PREPARING FOR CSA 2010: CARRIER CONSIDERATIONS

The Federal Motor Carrier Association (FMCSA) is preparing to launch the Comprehensive Safety Analysis 2010
(CSA 2010), a new safety inspection program designed to improve road safety by increasing FMCSA efficiency in
collecting and utilizing inspection data to identify high-risk carriers and drivers.

According to the FMCSA, studies have shown that unsafe driver behavior, both on the part of Commercial Motor
Vehicle (CMV) drivers and other drivers, is a major contributor to CMV-related crashes. Some studies indicate that
a small segment of the CMV driver population is involved in a disproportionately large number of crashes1. The
objective of the new safety regulations is to better identify potentially unsafe drivers and carriers before they are
involved in crashes by using statistically relevant data to predict which drivers and carriers are at a higher risk for
crashes. In order to make these predictions, the FMCSA is changing entirely the formulas used to score and predict
high-risk carriers and drivers.

The program has been operationally tested in states like Georgia, Kansas, Minnesota, and Missouri and will be
rolled out nationally in the coming months. This white paper will provide an overview of the key factors motor carriers
need to know and suggestions on how to achieve the ideal Carrier Safety Measurement System (CSMS) ratings to
avoid FMCSA interventions and fines.

Why prepare, and why now.

“Although individual companies such as mine have done well
“It’s not surprising that the FMCSA is
enforcing policy, the trucking industry as a whole has encountered
difficulty building continuity in policy enforcement.” No matter your stepping in at this point.”
current SafeStat score- good or bad - that score will be replaced with
a new score under the implementation of CSA 2010. The new Safety Gary Ruettgers, Operations Manager at Seaboard.
Measurement System (SMS) will evaluate the safety of individual motor
carriers by considering all safety-based roadside inspection violations, not just out-of-service violations, as well as
State-reported crashes by utilizing 24 months of performance data. In fact, 70-80 percent of the points accrued under CSA 2010
are tied to violations that were never included in SafeStat scores2. There will be no “grace period” before the SMS takes affect,
and inspections that take place today will count toward carrier SMS ratings once CSA 2010 takes effect.

Additionally, driver performance will play a more prominent role than ever before on a carrier’s safety rating. Any
inspection-violation a driver receives while working for a carrier will apply to that carrier’s SMS score for 24 months following
that violation. It is important to begin communicating with drivers now and preparing them fully for the implementation of CSA
2010.

How is SMS different from SafeStat?

Key Difference SMS SafeStat
1. More elaborate 7 Total - BASICS 4 Total - SEAs
evaluation of crtierion
2. Focus on Prediction vs. Uses safety performance problems Uses compliance violations to
Compliance to generate scaling interventions generate interventions
3. Comprehensive Emphasizes on-road performance Uses compliance violations to
using all safety-based inspection violations generate interventions
4. Predictive Uses risk-based violation ratings No predictive measures

5. Integrates Driver / Provides a tool for SIs to identify drivers with No connection between drivers and carriers
Carrier ratings safety problems during carrier investigations on safety ratings

1 http://csa2010.fmcsa.dot.gov/FAQs.aspx
2 Britton, Diana. “Lifelines.” Heavy Duty Trucking. February, 2010.
“Safe” has a new definition.
CSA 2010 introduces a new enforcement and compliance model that will allow FMCSA and its state partners to reach a larger
number of carriers in order to address safety problems before crashes occur. The Safety Measurement System (SMS) set forth
will assess each carrier’s safety performance in seven Behavior Analysis and Safety Improvement Categories (BASICs):
Unsafe Driving, Fatigued Driving, Driver Fitness, Controlled Substances/Alcohol, Vehicle Maintenance, Cargo-Related, and
Crash Indicator. These BASICs were developed based upon data from a number of studies that identified the associations
between violations and crash risk.

The SMS will calculate a measure for each BASIC by combining the time and severity weighted violations and crashes
normalized by exposure. More recent violations are weighted more heavily. The exposure a carrier represents will be
determined based upon the Carrier Safety Measurement System (CSMS) formula specific to each BASIC. The SMS will then
convert each carrier’s BASIC measures into percentiles based on “peer groups,” or like companies. See CSMS Formulas for
details.

