Risky Business

CSA 2010...from Shelly w/ CIS...What is it and why do I care?

By Shelly Benisch, CIC
Posted Nov 12th 2009 8:24AM

Hi everyone, I just attended conferences on CSA 2010 last week in Chicago & thought I’d share with all of you.   I know it’s sometimes difficult to stay on top of changes, so here’s a summary I put together:

CSA 2010 …..What is it?

This is important to you because it’s a game changer in how FMCSA regulates you AND your Owner Operators.   It will affect everyone with a CDL and every Carrier with a unit over 10,001 GVW.

CSA 2010 -   Comprehensive Safety Analysis is an FMCSA initiative to improve safety that begins July 2010

Goal of CSA – Improve truck & bus safety to reduce crashes, injuries & fatalities.  

The way they plan to implement this is thru:

The Safety Measurement System , which eliminates Safestat and is how they’ll track everyone.   

Function of SMS:   Reviews on-road safety performance of carriers & drivers to identify those that need interventions, resolve specific safety problems to see what problems are improving or getting worse.

There will be 2 distinct safety measurement systems, one for motor carriers and one for individual CDL drivers.   

Recent roadside violations & those that correlate most with crashes will be weighted more heavily than others.   Everyone will be compared to their peers, with more emphasis on individual drivers.

How it works:   Every month SMS will measure the previous 2 years of roadside violation & crash data & calculate a score in 7 safety behavior areas called BASICS (Behavioral Analysis & Safety Improvement Categories).   This is what they’ll look at:

Unsafe Driving               Speeding, reckless, lane change, inattention

Fatigued Driving          HOS, logbook & operating while ill or fatigued

Driver Fitness             Unfit drivers based on driver’s license as well as  

                                   medical qualifications

Alcohol & Substance    Use or possession of alcohol, illegal drugs

                          or misuse of prescription or other meds

Vehicle Maintenance    Brakes, lights, mechanical defects & failure

                           to make repairs

Loading/Cargo             Improper Load securement, cargo retention,

                            size & weight & also haz mat handling

Crash                          Histories or patterns of high crash involvement,

                                   including frequency & severity, based on info

                                   from state reported crashes

Violations are based on the relationship to crash risk.   Your score for each BASIC depends on the number of adverse safety events, their severity, and when they happened (more recent events weighted more heavily.) Then you’re placed in your peer group of similar size or number of inspections.   The score will be 1 – 100…1 is good, 100 is bad.

The major differences between the old Safestat & CSA 2010:

If one or more of your BASIC percentiles exceed a threshold, you then become a candidate for an intervention.   It starts with a Tier 1 warning letter and targeted roadside inspections.   If the score continues to rise in the monthly “formula”, Tier 2 begins an investigation that includes a notice of violation, cooperative safety plan, Off-site and On-site investigations.

CSA 2010 is proposing a Safety Fitness Determination (SFD) towards the end of 2010.   You will then have 3 possible Safety Fitness Determination ratings which are “Continue Operations”, “Marginal” or “Unfit”.   (So “Conditional” & “Unconditional” will be phased out.)

If a rating continues to deteriorate, SMS will begin a Tier 3 prescriptive for Notice of Claim which includes the “Unfit” designation.    (FMCSA is estimating a number of carriers are already in this category but have not yet been informed because SMS is going back in time and not obligated to follow each tier successively.)    Tier 4 imposes a “Suspend Operations” notice which is irrevocable.

FMCSA has estimated that 175,000 carriers and/or drivers will lose their jobs when CSA 2010 becomes effective because the “formula” is designed so that 30% will eventually be deficient.  

Today there are 12,000 compliance audits per year.   With CSA 2010, there will be an estimated 175,000 interventions per year.  

Remember there are 2 sides to SMS…the Carrier AND the driver.   This new format scoring currently favors a driver over a carrier.

For example, if a Carrier hires an Owner Operator with a bad score, then he leaves 2 weeks later, that score still stays with the Carrier for 3 years.    There are complaints that good inspections result favorably for the driver, but doesn’t “credit” the Carrier in return.

 

…I could have written several more pages on this subject such as how various offenses are calculated.     If you want more info, let me know as we do have feedback from the test states.   Also, CSA2010’s very lengthy summary is:

http://csa2010.fmcsa.dot.gov/Documents/SMSMethodologyVersion1_2Final_2009_06_18.pdf

Sorry for such a longwinded blog this week...I tried to condense the CSA2010 97 page webpage...it was the best I could do in short space!

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Shelly Benisch, CIC

Commercial Insurance Solutions, Inc. (CIS)

"We make your Expediting Insurance Easy!"

[email protected]    www.MyCISagent.com