just the facts - doleco usa · csa overview fmcsa challenge: have a larger impact on a larger...

Just the facts

Thomas BraySenior Editor, Transportation Management

J. J. Keller & Associates, Inc.

CSA

CSA Overview

FMCSA Challenge:Have a larger impact on a larger portion of the motor carrier population (in the past only 12,000/750,000 carriers contacted by FMCSA annually)In the past, only “formal” contact is a Compliance Review (which is a time and manpower intensive process)

CSA Overview

CSA Overview

What is it?It is an enforcement system for:

Tracking, measuring, and evaluating carrier and driver compliance and safetyContacting more carriersRating carriers (will require rulemaking)

CSA Overview

Who is tracked?All carriers that have a USDOT number (regardless of “type”), and their drivers

CSA Overview

CSA process:Data collectionNew Safety Measurement System (SMS)Safety Evaluation (Fitness Determination) based on SMSComprehensive and progressive interventions

Italicized are areas that have been subject to change or discussion

CSA Data

Data collectionAll crash dataRoadside inspection dataIntervention data

CSA Measurement

SMSUses seven “BASICs” (Behavior Analysis and Safety Improvement Categories) to analyze carriersMeasures safety performance using all roadside inspection safety-based violations in “severity tables” and violations discovered during interventionsWeights based time and severity of violations (based on relationship to crash risk)

CSA Measurement

Seven BASICsUnsafe Driving (Parts 392, 397, etc.)Hours-of-Service Compliance (Parts 392 and 395)Driver Fitness (Parts 383 and 391)Controlled Substances/Alcohol (Part 382 and 392)Vehicle Maintenance (Parts 392, 393, and 396)Hazardous Materials Compliance (HM regulations)Crash Indicator

CSA Measurement

Unsafe Driving BASICFollowing too closeSpeeding (amount over limit determines severity)Lane changePassing and turningCareless/recklessStandees forward of lineRRXing

CSA Measurement

Hours-of-Service (HOS) Compliance BASICOperating a CMV when fatiguedOverhours violationsFalse logsLogs not currentForm and manner

CSA Measurement

Driver Fitness BASICMultiple licenseNo licenseSuspended license (reason for suspension determines severity)Class and endorsement violationsUnqualified driverLack of training or experienceUnder age

CSA Measurement

Controlled Substances and Alcohol BASICUnder the influence of drugs or alcoholPossession of drugs and alcohol in CMVConsumption of alcohol within 4 hour of duty

CSA Measurement

Vehicle Maintenance BASICRequired lights not working or obscuredBrakesTiresSuspensionSteeringPeriodic inspectionCargo securement (non-hazmat)

CSA Measurement

Hazardous Materials (HM) Compliance BASIC

PlacardingShipment paperworkEmergency response informationTank certificationHM cargo securement

CSA Measurement

Crash BASICAll DOT recordable crashes are tracked (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)

Note: As part of future updates the FMCSA is studying a process that would consider preventability in the scoring

CSA Measurement

BASIC process overview: Measured and then compared (Scored)

Relevant intervention, inspection, violation, and crash data assigned to the carrier (and driver)Violations and crashes are classified into the correct BASIC Events are time weighted and severity weighted (valued)BASICs are totaled and normalized (BASIC Measure)Carriers are grouped and comparedPercentile in group assigned (BASIC Score)

CSA Measurement

Violation/Crash “valuing”Events are first severity weighted

Violations 1 to 10 (+2 if OOS*)*Applicable in HOS, Driver Fitness, Vehicle Maintenance, and HM BASICs

Accidents 1 to 3

Events are then time weighted0 to 6 months = 3 6 to 12 months = 2 12 + months = 1

CSA Measurement

Violation/Crash “valuing”Event scores are run through formula:

Violation = Severity + 2 if OOS (if applicable*) x time weight

Crash = Severity x time weight

* Applicable in HOS, Driver Fitness, Vehicle Maintenance, and HM BASICs

CSA Measurement

Safeties built inMaximum of 30 severity points in a BASIC from one inspectionStacking provision — in case of multiple violations of same regulation, only counted onceData sufficiency requirements — must be enough data on the carrier or driver to be scored

CSA Measurement

BASIC Measure processEvent values (severity- and time-weighted violations and crashes) in each BASIC are totaledTotal is then divided by a “normalizing factor” to arrive at “BASIC Measure”

CSA Measurement

BASIC Measure Process“Normalizing factors” are:

Unsafe Driving and Crash BASICs: Number of power units x Utilization factor (based on miles per units)HOS, Controlled Substance, and Driver Fitness BASICs: Total of all time weighted driver inspectionsVehicle Maintenance BASIC: Total of all time weighted vehicle inspectionsHM BASIC: Total of all time weighted placardableHM inspections

CSA MeasurementUnsafe Driving / Crash History

Total of Time Weighted Severity Values BASIC Measure =

Number of Power Units (18-month avg.) x Utilization

HOS/ Drugs & Alcohol / Driver Fitness / Vehicle / HM

Total of Time Weighted Severity ValuesBASIC Measure =

Number of Relevant Inspections (Time Weighted)

