Webinar Replay #80: FMCSA Crash Preventability Determination Program

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Steve Kessler: Good afternoon. Welcome everybody to the INFINITI Fast Forward Webinar Series.

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Steve Kessler: We’re very glad that you took some time today to join us. We have a good program online. Today, it’s about FMCSA updates to the crash preventability determination program.

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Steve Kessler: I believe recently, there have been some additions to the list of possible preventable accidents that we want to touch on, but also kind of a general overview of this process. It was interesting for me to find out this whole preventability determination program began back in May of 2020.

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Steve Kessler: So, there’s obviously there were some glitches with it. There’re still some glitches with it. But I think it’s a good program, and it’s worth making the effort, I believe, to get the accidents that weren’t your fault off your SMS data.

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Steve Kessler: couple of housekeeping items, and then I’ll introduce our guests. Everybody, as you know, is muted so we can’t hear you, but you have a chat box there that you can type a question into, or there’s also a Q&A box in the tray there that you can pose a question. So that’s how we’ll be able to communicate with you.

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Steve Kessler: So, while I introduce our guest, why don’t you all jump on the chat? Tell us who you are? Where are you from? What company you’re with, so we can get some idea who’s out there

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Steve Kessler: while you’re doing that, I’ll introduce our co-host. Mark Rhea has joined us for many of our webinars, and I’m sure some of you are familiar with Mark

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Steve Kessler: long-term transportation executive. He’s a licensed CDL. Holder. He’s a certified Director of Safety and is involved in a lot of safety related programs around the country.

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Steve Kessler: So, Mark, do you have any comments before we introduce our guests.

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Mark Rhea: No, no, I know we’ve all had experiences with FMCSA. Some good, some bad, and some of us maybe not at all. And we’re very fortunate to have Brandon. That can give us the straight scoop on the crash prevailability program, which certainly impacts all of us, and we should take very close interest in getting some of these crashes off our records. So, we’re really looking forward to today and getting the straight scoop.

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Steve Kessler: Great thanks Mark. Let me go ahead and introduce our guest. Some of you may know Brandon from some podcasts that he does with some frequency. I believe that it’s called truck safe live. But I want you all to welcome Brandon. Wiseman Brandon is the owner and president of truck safe consulting. He’s also a partner with Childress Law

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Steve Kessler: as a transportation attorney Brandon has assisted some of the nation’s leading motor carriers in developing and maintaining compliant and cutting-edge safety programs.

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Steve Kessler: and he has also represented carriers of all types and sizes before the FMCSA. On matters such as safety rating upgrades, and civil penalty proceedings

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Steve Kessler: through his consulting company. Brandon now offers carriers, state-of-the-art compliance, resources, and regulatory training materials covering a wide range of safety, related topics.

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Steve Kessler: Brandon’s also a regular speaker at industry events, and a contributor to a number of industry publications. So, without any further delay, Brandon, I’m going to turn it over to you, sir.

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Brandon Wiseman: Well, thanks so much, Steve and Mark, I appreciate you guys having me INFINITI for having me on. It’s always great to get together with a group of like-minded folks and talk about this important stuff. Happy New Year to everybody. Hope it’s going well, so far, hopefully, you’re sticking to your resolutions. I have a 4-week baby at home, and so my year is off to an exciting start here, and so fair warning to you. If I

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Brandon Wiseman: seem a bit delirious on this webinar, you know why. So, without any further ado, let’s talk about crash preventability.

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Brandon Wiseman: Several different things we can hit on when it comes to crash preventability. Steve mentioned it. As you know, the main purpose of today’s discussion is to talk about some recent changes to the, to the crash preventability determination program which we’ll get to at the end of the near the end of the presentation. But I thought it would be helpful to start with a kind of a look at the background, how the crash, preventability determination program came to be, why it came to be.

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Brandon Wiseman: and, some of its mechanics, how it functions, how regulated motor carriers can and should be using

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Brandon Wiseman: the system, as Steve mentioned, or, as Mark mentioned, to improve their SMS scores their CSA scores and make themselves look better to everybody that’s looking at those scores, including your insurers and your customers and the DOT. Certainly. So, it’s an important program, to say the least, and I think it’s a good idea to get

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Brandon Wiseman: handle on it. Make sure we’re all on the same page as to how it works, and then we’ll get into some of the more recent changes to the, to the platform. And what you need to know about those changes. So that’s how I’m planning to tackle this as we go along. If you have questions or thoughts on whatever we’re talking about, throw it in the Q&A box or the chat box.

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Brandon Wiseman: and we’ll take it as we go. I’d rather do that than wait till the end. It’s always better to do it while we’re going along, at least, in my opinion. So that’s how we’ll do it.

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Brandon Wiseman: all right. So, starting off then, with some background on the crash preventability determination program that’s going to get annoying me, saying that that every few minutes here so sorry for that.

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Brandon Wiseman: Anyway, the crash preventability program is part of the FMCSA’s compliance safety accountability better known as its CSA program. That program, as many of you probably are painfully aware, was implemented back in 2010. It was originally called CSA. 2010. And what is CSA for those who may not be familiar with it? CSA is

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Brandon Wiseman: the FMCSA’s enforcement tools, the tools that it has at its disposal to enforce the Federal motor carrier safety regulations against regulated motor carriers. What does it have in its tool belt to make sure that regulated carriers are complying with a multitude of safety regulations that it promulgates. It has primarily the CSA program.

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Brandon Wiseman: We sometimes colloquially think of the CSA program as CSA scores. But it’s broader than that. Those scores are part of the safety measurement system which we’ll get into here in a second. But the CSA program is kind of an umbrella program that encompasses not only your SMS scores, but also other Enforcement tools like warning letters. The FMCSA routinely sends out warning letters

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Brandon Wiseman: for carriers that find themselves above the alert thresholds in the CSA or the SMS basics, which we’ll get to in a minute. Also, safety fitness, determinations. SFDs are also known as safety ratings. That’s part of the CSA program now. So, when the FMCSA. Comes in and does their audits, if God forbid you ever get that knock at the door.

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Brandon Wiseman: Those audits are part of the CSA program and SMS, which is the big one. That’s the one we know. The program for safety measurement system. That is the scoring

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Brandon Wiseman: tool that the FMCSA. Uses. It has become the primary enforcement prioritization tool that the agency uses to prioritize carriers for further enforcement. Why does it do that?

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Brandon Wiseman: The FMCSA. As many of you will know, is a relatively small agency. As Federal agencies go, I think, at any given time they have around a thousand employees. Compare that to the Faa, for example, which has tens of thousands of employees. So, FMCSA is relatively small, doesn’t have that far of a reach when it comes to its enforcement, its ability to enforce the regulations that it regulates or that it promulgates.

