How CSA Works and What to Watch Out For

The long-awaited and much-modified Compliance, Safety, Accountability program known throughout the industry as CSA was officially launched by the Federal Motor Carrier Safety Administration (FMCSA) Dec. 12, 2010. And within weeks, fleets were experiencing driver issues resulting from the safety scoring system.
“It's had much more far-reaching effects than we could ever have anticipated,” says Randy Marten, chairman & CEO of Marten Transport. “They estimated that between 10 to 12% of the drivers would go away as a result of CSA, but I think that number will be much higher.” The carrier was part of the pilot program and has been operating under the system for longer than the typical carrier. Marten says he has already had to let about 12% of his drivers go because of CSA-related safety issues.

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FMCSA says the CSA program is designed to emphasize driver safety enforcement. According to the agency, studies have shown that unsafe driver behaviors are a major contributor to commercial vehicle-related crashes and also that a small segment of the commercial driver population is involved in a disproportionately large number of crashes. As a result, FMCSA expanded its approach to identifying and addressing unsafe drivers during interventions with motor carriers.

HOW THE PROGRAM WORKS

CSA is designed to identify truck driver behavior that can lead to an increased likelihood of a crash. Made up of seven Behavior Analysis Safety Improvement Categories, more commonly known as the seven BASICs, the program uses approximately 600 different violations to amass a score between 0 and 100 for each carrier. Each individual violation is assigned a severity weight to determine the final score and place the carrier within a percentile of similar carriers. Higher scores are deemed to be an indicator of increased crash likelihood with certain thresholds triggering an FMCSA intervention.
To determine a carrier's percentile scores, FMCSA uses the Safety Measurement System (SMS), which is comprised of the Carrier Safety Measurement System (CSMS) and the Driver Safety Measurement System (DSMS). The DSMS calculates a driver's score based on behavior and aggregates it with the carrier's CSMS score for the final tally.
The DSMS uses 36 months of a driver's roadside performance data across all their employers. More recent violations are weighted more heavily than older violations. Violations that occurred within the last six months count three times; violations that occurred between six months and a year ago count two times; and violations between one and two years old count only one time. After two years, violations do not count at all, but do remain on a driver's record.

THE BASICS

The BASICs were developed through a collection of information from a number of studies that quantify the associations between violations and crash risk, as well as statistical analysis and input from enforcement experts, FMCSA says. The BASICs are defined as follows:

• Unsafe driving: Operation of commercial motor vehicles in a dangerous or careless manner.
• Fatigued driving (hours of service): Operation of a vehicle by drivers who are ill, fatigued, or in non-compliance with the hours-of-service (HOS) regulations.
• Driver fitness: Drivers who are unfit due to lack of training, experience, or medical qualifications.
• Controlled substances and alcohol: Drivers who are impaired due to alcohol, illegal drugs, and misuse of prescription or over-the-counter medications.
• Vehicle maintenance: Failure to properly maintain a commercial vehicle.
• Cargo-related: Failure to properly prevent shifting loads, spilled or dropped cargo, overloading, and unsafe handling of hazardous materials.
• Crash indicator: SMS evaluates a motor carrier's crash history, which, while not specifically a behavior, may indicate a problem with the motor carrier that warrants intervention.

The carrier SMS evaluates the safety of individual motor carriers by considering all safety-based roadside inspection violations, not just out-of service violations, as well as state-reported crashes. By using 24 months of performance data, SMS assesses a motor carrier's safety performance in each of the seven BASICs.
SMS then calculates a measure for each BASIC by combining the time- and severity-weighted violations/crashes (more recent violations are weighted more heavily), normalized by exposure, which is a statistical calculation that allows SMS to make a fair comparison between carriers with different levels of activity (a hybrid of the number of power units per vehicle miles traveled or the number of relevant inspections).
Applying a similar approach to what was used in SafeStat, SMS converts each carrier's BASIC measures into percentiles based on rank relative to carriers with similar safety event groupings (number of relevant inspections, number of inspections with violations, or number of crashes).
The SMS data is updated monthly and takes approximately 10 business days to process and validate before it is uploaded to the CSA website.