BASIC Scoring Process: BASIC Measures are compared within “Safety Event Groups”Groups based on:

Number of inspections with a BASIC violation in Unsafe Driving and Drug/AlcoholNumber of driver inspections in HOS and Driver FitnessNumber of vehicle inspections in Vehicle MaintenanceNumber of placardable HM inspections in HM BASICCrash: Number of crashes

CSA Scoring

CSA Safety Event Groups

Unsafe Driving BASIC: Number of inspections with Unsafe violation:Group Combination

Vehicle FleetStraight

Vehicle Fleet1 3 to 8 3 to 42 9 to 21 5 to 83 22 to 57 9 to 184 58 to 149 19 to 495 150 or more 50 or more


Drug/Alcohol BASIC: Number of inspections with a Drug/Alcohol violation

Group Number of inspections with a Drug/Alcohol violation

1 12 23 34 4+

HOS, Driver Fitness, and Vehicle Maintenance: Number of “relevant” inspections

Group HOS Driver Fitness/Veh. Maint.

12345

3-1011-2021-100101-500

501+

5-1011-2021-100101-500

501+


HM: Number of “placardable HM” inspections

Group HM

12345

5-1011-1516-4041-100101+



Crash BASIC: Number of crashes

Group Combination Vehicle Fleet

Straight Vehicle Fleet

1 2-3 2

2 4-6 3-4

3 7-16 5-8

4 17-45 9-26

5 46+ 27+

CSA Scoring

Actual scoring process within the groups:1. Remove carriers that do not have enough

inspections or violations2. Rank all carriers/drivers in group

ascending order by the BASIC Measure1. Lowest (best) measure = 0%2. Highest (worst) measure = 100%

3. Assign remaining percentiles (BASIC Scores)

CSA Evaluation

Carrier scores are then compared to “intervention thresholds” in all BASICsThresholds based on carrier type and BASIC

CSA Evaluation

BASIC Passenger Carriers

HazMatCarriers

PropertyCarriers

Unsafe DrivingHOSCrash 50 60 65Driver FitnessDrug and AlcoholVehicle 65 75 80HM 80 80 80

Intervention thresholds:

CSA Evaluation

Investigations impact evaluation as well“Poor results” from FMCSA investigations are “fed” back into the system and used during evaluation“Poor results” based on violations of regulations discovered during investigations (audits)Will not “change” BASIC Score, but can “flip” a BASIC Evaluation to “over the threshold”

CSA Evaluations

Below all thresholds, no action takenCarrier can still be investigated for a complaint, based on a crash or series of crashes, or carrier request

Above the threshold, carrier can expect an intervention of some typeWell over 50 percent of all carrier investigations are initiated based on CSA BASIC Scores alone

CSA Interventions

Interventions Warning letterTargeted roadside enforcement (ISS recommendation of “Optional” or “Inspect”)Focused off-site investigationFocused on-site investigationComprehensive review (compliance review)Cooperative (corrective) safety planNotice of ViolationNotice of Claim/Consent Agreement

CSA Interventions

Which intervention? Depends on:Which BASIC(s) the carrier is over the thresholdHow high the carrier’s scores are in the BASICs that are over the thresholdHow many BASICs the carrier is over the thresholdCarrier’s enforcement history

Carriers that have been intervened with recently will not be subjected to another intervention

CSA Measurement

Drivers Safety Measurement System (DSMS) in place

Use same principles as Carrier SMS*Violations used, time weighting, and peer grouping are different

Scores are completely confidentialDriver “evaluation” only occurs during carrier intervention

Intervention based on past violations (only NOV and NOC used with drivers)

CSA Improving Scores

Learning the systemLearn the SMS process, specifically:

Severity weighting (all violations count, but the question is “how much!”)Time weightingBASIC Measure calculation (which BASICs are helped by good inspections)


View your existing data through the “CSA lens”Existing data can be viewed at:

http://ai.fmcsa.dot.gov/FMCSA Portal

https://portal.fmcsa.dot.gov/


Learning the systemLearn the high severity driver violations:

Reckless drivingJumping an out-of-service orderOperating a vehicle while ill, fatigued, or under the influenceViolating hours-of-service limitsFalse logsDriver having multiple licensesDriving a CMV while disqualified


Learning the systemLearn the high severity vehicle violations:

Required light not operatingBrake defectsTire defectsSuspension defectsSteering system defects


Get good data going into the systemGood data means “no violation” inspections and no preventable crashesReview all roadside inspections to check for errorsMake sure preventive maintenance program is effectivePrepare drivers for roadside inspections


Get “wrong” data out of the systemLearn and be willing to use the appeals processes:

Federal DataQs (https://dataqs.fmcsa.dot.gov/login.asp)

State Motor Carrier Safety OfficeCVSA Complaint Process


Avoid inspections conducted due to pre-existing violations (“foolish inspections”):

A moving violationSpeedingOther traffic violations

Operating with a violationLights not workingOverweight

CSA Improving ScoresTrain and track drivers on:

CSADefensive drivingCompliance with the safety regulations (hours, qualifications, etc.)Vehicle inspectionRoadside inspections

just the facts - doleco usa · csa overview fmcsa challenge: have a larger impact on a larger...

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