What is CSA 2010?
The Comprehensive Safety Analysis (CSA) 2010 is a major initiative of the Federal Motor Carrier Safety Administration (FMCSA) to improve the effectiveness of the Agency’s compliance and enforcement programs. The ultimate goal is to achieve a greater reduction in large truck and bus crashes, injuries, and fatalities by more efficiently using the resources of FMCSA and its State partners. (Excerpt from the Executive Summary of the CAS Phase 1 report to Congress, PDF)
CSA 2010 Safety Measurement Systems (SMS) Tips
Have “good” inspections going into the data system
Due to the nature of the CSA 2010 Safety Measurement System (SMS) data collection and evaluations systems, and the emphasis that is placed on recent roadside inspection data, the fastest way to impact the system is to get “good” roadside inspections into the system. What constitutes a “good” roadside inspection? One that has no violations!
Avoid “high point” violations
The severity weighting system used in the SMS places a “high value” on certain violations. To minimize the impact of the CSA 2010 system, carriers and driver need to take steps to avoid these high-value violations. These include violations such as:
- Jumping an out-of-service order
- Operating a vehicle while ill, fatigued, or under the influence
- Violating hours-of-service limits
- False logs
- Driving a CDL while disqualified
- Required light not operating
- Defective tires
- Suspension defects
- Steering system defects
- No flags and/or lights on a projecting load
- Cargo not secured
Finally, to minimize the impact that CSA 2010 will have on your operations take measures to reduce the number of preventable crashes the fleet is involved in. Measures that have been proven to prevent crashes include:
- Make sure drivers are trained on, and actively practice drive defensively.
- Investigate all accidents to determine if systemic corrections are necessary.
- Use the Four E’s approach to track and correct policies related to safe driving, compliance, and crashes (Evaluate the data, Engineer systems and polices to address problems, Educate the workforce on the systems and policies, and Enforce the systems and policies)
- Take immediate corrective action if a driver is involved in a negative safety event (driving complaint, citation, accident, etc.) Have the right culture Finally, have policies, procedures, and practices that foster a culture of safety and compliance, not one of “risk taking” or “getting the job done at all costs.”
Interventions for “Marginal” Carriers
Carriers that have been evaluated as needing interventions will be subject to a variety of interventions. The specific intervention will depend on the carrier’s BASIC scores and enforcement history. The interventions include:
This puts the carrier on notice that a BASIC has gone above the threshold, and correction is necessary.
Increased roadside enforcement
This will function much like the present ISS-D system. Carriers that have a BASIC over a threshold will be “flagged” in the Inspection Selection System used by roadside inspectors to select carriers for inspection. The system will also tell the inspectors which BASIC score (or scores) has gotten the carrier onto the “Inspect” list.
Focused off-site investigation
This intervention will involve checking a carrier’s compliance with the regulations and verify performance in BASIC areas that the carrier has shown to have problems in. It will involve the carrier sending the investigators requested records and responding to any follow-up requests. As an example, if the carrier has a poor BASIC score in the Driver Fitness BASIC, the focused on-site investigation would concentrate on Driver Fitness issues.
Focused on-site investigation
These interventions will involve a “narrow” audit of a carrier based on areas of poor performance. As an example, if the carrier has a poor BASIC score in the vehicle BASIC, the focused on-site investigation would concentrate on vehicle issues.
Cooperative safety plan
Following a focused investigation or a comprehensive review, the FMCSA may request that the carrier develop a cooperative safety plan intended to correct the carrier’s performance. The plan would have to be submitted to the FMCSA office and approved.
Notice of violation
The notice of violation would serve as a formal mechanism to inform carriers that the carrier must address compliance deficiencies.
Comprehensive on-site investigation
This is the equivalent of the present Compliance Review (audit) done by the FMCSA. It would only be used when other interventions have failed or if there are grounds for it (very poor BASIC score, accident follow up, valid complaint, the earlier investigation has found larger problems, etc.).
Notice of claim, penalty, and settlement agreement
These would be the steps used the FMCSA use following an intervention that did not go well. They basically involve “fining” the carrier or driver.
We Are Your CAS Partner
We’re here to help you navigate through the CSA 2010 and subsequent revisions. As your partner, we will write “Cooperative Safety Plans” for your company.