are required to complete entry-level driver training.

You must complete the required entry-level driver training for the class of CDL to which you are upgrading before you will be permitted to take the CDL skills test.

You are not required to complete entry-level driver training, as long as you obtain a CDL before the CLP, or renewed CLP, expires.

You must complete the required entry-level driver training for the endorsement(s) for which you are applying before you will be permitted to take the S or P skills test or H knowledge test.

You must complete the required entry-level driver training before you will be permitted to take the CDL skills test, the S or P skills test, or the H knowledge test.

You are not required to complete entry-level driver training to obtain a CDL, even if the previously-issued CDL has since lapsed.

You are not required to complete entry-level driver training for the previously-issued endorsement, even if it has since lapsed.

You must complete the required entry-level driver training before you will be permitted to take the CDL skills test.

What are the Entry-Level Driver Training regulations?

The ELDT regulations set the minimum Federal requirements for training that entry-level drivers must complete before being permitted to take certain commercial driver’s license (CDL) skills or knowledge tests on or after February 7, 2022.

Who is considered an entry-level driver? Individuals applying to:

  • Obtain a Class A CDL or Class B CDL for the first time;
  • Upgrade an existing Class B CDL to a Class A CDL;
  • Obtain a school bus (S), passenger (P), or hazardous materials (H) endorsement for the first time.
  • The ELDT requirements apply to individuals who obtain a commercial learner’s permit (CLP) on or after February 7, 2022.
  • The ELDT regulations are not retroactive; individuals who were issued a CDL or an S, P, or H endorsement prior to February 7, 2022 are not required to complete training for the respective CDL or endorsement.

ELDT Exceptions

The ELDT regulations do not apply to individuals excepted from the CDL requirements under 49 CFR part 383.

This includes:

I think we already knew this… ELD Mandate and Accidents

Overedrive Staff

Study finds trucking accidents up after ELDs

On its way to publication in the Journal of Operations Management last year, a study by researchers at the University of Arkansas previously reported on in 2019 in Overdrive ended up highlighting a significant outcome of the electronic logging device mandate implemented fully in 2017-’18.

The mandate, the study concluded, did not result in any reduction of accidents. Its implementation correlated, rather, with an increase in both accidents and in recorded unsafe driving incidents, specifically speeding.

Researchers found that compliance with federal hours of service regulations has significantly improved since the ELD mandate took effect in December 2017, especially for small carriers and independent owner-operators the researchers viewed as most impacted by the mandate. Large carriers, researchers assumed, had been using ELDs or their predecessor, the automatic on-board recording device, long before the mandate.

Despite higher levels of hours of service compliance, researchers found that the number of accidents increased for most carriers after the ELD mandate took effect. That was especially true for independent owner-operators, who saw an 11.6% increase in accidents, and small fleets of between two and 20 trucks, with a 9% increase, the study found.

An analysis of unsafe driving violations for different sizes of carriers showed an increase compared to violations before the mandate took effect. This was true for all sizes of carriers, the researchers said, but the increases were greater for small- and medium-sized carriers who had not been using ELDs prior to the mandate.

“Our results indicate the electronic logging device mandate did not immediately achieve its goal of reducing accidents,” said Andrew Balthrop, research associate in the Sam M. Walton College of Business at the University of Arkansas. “Drivers have reacted in ways the FMCSA has not fully anticipated, and these behaviors should be accounted for as the FMCSA revisits their hours-of-service policies.”

ince the mandate was handed down, FMCSA has responded in some measures to operators’ calls for hours of service flexibility by adding a 7/3 sleeper berth split in addition to the previously-allowed 8/2 split; adding the ability to pause the 14-hour on-duty clock for up to three hours a day via those split regs; and allowing drivers to take their 30-minute break in on-duty, non-driving status within the first eight hours of drive time rather than the first eight hours of on-duty time in off-duty status; and more.

The ELD mandate coincided with an increase in unsafe driving and speeding citations among truck drivers, and this likely caused an increase in accidents, Balthrop added. Researchers concluded that the stricter hours of service enforcement seems to have led more drivers to try to compress their routes into the time allotted.