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CSA 2010: The Driver Impact.

CSA 2010: The Driver Impact.


The Federal Motor Carrier Safety Administration (FMCSA) is in the process of implementing a revised safety
inspection program designed to improve road safety by identifying high-risk carriers and drivers.
This paper will review the key points of the Comprehensive Safety Analysis 2010 (CSA 2010) and offer some
suggestions on how you can prepare for continued success in a changing industry.

What is CSA 2010?


According to the FMCSA, the goal of CSA 2010 is to establish an
enforcement and compliance model to more efficiently address commercial If you are an owner-operator pulling on
motor vehicle (CMV) and driver safety problems before crashes occur.1 To your own authority, you will be scored in
do this, the FMCSA is changing the way it collects data and the formulas
used to score and predict high-risk carriers and drivers. the same way motor carriers are.
Please download our white paper, CSA
The implementation of CSA 2010 will affect every driver in the industry 2010: Carrier Considerations, for more
regardless of whether you lease a truck, work for a carrier or if you are an
information on how to prepare.
owner-operator running on your own authority. There has been wide
speculation throughout the industry that as many as 200,000 drivers could
become “unemployable” as a result of CSA 2010.2

How it Works.
CSA 2010 will include a new Safety Measurement System (SMS). The SMS is two-fold: the Driver SMS (DSMS) and the
Carrier SMS (CSMS). This system will score safety performance in seven Behavior Analysis and Safety Improvement
Categories (BASICs):

• Unsafe driving
• Fatigued driving
• Driver fitness (See driver fitness debunked)
• Controlled substances / alcohol
• Vehicle maintenance
• Cargo-related
• Crash indicator

1 FMCSA. Why is CSA 2010 Needed? http://csa2010.fmcsa.dot.gov/about/csa_why.aspx.


2 Kevin Jones. CSA 2010: truckers get, give earful at MATS. The Trucker. April 16, 2010.

CSA 2010: The Driver Impact. 1


These BASICs were developed by the FMCSA based upon data from a number of studies that identified associations between
violations and crash risk. Within each BASIC category, violations are weighted according to their statistical likelihood to cause
a crash or accident.

Carrier safety measurement system.


The CSMS will measure each BASIC by weighting the recency and severity of violations and crashes. The
CSMS then converts each carrier’s BASIC measure into percentiles within “peer groups,” or like companies.
This score will replace the carrier’s previous SafeStat score.

Driver safety measurement system.


Within each BASIC category, there are specific violations that will affect the DSMS. Like the CSMS, violations
on the DSMS are weighted by severity and recency. Any inspection-violation or accident a driver has while
working for a carrier will be reflected in the carrier’s overall safety rating for 24 months following the violation.
Additionally, a driver’s personal inspection-violation history will be stored within the DSMS for 36 months, and
crash records will follow you for 60 months. While driver scores will not be public, carriers will have access to
inspection, violation and crash history through their own CSMS data while a driver is employed by their fleet.

CSMS Formulas DSMS Formulas


Unsafe Driving, Controlled Substance and Alcohol Unsafe Driving, Controlled Substance and Alcohol

BASIC Measure = Time Weight x Severity Weight / Average BASIC Measure = Time Weight x Severity Weight
Measure of Carrier PUs
Time Weight
Time Weight 3 = within previous 12 months,
2 = 0-12 months 2 = between 12 and 24 months,
1 = 12-24 months 1 = between 24 and 36 months
Fatigued Driving, Driver Fitness, Vehicle Fatigued Driving, Driver Fitness, Vehicle
Maintenance, and Cargo-Related Maintenance, and Cargo-Related
BASIC Measure = Time Weight x Severity Weight / Number BASIC Measure = Time Weight x Severity Weight / Number
of Time-weighted relevant inspections of Violations (within previous 36 months)
For each Out-of-Service (OOS) violation, 2
points are added to the severity weighting.

Crash Indicator Crash Indicator

BASIC Measure = Time Weight x Severity Weight / Average BASIC Measure = Time Weight x Severity Weight / Average
Measure of Carrier PUs Measure of Carrier PUs
Severity Weight Severity Weight
1= Tow-away only 1= Tow-away only
2 = Injury or fatality 2 = Injury or fatality
+1 = Hazmat release (added to the weights above) +1 = Hazmat release (added to the weights above)

Why Does This Matter to Me?


