• 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

• Non-HAZMAT Cargo Violations placed into Vehicle Maintenance

• HAZMAT Violations remain behind in the new HAZMAT BASIC

• New HAZMAT BASIC to be public

The New Hazmat BASIC – What is FMCSA proposing to do?

What is the effect on Vehicle Maintenance, Cargo, and what does the new HAZMAT BASIC look like?

The New Hazmat BASIC

Top 10 Cargo Violations vs Top 10 Maintenance Violations

CSA Cargo BASIC today

= HAZMAT Violations

19 times more violations are written in Maintenance than

Cargo

Top 10 HAZMAT Violations vs Top 10 Maintenance Violations

Proposed HAZMAT BASIC

49 times more violations are written in NEW Maintenance than NEW HAZMAT

What happened to Cargo?

Reformulated Maintenance BASIC

= Cargo Violations

The TOP Cargo Violation today,

becomes #42 when tossed into

Maintenance

New (proposed) HAZMAT BASIC

Proposed HAZMAT BASIC

= HAZMAT Violations other than paperwork

Only ONE of the TOP 20 NEW HAZMAT

Violations is an actual HAZMAT safety issue (non-paperwork or

placard)

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.