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Brandon Wiseman: and those 1,000 employees are charged with regulating nearly 800,000 truck and bus companies operating in the United States. So a huge universe of regulated carriers, carriers that are subject to these rules.

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Brandon Wiseman: but not a very great way for the FMCSA. To enforce its rules, it must find a way to prioritize the worst offending motor carriers for their attention. That’s how it goes about regulating, is it focuses on the worst offending motor carriers.

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Brandon Wiseman: and how does it do that? It does that through primarily, the SMS system.

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Brandon Wiseman: So, the SMS system. This is important. Obviously, we’re getting to crash preventability, crash preventability is part of the SMS system. The SMS system.

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Brandon Wiseman: pulls in data from several different sources, most notably roadside inspections. So as your trucks and buses are driving down the highways, and your drivers get pulled over for roadside inspections. If you get violations written up on those roadside inspections, all that data gets

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Brandon Wiseman: filtered into the SMS system and put onto your account as the regulated motor carrier and those violations end up being distributed across 7 different

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Brandon Wiseman: categories. They’re currently called basics, behavioral analysis, safety, improvement categories, I think, is what it stands for. They’re changing the name of that just to safety categories here soon, so that’ll help. But anyway, the violations from those roadside inspections get spread across those 7 categories. They’re things like unsafe driving

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Brandon Wiseman: crash, indicator hours of service, vehicle, maintenance drug and alcohol driver fitness, those types of things and those violations end up on those categories every month.

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Brandon Wiseman: And then the system. The SMS system then looks at how many violations you’ve had in a particular category that month, and it does some math which I’m not going to get into now, but it ends up calculating a score for you each month in each of those 7 basics, and that score is expressed as a percentile score. So, it’s on a scale of one to 100, and that is what we know as SMS

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Brandon Wiseman: or CSA scores. And it is a percentile scale, because it compares you against your peers against other motor carriers that have a similar number of inspections with violations in those categories, and so on any given month.

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Brandon Wiseman: the.is paying attention to your SMS scores, and it is looking to see have you

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Brandon Wiseman: escalated above what they call intervention thresholds on any given month. And those intervention thresholds vary based on what type of carrier you are, and they vary across different basics. They’re generally around 65, or it’s usually 65, or 80. If you’re a general commodities, carrier. And so, if your scores escalate above those intervention thresholds because you have a high occurrence of violations

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Brandon Wiseman: in that category, then you will receive a warning triangle on that category on your CSA score, and that means you are prioritized for enforcement. That’s how the SMS system works in a nutshell. Does it necessarily mean you’re going to have the DOT knocking on your door to do an audit tomorrow because of it? No, not necessarily.

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Brandon Wiseman: In our experience. It’s carriers that have usually 2 or more basics in so-called alert status and have those in alert status for several months are the ones that tend to see the FMCSA. Show up and do an audit. But that’s the point of the system, and that’s a little bit of background of where it’s coming from. It’s a prioritization tool in a nutshell. Now, where does crash preventability fit

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Brandon Wiseman: into this? Well, as I mentioned briefly, there, one of those 7 basics

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Brandon Wiseman: is A is called crash indicator.

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Brandon Wiseman: That crash indicator basically takes into account into account all of your DOT recordable accidents. I’ll talk about what that term means here in a little bit, but it is bringing in all your DOT recordable accidents that you’ve incurred over the past 24 months. I think

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Brandon Wiseman: it’s certainly 24 months for violations. I think that’s true of crashes as well, but it’s bringing in those accidents, and it’s placing them on your account, and as you have more and more DOT recordable crashes. Your crash indicator score is going to tick up. And eventually it may exceed that intervention threshold. And that’s what we’re trying to avoid as regulated carriers, so that we don’t have the DOT knocking on our door. But more than that.

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Brandon Wiseman: DOT is not the only one looking at your scores, as many of you will know. There are several eyeballs on your scores. Insurers are looking at your scores, particularly if you’re

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Brandon Wiseman: for hire carrier that must have your insurance on file with the DOT. For example, they care about your scores because the higher your scores, then the more poorly that reflects on you in highway accident, litigation, right? And so high CSA scores can lead to increased insurance premiums. So that’s another reason to try and avoid high scores.

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Brandon Wiseman: Customers are looking at scores. Some of your customers, if you’re a for-hire carrier, some brokers and shippers will refuse to do business with carriers that have basic scores in alert status, for example. So, your customers may be looking at it, and certainly the plaintiff’s bar is going to be looking at it. God, forbid you get involved in a bad accident. You can be sure that a savvy plaintiff’s attorney is going

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Brandon Wiseman: to parade your scores in front of a jury in the context of that litigation and try and cast you as a bad actor based on your scores. And so, all of that is to say.

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Brandon Wiseman: the name of the game here is keeping your CSA scores in check so that you don’t create problems for yourselves in all these various areas.

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Brandon Wiseman: When it comes to the crash indicator score specifically, and the DOT recordable crashes that end up on your account.

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Brandon Wiseman: There has been an issue. Historically, I laugh because there have been many issues with the CSA program over the years that many have complained about and that the FMCSA. Has been slow to respond to it. We’re expecting some changes here in the next several months. Hopefully, that will address some of these changes

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Brandon Wiseman: or address some of these concerns, but not all of them. But one of the main criticisms of the system over the years has been the fact that historically the system has treated all DOT recordable accidents the same, regardless of whether they were your driver’s fault or not.

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Brandon Wiseman: In other words, if I have 10 accidents on my account, and let’s say only one of them was my driver’s fault. The other ones were not preventable on the part of my driver. Historically, you would have been you would have been. Your score would have been influenced by 10 accidents, although 9 of those were not your driver’s fault.

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Brandon Wiseman: and that seems unfair because it is unfair. Why should we, as a regulated motor carrier, be prioritized for enforcement based on accidents that we couldn’t have prevented? Our drivers couldn’t have prevented it. That’s been the concern, and you know I’m not an FMCSA. Apologist, but I guess from their perspective I’m guessing that their rationale has been well, maybe that’s true.

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Brandon Wiseman: It’s unfair to hold you accountable for accidents your drivers couldn’t have prevented. But at least we treat everybody the same right? We’re going to hold that standard to everybody, every other carrier that you’re being compared against, and then it should even out in the averages. I think that’s their mindset.

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Brandon Wiseman: Well, it’s still not fair, fundamentally for a carrier to be targeted, based on accidents that they couldn’t have prevented. So, what do we do about that concern? Well, the FMCSA. Heard those concerns that concern particularly.

