Presented by Mark CatlinJ. J. Keller & Associates, Inc.
September 2010
No new CSA driver regulations
No new CSA vehicle regulations
NO new CSA recordkeeping regulations
Not a system to “throw” 250,000 drivers off the road
It is an enforcement system for:› Tracking, measuring, evaluating, and
intervening with motor carriers (replacement for SafeStat)
› A new method for rating carriers (will require rulemaking)
All interstate carriers that have a USDOT number (regardless of “type”), including:› For hire (common or contract)› Private› Construction› Utility› Ag exempt› Non-CDL
Designed to more effectively target carriers with problems
Allows FMCSA and States to have more tools to intervene with “potentially unsafe” carriers
Uses all data from the roadside to identify potential problems
Will mean more potential enforcement against poor performing carriers
Recently announced delay in implementation until 2011
Today’s Measurement System: SafeStat
CSA 2010 SMS
Organized by four broad categories - Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management
Organized by seven specific BASICs
Identifies carrier for a compliance review (CR) Identifies safety problems to determine whom to investigate and where to focus the investigation
Uses only out-of-service (OOS) and moving violations from roadside inspections.
Uses all safety-based roadside inspection violations
No impact on safety rating Used to propose adverse safety fitness determination based on carriers’ current on-road safety performance (future)
Violations are not weighted based on relationship to crash risk
Violations are weighted based on relationship to crash risk
Assesses carriers only Assesses carriers and drivers – the driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations
No change:› Roadside inspections and associated
violations› DOT-recordable crash reports› Intervention violations
SMS BASICs focus on behaviors linked to crash risk
1. Unsafe Driving (Parts 392 & 397)2. Fatigued Driving (Hours-of-Service);
Parts 392 & 395)3. Driver Fitness (Parts 383 & 391)4. Controlled Substances/Alcohol (Parts 382 & 392)5. Vehicle Maintenance (Parts 393 & 396)6. Cargo-Related (Parts 392, 393, 397 & HM)7. Crash Indicator
Unsafe Driving BASIC› Following too close› Speeding› Lane change› Passing and turning› Careless/reckless› RRXing
Unsafe BASIC:› Now uses “utilization factor” in
combination with power units during the normalizing process
› Peer groups (now called safety event groups) based on number of inspections with Unsafe Driving violation rather than power units
› Speeding broken into 4 violations (based on amount over the limit)
Fatigued Driving BASIC› Operating a CMV when fatigued› 11, 14, 60/70 violations› False logs› Logs not current› Form and manner
Driver Fitness BASIC› Multiple license› No license› Class and endorsement violations› Unqualified driver› Lack of training or experience› Under age
Controlled Substances and Alcohol BASIC› Under the influence of drugs or alcohol› Possession of drugs and alcohol in CMV› Consumption of alcohol within 4 hour of
duty
Drug and Alcohol BASIC› Now uses relevant (driver) inspections to
normalize the data (rather than power units)
› Peer groups (now called safety event groups) are based on number of inspections with Drug and Alcohol violations rather than power units
Vehicle Maintenance BASIC› Required lights not working or obscured› Conspicuity marking inadequate› Brake› Tire› Suspension› Steering› Periodic inspection
Cargo-related BASIC› Hazmat (especially securement)› Failure to inspect cargo› Cargo securement
Cargo-Related BASIC› Size and weight removed from scoring,
however…
Crash BASIC› DOT recordable crashes (preventability is
not a factor, all crashes count)› Severity weighted based on injury or
fatality vs. no injury and the release of a hazardous material (cargo)
Crash BASIC› Now uses “utilization factor” in
combination with power units during the normalizing process
› Peer groups (now called safety event groups) based on number crashes rather than power units
› Preventability is not considered, all crashes are scored in the system
All BASICs› Severity weights update in all but Crash
BASIC
New intervention thresholds
BASIC Passenger HazMat Property
Unsafe DrivingFatigued DrivingCrash
50 60 65
Driver FitnessDrugs/AlcoholVehicle Maintenance Cargo-Related
65 75 80
• Intervention process triggered by: – One or more deficient BASICs,– High crash indicator, or – Complaint or fatal crash.
