About CSA 2010 - What Is It?
Comprehensive Safety Analysis 2010, CSA 2010, is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce commercial motor vehicle (CMV)-related crashes, injuries and fatalities. It introduces a new enforcement and compliance model that allows FMCSA and its State partners to contact a larger number of carriers earlier in order to address safety problems before crashes occur. When the program is fully rolled out by the end of 2010, FMCSA will have a new nationwide system for making the roads safer for motor carriers and the public alike!
In the development of the CSA 2010 program, FMCSA sought to incorporate several key attributes.
FLEXIBILITY - Adapt to Changing Environment. Accommodates changes to the transportation environment, such as evolutions in technology and changing programmatic responsibilities.
EFFICIENCY - Maximize Use of Resources. Improves Federal and State enforcement staff productivity, as well as the safety performance of members of the motor carrier community.
EFFECTIVENESS - Improve Safety Performance. . Identifies behaviors associated with safety risk; focuses compliance, enforcement, and remediation efforts on those unsafe behaviors.
INNOVATION - Leverage Data and Technology. Improves safety through the innovative use of technology to track and update safety performance data.
EQUITABILITY - Be Fair and Unbiased. Assesses and evaluates motor carrier safety and enforces Federal laws and safety regulations to ensure consistent treatment of similarly situated members of the motor carrier community.
Why Is CSA 2010 Needed?
Since the 1970s, Federal and State enforcement agencies in partnership with many other stakeholders have progressively reduced the rate of commercial vehicle crashes resulting in injuries or fatalities on our Nation’s highways.
The rate of crash reduction has slowed, prompting FMCSA to take a fresh look at how the agency evaluates the safety of motor carriers and drivers and to explore ways to improve its safety monitoring, evaluation, and intervention processes. CSA 2010 is the result of this comprehensive examination.
Limitations of the current Operational Model
FMCSA's compliance and safety programs improve and promote safety performance and save lives. However, agency resources available for these efforts have remained relatively constant over time, despite increases in the regulated population and additional programmatic responsibilities. FMCSA has identified limitations in both how safety is measured and how unsafe behaviors, once identified, are corrected.
· FMCSA's current compliance review (CR) program is resource-intensive and reaches only a small percentage of motor carriers, making it increasingly difficult to continue to improve motor carrier safety using existing tools.
· On-site CRs to determine a motor carrier's safety fitness require an average of three to four days to complete. At present staffing levels, FMCSA can perform CRs on only a small number of the 700,000 active interstate motor carriers.
· SafeStat is FMCSA’s current system for measuring safety performance. Despite its effectiveness SafeStat groups safety problems together to identify carriers for a one-size-fits-all CR. It also does not focus on the behaviors known to cause crashes.
· The FMSCA Large Truck Crash Causation Study indicates that increased attention should be given to drivers of commercial vehicles.
CSA 2010 builds on FMCSA’s current processes for assessing and improving the safety performance of motor carriers and drivers through a new safety measurement system and a new suite of tools. These include an enhanced CR, in addition to more focused and efficient interventions tailored to address specific problems.
How Does CSA 2010 Work?
CSA 2010 re-engineers the existing enforcement and compliance business process to provide a better view into how well large commercial motor vehicle (CMV) carriers and drivers are complying with safety rules, and to intervene earlier with those who are not. When the program is fully rolled out by the end of 2010, FMCSA will have a new enforcement and compliance Operational Model that will utilize its resources, and those of its state enforcement partners, more efficiently and effectively, making the roads even safer for everyone.
This new CSA 2010 operational model has three major components:
· Measurement - CSA 2010 measures safety performance in new ways, using inspection and crash results to identify carriers whose behaviors could reasonably lead to crashes.
· Evaluation - CSA 2010 helps FMCSA and its State partners to correct high risk behavior by contacting more carriers and drivers, with interventions tailored to their specific safety problem, as well as a new safety fitness determination methodology.
· Intervention - CSA 2010 covers the full spectrum of safety issues – from how data is collected, evaluated, and shared to how enforcement officials can intervene most effectively and efficiently to improve safety on our roads.
CSA 2010 has been carefully planned and developed over the past few years. It began with a thorough review of the agency’s current compliance review (CR) process, and proceeded through the development of a new Safety Measurement System (SMS) that will use all roadside inspection and crash data and the development of a new interventions toolbox to deal efficiently and effectively with safety problems of various natures and different levels (as identified in SMS). In addition, the new model includes a proposed change to Safety Fitness Determination (SFD), also tied to SMS results, although implementation of CSA 2010 is not dependent on the proposed change.
The expanded suite of intervention tools enable investigators to systematically evaluate why safety problems are occurring, to recommend remedies, to encourage corrective action(s), and, where corrective action is inadequate, to invoke strong penalties. The new SMS and interventions toolbox are now being tested in Colorado, Georgia, Minnesota, Missouri, Montana, and New Jersey. Testing began in February 2008 in four states, and expanded to add two more (Montana and Minnesota) in spring 2009. Two additional states may be added in Fall 2009.