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Brandon Wiseman: And then, as Steve mentioned, back in May of 2020, so 10 years after CSA’s implementation and 10 years of using non-preventable accident data to affect a motor carrier score. The FMCSA. Rolled out.

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Brandon Wiseman: It’s crash preventability determination program, CPDP.

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Brandon Wiseman: Now, when this was originally rolled out, this was rolled out as a pilot program. And if you know anything about FMCSA

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Brandon Wiseman: regulations, you’ll know

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Brandon Wiseman: potentially that sometimes they do this. Sometimes, if they have an idea for a regulatory program, they will, instead of rolling it out

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Brandon Wiseman: all at once, they will roll it out as a pilot program, where they test it out for a while and see how it’s going to go and put some data in there and make sure it’s going to work before they either

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Brandon Wiseman: you know, trash it or they move forward with it. Well, that’s how the crash preventability determination program started out in 2020 as a pilot program, a limited program. But the whole point of the program was, this is the purpose. This is right from the FMCSA’s website under the crash preventability determination program. If you were involved in an eligible crash.

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Brandon Wiseman: You may submit a request for data review, RDR. With the required police accident report and other supporting documents, photos or videos through the agency’s DataQs system. I’ll talk about that in a second.

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Brandon Wiseman: Here’s the main part. Crashes determined to be not preventable through the crash preventability determination program are removed from the calculation of the crash indicator basic in FMCSA’s SMS, but are still listed on the website.

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Brandon Wiseman: So that’s good news, right? I mean, that’s what should happen. That’s the way we should treat these accidents that are non-preventable on our commercial driver’s part should not influence our scores that are then used by all these stakeholders to judge our safety and compliance.

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Brandon Wiseman: And so that’s that was the original goal of the program. That is still the goal of the program. It has progressed out of that pilot program stage. It is no longer a pilot program. It is a full-fledged FMCSA. The program that said it is still limited in scope.

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Brandon Wiseman: and we’ll get into. Why, that is the case, and how that is the case here in a second. But just know that 2020. This was a program aimed at addressing that main issue, which is, why should we be unfairly disadvantaged when it comes to our CSA. Scores based on accidents that we couldn’t have prevented. So that’s the purpose of the program.

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Brandon Wiseman: So that’s his background. So how does the crash preventability determination program work, practically speaking. Well, let’s go through that. Let’s walk through exactly what types of accidents are eligible for the program. How do we go about submitting this? Because I found too many carriers don’t leverage this program to their benefit.

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Brandon Wiseman: you know. 1st of all, a lot of carriers don’t even look at their CSA scores, which is a mistake on your part. You need to be at least looking at your CSA scores on a monthly basis. And if that’s you, if you haven’t been looking at your scores, and you log in there, and it turns out that your crash indicator score is above alert threshold. Well, then, the next question is, what do we do to get a handle on that? My 1st piece of advice to you

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Brandon Wiseman: would be to go do a deep dive into all your accidents that are showing up on your crash indicator score and see if any are eligible for this crash, preventability, determination program. And if so

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Brandon Wiseman: file these crash preventability determination requests and potentially get them taken off your scores. That’s the quickest way to drive down your crash indicator score. If you find yourself in a position of having a high crash indicator score. So that’s the reason you would want to pursue a crash. Preventability. Determination review.

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Brandon Wiseman: Now, here’s where the limitations come into effect. It’s not every type of DOT recordable accident that you can submit a request for review on. There are certain enumerated categories of DOT recordable accidents that qualify for a review, and if they don’t qualify under one of those thresholds or one of those categories, then the DOT

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Brandon Wiseman: you may file it, but the.is not even going to look at it. It must fit into one of those eligibility categories. So, we’ll walk through each of those categories here in a second. But as a preliminary matter, I’ve used this term a lot, and I think it’s important that we stop and pause here and make sure we’re all on the same page with what is a DOT recordable accident.

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Brandon Wiseman: and why does it matter? It matters because those are the only accidents that should be showing up on your score. So, what is a DOT? Recordable accident?

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Brandon Wiseman: Well, the regulations define a DOT recordable accident. If you ever want to look up the definition, go to section 390.5 of the Federal safety regulations and you’ll find a definition of accident

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Brandon Wiseman: for purposes of the regulations. And here’s how they define it. It’s essentially 3 categories of accidents involving a commercial motor vehicle that would qualify as a DOT recordable accident. Number one would be any accident

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Brandon Wiseman: where there is a fatality. If anybody dies because of an accident involving a commercial motor vehicle, then it is. It is a DOT recordable accident.

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Brandon Wiseman: There are 2 other categories of accidents

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Brandon Wiseman: not involving a fatality that would also qualify as DOT recordable accidents. The 1st is an accident involving injury to any person requiring immediate medical attention away from the scene of the accident.

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Brandon Wiseman: so, if anybody is injured in the accident that involves a commercial motor vehicle, and they must receive treatment away from the scene. Transported by ambulance or otherwise. They must go to the hospital that is going to have a DOT recordable accident because of that injury.

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Brandon Wiseman: and then the last category. Are any accidents again involving a commercial motor vehicle where any of the vehicles involved

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Brandon Wiseman: incur disabling damage that requires that vehicle to be towed away from the scene so it can’t move under its own power. It’s been disabled due to the accident, so it must be towed away from the scene. Those 3 categories of accidents are DOT recordable accidents. If it doesn’t meet one any of those 3 categories, then it’s not a DOT recordable accident, and it shouldn’t be showing up on your scores. In the 1st place

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Brandon Wiseman: as an aside. If you look at your scores and you see, hey, there is an accident in here that shouldn’t have been in there because it wasn’t DOT recordable. You can petition to have that one removed and that’s done outside the crash preventability program. It’s done through the DataQ system. But you should do that for sure, because those accidents that don’t meet those criteria should not be affecting your scores in the 1st place, but assuming your accidents, meet one of these

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Brandon Wiseman: qualifying categories an easy way to remember this is hearse, nurse, and toe. At least that’s what I’ve heard others say. Hearse, fatality, nurse injury away from the scene, toe, tow away, assuming you have accidents on your account that are DOT recordable. Those are the ones that you need to look at more closely and figure out, do I have a chance of getting these taken off my scores

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Brandon Wiseman: based on their non preventability. And that’s where the crash preventability determination program comes into play.

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Brandon Wiseman: So, let’s say I’m a carrier that has DOT recordable crashes on my account.

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Brandon Wiseman: and I’m looking through all those crashes. I’ve got the police reports hopefully for all those crashes. If you’re not doing that, you should be doing that you should be, you should be hunting down the police reports for all your

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Brandon Wiseman: particularly all your DOT recordable accidents, because it’s going to be helpful to you. You’re going to need it for a crash preventability determination program review. Anyway, I’ll mention that in a minute. But it’s also helpful for you to understand the circumstances of that accident and determine whether it’s going to be eligible for consideration under this program.