DRIVER MONITORING AND SCREENING SCORES

It's critical under CSA that carriers properly screen potential drivers to assess their safety scores; however, FMCSA does not assign formal safety ratings to individual drivers. Neither drivers nor employing motor carriers have access to the DSMS. While carriers are prioritized for intervention based on their SMS score, drivers are only investigated during a carrier investigation, therefore, no intervention thresholds are in place for drivers.
Carriers and drivers do have access to the new pre-employment screening program (PSP) designed to assist carriers in assessing an individual operator's crash and serious safety violation history. Through NIC Technologies, motor carriers may request driver information for the purpose of pre-employment screening only. The driver must provide written consent. Individual drivers may request their own driver information record at any time. Electronic profiles contain five years of crash data and three years of inspection data.
A carrier pays $10 for each requested driver history. An annual subscription fee of $100 also applies. Carriers with fewer than 100 power units qualify for a discounted annual fee of $25 per year. Each subscription includes up to 10 user accounts, including the administrator. If you need more user credentials, you have to purchase a second subscription for an additional 10 user credentials. The cost of the second subscription is the same price as the initial subscription.
Individual drivers can request a personal driving history for a fee of $10. No subscription is necessary for individual drivers. To access PSP, visit http://www.psp.fmcsa.dot.gov/Pages/Enroll.aspx.
The PSP report, however, does not provide a driver DSMS score under CSA. It can be complicated to read and come up with an accurate DSMS using PSP because of differing language in reports, severity weights, caps on duplicate violations, and timeframes of incidents. This is an issue one industry supplier is attempting to remedy.

GIVING DRIVERS TOOLS

Vigillo released Roadside Resume, a free driver scorecard, in January. The program allows truck drivers to see their rating under the CSA system.
“This is the only service in the trucking industry that will make CSA scores available directly to individual drivers,” says Steve Bryan, CEO of Vigillo. “FMCSA does not have a mechanism that allows drivers to access their scores and see where they have safety deficiencies. Roadside Resume will provide that information in a free report at anytime to any driver holding a commercial driver's license.”
Vigillo's driver scorecards are based on three years of violation history and up to five current and past CDL numbers. The database includes information from carriers that are Vigillo CSA scorecard subscribers or from the newly created category of Affiliate members of the Vigillo Network, companies that have elected to provide this service to their drivers by giving Vigillo access to inspection data without paying to receive fleet scorecards.
The performance of drivers can have an impact on the ability of a fleet to secure freight from its customers, Bryan adds, so carriers need to be very focused on drivers who help and hurt their scores.
“Knowing CSA scores is critical for drivers,” Bryan explains. “There is no other industry where employees are scored and not told how they measure up. I'm not going to bash the CSA program, but I am going to bash government for creating a system to score drivers where their jobs and careers are dependent on those scores and then not tell them their score. That's riot-in-the-street-type stuff.”
As of early February, Vigillo had more than 700,000 drivers in its system. A huge influx of requests for driver reports began flowing into the company. “We were asking ourselves, ‘What in the world have we done?’” Bryan says. Vigillo's goal is to eventually have two million driver reports in its database, focusing primarily on long-haul Interstate truckers, “the ones who are really under the gun with CSA,” Bryan adds. Vigillo customer fleets have access to driver data for pre-employment screening purposes with permission from the driver.
Properly screening drivers is critical under CSA, says Don Osterberg, senior vice president of safety and driver training at Schneider National. The carrier implemented PSP into its process as soon as it was available and it's made an “enormous change” in how they screen driver applicants — but not without a price. “It's not cheap. At $10 each, it's not a small amount of money when you review as many drivers as we do.”
Osterberg believes that carriers will have to avail themselves of the government's PSP program or vendor reports such as those provided by Vigillo prior to hiring drivers or else set themselves up for litigation. “It will create exposure for carriers that don't use PSP,” he says. But he also concurs that reading the PSP reports can be tricky. “Descriptions of violations can differ from state to state; there is no common language, so they can be confusing.”

THE WHOLE STORY

The statistics from FMCSA are deceiving, Osterberg says, and there are a lot more carriers with “alert level” scores under CSA than most people think. Alert level means the carrier's CSA scores red-flag them for inspections. Osterberg, citing Dept. of Transportation statistics, says there are 750,000 carriers in the DOT database but only 92,000, or 12%, actually have CSA scores. FMCSA, he says, states that only 10% of fleets have alert level scores, but that's based on the total population. To be accurate, you have to look only at those fleets that have CSA scores and among them, 52,000, or 57%, have alert level scores, Osterberg explains.
Having an alert level score comes up as a red flag to enforcement personnel when they check a vehicle's DOT number and will target the driver for an inspection. Osterberg also suggests that CSA scores should be used by drivers in determining which carriers they haul for.
Drivers need to check a fleet's CSA score prior to hiring on or risk frequent inspections. If the carrier has consistent maintenance and equipment violations, drivers will steer clear of them to avoid adversely affecting their own safety records. Fleets that don't have enough data in the system to earn a CSA score are also red-flagged for inspections.
The number-one driver violation under CSA is speeding, according to David Heller, director of safety and policy for the Truckload Carrier's Assn. Despite the fact that many fleets have speed limiters on their rigs, he says, drivers are still racking up speeding violations on secondary roads. They may have gotten away with it in the past, but under CSA “they need to either get on board or they won't have a job,” Heller says.
That certainly is the case at Marten Transport. They are eliminating drivers with speeding issues even if they don't have any accidents because “it's just too big a risk and we can't afford it,” explains Randy Marten of Marten Transport. On the plus side, since CSA began, Marten says he's seen a large drop in DOT reportable accidents, which he largely attributes to equipping the fleet with electronic onboard recorders.
Another area where carriers have seen large numbers of violations is driver failure to wear a seat belt. That should be something “you don't even have to think about,” says Heller, but it's the third most common driver violation under CSA.
In the short time since its inception, the effects of CSA have gone much deeper than imagined, says Marten. “People who aren't up to speed on this are kidding themselves … badly.”