Feedback from enforcement staff and carriers indicate that the new model is both efficient, reaching more carriers, and effective, with some carriers undertaking proactive efforts to learn more and to correct their safety problems.
Safety Measurement System
When FMCSA rolls out CSA 2010, the Safety Measurement System (SMS) will replace SafeStat. Every month, SMS will measure the previous two years of roadside violation and crash data and calculate a score in seven safety behavior areas, called BASICs (Behavioral Analysis and Safety Improvement Categories).
CSA 2010 BASICs:
· Unsafe Driving — Dangerous or careless operation of commercial motor vehicles (CMVs). Data includes driver traffic violations and convictions for speeding, reckless driving, improper lane change, inattention, and other unsafe driving behavior.
· Fatigued Driving (Hours-of-Service) — Driving a CMV when fatigued. This is distinguished from incidents where unconsciousness or an inability to react is brought about by the use of alcohol, drugs, or other controlled substances. Data includes (1) hours-of-service violations discovered during an off-site investigation, on-site investigation, roadside inspection, or post-crash inspection, and (2) crash reports with driver fatigue as a contributing factor.
· Driver Fitness — Operation of a CMV by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualification. Data includes (1) inspection violations for failure to have a valid and appropriate commercial driver's license or medical or training documentation, (2) crash reports citing a lack of experience or medical reason as a cause or contributory factor, and (3) violations from an off-site investigation or an on-site investigation for failure to maintain proper driver qualification files, or use of unqualified drivers.
· Controlled Substances and Alcohol — Operation of a CMV while impaired due to alcohol, illegal drugs, and misuse of prescription medications or over-the-counter medications. Data includes (1) roadside violations involving controlled substances or alcohol, (2) crash reports citing driver impairment or intoxication as a cause, (3) positive drug or alcohol test results on drivers, and (4) lack of appropriate testing or other deficiencies in motor carrier controlled substances and alcohol testing programs.
· Vehicle Maintenance — CMV failure due to improper or inadequate maintenance. Data includes (1) roadside violations for brakes, lights, and other mechanical defects, (2) crash reports citing a mechanical failure as a contributing factor, and (3) violations from an off-site investigation or an on-site investigation associated with pre-trip inspections, maintenance records, and repair records.
· Cargo Related — Shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. Data includes (1) roadside inspection violations pertaining to load securement, cargo retention, and hazardous material handling, and (2) crash reports citing shifting loads, or spilled/dropped cargo as a cause or contributing factor.
· Crash Indicator— Histories or patterns of high crash involvement, including frequency and severity. Data includes law enforcement crash reports and crashes reported by the carrier and discovered during on-site investigations.
Recent roadside violations and violations that correlate most with crashes will be weighted more heavily than other violations. SMS will then rank carrier scores relative to their peers to determine which entities have specific safety problems.
Safety Evaluation
Safety evaluation is the process of determining how to address carriers with poor safety performance. SMS allows FMCSA to more effectively evaluate safety performance using new measures for
1. identifying which carriers require what type of intervention using a policy-driven process called intervention selection, and
2. determining which carriers should be proposed "unfit" to operate, using a regulatory process called Safety Fitness Determination (SFD).
(An Unfit Suspension will prohibit a carrier from operating, based on the conclusion of a SFD. The details of Unfit Suspension will be described in the SFD Rulemaking.)
FMCSA is developing a Safety Fitness Determination (SFD) methodology, subject to ongoing rulemaking, to replace the current system, which is solely dependent on the onsite compliance review results. The SFD will expand the use of on-road performance as calculated in the SMS and include results of all investigations. It will also allow FMCSA to determine safety fitness on a larger segment of the industry.
Intervention
FMCSA and State partners will use measurement results to identify carriers for CSA 2010 interventions. These interventions will offer an expanded suite of tools ranging from warning letters to comprehensive on-site investigations that supplement the labor-intensive compliance review to better address the specific safety problems identified.
CSA 2010 investigators will be equipped to systematically evaluate why safety problems are occurring, to recommend remedies, to encourage corrective action(s), and, where corrective action is inadequate, to invoke strong penalties. Interventions will provide carriers with the information necessary to understand their safety problems and to change unsafe behavior early on. Interventions under CSA 2010 can be broken into 3 basic categories, which are described in detail below: early contact, investigation, and follow-on.
Early Contact
Warning Letter - Correspondence sent to a carrier's place of business that specifically identifies a deficient BASIC(s) and outlines possible consequences of continued safety problems. The warning letter provides instructions for accessing carrier safety data and measurement as well as a point of contact.
Carrier Access to Safety Data and Measurement - Carriers have access to their measurement results (BASICs scores), as well as the inspection reports and violations that went into those results. With this information, carriers can chart a course of self-improvement. Carriers can also monitor this data for accuracy and challenge it as necessary through FMCSA’s DataQs system:.
Targeted Roadside Inspection - CSA 2010 provides roadside inspectors with data that identifies a carrier’s specific safety problems, by BASIC, based on the new measurement system. Targeted roadside inspections occur at permanent and temporary roadside inspection locations where connectivity to the SMS information is available. As Commercial Vehicle Information Systems and Networks (CVISN) technologies evolve they will be incorporated into the roadside inspections.