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Brandon Wiseman: So, a few points, what types of

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Brandon Wiseman: DOT recordable accidents are eligible for consideration, for appeal essentially, in this program. Well, the 1st point here is that the accident must have occurred in the past 5 years from when you file your request.

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Brandon Wiseman: So again, the program’s been in place from 2020 since 2020. But if you’re filing your appeal today, you can’t go back. Well, I guess you could, because we’re in 2026.

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Brandon Wiseman: The furthest you can go back is 5 years with your crashes. So, as we continue to move along in in the lifespan of the crash preventability determination program. At some point we’re going to get to a point where your accidents are too old to even challenge in this system. So, the point is, they must have occurred in the past 5 years. All right. So that’s the 1st point.

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Brandon Wiseman: The more nuanced point is that the accident must fit within one of currently 16 categories of eligible accidents.

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Brandon Wiseman: And this is what the change. The more recent change has been to the program. That group of 16 eligible accident types has recently been expanded to 21. And so, I’m going to walk through those changes again here towards the end of the of the presentation today, but

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Brandon Wiseman: up until recently the number has been 16. The FMCSA. Has established 16 crash types that are eligible for consideration under the program. They’ve published an eligibility guide. I’m not sure if these slides will be shared, but if they will, that’s a link that you could click on that slide there to the eligibility guide where you can go and download that. Otherwise, you can just Google, FMCSA

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Brandon Wiseman: crash, preventability, eligibility, guide, and you’ll find it easily. But that guide breaks down the 16 categories of accidents that have historically been eligible for consideration under this program, and you better hope your accident fits neatly into those. One of those 16 categories was ours. I think our collective experience with this program over the years. And why are they? Why have they limited this program to just 16 accident types? And now 21.

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Brandon Wiseman: Well, remember again, this started as a pilot program. So, they had to find some ways initially to limit this. So, they did that by limiting the types of accidents that would be eligible for consideration. But then remember back to what I said early on in this presentation, which is that the FMCSA. Is pretty is a small agency, and so it’s habitually short staffed.

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Brandon Wiseman: They just do not have the manpower to effectively regulate the universe of carriers that they’re charged with regulating. So, when it comes to the crash preventability determination program that also comes into play here. They just don’t have enough staff to be able to review any significant number of crash preventability requests each month.

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Brandon Wiseman: and so, they had to limit this. To what types of accidents, the types of accidents that are easiest for the FMCSA. Staff to make a determination of whose fault it was or not.

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Brandon Wiseman: So that’s what the 16 crash types have represented are the ones where it’s very clear by the evidence that the carrier has to submit whether the accident was non preventable on the driver’s part, the commercial driver’s part or not. So that’s why it’s historically been limited to 16 crash types. And now 21 to make it to make the FMCSA’s job easier for it. If they were to open this program up to any crash type they would just be inundated with

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Brandon Wiseman: probably thousands of crash preventability reviews each month, and it would just quickly overwhelm, overwhelm them to give you a sense with just the 16 eligible crash types that we have now the current lead time on getting a response from FMCSA, on your crash preventability request is now upwards of 90 days.

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Brandon Wiseman: And that’s it’s getting even slower than that. So, 3 months is the average. I’ve had them linger for up to 6 months. And so, they’re just not even keeping up with 16 eligible crash types. Now we’re going to increase it to 21. So, we’ll see how that goes. But

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Brandon Wiseman: I can imagine how it’s probably going to go. Unfortunately.

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Steve Kessler: So, do you want to take a couple of questions now?

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Steve Kessler: Sure, yeah, let’s do it.

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Steve Kessler: We have a question here from Norman. He’s asking, what’s the benefit of doing a DataQ beyond? 4 years since it would be off the SMS and PSP.

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Brandon Wiseman: It’s a good point. So, if the SMS is only considering the last 2 years’ worth of crash data, what benefit do you have to challenging an older crash. It’s probably not so much on the SMS side of things as it is on other areas where the DOT enforces their regulations. So, the example that comes to my mind is because I’ve had to do this on several occasions. If the DOT comes in and audits

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Brandon Wiseman: your operations, if they’re in your office and looking at your records, they may be looking at accidents beyond the 2-year period that the SMS is looking at. So sometimes it’s beneficial to be able to argue to them in the context of that audit that, hey? This older crash was non-preventable on my driver’s part. So that may be one reason that you would use the program for older accidents, and then the other one is.

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Brandon Wiseman: if you want to do it for highway accident, exposure type, you know, to

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Brandon Wiseman: to make it clear hopefully that this accident was non-preventable. And then, if that accident ever ends up in litigation. Now, you’ve got a favorable result from the FMCSA. Agreeing with your position that it was non-preventable for the older accidents. And so maybe that’s a benefit to you. But I agree with your overall sentiment, which is, it’s going to make the most sense to use this program for accidents occurring within the last 24 months.

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Steve Kessler: There’s another question that popped in, and I believe was mentioned. That, you know, requires a police report of the accident, and there’s a comment. Here it says, please do not always come to the scene.

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Brandon Wiseman: Yeah.

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Steve Kessler: Will you automatically be disqualified to do an appeal.

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Brandon Wiseman: You are going to be disqualified to do a crash preventability determination program appeal without a police report. So that’s going to be a hindrance to you.

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Steve Kessler: Very good.

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Brandon Wiseman: All right.

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Steve Kessler: What we got so far. Thanks.

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Brandon Wiseman: Okay. I see one more here in the Q&A box. I’ll go ahead and take this one, too.

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Steve Kessler: Go ahead!

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Brandon Wiseman: Says your truck is in an accident. Driver not charged. 3rd party is towed away, and the driver and the driver taken to the hospital. This is on my SMS. I’ve data, queued it, and it was denied. Do I do it again? All right. Truck is in an accident driver not charged 3rd party is towed away.

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Brandon Wiseman: Yeah, I mean, that’s still a DOT recordable accident, right? It doesn’t matter whose vehicle has to be towed away from the scene due to disabling damage. Let’s say, let’s say this was not your driver’s fault. Let’s say that that 3rd party ran smack into the back of your trailer. And then that 3rd party’s car had to be towed away from the scene. That’s still a DOT recordable accident. And so, it’s still going to land on your SMS account. Then the question is, is it eligible for this program?