Typical violations and severity rating:

Failure to obey traffic control device	5
Headlamps - failing to dim when required	3
Following too close	5
Improper lane change	5
Lane restriction violation	3
Improper passing	5
Unlawfully parking and/or leaving vehicle in the roadway	1
Reckless driving	10
Railroad grade crossing violation	5
Speeding	5
State/local laws - speeding 1-5 mph over the speed limit	1
State/local laws - speeding 6-10 mph over the speed limit	4
State/local laws - speeding 11-14 mph over the speed limit	7
State/local laws - speeding 15 or mph over the speed limit	10
State/local laws - speeding in a work/construction zone	10
State/local laws - operating a commercial vehicle while texting	10
Improper turns	5
Failure to yield right of way	5
Hours-of-service violation	7

Legal Representation

If you or your trucking company have questions about CMV violations or questions about compliance with any of these regulations, the attorneys at the law firm of Bostwick & Price, P.C. are available to answer your questions and concerns. www.bostwickprice.com

CSA Compliance

By Jim Sassen, Contributor

There are two types of carrier reactions when it comes to navigating the new Compliance, Safety, Accountability program launched by the Federal Motor Carrier Safety Administration, better known simply as CSA.

There are carriers who ignore the program and delay action, hoping everything works out. If you are in this group, you may already have seen your safety rating suffer compared to the old SafeStat system.

The other carriers are educating themselves and proactively managing the new CSA scoring methodology. You should be in this camp, even though navigating the new methodology may not be easy and has been complicated by interpretation and implementation issues.

For most fleets, the new CSA scoring methodology is more complicated and harder to manage than the old system. Carriers can face a steep learning curve as they adapt to meet the challenges of complying, as with any new methodology.

But there are no indications that the CSA program is going away. Carriers who better understand and proactively manage it now are more likely to stay out of trouble with the FMCSA and ahead of their competition with fewer roadside inspections, audits, warning letters, fines and accidents.
To implement and manage the new CSA program successfully, there are several actions you can take, all of which can contribute to a culture of safety across your organization.


1. Understand how the new CSA scoring methodology works, how your fleet will be affected by scores and how your fleet is currently scored under the new system.

This step includes understanding the seven Behavioral Analysis Safety Improvement Categories (BASICs) used for scoring: Unsafe Driving, Fatigued Driving, Driver Fitness, Vehicle Maintenance, Controlled Substances/Alcohol, Crash Indicator and Improper Loading/Cargo Securement. For more information, see the FMCSA website: http://csa.fmcsa.dot.gov.

2. Create or acquire simple-to-use CSA management tools, including scorecards. Some solutions allow you to integrate relevant performance data you already have, such as safety performance, hours of service and vehicle maintenance data, to help you proactively manage CSA compliance.

Once you incorporate this critical performance data, create a centralized location for all CSA-related information so your driver managers can have visibility into and responsibility for their drivers' performance.

3. Use the tools, scorecards and CSA scoring data together to identify performance improvement opportunities. You can accomplish this by correlating your relevant performance data to the seven applicable BASICs in the CSA scoring system. By proactively managing this data, you'll begin to see potential performance issues and trends before they result in violations, poor CSA scores, fines - and, in the worst-case scenario, accidents.

4. Once you have used the tools to identify performance improvement areas, focus your time and efforts on the drivers who need the most help. Develop consistent processes, training and tools to help managers coach drivers. This includes creating standardized coaching guidelines and a system of follow-up procedures to ensure that these discussions are taking place in a timely manner and having positive results. You should also capture and maintain histories of these performance discussions.

5. Promote visibility, accountability and positive competition with your drivers and driver managers. Use scorecards and tools that let you know when performance issues are being addressed by your drivers and driver managers. Let them see how they are performing compared with their peer groups, without compromising confidentiality.

6. Reward the positive and coach the negative. With the right CSA management tools, you can proactively identify potentially negative issues and turn them into positive solutions.

No matter what CSA or safety management system you have in place, the goal remains the same for everyone involved - to create safer roads and highways. To ensure success, fleet managers and executives must commit themselves to creating a business culture that values - and indeed embraces - safety as a core attribute of their success.

Don't wait for a warning letter from the FMCSA or until the CSA scoring system is perfected to address safety and CSA compliance. Take action immediately to actively manage compliance or risk falling further behind.

Legal Representation

If you or your trucking company have questions about CMV violations or questions about compliance with any of these regulations, the attorneys at the law firm of Bostwick & Price, P.C. are available to answer your questions and concerns. www.bostwickprice.com