CSA 2010 changes are effective July 2012. Are you ready?

03 July 2012

New changes go into effect for the CSA program in July 2012.

The goal of the Federal Motor Carrier Safety Administration (FMSCA) is to reduce commercial motor vehicle crashes, fatalities and injuries on our nation's highways. It is no surprise that the programs and systems are constantly changing. The Safety Measurement System (SMS), originally implemented in December 2010 as part of the agency's broader Compliance, Safety, Accountability (CSA) initiative, is the latest system to undergo improvements.

The SMS is designed to help prioritize enforcement resources and monitor whether a motor carrier's safety problems are improving. By quantifying the on-road safety performance of motor carriers, FMCSA can identify trends in safety problems that need to be addressed.

According to the FMCSA's official Federal Register notice issued on March 27, 2012, feedback and data was analyzed from a number of different enforcement personnel, safety advocates, state partners and industry representatives to identify areas where improvements were needed. The result of this stringent analysis is that a number of enhancements that are being made to SMS. These improvements are the first in a series that will take place as frequently as twice a year. A customary, preview period will be provided for public comment.

The first seven changes that are taking place in July 2012 are as follows:

Strengthening the Vehicle Maintenance Behavior Analysis and Safety Improvement Category (BASIC) by incorporating cargo load securement violations from today's Cargo-Related Basic.
Changing the Cargo-Related Basic to the Hazardous Materials (HM) BASIC to better identify HM-related safety problems.
Better aligning the SMS with Intermodal Equipment Provider (IEP) regulations.
Aligning violations that are included in the SMS with Commercial Vehicle Safety Alliance (CVSA) inspection levels by eliminating vehicle violations derived from driver-only inspections and driver violations from vehicle-only inspections.
More accurately identifying carriers involved in transporting HM.
More accurately identifying carriers involved in transporting passengers.
Modifying the SMS display to:

Change current terminology, "inconclusive" and "insufficient data," to fact-based descriptions.
Separate crashes with injuries and crashes with fatalities.

Improving BASIC

The FMCSA implemented SMS as an avenue for identifying high-risk motor carriers for on-site investigations. It also serves as the barometer for deciding which carriers are issued warning letters, and works in coordination with other types of roadside inspection software to help determine carriers that could benefit from additional inspections. SMS quantifies the data and groups it into seven Behavioral Analysis Safety Improvement Categories. These categories are:

Unsafe driving
Fatigued driving (Hours-of-Service)
Driver fitness
Controlled substances and alcohol
Vehicle maintenance
Cargo related
Crash history

According the FMCSA, it has always expected to continually modify SMS as their evaluations led to new insights and as new data became available. The last two years have proven that there are some inefficiencies and confusion as it relates to the current system.

To that end, most of the improvements that are being made are being done in an effort to more accurately reflect the true safety profile of a specific company. For example, industry members have continually complained that carriers that haul predominately open trailers-or flatbeds-have higher than expected Cargo-Related BASIC percentiles due to readily identified load securement issues with these types of trailers. Industry members have pointed out that this causes a potential bias.

In its analysis, the FMSCA determined that the best way to address the potential bias while still correctly identifying carriers with cargo securement issues was to move the cargo/load securement violations from today's Cargo-Related BASIC to the Vehicle Maintenance BASIC. Their data shows that by implementing this change, they will still be able to identify carriers that have a higher crash risk while addressing the bias, and continue to hold carriers accountable for cargo securement violations.

Ready for change?

Anytime we face change-whether it's in our industry or in our personal lives- we tend to resist it. It seems that the CSA changes to SMS are no different. There are, however, a few things that your company can do to ready itself.

The preview period for the changes started on March 27, 2012 and will run through July. The data preview can be found at http://csa.fmcsa.dot.gov/. Your DOT number and PIN number will be required to log in. This allows motor carriers to preview how the improvements will impact their individual safety data within the system and make decisions based on their findings. It also gives motor carriers the opportunity to provide public feedback-bringing the voice of America's motor carriers into the conversation.

Each of the areas within the system where a change is being made is highlighted. NBIS highly recommends that you take the time to acknowledge the changes and understand why they are being made. Through ongoing research and careful consideration of the public's comments, the FMCSA will continue to be able to make the necessary improvements. Your company's voice is imperative to the process.

The FMCSA rules are not stagnant, as the industry and technology improves, the FMCSA will leverage your feedback and make every attempt to improve safety rulings. We won't know exactly what the next round of changes to SMS will bring until later this year, but we do know one thing for certain: our comments as an industry matter.

Take the time to preview the changes and see how it will affect your company's scores in the seven BASIC categories. It may seem like a trivial exercise, but we can assure you it is not. In fact, in an effort to get an unbiased, objective opinion of SMS data, the FMCSA ordered an independent evaluation of the data by the University of Michigan Transportation Research Institute (UMTRI). Not surprisingly, the UMTRI found that crash rates were higher for motor carriers identified with safety problems in SMS's seven BASICs. In sum, BASIC scores have a direct correlation to a company's ability to perform safely.

Although it may be difficult, NBIS encourages all business owners to embrace the changes that are being made and speak up when you have an opinion. For when we do this as an industry, when we implement positive change, as a result - the industry improves.

Resources

1. Foundational Document can be found at: http://csa.fmcsa.dot.gov/Documents/SMS_FoundationalDoc_final.pdf

2. The Federal Register notice can be found here: https://www.federalregister.gov/articles/2012/03/27/2012-7360/improvements-to-the-compliance-safety-accountability-csa-motor-carrier-safety-measurement-system-sms

3. The data preview can be found at http://csa.fmcsa.dot.gov/. DOT number and PIN needed to log in.