A major misconception regarding CSA 2010 is that drivers will receive a public score similar to that of carriers and that FMCSA
will revoke a driver’s CDL based upon inspection data. Both are untrue. So why does this matter to you as a driver? And why
are people estimating that so many drivers will lose their jobs?
• The DSMS will be used as a tool by law enforcement to pinpoint the performance of individual drivers when
conducting safety investigations.
• By accessing CSMS data, carriers will be able to see raw inspection and crash information. Carriers are likely to
tighten safety and employment policies based upon the effect a driver’s performance has on the carrier’s SMS.
• Drivers will be scrutinized more during the hiring process through the new Pre-employment Screening Program
(PSP). See “Understand the changes…” for more information.

CSA 2010: The Driver Impact. 2


How do I Prepare?
“Drivers need to be less aggressive,” Dan Harman,3 a driver for 18 years says. According to the FMCSA, aggressive driving
(i.e. running red lights, making frequent lane changes, cutting off other drivers, etc.) is the number one cause of crashes.4
So, the easy answer to CSA 2010 and protecting your career is: drive safely. The fact remains, though, that mistakes happen,
violations will occur, and there are steps you can take to protect your career.

Get to know the BASICs.


By understanding which violations are included in the inspection process, which violations carry the most weight
within the SMS, and which violations draw attention to a driver; you can focus on resolving individual “problem
areas” to help keep your record as clean as possible.

Severe violations. Clearly, those violations rated with high severity will do the biggest damage
to a driver’s and a carrier’s SMS score, and quickly. You can obtain a complete list of violations
and their severity weighting at: http://www.modot.mo.gov/mcs/documents/BASICoverview.pdf

Red flag violations. The FMCSA has identified 11 violations that, if received, will always be
followed up on as part of a carrier investigation. If you obtain one of the violations listed in the Red
Flag Violations sidebar on the next page, you can count on being a focus of your carrier’s next
safety investigation.

Gateway violations. It would be easy to tell you not to worry about onesie-twosie violations, to
focus on the high-value items within BASICs to ensure the lowest possible score. For the most
part, it’s those onesie-twosie violations that draw attention to a driver or vehicle and prompt a full
inspection.

Know who you are driving for.


Just as driver performance will affect a CSMS score, a CSMS score can put a driver at higher or lower risk for
roadside inspections. Therefore, just as it is in the best interest of the carrier to hire only the safest drivers, it will
be in your best interest to pull for the safest carriers.

Carrier scores will be publicly available November 30.

Before pulling for a carrier. When seeking out employment with a new carrier check their
BASIC scores. Do they have high instances of HOS violations or vehicle maintenance violations?
This may be a sign that the carrier is neglectful of the drivers or equipment. Or does the carrier
score poorly in unsafe driving and driver fitness categories? This may indicate a history of bad
hiring decisions that need to be corrected. Either way, before taking a position with a carrier, it is
in your best interest to get the carrier’s perspective on safety and what actions they are taking to
correct negative safety areas.

Tracking your carrier. When driving for a carrier, check their CSMS score regularly. If you know
the weak points within your carrier’s score, you will know ahead of time what will be the focus of
your next roadside inspection. You can proactively guard against contributing to this poor score.
In fact, by obtaining a clean inspection, you will help improve your carrier’s SMS and gain some
appreciation.

Keeping an eye on your carrier’s SMS score can also give you the heads-up on a downward
safety trend within the fleet. If your carrier’s SMS score begins plummeting, all trucks within the
fleet will be at higher risk for inspections.

3 Dan Harman. KC Trucker LLC. Interview. May 20, 2010.


4 Transportation Research Board. Conference Proceedings 38. Future Truck and Bus Safety Research Opportunities. P 28.

CSA 2010: The Driver Impact. 3


Understand the changes, on-the-road and off-the-road.
The implications of CSA 2010 will be widespread, not only on roadsides, but also within carrier recruiting and
employment practices. While these changes may increase pressure on driver performance, the end goal for
both the driver and the carrier in the implementation of these policies is the same: to improve safety scores and
decrease a risk of inspection.

Pre-employment screening program. The PSP is a separate initiative being implemented by


the FMCSA. The PSP will give carrier’s access to a driver’s safety history through an online
database compiled from 36 months of inspection history and 60 months crash data. CSA 2010
will give motor carrier’s more reason than even before to fully research a driver’s safety record
before hiring a driver. While a carrier can only access this information with your express
permission, the PSP is likely to become a part of every carrier’s standard background check.

Make sure you know what the PSP has on you before you have to answer for it with a potential
carrier. You can access your own PSP data at http://www.psp.fmcsa.dot.gov. There is a $10
charge per request.5
Employment policies. Carriers will be likely to implement more stringent terms of employment
and safety policies as a result of CSA 2010. Make sure that you read all paperwork you sign with
your company carefully and that you fully understand your obligations as an employee. Always
remember that a revised SMS program does not undermine the requirement that a carrier
provide a fair and just working environment.

