CSA

The Compliance, Safety, Accountability (CSA) program is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety through better safety measures and more effective interventions.  The program has three major components:

• Safety Measurement System (SMS)
• Expanded Enforcement Model
• New Safety Fitness Determination Model (Subject to future rulemaking)

Implemented nationally throughout 2011, CSA has already demonstrated impact.  FMCSA compiled safety measures in SMS on over 200,000 carriers.  Early interventions have included over 50,000 warning letters sent to carriers with deficiencies on one or more safety measurement categories and indications are that these letters have proven effective in prompting carriers to review their safety measures and then make improvements in their safety performance as reflected in their SMS scores. CSA SMS safety measures will also be used in determining safety ratings. A proposed rulemaking for “Safety Fitness Determination” is expected later in 2012.  

FMCSA provides extensive information to educate carriers, drivers, and other stakeholders about the details of the CSA program – see:  http://csa.fmcsa.dot.gov.

• New Developments
• Timeline
• Brief history of CSA program
• CSA program - Current Status
• CSA Future Developments
• CSA Impacts
• Prepare Your Business
• CCJ CSA Special Report

New Developments

FMCSA has made a number of enhancements to the Safety Measurement System (SMS) following the CSA Operational Model Test based on feedback from FMCSA staff, state partners, industry, and safety advocates. This release is the first in a series of improvements to SMS that will take place up to twice a year. FMCSA will provide a preview period for enforcement personnel and motor carriers up to two times per year before implementing SMS changes.

The first package of SMS enhancements will include:

1. Strengthening the Vehicle Maintenance Behavior Analysis and Safety Improvement Category (BASIC) by incorporating cargo/load securement violations from today's Cargo-Related BASIC.
2. Changing the Cargo-Related BASIC to the Hazardous Materials (HM) BASIC to better identify HM-related safety problems.
3. Better aligning the SMS with Intermodal Equipment Provider (IEP) regulations.
4. Aligning violations that are included in the SMS with Commercial Vehicle Safety Alliance (CVSA) inspection levels by eliminating vehicle violations derived from driver-only inspections and driver violations from vehicle-only inspections.
5. More accurately identifying carriers involved in transporting HM.
6. More accurately identifying carriers involved in transporting passengers.
7. Modifying the SMS display to: Change current terminology, “inconclusive” and “insufficient data” to fact-based descriptions
8. Separate crashes with injuries and crashes with fatalities.

Carriers currently have the opportunity to preview these SMS changes and expected impact on their ratings. FMCSA will accept feedback on the changes and may then make additional adjustments prior to including the enhancements in the public SMS numbers. For more information about the changes, visit:  http://csa.fmcsa.dot.gov/Documents/SMS_FoundationalDoc_final.pdf

Current/ Recent Timeline
2011: CSA Interventions Implemented State-by-State 

• Warning letters or investigation notices were sent to carriers with deficient BASICs
• Systematic introduction of new investigation types and safety management rules
   

December 2010: Safety Measurement System (SMS) Replaces SafeStat Safety Measures

• FMCSA/States began to prioritize enforcement with SMS
• SMS results were made available to the public - link: ai.fmcsa.dot.gov/SMS/
• Enhanced enforcement models were implemented
• National training program initiated to support new intervention process
   

April 2010 - November 2010: Carrier Data Review

• Carrier review of violations by BASIC and crash data (April - November)
• Carrier preview of SMS results and safety assessment in BASICs (August - November)

In addition to the CSA program implementation, FMCSA is preparing a "Safety Fitness Determination" rulemaking that will revise the carrier safety rating process to use the CSA safety measures. It will also revise the process to no longer require a comprehensive review, enabling this rating process to affect many more carriers and on a much more timely basis. The proposed version of this regulation is expected to be published in late December 2011.