Changes in your fleet’s size could affect your fleet peer group, and therefore could affect your BASIC score. Currently, data is
normalized using Power Units (PUs), but Vehicle Miles Traveled (VMT) may be used in the future. Fleet size data is pulled from
MCS-150 Carrier Census forms— therefore it is important to ensure your company regularly updates this form. Many believe
VMT is a better means to classify fleets into like-sized peer groups; however according to the FMCSA only 55% of fleets had
annualized VMT data. If more Carriers report their fleets’ VMT data through MCS-150 Carrier Census forms, the FMCSA could
potentially change the scoring methodology.

The most heavily weighted violations are those that, statistically, have a higher likelihood to cause an accident. Specifically,
violations related to Driver Fitness, Hours of Service (including log-book violations), defective tires, steering system defects,
and all violations related to cargo security are among the most heavily weighted violations.

CSMS Formulas
Unsafe Driving and Controlled Substances/Alcohol BASIC = Total time and severity weighted applicable violations
Average measure of Carrier PUs3

Total time and severity weighted applicapble violations

Fatigued driving (HOS) and Driver Fitness BASIC =
Number of time weighted relevant inspections.

Total of time and severity weighted applicable violations

Vehicle Maintenance and Cargo-Related BASIC = Number of time weighted relevant inspections.

Total time and severity weighted applicable crashes

Crash Indicator Measure = Average measure of Carrier PUs3

Get prepared.
Although the program launch date has been changed multiple times, the reality is that CSA 2010 is currently active in test states
and will eventually roll out nationally. It is in your best interest to take this time to evaluate your current safety policies against
the upcoming changes.
Check your safety history.
The past 24 months of inspection data are incorporated into a carrier’s initial SMS score. Preview this
information now at http://csa2010.fmcs.dot.gov to see the effect of current data on your score and to ensure that
the information is accurate.

Once you have reviewed your inspection and violation history, you should be able to identify trends in your fleet’s
performance. Evaluate how your existing violations are weighted on the new SMS and rectify any negative
patterns in heavily weighted violations. Drivers’ Red Flag violations should be a top priority because they “are
always investigated as part of a carrier investigation.”4 These Red Flag violations include violating
Out-of-Service Orders (OSS), operating a commercial vehicle under the influence or in possession of alcohol or
drugs, and violations related to driver qualification.

3 Average PU = PU (current) + PU (6 months ago) + PU (18 months ago) / 3

4 http://csa2010.fmcsa.dot.gov/FAQs.aspx?role=MC
 Have safety policies, and reinforce them.
Having thorough and clear hiring and training policies is critical. The best safety policies are “…direct,
straightforward, and simple” says Bob Byrnes, Safety Director at TLC Companies. Corporate policies should
specifically call out the requirements a driver must follow to start and maintain employment with a carrier. Mr.
Byrnes emphasizes that now more than ever it’s important to not just establish disciplinary actions relating to
driver citations, but also rewards for safe driving.
Tighten hiring policies.
Conduct substantial background checks on drivers prior to employment. Reconsider hiring any
driver with serious BASIC violations over the past 36 months; reckless driving and any drug or
alcohol related violations in the past 36 months will weigh the most heavily on a Carrier’s BASIC
rating.

Consider adopting the Pre-Employment Screening Program (PSP). This separate initiative by the
FMCSA will provide motor carriers with access to a driver’s crash and serious violation history,
pre-employment. This is a paid service provided through NIC5 and requires driver approval prior to
accessing personal data. Bear in mind that, "You will be required to consent in writing that you will
only use the records for pre-employment screening purposes, that you have obtained the written
consent of all applicants whose records you purchase, and that you will abide by regulations
provided under the Fair Credit Reporting Act, among others."6

Pre-trip inspections are critical.

Stringent pre-trip vehicle inspection procedures are the best defense against many potentially
damaging BASIC violations for carriers and drivers. “The DOT is going to be very detailed with their
enforcement checks” says Mr. Ruettgers. “Ultimately, it’s going to be up to drivers to check their
equipment to ensure it meets federal guidelines.” Recently a driver from Seaboard’s fleet (operating
in the CSA test state of Kansas) received an OOS violation due to four inches of reflective tape
hanging from the driver’s outside trailer.