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Brandon Wiseman: In that example I gave where it was a rear end collision? And it was only the 3rd party that was towed away. It’s still DOT recordable, so it’s going to be on my scores. But it would be eligible for consideration under the preventability determination program. And so, I would file one of these CPDP appeals in your case. I don’t have all the obviously I don’t have all of the facts of the case, so I don’t know if yours is eligible for this program or not.

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Brandon Wiseman: If it was, you said you filed a DataQ. It would be interesting to know on what basis you filed the DataQ. Did you file it on the basis that it wasn’t DOT recordable? Or did you try and leverage the crash preventability determination program? That would be my question to you.

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Brandon Wiseman: all right. So, kind of already hinted at. Then, my next bullet points here, which is that the DataQ system is the system we use to file crash, preventability determination program request. You may know the DataQ system. You’ve probably pulled your hair out about it, just like I have over the years. And like most of the carriers that use the system.

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Brandon Wiseman: It’s a frustrating system to use, but it is the system that we have available to us as regulated motor carriers to challenge erroneous data that gets put into the system and affects our scores, including

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Brandon Wiseman: roadside violations that we disagree with, or that the officer got wrong, that we use the DataQ system to challenge those. But it’s also the system where you file this crash preventability requests for data review. And so, I just wanted to walk through because I get so many questions about this, I thought I would just walk through some quick screenshots here of what it looks like to actually file a crash preventability request for data review through the DataQ system.

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Brandon Wiseman: So, 1st of all, you got to have a data Q system account. Anybody can sign up for an account, it’s free to sign up. It is a bit of a pain now, more than it has been in the past, because it’s 2 factor authentication.

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Brandon Wiseman: So, you got to get a login.gov account, and you got to send a text message to your phone and type in the code. And all that goes along with that. But that’s the age we live in. Right? So, once you get your DataQs account set up, then you would log on to the DataQs homepage. And then you would initiate a request for data review.

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Brandon Wiseman: And when you initiate a request for data review the very 1st page, you’re going to see is this one you’re looking at, which is asking you what type of request for data review do you want to submit?

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Brandon Wiseman: Well, if you’re if you’re a regular user of DataQs, you’re probably more often going to most often going to be challenging violations from roadside inspections. So that’s a little bit of a different process. But that’s the primary use of the DataQ system. But for our purposes today, in our discussion, what we’re filing is a challenge to a crash to the preventability of a crash. So, you could see here that I’ve selected the crash

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Brandon Wiseman: type of request for data review, and then it’ll tell you there at the bottom exactly what you’re getting yourself into with this request for data review, and then you move on to the next screen. What’s the next screen next screen is going to ask you to try and find the accident at issue. Which accident are you challenging the preventability of.

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Brandon Wiseman: And so, you can do that through the system by so, by searching several different things, several different fields, you can see here that you must. You must put it in the state in which the accident occurred. It won’t let you

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Brandon Wiseman: move through the process if you don’t have the state listed.

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Brandon Wiseman: but then you could see that there are some other non-required fields here, and you could search using any of them. If you’ve got the accident report number. Then you could type that there, and you could see that in the middle of the screen there. And that’s sometimes the quickest way to get to the accident you want to challenge. But sometimes those accident report numbers are hard to get the system to find them.

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Brandon Wiseman: So usually what I like to do is type in the carrier’s US DOT number there, and I’ll just search by the State and the US DOT number, and then you click that search button, and it’s going to give you a list of all of the accidents in that state for that US DOT number that are tied to that US DOT number

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Brandon Wiseman: and to the person’s earlier point about not having a police report. If there wasn’t a police report, the system’s not going to have it in there, and so

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Brandon Wiseman: you’re not going to find it here, and you’re not going to be able to move through this process for that particular accident. But assuming you have the police report and assuming the system has it uploaded, then you can move to the next step. Sometimes it takes a little while to get these reports uploaded to the system. So, if you’re not seeing it in the system quite yet, give it

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Brandon Wiseman: 15 days, or whatever, and wait and see if it ends up in the system. Sometimes it’s just a matter of time before it shows up.

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Brandon Wiseman: But let’s say I find the accident through this search, and I pick that accident. Well, here’s the next screen that’s going to show up. I’ve got this redacted because I used a real US DOT number, but it will pull up that report. It will tell you about the state in which the accident occurred. It will tell you the date of the accident, and then it’s going to ask you what you are challenging about this particular accident.

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Brandon Wiseman: There are several different things you can challenge about an accident. You can challenge that. They put the wrong motor carrier down on the Accident report, for example, you can challenge that. The driver’s name was incorrect on the report, and that 3rd option there is the one I talked about a little bit earlier, where you can challenge that this particular accident is not DOT recordable and show so it shouldn’t be in the system. To begin with.

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Brandon Wiseman: if that’s the case, you would choose that 3rd option there. But here is the crash preventability program. What we’re after is the crash could not be prevented. That’s the option we would choose for this particular accident.

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Brandon Wiseman: and you can see, as you go along here, the system provides you some helpful context as to what it is that you’re selecting in case you kind of forget how to do this. But then, once you move through that, and you tell the system that you want to challenge the preventability of an accident? That’s where you are brought to this screen. And this is what we’re here to talk about, which is

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Brandon Wiseman: these different eligible crash types. Again, to be eligible for review under this program it must meet one of these eligible crash types. I pulled down this screenshot just yesterday, and if you I don’t think this is showing the whole screen here. But if you were to count the number of eligible crash types that are currently showing up as of yesterday in the system it is still 16,

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Brandon Wiseman: even though they have recently expanded it to 21. As I understand it, they are still in the process of updating the system to accommodate requests under the new ones that we’ll talk about in a minute. But just know, for now and for the indefinite future, it’s still those 16 that the system has been accepting for the last several years that are eligible.

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Brandon Wiseman: But I’ll get into the changes here in a minute. But this is the screen you’d be taken to. You can see here that your next step, your next task in this system is to pick which of the eligible crash types you think your accident fits under.

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Brandon Wiseman: and you must pick one. If you don’t pick one, you’re not going to move on. So, you have got to pick the one that you think fits best, and hopefully it fits closely to the eligibility guide. Otherwise, it’s going to get denied. But that’s the step you pick which one that you are, which category it falls under.

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Brandon Wiseman: and then you move on to the last screen here. And this is the kind of the meat of your request for data review. This is where you get to explain your side of the story, why you think this accident was non-preventable on your driver’s part. This is where you get to attach any evidence that you have to support your case, and this is where you get to make your case. Whatever you put in this screen here is going to get sent over to the FMCSA. And that’s what they’re going to use to make their preventability determination.

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Brandon Wiseman: All right. So, you can see your options here you get a little text box there, up at the top, where you get to write in whatever narrative explanation you want to write your version of the story. But the more important thing is going to be the attachments that you attach to the to the review. If you don’t attach any attachments, you probably have a low likelihood of success has been my experience.

