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Comprehensive Safety Analysis 2010 Compliance, Safety, Accountability

Is Live as of December 12, 2010

Compliance, Safety, Accountability (CSA) Important Facts

Just the facts, Max.
Compliance, Safety, Accountability - csa2010.fmcsa.dot.gov

#1 There is no "phase in" or "grace period." CSA is here. It is live.

#2 Do not mistake silence as approval. There are no "progressive" or gradual enforcement steps; a warning is a courtesy at best and is not required nor should it be expected.

#3 CSA is "comprehensive" because it "scores" all "data" as, for example, 'warning tickets' or 'non-fault collisions' resulting in CSA drivers points

Notice of Violations (NOV) and Notice of Claim (NOC), resulting in civil penalties (monetary fines) may be assessed without having received any prior warning letters (WL). Other actions or "interventions" may be taken by the DOT as well.

"...a carrier (company, owner-operator, etc.) will enter the process anywhere from Warning Letters to on-site comprehensive depending on the nature and severity of the problems."

#4 Review your Compliance, Safety, Accountability Safety Measurement Score (See explanation below).

#5 Do a Pre-Employment Screening click here of new hires.

Prepare now and avoid a regulatory nightmare later.

If not having done so already, you will need to develop minimum qualifications (preferably in writing) that you will accept before allowing a driver continued employment. The qualifications, which should be developed in consultation with the appropriate department management, should relate to the driverís training and recent experience.

"Pilot studies in the eight CSA 2010 states have resulted in:
- 3 times the number of DOT Audits
- 3 times the fines
- Over 1/3 of companies found "UNFIT"
- Loss of driving personnel"

Don Osterberg,
VP Schneider, March 17, 2010
CSA 2010's impact on the driver force

Hank Seaton, Esq. on CSA 2010, "If you use these standards, 57% of carriers will be deemed unsafe." Tweet on 5-11-2011 @Transplace

Meet the CSA Safety Challenge

To prepare to deal with DOT "interventions," audits and other DOT enforcement actions, the DOT Safety Audit Guide management program click here will walk you through the DOT required Safety Management System (SMS) compliance process.

To transform your organization, the Safety Leaderís Handbook click here will guide the next generation of Leaders in Implementation, Analysis and Performance Measures to maximize safe operations. Be a Safety Leader.

"The key to greatness is to always look to do better. You will always be merely good relative to what you can do next."
Jim Collins (Good to Great)

Driver Tips:

Avoid roadside inspections - 35.4% of Roadside Inspections are triggered by speeding

There are 3 million annual truck inspections with a:
- 73% Violation rate
- 25% Out Of Service rate

There are 82 million weigh inspections with DOT staff in place resulting in 1/2 million citations.

*The most cited key OOS Violations:

Logbook 40.0%  Brakes 41.2%
HOS 28.7%  Lighting 16.6%
CDL 19.4%   Tires 9.4%
    Load Securement 15.7%
* Source: J. Loftus, FMCSA, Office of Analysis, Research, and Technology, 2008

Please keep in mind that several regulations are so important that violating them causes an order to park your equipment (OOS order) until everything is fixed. In a nutshell, these regulations are concerned with:
- Alcohol and controlled substances testing and using impaired drivers (CDL drivers only click here)
- Commercial driversí licenses and driversí physical fitness to drive
- Proof of insurance
- Equipment repair and inspection
MoDOT, Winter 2010

All driver's need to do due diligence on their equipment and load securement click here and Hours of Service (HOS)/ Logbooks click here

These are your tools to stay ahead of the DOT enforcement curve.

Due Diligence

Do a CSA Safety Measurememt System review: Check Your BASICs Scores

As of May 2010 FMCSA Administrator Anne S. Ferro noted that only some 7,000 DOT registered companies have looked at their BASICs scores out of one-half million active companies. - The Trucker 5/21/2010

By October 2010 only 12,000 companies or organizations checked their data - a mere 2 percent.

