What Lies Ahead with Changes to CSA

Compliance, Safety, Accountability (CSA) has been around since 2010 and while the idea of CSA may sound like old news, the talk of significant changes to the Safety Management System (SMS) is just beginning.

In mid-February, the FMCSA published a notice with a request for comments on the Federal Register. FMCSA’s notice is filled with proposed changes to the SMS, announced the ability to preview how the changes would look to a specific motor carrier number, and finally, requests comments and input to the proposed changes.

Previously, the SMS focused on seven Behavior Analysis and Safety Improvement Categories (BASICs). The FMCSA has proposed reorganizing the BASICs and naming them “safety categories.” Image 1.1 shows the old vs. new safety categories.

improve and assist enforcement officials in conducting targeted investigations. Vehicle Maintenance: Driver Observed would focus on violations that may be identified by a driver during a pre or post trip inspection and/or while operating a vehicle. The secondary safety category, Vehicle Maintenance, would include all other vehicle maintenance violations.

Another proposed change puts all violations for operating while under an OOS Order and places it in Unsafe Driving. Today, the SMS places operating while under an OOS Order across different categories based on the root cause of the violation (i.e. operating out of service after an hours of service violation would go to the Hours of Service Compliance BASIC, and operating out of service after an equipment violation would go to the Vehicle Maintenance BASIC).

Allison has spent the last 13+ years in various management & safety roles within the trucking industry, including her current role as Director of Safety & Member Services for the IMTA. Not only does Allison have tremendous expertise in safety and compliance, she also has a very positive working relationship with our regulatory and enforcement partners.

The two most significant changes to the newly named safety categories, is the removal of Controlled Substances/Alcohol and the addition of Vehicle Maintenance: Driver Observed. Controlled Substances/Alcohol has the fewest violations of any of the current BASICs in the industry and is cited relatively infrequently. Through FMCSA’s Exploratory Factor Analysis (EFA), they have identified that controlled substances and alcohol violations are strongly associated with the Unsafe Driving BASIC. Moving forward, any Controlled Substance/Alcohol violations would be moved into the Unsafe Driving safety category.

FMCSA also indicated the EFA results showed that breaking Vehicle Maintenance into two separate categories would help carriers

The Federal Register also discusses the sheer number of violation types. Over the last decade, violation codes used in the SMS system has grown from approximately 650 violations to 959 violations, often times making it hard to establish specific safety issues within a fleet. The Federal Register breaks down and consolidates violations for each safety category, reducing the violation codes considerably, as shown in Image 1.2.

The Federal Register continues on to discuss changes in the SMS as it relates to severity weights, percentiles and intervention thresholds. While the changes to the calculations are all important to monitor, the most immediate need is for motor carriers to be in tune with their SMS scores as they stand today. At this point, we don’t have a firm timeline on when these changes may be implemented, but FMCSA has been very clear they want changes to the SMS program. Motor carriers have the opportunity to preview their scores in the new scoring system through the CSA website or FMCSA portal. Once scores are reviewed, make a plan for action. In a reactive manner, motor carriers can review their violations and submit DataQs when appropriate to improve scores. Driving the scores down where possible will be beneficial to keep compliance in check as changes come. In a proactive manner, motor carriers should coach the importance of compliance in each of the safety categories. Additionally, make and implement a plan to continually monitor SMS scores. These scores are a large indicator for motor carrier prioritization as it relates to auditing.

Image 1.2 Violation Consolidation

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