Just when you think you have a handle on trucking regulations, they change. First, it was ELDs. Now, it’s CSA scores. In this article, we’ll walk through the CSA program at a high-level, the timeline and rationale of the CSA score changes, and the expected changes. For an in-depth look at the FMCSA’s CSA program, check out our complete guide to CSA scores.
To jump directly to the CSA program key event timeline and expected changes, click here.
What is the CSA program?
Let’s start with some basics about the CSA program. The Compliance, Safety, Accountability (CSA) program was created by the FMCSA to help identify high-risk motor carriers. There are two main goals of the CSA program:
- Prevent accidents through proactive intervention
- Hold carriers accountable for safety standards
The Safety Measurement System (SMS) was created to track and measure key data points that are thought to help measure risk. The data used includes state-reported crashes, roadside inspections, and investigation results from the last two years. Data is assigned to a carrier’s DOT number and is updated once per month.
According to the FMCSA’s CSA factsheet, the SMS considers:
- The number of safety violations and inspections
- The severity of safety violations or crashes
- When the safety violations occurred, with recent events weighted more heavily
- The number of trucks/buses a carrier operates and the number of vehicle miles traveled
- Acute and Critical Violations found during investigations
This data is then organized into seven categories known as the Behavior Analysis and Safety Improvement Categories (BASICs).
How to check your CSA score
Your CSA score will often change, so it’s a good idea to continually monitor it. You can check part of your CSA score by going to the FMCSA website and entering your DOT number.
To view complete data, you’ll need to log in. The Crash Indicator and Hazardous Materials (HM) Compliance BASIC’s are hidden from public view. To log in, you’ll need to enter your PIN provided by the FMCSA. You can request a PIN here.
The Crash Indicator and Hazardous Materials (HM) Compliance BASIC’s were hidden from public view in December of 2015 by the FAST Act highway bill. The reasoning was due to industry concerns about whether the carriers’ safety performance was being accurately measured.
What happens if you have a bad CSA score?
While there’s no minimum CSA score point total that guarantees the FMCSA will take action, there are certain “Intervention Thresholds” used to prioritize interventions.
So put simply, if your CSA score is above a certain threshold, the odds of an FMCSA warning letter or intervention increase. The intervention thresholds vary by cargo type and BASIC, as shown below:
|Unsafe Driving, Crash Indicator, HOS Compliance, Vehicle Maintenance, Controlled Substances/Alcohol||50%||60%||65%|
Some issues will lead to corrective action; worse ones will mean fines. The worst-case scenario is getting an out-of-service order that shuts down your operation. These are decided on a case-by-case basis by the FMCSA.
Can you challenge a CSA violation or fine?
Yes, according to Travis Baskin, Head of Regulatory Affairs at KeepTruckin. You can use the DataQs system. Baskin says, “It’s a simple process set up for carriers to challenge violations logged against them during inspections, audits, or compliance reviews. You can also submit supporting documentation that may not have been available at the time so that the appropriate officials have all they need to make the right decision.”
What should I do if I get a warning letter?
Travis Baskin says, “While you don’t have to respond to a warning letter directly, you should take steps to address the concerns raised by one. For example, if you receive a warning letter highlighting concerns regarding the Hours-of-Service BASIC, you should focus efforts on training drivers on the Hours-of-Service regulations and guidance and on the proper use of ELDs for keeping Records of Duty Status.”
The CSA score story so far
2010: CSA launches. All BASIC scores are available to the public.
December 2015: FAST Act requires the FMCSA to remove all SMS percentile rankings from public view and orders a review of CSA by the National Academies of Science (NAS)
March 2016: FMCSA makes required changes and makes 5 of the 7 BASICs publically available. The Crash Risk Indicator and Hazardous Materials BASICs remain hidden and still are as of January 2020.
2017: The National Academies of Science (NAS) issues a report on their review of the CSA program. Here are the summarized findings of the report:
- Investigate a new statistical model, within the existing structure of SMS, over the next two years. FMCSA should evaluate the model’s effectiveness at identifying motor carriers for intervention to inform the decision of whether to implement this new model.
- Improve the quality of Motor Carrier Management Information System (MCMIS) data that feeds SMS by continuing to collaborate with States and other agencies. This effort should focus on data related to crash reports and carrier exposure (e.g., Vehicle Miles Traveled, Power Units, etc.).
- Explore ways to collect additional data that could enhance the recommended methodology for safety assessment.
- Make user-friendly versions of the MCMIS data file, and computer code used to calculate SMS results, available to the public.
- Conduct a study to better understand if percentile ranks should be available to the public.
- Use absolute measures, in addition to relative percentiles, to determine which carriers are prioritized for intervention.
Check out the full findings from the NAS study.
June 2018: The FMCSA files a report to Congress outlining changes to the SMS system based on the NAS report findings.
September 2018: FMCSA starts “small scale” testing the new scoring system.
September 2019: U.S. DOT’s Office of Inspector General (OIG) completes its required review of the FMCSA’s corrective action plan and states that the FMCSA’s plan “mostly addresses” CSA program’s deficiencies.
The current status (as of January 2020): The FMCSA is still determining whether it is ready to proceed with full-scale testing. This decision is expected by September 30th of 2020.
What’s expected to change?
The changes that are coming to the CSA are the biggest since it was launched in 2010. Its focus, which was on predicting accidents, is now on prevention and creating a safety culture. This includes looking at new types of data, such as driver turnover, driver compensation, and cargo type.
The new scoring system should be much easier to understand. As you might expect, there is a new acronym involved. Item Response Theory (IRT) is replacing the old SMS. IRT is basically the new math, and it is replacing things like the old weighting system in SMS that was found to be lacking.
What this means on a practical basis is:
- A single CSA BASIC score will replace all the complicated weights, points, and BASIC measures.
- Percentile ratings are expected to go away.
- Violations will not be weighted by how recent they are.
- Different state enforcement levels will be taken into account (if you drive in a tough enforcement area, you won’t be rated below someone who is less safe but drives where enforcement is less strict).
- If you have excellent marks in all but a couple of areas, your fleet’s overall score won’t be as bad as under the old system.
- Things like power units, driver count, inspection count, and miles traveled will be taken into account to make a more level playing field between carriers. It should even consider the fact that northern carriers drive in icy winter weather.
Again, full-scale testing hasn’t even started, so none of this is final.
The FMCSA is currently testing the new (IRT) system beside the old (SMS) one at a “small scale.” If the small-scale tests go as expected, the FMCSA will release a timeline for “ full-scale testing.” At the completion of that test, the official changes will be announced.
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