An FMCSA-issued U.S. DOT Number Personal Identification Number (PIN) (NOT a Docket Number PIN) is needed to access this CSA website. If you do not know or have forgotten your PIN, you can request one via at SAFER click here . (Then - the third RED colored paragraph down - click on: Click here to request your Docket Number PIN and/or USDOT Number PIN. ) If you registered for a DOT number online, then the PIN given to you at that time should be correct. You may also call the DOT at 1-800-832-5660 for assistance. With your PIN Number and knowing your DOT Number, go to the CSA click here official CSA site and on this page find and click on "SMS RESULTS". Note: if you want to see what the public sees, then just click on the "SMS RESULTS" and on the next page do a search (on the Right Hand Side of the page: "SEARCH FOR MOTOR CARRIER SMS MONTHLY RESULTS").

Some Highlights of the CSA Site

• If your MCS-150 Registration is stale (over 24 months old) and needs to be renewed, a pop-up window may flag you. You need to know last years mileage and how many power units you operated or controlled for that year. Click on "UPDATE CARRIER REGISTRATION INFORMATION" - a color Orange flag icon to renew a stale registration (over 24 months old). Stale 'Carrier Registration Information' is highlighted in color orange.

• Clicking on a BASIC like 'UNSAFE DRIVING' brings up that page, with a simple explanation of the BASIC "Operation of commercial motor vehicles by drivers in a dangerous or careless manner" and the revelant "parts in the Federal Motor Carrier Safety Regulations: FMCSR Parts 392 and 397.

• The color Orange "Alert" icon is of interest as well and needs to be investigated.

• The Data Preview began on April 12, 2010 and ended on November 30, 2010, December 12, 2010, the national launch date for the CSA safety enforcement program.

• The DOT recommends each month you review your violation history, verify all data, know how to make data corrections (via Data Qs) and update carrier registration information as necessary.

• Log-out at the end of the session.

Other Considerations

- The official Start Date was December 12, 2010.

- The official program name became "Compliance, Safety, Accountability."


BASICs - "Behavioral Analysis and Safety Improvement Categories" are the seven measures of a company's safety performance (6 Basics + the Crash Indicator) over the last 24 months.

SMS - "Safety Measurement System" is a "point system," based on inspections, violations, crashes, etc. to score a company or its driver(s)

CSMS - "Carrier Safety Measurement System" are all safety "violations" from last 24 months (updated monthly) 7 million inspections and crashes (safety event data)

CSP - "Cooperative Safety Plan" is a voluntary commitment to put in writing, what systems will be put in place to correct compliance problems

CSA - Compliance, Safety, Accountability

CSA 2010 - the name of the pilot program

NOV - "Notice of Violation" - are not new but have been "underutilized" for carriers and drivers; allege certain facts and violations, contain orders to resolve the alleged violations, contain an assessed penalty with supporting documentation regarding what factors were used to determine the penalty, and, by law, allows a respondent the ability to appeal or contest the NOV (Hazmat example) click here.

NOC - "Notice of Claim," is a request to pay a civil penalty; a Notice of Claim (NOC) becomes a Final Agency Order if the respondent fails to reply to the NOC within the time prescribed by 49 CFR 386.14 click here. Individual drivers on a larger scale will face NOV or NOC fines Ė just like motor carriers.

Red Flag Driver - is a driver ticketed or cited for a Red Flag Violation. Further adjudication (as an actual conviction) or lack of an actual conviction may not remove the stigma.

Red Flag Violation - are considered egregious violations of the Federal Motor Carrier Safety Regulations (FMCSRs). Example:
BASIC Part Violation Description
Driver Fitness 383.21 Operating a CMV with more than one license

Other Red Flag Violations include: Operating an OOS vehicle, use or possession of drugs or alcohol, not being properly licensed, and so on. Check the current list of Red Flag Driver Violations in the CSA FAQs.

SFD - "Safety Fitness Determination" is a safety evaluation falling in one of the following categories: Unfit, Marginal, or Continue Operation

OOS - "Out Of Service" is an order to cease operations immediately.

DATAQs - The DataQs system click here is to be used by both Companies and DRIVERS to challenge the data issued by FMCSA (example: a crash report or ticket shown incorrectly, or belonging to another carrier or driver). A driver registers as a General Public User, creates a User Profile and needs to follow the instructions on the site. Challenging data, however, may not result in the error being corrected, according to Rick Craig, OOIDA Director of Regulatory Affairs. Document simple (make and keep good records) every action taken to correct any DOT mistakes.

ISS - Inspection Selection System number, is available on the FMCSA's COMPASS system.

The ISS numeric value determines if a DOT number holder has been identified for further Roadside Inspections.

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