[ / MARVIN JOHNSON &ASSOCIATES csa guide

How CSA works

The CSA system is a complicated one, but with a little research you can learn how the system functions and use it as a tool to improve your operation. The following pages will explain the program and give you some best practice tips to help control and improve your scores.

If you have further questions, please feel free to contact a member of our Safety & Loss Prevention Team for assistance.

Severity points

  • Some violations are more serious than others, and severity weighting takes these differences into account
  • Severity weighting accounts for the level of crash risk relative to the other violations used in the same BASIC
  • Measures how likely it is that the violation is going to cause an accident or possibly make the outcome of the accident worse
  • If the violation results in an out of service then two additional points are added to the severity score
  • Severity points range from 1 to 10
  • The CSA methodology listed on the CSA website contains a listing of all violations with their corresponding severity weights

Time Weighting:

  • Rewards you for improvements – as violations age they score fewer points against you
  • The time weight is a multiplier as follows:
  • 0 to 6 months = x3
  • 6+ to 12 months = x2
  • 12+ to 24 months = x1

Example Score Calculations:

Violation occurred two months ago for log book not current:

5 (severity points) x 3 (time weight) = 15 points for violation

Same violation after 8 months:

5 (severity points) x 2 (time weight) = 10 points for violation

Same violation after 12 months:

5 (severity points) x 1 (time weight) = 5 points for violation

Peer Comparison:

  • Your company scores in each BASIC are compared to other carriers in your peer group (also known as Safety Event Grouping) based on number of units and/or number of relevant inspections depending on which BASIC you are looking at
  • The score you can see for each BASIC is how you rank against your peers in your group
  • The higher the score the worse you are doing
  • For example, a score of 85% means that 85% of the carriers in your peer group are doing better than you
  • The peer rankings for drivers are not available to the public in the current CSA system
  • The new SMS system preview allows you to download all of the carriers in your peer group and see your ranking and score against theirs

Intervention Thresholds:

  • If your BASIC scores are above a threshold it will lead to some type of intervention from FMCSA
  • The threshold levels for various types of carriers are listed in the table below:

BASIC / General / HM / Passenger
Unsafe Driving / >= 65% / >= 60% / >= 50%
HOS Compliance / 65 / 60 / 50
Driver Fitness / 80 / 75 / 65
Controlled Substances & Alcohol / 80 / 75 / 65
Vehicle Maintenance / 80 / 75 / 65
Hazardous Materials / 80 / 75 / 65
Crash Indicator / 65 / 60 / 50

Intervention Tools:

  • FMCSA now has many more ways to interact with a carrier other than just the full compliance review
  • These new tools give them the flexibility they need to contact more carriers earlier in the process before their safety and compliance issues get out of control and require much more effort to correct

Available Intervention Tools:

Early contact – meant to notify the carrier of problem areas and monitor to check for improvements

  • Warning letter
  • Carrier access to safety data
  • Targeted roadside inspections

Investigation – allows FMCSA to review a single area or the full compliance program based on the carrier’s specific deficiencies

  • Offsite – for minor recordkeeping issues
  • Onsite focused – when a carrier only has 1 or 2 issues
  • Onsite comprehensive – when a carrier has issues in several areas

Follow on Actions - When violations are found during an intervention several things could happen between FMCSA and the carrier and/or driver

  • Safety Management Plan – carrier agrees to work with FMCSA to develop a corrective action plan to improve deficient areas
  • This is the required method of requesting a safety rating upgrade
  • May also include ongoing monitoring and communication between the FMCSA investigator and the carrier
  • Notice of violation – carrier and/or driver is notified of the violation and how much a fine will be if the violations are not ceased and corrected
  • Notice of claim – carrier and/or driver is fined
  • Out of service order – carrier or driver is not allowed to operate until violations are corrected

Interventions with Drivers

  • When FMCSA takes an intervention with a carrier they will review the safety history of the drivers working there
  • The history will include events at other carriers the driver has worked for as well as the current carrier
  • Drivers who have a pattern of violations who have continued to violate the rules could have action taken against them by FMCSA
  • Action could be a notice of violation or a notice of claim
  • FMCSA also has the authority to declare a driver an imminent hazard and disqualify the driver
  • Drivers will not be able to just move on to another carrier and continue the same pattern of bad behavior with no consequences
  • Carriers can also access a driver’s history through the Pre-Employment Screening (PSP) reports for a $10 fee per report

The 7 BASICs:

  • Each violation is assigned into one of seven areas called Behavior Analysis Safety Improvement Categories (BASICs)
  • The BASICs were listed on the previous page along with their corresponding threshold levels
  • The following pages will explain what each BASIC consists of and tips for controlling your violations in each area
  • Unsafe Driving and HOS Compliance are considered “stand alone” BASICs meaning that being over the threshold in either of these areas will lead to some type of intervention
  • Note that according to records collected from CVSA inspections, 80% of inspections are triggered by an obvious driver related violation or vehicle defect
  • Focusing on these types of violations will go a long way towards controlling your scores in all of the BASICs

unsafe driving basic

Key Points to Remember:

  • A high Unsafe Driving score tends to have a domino effect and leads to violations in other areas
  • For example, driver is stopped for speeding then written up for hours of service, or maintenance violations
  • To avoid the domino effect control your speed and other obvious violations and vehicle defects
  • Drivers do not have to be issued a “ticket” or be convicted of the offense for it to count against the company’s and the driver’s CSA scores
  • Violations in the driver’s personal vehicle do not count towards CSA
  • Violations that are not part of a CVSA inspection do not count
  • For example a police officer issues a citation for speeding in a commercial vehicle, but no inspection is conducted along with the traffic stop - This data would not go into the CSA scores
  • Only violations that are listed on a CVSA inspection report count

Strategies for Success:

  • SLOW DOWN – 80% of inspections are conducted because of an observable defect or violation
  • Speeding and not wearing a seatbelt are examples of an observable violation
  • Realize that going a few miles per hour over the speed limit will not gain any meaningful amount of time on a trip, but will get you stopped and inspected
  • Watch for speed zone transition areas such as construction zones, entering towns, school zones, etc.
  • Stay out of the third lane – in many states it is illegal for trucks to run in any lane past the second lane
  • Even if it is not illegal where you are it will still draw unnecessary attention from a police officer
  • Always leave a safe and legal following distance
  • Always wear your seatbelt – this is a 7 point violation
  • Never text or talk on a hand held cell phone while operating a CMV
  • These violations carry a 10 point severity weight which is the highest possible points
  • Companies should have policies in place to control driver behavior in these areas
  • In the past most company policies only addressed violations that resulted in a conviction
  • Policies should be revised to address all violations in order to control the score in this BASIC

hours of service compliance

Key Points to Remember:

  • Any violation that is listed on a CVSA inspection will count against your CSA scores – not just out of service violations as in the past
  • Record of Duty Status Not Current is the most common violation in this BASIC
  • This violation commonly accounts for 30-50% of a carrier’s violations in the HOS Compliance BASIC
  • “Current” means your log must be completed up to your last change of duty status at all times

Strategies for Success:

  • Always be current on your log book
  • The old adage “run legal and log it like you ran it” will keep you out of trouble in this area
  • Drivers should start the week off right by leaving early enough to arrive at their first destination with enough time to take a 10 hour break
  • Drivers who do this average more money per week and are less stressed doing it
  • This is a common tip from drivers with millions of accident free miles – they probably know what they are talking about
  • SLOW DOWN – 80% of inspections are conducted because of an observable defect or violation such as speeding
  • If you are stopped for speeding many times that leads to a log book violation such as not being current
  • Dispatchers and load planners must be trained and proficient on the hours of service regulations, and allow enough time for the load to be delivered legally and safely
  • Dispatchers must seek out input from drivers about issues such as normal waiting, loading and unloading times at various locations and use this information to make better load scheduling decisions
  • Electronic logs are proving to be a very effective way to control the scores in this BASIC
  • E-logs virtually eliminate violations for not being current, not having a log, and falsification
  • Contrary to the old “I can’t make any money running legal” argument - Feedback from companies using E-logs shows that most drivers average more miles per week than they did using paper logs

driver fitness

key points to remember:

  • This is not a physical fitness test for drivers
  • Inspectors are not being issued body fat calipers, blood pressure cuffs, or roadside treadmills to check driver “fitness”
  • Violations occur in this category when the driver either does not have the proper qualifications to drive the vehicle or does not possess proof of these qualifications such as the violations listed below
  • Example violations could be:
  • Driving while disqualified
  • Driving a CMV without a CDL
  • No medical certificate in driver’s possession
  • Expired medical certificate
  • Not medically qualified
  • Non-English speaking driver

strategies for success:

  • Drivers must maintain a current address on their license at all times in order to receive notices from their state regarding their status on items such as driver physicals and proof of financial responsibility
  • These notices generally are not forwarded and failure to respond often leads to a suspension
  • Best Practice - Require all change of address notifications to be submitted to the safety department at your company then they can be distributed to other departments from there
  • When a change of address is brought in the driver should be required to update their address with the BMV within 30 days
  • Do not wait until the last minute to renew your DOT physical
  • Allow enough time just in case there is a new issue such as blood pressure, vision or sleep apnea that must be addressed
  • To be in compliance, motor carriers must order a CDLIS MVR on the driver to verify their medical examination expiration status prior to allowing them to drive a CMV
  • Drivers must always carry their medical certificate with them until February 2015 (this was delayed due to some states not placing the status on the MVR)
  • Carriers should perform the required annual review of each driver’s record – do a thorough review of all of the records obtained
  • MVR and records related to accidents or other safety violations
  • Certification of violations completed by driver
  • Check for current address on file
  • Carriers should require drivers to bring all notices received from the BMV into the safety department for review

controlled substances & alcohol

key points to remember:

  • Drivers could have violations in this category that previous employers may not be required to tell you about or neglect to tell you in normal background investigations
  • Drivers may have violations in this category that may not show up on an MVR due to some form of plea deal or the lack of a conviction
  • Violations in this BASIC demonstrate that the driver makes reckless decisions and is willing to put themselves and the entire company at risk
  • Example Violations:
  • Possession/use/under the influence of alcohol within 4 hours of duty
  • Use or possession of controlled substances
  • Testing program violations from an intervention could also go in this BASIC

strategies for success:

  • Always order the Pre-Employment Screening Program (PSP) report on a driver before hiring
  • Any violations in this category will show up on the PSP for three years even if they do not show up on an MVR or background check
  • Have a zero tolerance policy for any violations of controlled substance or alcohol regulations and do not make exceptions to the policy
  • Have a solid testing program in place to discourage use by drivers
  • Train all driver supervisors so they can recognize when a driver is under the influence of controlled substances or alcohol
  • Train drivers so they understand when they are required to be ready for duty so illegally consuming alcohol does not become an issue
  • Train drivers on the fact that alcohol can never be possessed anywhere in the unit unless it is part of the load listed on the shipping papers

maintenance

key points to remember:

  • 80% of roadside inspections are conducted due to an observable defect or violation such as an inoperable light, cracked windshield, improper load securement, etc.
  • Most vehicle violations are found by an inspector while conducting a simple level 2 inspection – the inspector simply walks around the vehicle without getting under it and finds the violations
  • Many drivers have never been trained to conduct a thorough vehicle inspection so train your drivers on what to look for
  • Beginning in December 2012 cargo securement violations were moved into this BASIC
  • Example violations:
  • Inoperable lights
  • Tire tread depth or air leaks
  • Brake defects or out of adjustment
  • Operating a CMV without a periodic inspection
  • Discharged or unsecured fire extinguishers
  • Damaged load securement device
  • Insufficient number of securement devices
  • Failure to prevent cargo shifting
  • Leaking, spilling, blowing, or falling cargo
  • Loose or unfastened tiedown

strategies for success:

Maintenance Program Strategies for Success:

  • Have prospective drivers conduct a vehicle inspection as part of a road test to gauge their knowledge about the process and set the example from day 1
  • Share CSA inspection data with your mechanics and drivers - adapt the maintenance schedules to address weak areas
  • Train your drivers on the proper procedures for doing a vehicle inspection
  • Answer this question – if you did not train the driver on this who did?
  • Each time a piece of equipment is brought into your shop inspect all of the lights – it only take a few seconds and will catch many violations before they lead to a bad roadside inspection
  • Drivers – each time you get out of your truck turn on all of your lights and flashers to do a quick light check
  • It only takes a few seconds and you can correct an issue before it becomes a problem that counts against your CSA record
  • Keep your equipment clean, especially of any fuel or grease – inspectors are more likely to inspect a dirty truck because it appears poorly maintained

Cargo Securement Strategies for Success:

  • Companies should train their drivers on how to secure items that they haul frequently
  • Take pictures of actual loads that you haul to show the proper securement technique
  • When in doubt throw another strap or chain on it
  • Never use just one securement device to secure anything, always use at least two
  • Using at least two securement devices within the first 10 feet of each article will avoid many load securement violations
  • Become familiar with 393.110(b) – how to secure cargo that is not blocked to prevent forward movement
  • If an article is not touching the header board, bulkhead, or other cargo in front of it this rule will apply
  • Always use edge protectors when hauling articles with sharp corners
  • Never use bungee cords as the sole means to secure anything on the vehicle (including dunnage on or under the trailer) – these devices have no weight rating and are not approved for this purpose
  • Check load securement devices frequently to ensure that they have not become loose or damaged
  • Establish a maintenance service routine for load securement devices
  • Ensure that each unit has the proper equipment to secure loads
  • Check equipment for damage
  • Replace equipment that is showing evidence of damage

hazardous materials (HM) Compliance