Since all cargo security violations are heavily weighted, carrier policies should reinforce the North
American Cargo Securement Standards, including periodic inspections and specifications for
particular types of commodities. Make sure that tiedowns are adequately applied and rated for the
cargo, are in working order, and are never weakened by knots7. Download the 141-page training
guide for more specifics and details at the FMCSA website:
http://www.fmcsa.dot.gov/documents/cargo/cargosecurement-16-04.pdf

Educate your drivers.

CSA 2010 will make safety more of a team effort than ever before between drivers and
driver-management. “Drivers ignore a lot of issues right now. They have to understand that things
will change in the future” says Mr. Byrnes.

Discuss with your drivers how these new standards will affect their personal safety scores and
explain the connection to your corporate policies. Have an immediate action plan in place for
if/when a driver is involved in a negative safety event, including citation, accident or complaint.
Consider including scaling disciplinary actions based upon the severity of the violation, starting with
one-on-one meetings and training sessions up to and including driver termination. Consider
adjusting your intervention triggers based upon points accrued to better align with the new
standards.

Reward good driving.

With so many opportunities for drivers to be penalized for unsafe driving it’s increasingly important
to include positive reinforcement as part of your comprehensive approach to safety. Rewarding
drivers with cash, prizes and recognition for miles-driven without incident are just a few ways to keep
the word “Safe” from becoming a negative four-letter-word. For more information on safety and
recognition programs, please reference Why Drivers Stay with Fleets at
http://www.multiservice.com/knowledge-center/thought-leadership.

5 http://www.psp.fmcsa.dot.gov/Pages/default.aspx (provided by NIC Inc. http://www.nicusa.com)

6 http://www.psp.fmcsa.dot.gov/Pages/FAQ.aspx
7 http://www.fmcsa.dot.gov/documents/cargo/cargosecurement-16-04.pdf
 Be prepared to challenge incorrect data.
Maintain copies of inspection reports, including “clean inspections.” This will allow you to identify company-wide
violation trends and proactively correct them. An auditable history of inspections will also provide the necessary
data needed to challenge any incorrect data impacting your SMS score.

The FMCSA created the DataQs program to allow carriers and drivers to challenge information residing in
FMCSA databases, including crash and inspection reports, compliance review and/or intervention results, and
enforcement actions. When challenging violations and crash data through DataQs, be as specific and detailed
as possible and provide thorough supporting documents – for example, lease agreements or other evidence to
establish correct responsibility for violations.

Ensure that contact information is accurate and check status frequently to see if additional information or
evidence is requested8. Sixty-five percent of data challenges filed through DataQs result in data updates9, so
the efforts are well worth your time.

Carriers’ BASIC scores will be influenced by a driver’s violation history while that driver is employed by the
carrier; therefore it is in each carrier’s best interest to be informed of a driver’s citation status and update Federal
and State SMS histories when a driver’s violations or citations are overturned.

Consider cost-opportunity.
With all areas of safety now under the microscope, most fleets will see increased documentation management,
internal auditing policies, and increased driver training and screening frequencies. When evaluating your
methodology for improving safety performance, some consideration must go to cost-efficiency.

Now is a good time to investigate the cost-benefit of implementing technologies like e-logs or onboard recorders,
as well as data analysis software solutions. Service providers that offer human resource management, file
management or drug and alcohol screenings, log auditing, vehicle maintenance, and transportation law may
save valuable internal resources at a reasonable rate.

Ready or not.

There are myriad opinions in the transportation community regarding whether the new guidelines are intelligent, fair
and/or thorough. Time and data will tell if the new program achieves its ultimate objective: to reduce CMV crashes,
fatalities and injuries on our nation’s highways. There’s no magic formula to guarantee your fleet a great BASIC
score. No matter how cautious and careful a carrier and its drivers, accidents, citations and violations will happen.
The key is to understand the direct relationship those offenses will have on your company safety ratings and be
prepared to manage your fleet through those eventualities.

8 http://csa2010.fmcsa.dot.gov/Docmuments/CSA2010IndustryBriefing.ppt#470,29,Challenging Data
9 U.S. Department of Transportation, Federal Motor Carrier Safety Administration, Listening Session #2 12/10/2009