This study analyzed inspection data from over 2000 commercial vehicle customers over two years. It included over 895,000 violations from the maintenance and cargo BASICs. The document discusses proposed changes to separate hazmat violations into a new public hazmat BASIC while moving non-hazmat cargo violations into the vehicle maintenance BASIC. It notes that maintenance violations greatly outnumber cargo violations and the new system would see maintenance violations outweigh hazmat violations even more so. There is a concern that non-hazmat cargo issues will receive less scrutiny under the new framework.

1. • This study is based on the data of 2000+ Vigillo Customers
• Two Years of Inspection Data
• Includes Violations from Maintenance and Cargo BASICs as
formulated today
• Total study of 895,480 violations

2. The New Hazmat BASIC – What is FMCSA
proposing to do?
• Non-HAZMAT Cargo Violations placed into
Vehicle Maintenance
• HAZMAT Violations remain behind in the
new HAZMAT BASIC
• New HAZMAT BASIC to be public

3. The New Hazmat BASIC
What is the effect on Vehicle Maintenance,
Cargo, and what does the new HAZMAT BASIC
look like?

4. CSA Cargo BASIC today
= HAZMAT Violations
Top 10 Cargo Violations vs Top 10 Maintenance Violations
19 times more
violations are written
in Maintenance than
Cargo

5. Proposed HAZMAT BASIC
Top 10 HAZMAT Violations vs Top 10 Maintenance Violations
49 times more
violations are written
in NEW Maintenance
than NEW HAZMAT

6. Reformulated Maintenance BASIC
= Cargo Violations
What happened to Cargo? The TOP Cargo
Violation today,
becomes #42 when
tossed into
Maintenance

7. Proposed HAZMAT BASIC
= HAZMAT Violations
other than paperwork
New (proposed) HAZMAT BASIC
Only ONE of the TOP
20 NEW HAZMAT
Violations is an actual
HAZMAT safety issue
(non-paperwork or
placard)

8. Discussion Points:
Maintenance Violations nationally occur 95:5 in number of violations when compared
to the Existing Cargo BASIC (849,097:46,383) Maintenance is a vast ocean.
When New HAZMAT BASIC is formulated, the ratio goes to 98:2,
Maintenance:HAZMAT, (880,520:14,960) New Maintenance ocean gets a bit bigger
It appears as though Non-HAZMAT Cargo violations (A teacup) will disappear into
Maintenance (Vast ocean) and disappear from scrutiny. (do you hear the open deck
segment cheering?)
Carriers certified as HAZMAT, or deemed HAZMAT due to a placardable inspection will
exist in a highly volatile (very thin data) BASIC that will be made public.