Document, document, document. We understand that paperwork is a hassle, and not your favorite part
of the job. But, a paper trail may be your new best friend.

Because a clean inspection counts toward a carrier’s SMS score in the same way violations count against a
carrier’s score, it is important to maintain copies of ALL inspection reports you receive.

Violation and crash histories within the SMS may be argued through a system called DataQs, which was set up
by the FMCSA to allow carriers and drivers to challenge information in the database. An auditable history of
roadside inspection slips will provide necessary documentation needed to challenge incorrect data within the
system.

Make sure you read and understand the complete roadside inspection slip before signing it.

Additionally, it remains important to fight citations issued against your CDL when you feel they are unjustified. If
you are able to have a citation overturned in a court of law, documentation of the case may support an argument
to have your SMS score reduced if that violation was also listed on your inspection.

What’s Next?
The prospect of CSA 2010 has seen no shortfall of debate, confusion and frustration within the transportation industry. The
increased focus it places on driver safety is undeniable, and the FMCSA isn’t finished yet. The administration has already noted
plans to increase rules and regulations for the trucking industry by 2025.4 Drivers and carriers need to be on the same team to
work with the revised regulations.

CSA 2010 also brings the prospect of career opportunity for professional drivers. Carriers will be seeking out the cream of the
crop to haul freight for their companies, and they will be willing to pay well and work together with those drivers that help
maintain a strong reputation for safety.

“Trucking is a lifestyle,” Mr. Harman says. Drivers that love this lifestyle will make these new regulations work: for them, for their
carriers and for the reputation of the industry.

5 FMCSA. Driver Pre-Employment Screening Program http://www.psp.fmcsa.dot.gov.

CSA 2010: The Driver Impact. 4


CSA 2010: Driver Reference Guide.

Gateway violations. Red flag violations.

BASIC Severity Violation


• Speeding. 1 – 100 mph over the speed limit is
Fatigued Driving (HOS) 10 Violating Part 395
enough probable cause to warrant a full Out-of-Service (OOS) Order
inspection Controlled Substances / Possessing, using or being
10
Alcohol under the influence of a
controlled substance
• Failure to use a seatbelt. A fastened belt worn
Allowing driver to operate
improperly may still be considered “failure to Driver Fitness 10 with more than one
Commercial Driver’s License
use” and land you in a full inspection. (CDL)

Operating a commercial
Controlled Substances /
• Lamps / lights / turn signals. Vary in their 10 motor vehicle (CMV) with
Alcohol more than one CDL
severity ratings, but when any of these lights fail
they scream “inspect me” to an officer. 10 Operating an OOS vehicle
Vehicle Maintenance
before making repairs

Driving while disqualified


• Tires. Tires are serious business – high severity Driver Fitness 6
(383.51a, 391.15a)
weighting and a high likelihood of earning you a
Possessing, being under the
full inspection. 5
Driver Fitness influence of, or using alcohol
within 4 hours of going on
duty

3-6 Operating without a valid


Driver Fitness
CDL

Driver Fitness 3-6 Driving without a valid


operator’s license

Driver Fitness 1-2 False entry on medical


examiner’s certificate

The driver fitness myth debunked: What it really is.

Believe it or not, driver fitness has nothing to do with your BMI or how many push-ups you can do.
Here’s what driver fitness, as defined by the FMCSA, really includes:

1. Allowing a driver to operate during out-of-service (OOS) order


2. Failing to comply with imminent hazard OOS order
3. Driving while disqualified
4. Driving without a valid operator’s license
5. Operating without a valid CDL
6. Operating a CMV with more than one CDL
7. False entry on medical examiner’s certificate
8. Allowing driver to operate with more than one CDL

CSA 2010: The Driver Impact. 5


Multi Service® established Open Road Drivers Plan®, a legal referral service for professional
drivers, as a safety and retention tool for fleet owners. Since 1989, professional truck drivers
have been utilizing this unique service to gain local, licensed legal services for their traffic
citations. Open Road Drivers Plan works in accordance with fleets to improve safety
initiatives and driver appreciation throughout the trucking industry.

Thank you for your interest in this free white paper. We welcome your comments, feedback,
and suggestions. Please consider sending us a note about how this paper has helped you.
Check out the Open Road Drivers Plan website at www.ordp.com. If you would like to contact
an Open Road Drivers Plan representative directly, you can call 1-800-848-3060 or email
ordp@multiservice.com

CSA 2010: The Driver Impact. 6

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