Earlier this month, the American Trucking Association (ATA) conducted a webinar on CSA 2010. I have documented the notes from that webinar. Please forgive the lengthiness of this section - it's of critical importance.
As I hope you are aware by now, FMCSA's new program, CSA 2010, plans to completely replace the existing model (SafeStat) for commercial vehicle enforcement and compliance by the end of 2010. CSA 2010's ultimate goal is to reduce large truck and bus fatalities by contacting more carriers and drivers, using improved data to better identify high risk carriers and drivers, and applying a wider range of interventions to correct high risk behaviors.
CSA 2010's model consists of three major components:
1. Safety Measurement System (SMS) - Focuses on motor carriers' & drivers' compliance problems (CSMS & DSMS)
2. Intervention Process - Uses a mix of FMCSA interventions rather than just compliance review (CR)
3. Safety Fitness Determination (SFD) - SFD tied in the future to current safety performance; not limited to acute/critical violations from a CR. Proposed rule on New Safety Fitness Determination (i.e. safety rating) in early 2010
How Carrier Scores Will be Determined
The new Safety Measurement System (SMS) will:
- Use crash records & ALL roadside inspection safety-based violations in measuring motor carrier/driver safety performance (not just out-of service violations as under SafeStat)
- Calculate safety performance based on 7 Behavior Analysis & Safety Improvement Categories (BASICs)
- Weigh all violations from inspections for time and severity (violations diminish over time; e.g. most recent 6 months weighted heavier)
- Compare the data against motor carriers that are about the same size with the same number of inspections
7 BASICs
The 7 BASICs focus on behaviors linked to potential crash risk. Each BASIC is time & severity weighted to determine performance then ranked to trigger intervention process. After the future rulemaking, the BASICs will feed the Safety Fitness Determination (SFD).
1. Unsafe Driving (392 & 397): Dangerous or careless operation
a. Data that will feed the Unsafe Driving BASIC includes traffic violations (warnings & citations) and convictions such as speeding, reckless driving, improper lane change, inattention, and unsafe driving behavio
2. Fatigued Driving (392 & 395): Violations of HOS rules
a. Data that will feed the Fatigued Driving BASIC includes Hours-of-service violations discovered during roadside inspections, off-site investigations, on-site investigations, or post-crash inspections
3. Driver Fitness (383 & 391): Unfit due to lack of training, experience or medical qualification
a. Data that will feed the Driver Fitness BASIC includes inspection violations for failure to have valid and appropriate CDL or medical or training documentation
4. Controlled Substances/Alcohol (382 & 392): Impaired due to alcohol or drugs
a. Data that will feed the Controlled Substances/Alcohol BASIC includes roadside violations of controlled substances or alcohol
5. Vehicle Maintenance (393 & 396): Improper or inadequate maintenance
a. Data that feeds the Vehicle Maintenance BASIC includes roadside violations for brakes, lights, and other mechanical defects
6. Cargo-Related (392, 393, 397 & HazMat): Shifting loads or dropped cargo & unsafe handling of hazardous materials
a. Data that will feed the Cargo-Related BASIC includes roadside inspection violations pertaining to load securement, cargo retention, and HazMat handling
7. Crash Indicator: High frequency & severity of crash involvement
a. Data that will feed the Crash Indicator BASIC includes law enforcement crash reports and those discovered during on-site investigations
Intervention Process
The mix of FMCSA interventions include early contact in the form of a warning letter and targeted roadside inspections. Enforcement steps up from there with investigations, which include off-site investigations, as well as on-site focused investigations and on-site comprehensive investigations. Finally, to make sure compliance is achieved and maintained, FMCSA implemented Follow-on interventions, or corrective actions. These include:
- Cooperative Safety Plan (CSP) - implemented by the carrier and voluntary. The carrier and FMCSA work together to create a plan to address the underlying problems that cause the motor carrier's substandard compliance.
- Notice of Violation (NOV) - a formal notice of safety deficiencies that require a response. No fine is assessed. FMCSA will use this measure when violations can be immediately corrected and the motor carrier is in full cooperation to fix the problem.
- Notice of Claim (NOC) - this measure involves the assessment of a fine.
FMCSA enforcement personnel can start the enforcement process anywhere along that ladder of enforcement. It does not necessarily start with a letter and progress through the steps.
The higher the risk posed by the motor carriers' lack of compliance, the more likely they are to face stiff enforcement in lieu of a warning letter.
How to Prepare
CSA 2010 will be rolled out across the country between July and December 2010. Here's how carriers can prepare now:
- Understanding the CSA 2010 Methodology
- ALL violations count
- Understand the BASICs
- Know the high severity weight violations
- Know that violations diminish over time
- Set up plans/policies to respond to potential interventions
- Obtain & Review Motor Carrier Safety Profile
- Use COMPASS to obtain and review your safety data at https://portal.fmcsa.dot.gov/
- o Focus now on potential problem areas
- o Check COMPASS for unreported inspections and incorrectly assigned inspections
- o Remember drivers, shippers, insurance firms, and attorneys can see your files, too
- Clean up CSA 2010 Data Files
- Update Your Census Data Regularly via the MCS-150
- Update the MCS-150 regularly (e.g. quarterly)
- Currently, the number of power units is being used as the normalizing factor; make sure it's updated
- Vehicles Miles Traveled (VMT) may become important; keep it updated
- Compare Past Violations (last 24 months) to High Severity Weighted Violations
- Know Why Your Trucks Are Getting Inspected
- Know what prompts inspections of your trucks (traffic violations, observable defects, inspection selection score)
- Correct problem areas:
- If speeding (speed governors, HR actions, etc.)
- If observable defects, bad lights, tires, etc. (emphasize pre-trip inspections, maintenance program, etc.)
- Reduce the number of inspections
- Raise Driver's Awareness of Importance of Clean Inspections
- Roadside inspections with or without violations will count in CSA 2010; clean inspections are critical
- Have drivers demand an inspection report if there are no violations (i.e., clean inspections)
- Consider establishing a driver bonus program for clean inspection reports
- Review Driver Safety History When Hiring: Pre-employment Screening Program
- Law enforcement has access to driver's history through the Driver Information Resource
- Same information will soon be available for motor carrier review (planned Jan 2010)
- Will be called Pre-employment Screening Program
- Valuable resource: pre-hire
- Subscription & transaction fees; budget for it
- Manage Driver Behavior & Safety Practices
- Educate drivers & management personnel
- Consider allocating more resources to review safety profiles, check driver records and respond to FMCSA interventions
- Make and keep crash accountability determinations
- Recognize that exceeding FMCSA thresholds in Unsafe Driving or Fatigued Driving will lead to intervention
Between now and July 2010, more and more information will continue to be made available. Stay tuned!