Brief history of CSA program

• Field tested 2008 – 2010 covering 9 states
  (CO, GA, MO, NJ, MT, MN, MD, KS, DE)
• Carrier preview of CSA ratings – as of 4/2010
• CSA rating methodology refined to better reflect carrier risk exposure (overview presentation: csa.fmcsa.dot.gov/Documents/IntroductiontoSMS2_1.ppt
• Carrier CSA ratings made available to public as of 12/2010 ai.fmcsa.dot.gov/SMS
• Warning letters sent to approx. 25,000 carriers in 2/2011
• State enforcement agencies continuing to expand operations for focused investigations

CSA program - Current Status

• CSA ratings are here to stay and apply to all carriers – although many smaller carriers have insufficient data
• High (poor) ratings – once considered “deficient” and then “alert” – now mean “being monitored”
• CSA ratings are not a safety rating – but can be used to assess safety risk
• Enforcement interventions are accelerating with more flexible tools for focused on-site and off-site investigations
• Rating methodology is still being refined to better identify “systematic breakdowns” in carriers' safety performance

CSA Future Developments

• CSA Part III – the new safety rating process
• Safety ratings to be based on CSA safety measures
• Poor ratings will trigger evaluations
• Poor ratings in key categories – Unsafe Driving or Fatigued Driving – could result in an overall rating of "Unfit".
• Proposed rulemaking expected by November 2011
• CSA ratings as risk measures
• SMS category ratings will continue to improve as “excellent predictors” of crash risk and poor safety performance
• Good CSA scorecards will be essential to conducting business

CSA Impacts

Prepare Your Business

Review Your Data

CSA is now an on-going program and carrier safety measurement data is refreshed monthly. Carriers and drivers must strive to make continuous improvements in their safety performance. Carriers should regularly review their safety measurements available at: ai.fmcsa.dot.gov/SMS.

Manage Unsafe Driving

Driver behavior is a primary contributing factor in truck crashes. Driver behavior management tools that can be considered for helping to reduce risks and crashes include:

• Critical Event Reporting with driver alerts
• Predictive Performance Service
• CSA Safety Performance Service
• In-cab cameras for event recording
• Specialized driver behavior monitoring devices with driver alerts

In-cab driver alerts combined with proactive driver performance management via constructive coaching and feedback can be effective at helping reduce risks. FMCSA studies confirm that drivers who score poorly in unsafe driving measures have a much higher accident rate.

Manage Driver HOS Compliance

Electronic on-board recorders (EOBRs) are proven effective in improving Hours of Service (HOS) compliance management, which is essential in decreasing HOS violations.

HOS audits with EOBRs are electronic, making them:

• More efficient - but supporting documents still needed
• Less likely with CSA intervention models (since roadside violations drive audits)

The Department of Transportation is evaluating wireless roadside inspections and other alternative compliance programs to ensure positive reviews are accomplished (with EOBRs)

Expand Safety Management Program Focus

There are a number of ways that you can help expand your fleet's focus on safety and help manage your CSA safety measures, including:

• A hiring process that uses FMCSA's driver Pre-Employment Screening Program portal
• Internal driver interventions focused on all BASICs
• Focused training in driving skills, job skills, and compliance
• Educate your drivers and staff that good safety measures are mission critical

For more information on EOBR related regulations, see:

• 395.15 Automatic on-board recording devices

DISCLAIMER: Due to the continuous changing nature of government regulations, it is impossible to guarantee the accuracy of the materials contained on this website and Qualcomm does not make any guarantee or warranty as to the materials being correct, complete or up-to-date. These materials are for informational purposes only, are not intended to be legal advice, and do not necessarily reflect the opinion of Qualcomm Incorporated.

Sources

CSA - Comprehensive Safety Analysis. Federal Motor Carrier Safety Administration. Web.
15 June 2010. <http://csa2010.fmcsa.dot.gov>.

Price, Bryan. "CSA 2010: New Safety Measurement System Shows Promise in Operational Model." Transportation Research Board 89th Annual Meeting. Marriott Wardman Park Hotel, Washington, DC.
12 January 2010. Presentation.

"What's New." CSA - Comprehensive Safety Analysis. Federal Motor Carrier Safety Administration. Web. 16 August 2010. <http://csa2010.fmcsa.dot.gov/whats_new.aspx>.

John A. Volpe National Transportation Systems Center. Safety Measurement System (SMS) Methodology. Rep. Volume 2. August 2010. Print.