The Federal Motor Carrier Safety Administration (FMCSA) of the Department of Transportation is instigating a new Comprehensive Safety Analysis System (CSA 2010) to more clearly determine motor carrier safety fitness and better target enforcement efforts against unsafe operators/commercial carriers.
This new system will go “live” via a new upgraded Web site by the end of the year, replacing the SAFESTAT approach, which was put in place in 1996. “CSA 2010 is not a new regulation. There is no new regulation being added. There is no new log book or driver file. It does not impose any new safety rules other than what you are subject to today. It does not eliminate on-site reviews. It is not going to diminish our enforcement of any regulations,” said Steven Mattioli, FMCSA, division administrator, Springfield, Ill., during the 2010 National Agronomic Environmental Health and Safety School in mid-August.
Mattioli told the school attendees that the new CSA 2010 has been designed as a holistic approach to take advantage of easier internet data collection and improved computer systems. The overall goal is improved safety by motor carrier companies with a specific goal of lowering the annual fatalities involving commercial vehicles, which stayed at about 5,000 per year from 2001 through 2007. The number dipped to about 4,000 in 2008, and the 2009 number currently being finalized is thought to be in the same neighborhood as 2008.
THREE MAIN COMPONENTS
There are three main components of CSA 2010, Mattioli explained. There is a safety measurement system or yardstick from which a company is measured, a safety fitness determination or safety rating of every company and an intervention system or way to push for effectively and efficiently having safety issues resolved by each company.
The measurement system is being divided into seven Behavior Analysis & Safety Improvement Categories (BASICS). The categories are Unsafe Driving, Fatigued Driving, Driver Fitness, Controlled Substances/Alcohol, Vehicle Maintenance, Improper Loading and Crash Indicator.
“Under the old system, we only had four broad categories; under the new system we have seven. We had a one-size-fi ts-all approach, and now we will have numerous new things we can do on this new system. One reason we made more basics than we had is because the better you measure something the better you can intervene when you have to,” Mattioli said.
The new system uses a lot more inspection data other than just out-of-service data collected. Data will be time-weighted from zero to six months, six months to 12 months and 12 months to 24 months, with data that happens most recently weighted higher than data from 24 months in the past.
There will also be a violation, severity weight. So, as an example, not signing a log book will not weigh as heavily as a false log book.
One inspection or one crash report will not be the basis for a score because filtering of data requires “data sufficiency.” “You are not going to get a score in any of these basics if there is not enough data to score you,” Mattioli told the Safety School audience. “For example, for the vehicle maintenance basic, you have to have five inspections in the last two years for you to get a score.”
Also, companies of the same size will be put in peer groups so that a one-truck company will not be compared to a 1,000-truck company.
Once a score has been assigned in the seven basic area and peer grouped, a company is then placed in a percentile ranking. “In other words, if there are 100 carriers in your group and you are assigned a score of 75 in a particular basic, the 75 means that you scored worse than 75 percent of the other companies in your peer group. A score of 100 means that you are the worst in your peer group. That is comparing you with other similar companies,” Mattioli said.
Each basic is going to have a percentile that will distinguish if an intervention is going to occur by the FMCSA for a company. A company above the percentile line for a safety fitness determination will be subject to being proposed as unfit to operate or subject to an intervention while continuing to operate. Companies below the percentage line (lower numbers) will not have any action occur.
The intervention options will be much more than in the past when an on-site inspection/review was really the only course of action. “Because we have lots of data, we might not need the on-site review, and we want safety fitness determination to be more timely and frequent than it has been. We want to cover more carriers. We are covering less than 2 percent of the carriers on our national list right now,” Mattioli explained.
“The majority of the companies on our list have less than 10 trucks, which accounts for about 70 percent. The large carriers with 100 to 500 or more trucks are really a small percentage. Most of the ones we see today under the SAFESTAT system, I’d say, range from 10 to 30 trucks,” Mattioli said.
MANY WARNING LETTERS
Warning letters will be the least serious intervention. “The new system uses a lot more warning letters than the old system, and the warning letters are better. They are more specific to what the issue is and give you more information on where to find the data you need to make changes. If we can fix something with a warning letter instead of someone coming out and wasting your time and our time and have compliance, that is a win-win,” he said.
An on-site focused investigation can also replace a full compliance review, he suggested, and to avoid more than a warning letter requires doing as asked. If the letter asks a company to do something, then taking action will speak positively. Not responding or not sending documents and answers will result in the system jumping the compliance issue to a higher intervention level such as a focused on-site review.
Mattioli noted that only data placed in the system by certified state troopers or inspectors will be included to influence the compliance data. “A regular police officer that is not certified to do inspections means that the data will not come into the system,” he said.
To not have trouble with CSA 2010, Mattioli suggested simple procedures:
- Maintain good compliance and good maintenance programs.
- View your Comprehensive Safety Information (CSI) on the Web site regularly.
- Involve your drivers so that they understand consequences.
- Keep your company and driver data current.
- Check safety data on the Web and use the Dataqs Web site to challenge reports on file.
- Respond to warning letters and administration contact.
- Try to accomplish clean inspections/reviews because they are big positives on scores.
Mattioli said his Illinois office will turn on the new CSA 2010 system Dec. 1. The Web sites already up and running are https://csa2010.fmcsa.dot.gov and https://dataqs.fmcsa.dot.gov.
It should be remembered that companies must register for their Web access and only one pin number will be issued per company. There cannot be different pins for different locations of a company.
This article is brought to you in cooperation with the National Agronomic Environmental Health and Safety School.