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Brandon Wiseman: the one the accidents where you’re able to attach quite a bit of evidence to support your version of the facts. Those are the ones that are going to have the higher chance of success. So that’s another tip for you is to make sure you attach as much evidence as you must support your contention that your accident fits into the eligibility guide and was non-preventable on your driver’s part. So good examples. Here you can see a police report is required that says it. Right under that attached supporting documents.

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Brandon Wiseman: Police report from a law enforcement agency is required. So, you would have to attach that as one of your attachments here. Other things that commonly get attached here are photographs of the scene of the accident videos. If you’re lucky enough to have video footage showing the sequence of events

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Brandon Wiseman: now, I will. I’ve got a whole slide on tips here in a minute. So, I’ll mention that tip here in a minute. But this is where you file your request for data review. You get all of that uploaded here on this screen, and then you click next. And then your

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Brandon Wiseman: preventability request gets submitted to the DOT. You’ll get an email from the system confirming that you’re confirming your submission. And then just watch your email, because if they come sometimes the reviewers will come back and want to see something else from you. They may request additional documentation from you, and so all of those follow up. Requests will end up in the system. You could see them. If you log into your account on DataQs and you’ll also get an email notification.

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Brandon Wiseman: If a reviewer has any follow-up request.

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Brandon Wiseman: So that’s how you file a crash preventability determination program request through the DataQ system.

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Brandon Wiseman: Any questions here, Steve, that we need to get to before we move on here.

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Steve Kessler: Yeah, there, there are a couple let me see, here

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Steve Kessler: we have a lot of people that obviously are very skilled at this, and they’re commenting back and forth to each other, which I think is great.

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Steve Kessler: Let me see here.

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Mark Rhea: Here’s 1 1 question asking if you need a medical certificate.

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Brandon Wiseman: No, that’s not a required field I have had.

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Brandon Wiseman: I have had a follow-up request from a reviewer, ask for a driver’s med card, and

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Brandon Wiseman: I don’t think that’s a legitimate request to be honest with you, because drivers

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Brandon Wiseman: status of whether they have a valid Med card or not is not going to be is not a factor into whether the accident was preventable or not, so I don’t know why they request that I have had that happen. But in my view, it shouldn’t be something that carriers are required to provide.

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Brandon Wiseman: Now with that said there is another document type that is required, but only for certain types of accidents, fatality, accidents. You are required as the carrier to submit a copy of the post-accident, drug or drug and alcohol test result from your surviving driver. That is a required document that you would have to provide, but only for fatality accidents. But the Med card is not something that the system is supposed to require of you.

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Steve Kessler: There’s another question. Here are the FMCSA’s crash preventability findings, legally binding.

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Brandon Wiseman: Depends what you mean by legally binding, I would say my general response to that would be no. In other words, if that accident is caught up in litigation, and the FMCSA. Determines that it was

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Brandon Wiseman: preventable on your driver’s part. Could the plaintiff’s attorney use that as prima facie evidence that your driver was liable in that accident, I would say, no, I don’t think any court in the country would use that as prima facie evidence. There’s a question of whether it’s even admissible, in my view, in that litigation. But even if it’s admissible in my view, it’s at best just going to be, you know some persuasive evidence, but it shouldn’t be the end. All be all in that litigation.

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Steve Kessler: That makes sense. Does an injury have to be reported for treatment at the time of the accident?

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Steve Kessler: I guess that’s whether it’s reportable or not.

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Brandon Wiseman: Yeah, it gets a little tricky. And the question is, and this happens all the time. Let’s say that nobody leaves in an ambulance from the scene of the accident, but you later find out that

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Brandon Wiseman: the 3rd party was transport, took themselves to the hospital, and was treated for an injury at the hospital. Is that a DOT? Recordable accident? Possibly so. The FMCSA. Has some regulatory guidance on that question. Specifically, that’s it’s not a regulation. It’s not in the definitions or anything like that. It’s in what they call regulatory guidance. So, I would advise you to go search out FMCSA’s guidance on what

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Brandon Wiseman: to do in that situation. But I think the FMCSA’s answer is yes. If you find out that somebody was later transported to a hospital for treatment

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Brandon Wiseman: than it is a DOT recordable accident. They’ve wavered on this question

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Brandon Wiseman: in the past several years, particularly when it comes to what if they go to the hospital, but only for like X-rays.

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Brandon Wiseman: But they aren’t treated for anything, and they just get X-rays. I think in the past they had even considered that to be a DOT recordable accident. But I think within the last 5 years or so they changed their guidance on that. And so, I think, where it currently stands is if they go to the hospital and they only get X-rays, they’re only there for observation, then it doesn’t qualify as DOT recordable. But if they are treated for anything, then it is DOT recordable.

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Steve Kessler: Here’s a good one. Would staged accidents be eligible under rare and unusual.

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Brandon Wiseman: Yeah. So, we’re going to get to the eligibility categories here in a minute. And yeah, staged accidents. Unfortunately, something we must deal with as carriers with big targets on our backs. Yeah, I would file it under that. Whether the FMCSA would agree that that qualifies is a different question, because I worry

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Brandon Wiseman: that the FMCSA. Is going to see that. And they’re not going to want to decide whether this was staged or not. So, I worry that FMCSA probably is not going to consider that to be an eligible crash type unless it fits into one of the other eligible crash types. To give you an example of the rare and unusual. You probably know this, but the example of a rare and unusual eligible crash type that they list in their eligibility. Guide, is your truck getting struck by a skydiver

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Brandon Wiseman: falling out of the sky and striking your striking your truck? That is one example of a rare and unusual crash that would qualify under that category. But, anyway

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Brandon Wiseman: let’s move on here and.

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Steve Kessler: Yeah, let’s move ahead.

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Brandon Wiseman: Yeah, because I’m starting to get worried. I’m not going to get to all this. So, let’s get through it. I’ve already kind of given some of these tips. But here are just some other tips for filing, effective crash, preventability, determination, request, main point. Here is the burden is on you as the one challenging the preventability. Keep that in mind. It’s not a situation where you can just file the request

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Brandon Wiseman: and say, hey, FMCSA, look at this and wash your hands of it. You must. The burden is on you to prove your case. Meaning again, you need to submit as much evidence as you must back up your case. This was the other tip I was going to get to earlier. But keep in mind that there’s a maximum file size for attachments in this system, which is a pain. It was an even bigger pain

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Brandon Wiseman: not too long ago, when the maximum file size was 5 MB.

