On December 10, 2010, a pilot enforcement program known as Comprehensive Safety Analysis 2010 (CSA 2010) was relaunched nationally and became Compliance, Safety, Accountability or more commonly, CSA.
The heart of CSA is the Carrier Safety Measurement System (CSMS). Another part is the Driver Safety Measurement System (DSMS), which measures the safety of individual commercial motor vehicle (CMV) drivers.
The Driver Safety Measurement System is designed to identify drivers with a history of safety violations. The information is used to target enforcement when an investigator visits a motor carrier during a compliance review or other intervention. This information is not provided to the public.
The SMS is based on available roadside safety performance data. This roadside data is used to rank operational safety in six Behavior Analysis and Safety Improvement Categories (BASICs) and a crash involvement (Crash Indicator). Law enforcement may use rankings within these BASICs and the Crash Indicator to select organizations for further investigation or selection for additional roadside inspections. As this information is public (except for the Crash indication), anyone including shippers, insurance carriers, job candidates, etc., can look at the BASICs as well.
If a certain score (or threshold) is passed, the basic may be flagged.
Flagged BASICs can result in DOT Audits or investigations that can last from several hours to several days, or even weeks, depending on the size of the fleet and the scope of the investigation. If any regulatory discrepancies are discovered during an audit or investigation, the DOT can respond in a number of ways ranging from fines, to issuing a downgraded safety rating, or “orders” to comply or to develop a safety plan.
Essentially, the results of every Roadside Inspection (RI) are important because the safety performance data from the inspection can affect the BASIC or CSA score.
How do I get my CSA scores down?
“I am asked over and over again, ‘how do I get my CSA scores down?’ Generally speaking, you have to control your drivers. You can’t just turn them loose and let them do whatever they want to do. Every time they get written up by the police at a scalehouse, or on the side of the road, your score goes up. You need to be in your drivers’ ears all the time. It’s not too much more complicated than that.”
In addition, I recommend that you—
1. Become aware of your CSA scores. The CSA scores can be checked at:
2. Have a process in place for immediate repair of any vehicle safety defects or faults. A successful maintenance program should be 80% proactive or preventative, and 20% reactive. Catch problems when they are small and manageable.
3. Make sure your driver(s) understand Hours of Service rules and regulations (Part 395).
4. Make sure drivers are well-rested and alert when they drive.
5. Hire well. Do good background investigations and drug and alcohol testing, if required. Road test drivers before hire and do driver check rides at least annually.
6. Have a set of written standards for your fleet. Document driver and vehicle expectations. Provide drivers with safety training, manuals, guides and training. Monitor driving performance and give feedback when necessary.
7. Learn and know the DOT regulations. Know what the regulations expect of you and your team. Then communicate your expectations, on a daily basis.
Organizations with low CSA scores do all of the above and more.
John Taratuta is an independent Risk Engineer. (989) 474-9599