• Intervention selection influenced by:– Safety performance,– HM or passenger carrier, and– Intervention history.
No change› FMCSA reinforced that warning letter will
be going out to all carriers with a deficient BASIC in December
› Interventions fully operational nationwide in 2011
No overall structural changes, CSA still uses:› Data Collection› Safety Measurement Systems (SMS)› Safety Evaluation› Progressive interventions
FMCSA still referring to program as “CSA 2010”
SMS replacing SafeStat and intervention rollout timeline stayed the same (begins November/December 2011)
Rulemaking related to new audit and rating process set for release Spring 2011
• More Carriers will fall into the Marginal and Unfit Categories
• More Carriers will have some type of Interventions
• Drivers will receive more scrutiny• Companies will need to carefully screen
new drivers• Greater need for “good” data/ “clean”
inspections
Educate Yourselves and Your Employees:› Understand the SMS Methodology and the BASICs› Check the website for information and updates (
http://csa2010.fmcsa.dot.gov)› Raise awareness that every inspection counts and every
violation counts Ensure compliance
› Review inspections and violation history over the past 2 years › Address safety problems now› Educate drivers about how their performance impacts their own
driving record and the safety assessment of the carrier Check and update records
› Motor Carrier Census (Form MCS -150)› Routinely monitor and review inspection and crash data› Question potentially incorrect data (DataQs:
https://dataqs.fmcsa.dot.gov)
Learn the SMS process, specifically: Severity weighting (nearly all on-road
violations count, but how much?) Time weighting (time reduces violation and
crash values) BASIC Measure calculation (specifically,
which BASICs are helped by good inspections and which can only be helped by stopping violations)
Learn the high severity driver violations and take steps to avoid them:
Jumping an out-of-service order Reckless driving Operating a vehicle while ill, fatigued,
or under the influence Texting while driving Violating hours-of-service limits False logs Moving violations Driver having multiple licenses Driving a CMV while disqualified
Learn the high severity vehicle violations and take steps to avoid them:
Operating an out-of-service vehicle Tire defects Suspension defects Steering system defects Required light not operating Brake defects Cargo not secured
Learn the high frequency driver violations and take steps to avoid them:
Log violation, general (183,171 severity 2) Speeding (129,714 severity 1, 4, 5, 7, or 10) Log not current (129,689 severity 5) No med certificate in possession (100,257
severity 1) Non-English speaking driver (72,868 severity 4) Over 14 hours (66,942 severity 7) Failure to use seat belt (53,666 severity 7) Over 11 hours (37,178 severity 7) False log (36,291 severity 7) Expired medical certificate (32,697 severity 1)
Learn the high frequency vehicle violations and take steps to avoid them:
Required light inop. (378,730 severity 6) No or defective light (276,381 severity 6) Brake hose rubbing (214,504 severity 4) General maintenance (198,704 severity 2) Tire under 2/32 (195,456 severity 8) Oil/grease leak (171,964 severity 3) Brake out of adjustment (154,749 severity 4) No periodic/annual inspection (146,539 severity 4) Extinguisher violation (144,751 severity 2) No brake lights (106,588 severity 6)
BASIC scores surprisingly poor Many inaccuracies in SMS reporting Some states are several months behind in
updating SMS data Managing CSA 2010 (monitoring scores,
filing appeals, etc.) very time consuming Difficult to pinpoint issues to a region or
location Good record-keeping is essential
Most significant regulatory action in over 20 years
Positive results on safety, but burdensome to carriers
New enforcement model impacts all carriers
Maintaining programs that address each BASIC is the key to avoiding interventions, but carriers must also establish programs and dedicate resources to “manage” CSA 2010.
Having visibility into potential issues prior to SMS reporting will provide carriers a significant advantage
Unsafe drivers will create significant liability for carriers
Changes to the scoring methodology, enforcement actions and other program elements should be expected
Thank you for joining us!
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