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Brandon Wiseman: I don’t know if you know anything about file sizes but 5 MB. You could barely even submit one photograph of the accident. Luckily, they’ve raised that recently up to 25 MB which will accommodate most photographs but still have trouble with some video files.

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Brandon Wiseman: So, the system will just reject your challenge if you try and submit an attachment bigger than that. So, keep that in mind. If you’re trying to particularly video evidence, if you’re going to submit a video, you need to trim it down as best as you can and try and get that file size down so that you don’t run into problems there. Police report must be submitted. And then the FMCSA sometimes requests those drug and alcohol test results, particularly for fatalities.

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Brandon Wiseman: We’ve already talked about timing their website says 60 days. It’s not 60 days. It’s at least 90 days nowadays, if not more, is the typical turnaround for these, and there are the results, the possible results that you’ll get. Once you finally get a response from the FMCSA. It could be pending request or response. That’s if they’ve reached out to you, and have requested some additional documentation, for

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Brandon Wiseman: example.

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Brandon Wiseman: closed, not eligible. That would mean you submitted a request for an accident that doesn’t fit into one of the eligible crash types

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Brandon Wiseman: closed. No request or response. That’s if they had requested additional information from you, and you failed to answer their request, and then closed determination made, and then the determination is either going to be preventable or non-preventable. So those are the possible results.

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Brandon Wiseman: All right. So, let’s get to the eligible crash types, the important part, obviously so as mentioned, to date 16 crash types. There’s not 16 listed here on the slide because I ran out of room, but these there are subcategories of some of these. These are the main categories of accidents, and there are a few of these have some, some subcategories, but these are the ones that have historically been accepted as eligible crash types. And again.

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Brandon Wiseman: you can. As you. As we go through these, you can see why they have been eligible, because these are the easiest for the FMCSA. To determine whose fault, it was right. So, if the commercial motor vehicle was struck in the rear. So rear ends are going to be quintessential examples of eligible crash types. If somebody runs into the back of your trailer and you’ve got evidence to prove that that’s going to be eligible.

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Brandon Wiseman: The other driver was driving the wrong direction on a road or made an illegal turn. Those are eligible. Your vehicle was parked or legally stopped when it was impacted. That’s going to be eligible failure of the other vehicle to stop at a stop sign or stop light.

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Brandon Wiseman: If the other driver had a DUI if they were drunk or impaired, and they impacted your vehicle. That’s an eligible crash type. If the other driver incurred a medical issue falling asleep or was distracted.

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Brandon Wiseman: Cargo, equipment, debris or infrastructure failure. If you’re driving and the bridge fails, and your driver impacts the

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Brandon Wiseman: the debris on the roadway. That will be eligible if your driver’s hit by a deer. Animal strikes are eligible. Driver assisted. Suicides are eligible. If somebody jumps in front of your truck, trying to kill themselves. That’s eligible. And then that rare and unusual category which is, it’s hard to find an accident that fits in that category, but those are the accidents that have historically been eligible.

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Brandon Wiseman: and if you were to pull up the eligibility guide, this is what you would see for each of those eligible crash types of an illustration of what the FMCSA. Considers eligible versus what they consider not eligible under each of those categories.

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Brandon Wiseman: Just to give you an example of how stringent they’ve been on some of these. That second example on the bottom of the screen always got on my nerves, right? So, one way, driver operating the wrong way on the roadway is supposed to be an eligible crash type for a preventability. But you could see here that if it’s a 2-lane highway

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Brandon Wiseman: and the other driver crosses the center line, but not fully across the center line, maybe just their front. 2 tires cross the center line, and they impact your driver. Then suddenly, it’s not eligible anymore, because they have stuck strictly to their eligibility guide. So, for it to fit under that wrong way, category.

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Brandon Wiseman: the driver must be fully across the center line. I’ve had it be so nitpicky in the past we had. I think it was a police report. I don’t think there was photographs, but police report showing that 3 of the 4 wheels were fully across the center line, and the 4th wheel was not across, and it was determined, not eligible for consideration, because that

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Brandon Wiseman: 4th wheel wasn’t fully across. So, the point there is that you need to make sure that your accident is closely aligned with these eligibility guides, or it’s probably going to be deemed ineligible. Now, does that prevent me from going ahead and filing a DataQ or a request on a close call? No, I’m still going to file it, but the further it gets away from the eligibility guide, the less inclined I’m going to be to file the request.

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Brandon Wiseman: So, what is changing? Sorry I didn’t leave as much time as I had hoped for this, but the good news is not a whole lot is changing, but they are adding some new eligible crash types that are worth looking at, and they are making some minor tweaks to existing crash types. So, let’s look at these.

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Brandon Wiseman: So, you can see here revisions to existing crash types for new eligible crash types and what accidents are going to qualify under these new criteria. Once the DataQs website gets updated. You can see here that they are making this retroactive to accidents occurring on or after December 1st of last year. So even though the system hasn’t been updated yet, so that you can file these once the system is updated.

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Brandon Wiseman: if you have an accident that fits into one of the 4 new categories, and it occurred on or after December 1st of last year, then you’ll be able to file that after the fact, if its if

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Brandon Wiseman: if it only fits. If it was before December 1st of 2024, then it still must fit into those existing 16 crash types that we previously discussed. All right. So, what are the revisions to the existing crash types? Well, here they are.

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Brandon Wiseman: The DUI example I gave the change that they’re making to this is that for that category you no longer must provide proof that the other driver was arrested for a DUI. That had been the case previously you had to have records of the other driver’s arrest for a DUI to move forward with your request under that category.

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Brandon Wiseman: So now, if you have a police report that indicates that the other driver involved was intoxicated. That should be enough to fit you under that eligible category.

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Brandon Wiseman: So, I think that’s a good change in the right direction.

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Brandon Wiseman: Another change. The struck by a driver who admitted falling asleep or being distracted category, removed the requirement for the driver’s explicit admission. Again, going back to how stringent they interpreted these eligibility categories previously that category there had to be an explicit admission from the other driver that they had fallen asleep, or that they were distracted, and that had to be in the police report for you to move forward with that crash type.

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Brandon Wiseman: Now they remove that requirement. They’ve relaxed it a little bit, making it easier for carriers to provide whatever evidence they have that the other driver was distracted, or on their phone, or whatever.

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Brandon Wiseman: And then some language adjustments to now allow multi vehicle crashes to qualify under specific categories, addressing prior exclusions. This has been another big problem with the program, at least in my experience, are like chain reaction accidents. Where, you know, there’s the initial crash. And then there’s a chain reaction, and then your commercial motor vehicle is involved later in the chain.

