What is CSA?
The Federal Motor Carrier Safety Administration (FMCSA), together with its state partners and the trucking industry, are working to further reduce commercial motor vehicle (CMV) crashes, injuries and fatalities on our nation's highways. To this end, the FMCSA implemented the Compliance, Safety, Accountability (CSA) program in December of 2010. CSA introduces a new enforcement and compliance model that allows FMCSA to identify high-risk motor carriers, as well as individual drivers, and intervene in ways that work to reduce high-risk behaviors and impact safety. The CSA initiative applies to all vehicles over 10,000 lbs. that travel interstate or haul hazardous materials, both for-hire and private fleets. Its purpose is to identify behavioral and safety problems, and intervene by way of warning letters and investigations. The FMCSA will then monitor those carriers for improvements.
How Does CSA Work? SMS and BASIC Scores
The Safety Measurement System (SMS) methodology, one of the tools that measure the safety of motor carriers, was developed to support the CSA initiative. SMS quantifies on-road safety performance of carriers and drivers to identify candidates for interventions, determine the specific safety problems that a carrier or driver exhibits and then monitor whether safety problems are improving or worsening. SMS assesses a carrier’s safety performance on the basis of its roadside inspection violations and crashes while using a subset of these to evaluate an individual driver’s safety performance across employers. By including individual drivers in the assessments, a driver with a poor safety background will be detected even as he/she changes companies. SMS has replaced SafeStat in the new operational model and uses a motor carrier’s data from the previous 24 months of roadside inspections and state-reported motor vehicle crashes to quantify performance in seven different categories.
These categories make up the Behavior Analysis and Safety Improvement Categories (BASIC). All BASIC assessments are publically available online except for two - the Cargo-Related and Crash Indicator BASICs. FMSCA maintains that SMS is used to prioritize motor carriers for safety interventions, but are not meant to be safety ratings. The BASICs are as follows:
- Unsafe Driving
Operation of CMVs by drivers in a dangerous or careless manner. Examples of violations include speeding, reckless driving, improper lane change and inattention (FMCSR Parts 392 and 397). Drivers not wearing their seatbelts will also impact this score. Of all the BASIC categories, Unsafe Driving can most adversely affect a company by higher insurance rates and possibly losing shipper contracts. Following all rules of the road, utilizing speed governors on trucks and frequent safety training can help this score.
- Fatigued Driving (Hours-of-Service)
This BASIC category includes violations of regulations pertaining to logbooks as they relate to hours-of-service (HOS) requirements and the management of driver fatigue. Examples of violations include exceeding HOS, maintaining an incomplete or inaccurate logbook and operating a CMV while ill or fatigued (FMCSR Parts 392 and 395). Utilizing electronic logs, ensuring drivers get the appropriate rest and keeping all logs current and accurate can help this score.
- Driver Fitness
Operation of CMVs by drivers who are unfit due to lack of training, experience or medical qualifications. Examples of violations include failure to have a valid, current and appropriate commercial driver’s license (CDL) and being medically unqualified to operate a CMV (FMCSR Parts 383 and 391). Keeping all drivers’ CDLs current and having copies of up-to-date medical cards in every vehicle can help this score.
- Controlled Substances and Alcohol
Operation of CMVs by drivers who are impaired due to alcohol, illegal drugs and misuse of prescription/over-the-counter medications. Examples of violations include use or possession of controlled substances or alcohol (FMCSR Parts 382 and 392). Keeping copies of prescriptions in the vehicle, drug testing and having strict no-tolerance rules for alcohol and drugs can help with this score.
- Vehicle Maintenance
Failure to properly maintain a CMV. Examples of violations include brakes, lights, other mechanical defects and failure to make required repairs (FMCSR Parts 393 and 396). Inspecting your vehicle daily and performing regular and routine maintenance can help with this score.
Failure to properly prevent shifting loads, spilling or dropping cargo, overloading and unsafe handling of hazardous materials on a CMV. Examples of violations include improper load securement, cargo retention and hazardous material handling (FMCSR Parts 392, 393, 397 and HM Violations). Educating drivers of flatbed trucks, auto haulers and intermodal trucks on how to secure loads and meet security requirements can help with this score. Hazardous material carriers should ensure drivers have proper training and understand placarding rules. These issues have now become a part of the Maintenance BASIC.
- Crash Indicator
Histories or patterns of high crash involvement, including frequency and severity. This is based on information from state-reported crashes. The FMCSA is working to allow motor carriers to dispute crashes that are not at-fault accidents.
While the FMCSA believes the BASIC scores are helping to identify unsafe carriers and drivers, others in the industry are not in total agreement on the methodology behind the scores. In June of 2012, the American Trucking Association (ATA) called on the FMCSA to release the study used to develop the CSA scoring system. Another recent study by The Alliance for Safe, Efficient, and Competitive Truck Transportation group showed that there was no correlation between CSA BASIC data and actual crash performance. The FMCSA does caution that SMS results are not intended to imply any federal safety rating of a carrier and conclusions should not be drawn based on data in the system alone. FMSCA encourages frequent review by motor carriers of the SMS and to initiate any correction requests through DataQs, their online electronic data correcting system. The SMS was designed and intended to be continually improved. To that end, in March of 2012, the FMCSA announced several improvements to the system, which will be rolled out in December 2012. For a complete listing of the scheduled improvements, click here
Business and Insurance Impact
To date, insurance companies and underwriters are placing varying levels of importance on CSA/SMS scores when determining whether to quote an account and the impact on pricing. One long-standing commercial transportation carrier uses CSA/SMS data to determine if they will offer coverage to a motor carrier, but noted that loss history is still the most important factor. Furthermore, they put equal weight on all SMS scores and look closely at the data to analyze why particular scores were received in each category. An underwriter from that company advised, “We use SMS as a tool, not an end all. It’s just one of the many things we look at. If a carrier has alerts in all categories with high percentages, they could be in jeopardy of having their authority revoked and as such our willingness to offer a quote is small.”
Insurance companies weigh this public data in terms of being “defendable” in court, should an accident occur and end up at trial. Shippers are also reviewing the SMS in order to determine which motor carriers to utilize for their business needs. In severe cases, if a motor carrier ignores interventions and does not comply with DOT rules, regulations, severe SMS alerts and warning letters, the DOT could revoke a motor carrier’s authority. Investing time and money in understanding the SMS and BASICs in CSA, and ultimately overall safety, will have a positive impact on insurance costs and could also attract shippers wishing to work with the “safest” motor carriers.
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Andrea Dickinson and Chris Loggie of AmWINS Brokerage of Illinois contributed to this article.
Legal Disclaimer: Views expressed here do not constitute legal advice. The information contained herein is for general guidance of matter only and not for the purpose of providing legal advice. Discussion of insurance policy language is descriptive only. Every policy has different policy language. Coverage afforded under any insurance policy issued is subject to individual policy terms and conditions. Please refer to your policy for the actual language.
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