Investigation
Off-site Investigation - A carrier is required to submit documents to FMCSA or a State partner. These documents are used to evaluate the safety problems identified through the SMS and to determine their root causes. Types of documents requested may include third party documents such as toll receipts, border crossing records, or drug testing records. The goal is to identify issues responsible for poor safety performance. If the carrier does not submit requested documents they may be subject to an on-site investigation or to subpoena records (see below).
On-site Focused Investigation - The purpose of this intervention is to evaluate the safety problems identified through the SMS and their root causes. An on-site focused investigation may be selected when deficiencies in two or less BASICs exist. "Focused" on-site investigations target specific problem areas (for example, maintenance records), while "comprehensive" on-site investigations address all aspects of the carrier’s operation.
On-site Comprehensive Investigation - This intervention is similar to a CR and takes place at the carrier’s place of business. It is used when the carrier exhibits broad and complex safety problems through continually deficient BASICs, worsening multiple BASICs (three or more), or a fatal crash or complaint.
Follow-on
Cooperative Safety Plan (CSP) - Implemented by the carrier, this safety improvement plan is voluntary. The carrier and FMCSA collaboratively create a plan, based on a standard template, to address the underlying problems resulting from the carrier's substandard safety performance.
Notice of Violation (NOV) - The NOV is a formal notice of safety deficiencies that requires a response from the carrier. It is used when the regulatory violations discovered are severe enough to warrant formal action but not a civil penalty (fine). It is also used in cases where the violation is immediately correctable and the level of, or desire for, cooperation is high. To avoid further intervention, including fines, the carrier must provide evidence of corrective action or initiate a successful challenge to the violation.
Notice of Claim (NOC) - An NOC is issued in cases where the regulatory violations are severe enough to warrant assessment and issuance of civil penalties.
Settlement Agreement - A Settlement Agreement is a contract negotiated with the carrier to enact remedies that address the root cause of a safety problem, defer or reduce penalties, or terminate enforcement proceedings.
CSA 2010 mandates proactive and progressive interventions for carriers and drivers that have been identified with safety deficiencies. CSA 2010 interventions are unique tools designed to communicate, investigate, and correct carrier safety performance problems before crashes occur. The interventions increase in severity and degree of interaction based on the risk posed by the carrier. FMCSA and its state partners will use CSA 2010 interventions to maintain a strong enforcement presence by more effectively targeting motor carrier safety deficiencies soon after those problems are identified.
What Is The Timeline For CSA 2010?
In February 2008, FMCSA launched a field test of the CSA 2010 Operational Model in Colorado, Georgia, Missouri, and New Jersey encompassing about 50 percent of the carriers and government resources in each State. In spring 2009, FMCSA added Montana and Minnesota to the test group. New interventions are being applied to all interstate and hazmat motor carriers domiciled in these States utilizing all government resources on the test.
Federal and State participants provide feedback and input into the Operational Model through participation in the CSA 2010 Federal and State Working Group (FSWG), supporting development and refinement of the new model.
Quantitative and qualitative data relating to the CSA 2010 Operational Model will be collected through the conclusion of the test in mid-2010. An independent third party, University of Michigan Transportation Research Institute (UMTRI), will evaluate the program using this data to determine the new Operational Model’s effectiveness (i.e. potential for improving safety) and efficiency (i.e. impact on scarce resources).Preliminary results are promising.
The CSA 2010 Timeline illustrates the timeline for the implementation of CSA 2010 and the concurrent communication and outreach effort.
Between now and full implementation, FMCSA is launching an outreach effort to inform carriers and drivers of the upcoming change, and to encourage all stakeholders to become more involved. Support of the FMCSA leadership and continued outreach to stakeholders such as the National Transportation Safety Board, Congress, the Government Accounting Office, safety advocate groups, industry, and the Commercial Vehicle Safety Alliance, paves the way for successful implementation of CSA 2010 nationwide.
Your Role
How does CSA 2010 affect you?
The Federal Motor Carrier Safety Administration’s FMCSA new national safety initiative for commercial motor vehicles, CSA 2010, is a more efficient and effective method for targeting the safety problems of both motor carriers and their drivers to reduce commercial motor vehicle crashes and fatalities.
The success of this new effort requires the cooperation of many stakeholders like you—people at all levels within FMCSA, state partners, motor carriers, trucking associations, and industry. Here you will find information specific to your role in implementing CSA 2010 nationwide. Check these pages regularly for updates.
Motor Carriers & Drivers
Commercial motor vehicle drivers, owner-operators, fleet managers, fleet owners, and other commercial vehicles on the Nation’s roadways are essential participants in FMCSA’s CSA 2010 (Comprehensive Safety Analysis 2010) initiative to reduce motor vehicle crashes and fatalities. This section provides vital information to help you understand your roles and responsibilities under the new CSA 2010 operational model.
What does CSA 2010 mean to me?
CSA 2010 replaces SafeStat with a new Safety Measurement System (SMS) that measures the previous two years of roadside violations and crash data. With SMS, every inspection counts, not just out-of-service violations, and both driver and carrier safety performance are monitored.