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Brandon Wiseman: My experience has been that in those cases the FMCSA. Has just thrown up their hands and said, we’re not going to consider that for this program. But now they’ve made some tweaks to the language to allow multi vehicle crashes to qualify, assuming they meet the eligibility categories.

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Brandon Wiseman: So then, the big part here are the 4 new crash types. So here they are

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Brandon Wiseman: the 1st new crash type that will be eligible for consideration are crashes where the commercial vehicle was struck on the side by a motorist traveling in the same direction.

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Brandon Wiseman: So, side swipes, I’ll show you the pictures of these here in a second. But side swipes are now going to be eligible. Once the system gets updated. Also, incidents involving motorists entering the roadway from a private driveway or parking lot. So, if your commercial vehicle is driving down the road and somebody enters the roadway from a private driveway or from a parking lot and strikes your commercial motor vehicle that is now going to be an eligible crash. Time

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Brandon Wiseman: also crashes caused by motorists who lost control of their vehicle as long as the police report documents, that loss of control. So, going back to my example, where the vehicle had crossed the center line but wasn’t fully across. Well, now, maybe it qualifies under this type for this category. The other driver lost control, and even though it wasn’t fully across the line if the police report indicates that that other driver lost control.

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Brandon Wiseman: Well, now, maybe it fits under this category, and then the last one, I think, is the most important one of them all, because it’s kind of a catch, all category, in my view, at least for fleets that have

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Brandon Wiseman: event recorders, cameras installed in their trucks. It’s any other crash type where video evidence demonstrates the sequence of events offering broader applicability for various scenarios. I think this is the biggest change. I think this is the most welcome one. If you’ve got

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Brandon Wiseman: video footage to prove that your driver was not at fault, that this was non-preventable on their part, then it should be eligible for consideration, if nothing else, you should be able to submit that evidence that video evidence, as long as it shows the sequence of events so leading up to the accident, the accident. And then, shortly after the accident. That’s the key to this new category that will be eligible.

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Brandon Wiseman: So, to wrap things up here, let’s look at their kind of their illustrations that they’ve added for these new crash types. This is that struck in the side accident type. You can see here that they’ve shown 2 examples of eligible under this category, one where you know the key here is that the other vehicle has to be moving in the same direction as the commercial motor vehicle whether it’s a sideswipe, or they just veer into like a lane. Change

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Brandon Wiseman: into your trailer, for example, those are going to be eligible. What’s not eligible under this this particular category is a vehicle operating in the other direction and then impacting the side of your commercial vehicle.

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Brandon Wiseman: Here’s that one where a vehicle’s entering the roadway from a private driveway or a parking lot.

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Brandon Wiseman: You can see here that there’s some consideration given to stop signs. You could see that they’re saying that if it’s another vehicle entering the roadway because there was a missing stop sign, for example, that’s not going to be an eligible under this category, at least, whereas exiting a driveway that had no signage would be an eligible category. And so

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Brandon Wiseman: again, you can go find this eligibility guide. I think it’s particularly helpful to kind of run your accidents up against this guide and see what fits and what doesn’t. Here’s that spinning out of control, new accident type, self-explanatory for this one. The key here is that the police report must indicate that the other vehicle lost control.

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Brandon Wiseman: And then, lastly, that video evidence you know this one again. Pretty self-explanatory. The key here is that the video must show the sequence of events. So, if it’s missing key parts of the event leading up to it. Then it’s not going to be eligible, so just make sure that you’ve got some lead up to the event, the event, and then a little bit after, and then it should be eligible for consideration under that new type.

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Brandon Wiseman: So

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Brandon Wiseman: that’s it in a nutshell. That’s the crash preventability determination program. Those are the proposed changes. I know we’re at our time. I’ve got extra time here, so I’m happy to address any questions. If anybody wants to stick around for a few more minutes. Here.

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Steve Kessler: There is. There’s 1 question that was put in a little earlier about any information about a mechanical failure resulting in truck fire.

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Steve Kessler: No other parties involved because of having to be towed. It is recordable, is, does that.

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Brandon Wiseman: Not in the crash preventability determination program. I think your best bet there is going to be whether that’s a DOT recordable or not, and I think FMCSA. Has some guidance on that type of thing as well. It sounds like you’ve already looked at that guidance and determined it was, it was recordable. So, I don’t think you’re going to have any recourse there under this program.

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Steve Kessler: Great good one. Last thing before everybody goes. We’ve talked a lot about crashes and such today, and I wanted to remind everybody that we have

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Steve Kessler: a new packet of content.

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Steve Kessler: That is all about training at the scene of an accident. There are 25 videos. It’s premium content. Some of it’s for the driver. Some of it is for the company. And that also comes with a digital checklist

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Steve Kessler: that would allow a driver to pull out their cell phone and go through a checklist of items that need to be accomplished.

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Steve Kessler: At the scene of an accident. Also, there’s

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Steve Kessler: hold on. There’s another poll question I want to put up. Let me just end this one.

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Steve Kessler: And then I want to relaunch.

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Steve Kessler: See if this is going to do it.

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Steve Kessler: Hang on folks, because this is important. If any of you are NATMI certified directors of safety.

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Steve Kessler: then there is. If you can answer, yes.

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Steve Kessler: I can’t seem to get to my poll question here. Oh, here we go.

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Steve Kessler: Now, if you’re a certified director of safety, and

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Steve Kessler: you would like to get the certificate to verify that you’ve attended.

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Steve Kessler: Then you can go ahead, and

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Steve Kessler: I don’t know why it’s not putting it out there.

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Steve Kessler: It’s not going to let me launch it

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Steve Kessler: reach out to me, or you can go ahead and send a question into the company, and we’ll make sure that everybody that was on here you can send an email back. I think the invites came to me, and I’ll make sure that we get you a certificate so you can get your NATMI credits.

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Steve Kessler: So sorry for the mess up there and getting that out there.

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Steve Kessler: Let me just say this, folks, this was great information. There were a lot of great comments. Brandon, you’ve got a lot of thank yous here.

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Steve Kessler: It was a great presentation. It’s good information. Reach out to Brandon, I think. Probably if you’ve got a more specific question, he’d probably be happy to reach out to you when he gets a chance.

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Steve Kessler: But having said that, thank you all today for joining the program. Great information, good refresher. And I have to say we have a lot of folks commenting here that are well tuned into this program, and that made me happy to see that. So.

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Steve Kessler: Brandon. Thank you, sir. Appreciate your time.

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Steve Kessler: See everyone.

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Steve Kessler: thank you, and everybody have a great rest of the day be safe, and we hope to see you on the next program.

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Steve Kessler: Thank you all very much.

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Mark Rhea: Thank you. Thank you.