The FMCSA just announced their PROPOSED changes to the way their CSA system will prioritize trucking companies for intervention (see Compliance Review or DOT Audit).
Now what?
First, don’t panic. These changes were required to be made and nothing is set in stone yet. It will take at least 3 to 6 months for any changes to be made.
But, we really don’t forsee much changing from their current proposal…because it’s the Federal Motor Carrier Safety Administration.
Now, what are the changes and how is it going to impact you?
There are MANY changes that are being proposed.
Here’s an overview:
CSA BASICs are no longer going to be called BASICs…it’s now “Safety Categories”
Okay, nothing much happening here. BASICs was kind of lame anyway. This sounds nicer.
FMCSA CSA Changes: Unsafe Driving Category Changes
The Unsafe Driving Safety Category will now include ALL Out of Service violations and all drug and alcohol violations.
The existing Vehicle Maintenance Safety Category will be split into:
VM: Driver Observed and
Vehicle Maintenance
As the title suggests, anything that a driver could reasonably be expected to catch during a pre-trip inspection will fall into the first category.
Anything that a mechanic or DOT officer would normally discover during a annual DOT inspection or a Level 1 DOT inspection would fall into the second new vehicle maintenance category.
We’re helping all of our clients through this process as part of our trucking compliance services!
FMCSA CSA Changes: Reorganizing Roadside Violations
All existing 959 roadside violations will now be classified into 116 violation groups of similar safety behaviors.
Under the new SMS, DOT violations that identify the same or similar underlying safety issue would be grouped together.
If a motor carrier receives more than one of the violations in a violation group during a single inspection, the new methodology would treat that set of violations as a single violation when calculating the carrier’s measure in that safety category.
So, if a driver currently violates both the 11 hour rule (395.3A3-PROP: Driving beyond 11 hour driving limit and the 14 hour rule (395.3A2-PROP: Driving beyond 14 hour duty period at the same time, the driver would be cited for both during a roadside inspection.
Each would be found on their roadside inspection report (DVER ) and each would count towards the current intervention thresholds.
With the new FMCSA CSA changes, each violation will still show up on their DVER. But only one inspection in the new “Roadside Violation Group” will be counted towards the intervention thresholds.
Grab a complete list of the new Roadside Violation Groups here.
FMCSA CSA Changes: Simplified Severity Weights
Violation severity weights are being changed to adopt a more straightforward approach.
The old “1-10” weighting scale for violations in SMS is now being replaced with a two-value scale: a severity weight of either 1 or 2.
Currently, all violations are given a “weight” of 1 to 10. 1 is not severe and 10 is the most severe DOT violation that a driver can receive. Check out a list of those CSA violation points here.
This simplified approach identifies carriers with higher crash rates for prioritization and makes it clearer why a specific violation is weighted more heavily than others.
Here’s how the new FMCSA CSA points system will work:
All violations recveive 1 severity point except:
Multiple violations in the same group (like the HOS example that we just discussed)
All Out of Service Violations (outside of Unsafe Driving)
Driver Disqualifying Violations
Common Driver Disqualifying Violations:
These common disqualifying DOT violations are:
- Speeding in excess of 15 MPH
- Using a handheld cell phone or texting while driving
- Driving without a CDL
- Following too closely
- Making Improper Lane Change
- Reckless Driving
- Driving with a suspended CDL (for safety related reasons)
- DUI/DWI
- Leaving the Scene of an accident
- Using the vehicle to commit a felony
(Check out the full list of violations (as defined in 49 CFR 383.51) here.
The time weights for violations will remain the same as they currently are.
See How the New FMCSA CSA Changes will affect your company by logging into your FMCSA CSA Prioritization Preview here!
FMCSA CSA Changes: Improved Intervention Thresholds
The Intervention thresholds for three safety categories will be adjusted to focus on carriers with the highest crash rates.
The Unsafe Driving, Hours of Service and Crash BASIC score (now Safety Categories) will remain the same:
Unsafe Driving Safety Category Alert Threshold: 65%
Hours of Service Compliance Safety Category Alert Threshold: 65%
Crash Indicator Safety Category Alert Threshold: 65%
The new Vehicle Maintenance: Driver Observed and Vehicle Maintenance safety categories will have the same thresholds as the SMS Vehicle Maintenance BASIC:
- 80% for general carriers.
- 65% for passenger carriers.
- 75% for HM carriers
The Driver Fitness thresholds will increase from:
- 80% to 90% for general carriers.
- 65% to 75% for passenger carriers.
- 75% to 85% for HM carriers.
The HM Compliance thresholds will increase from 80% to 90% for all carrier types.
FMCSA CSA Changes: Proportionate Percentiles
The FMCSA is attempting to eliminate large percentile changes that occur for non-safety related reasons.
“Proportionate percentiles” will use the exact number of inspections and crashes to assign a percentile for a motor carrier, rather than relying on the cutoffs in SMS established by the current safety event groups.
This is a great change and will help reduce or eliminate large swings in a trucking company’s SMS score when there are no new violations during a month.
For instance, many carriers have experienced a large change in their CSA score when they move from one “safety event group” to another because one inspection fell off of their record from 2 years ago.
This new change should make that less likely to happen.
FMCSA CSA Changes: Greater Focus on Recent Violations
When enacted, the FMCSA will only be calculating percentiles for motor carriers with violations cited within the last 12 months.
For all safety categories outside of the Crash Safety Category (formerlly the Crash BASIC score), any violation outside of the last 12 months won’t be used to generate a percentile score for your company.
Under the new FMCSA CSA changes, any violation outside of the last 12 months won’t be used to prioritize your company for a DOT intervention. So that should help better secure your good CSA scores.
It’s important to note that violations older than 12 months will still be counted against trucking companies under the new SMS methodology.
But, if you don’t have a violation in a safety category within the last 12 months, you won’t have a CSA BASIC alert in that safety category.
FMCSA CSA Changes: Updated Utilization Factor
This is a minor change that won’t affect most trucking companies.
Currently, your vehicle miles travelled (VMT) is used to help calculate your CSA BASIC scores for both the Unsafe Driving and Crash BASICs.
That won’t change under the new FMCSA CSA changes.
The FMCSA is just bumping the upper limit of the VMT calculation up to a maximum of 250,000 miles per year. (It’s currently set to 200,000).
Most carriers don’t run anything close to that number in each truck, so not much of a change at all here.
But, you should update you MCS 150 often in order to ensure that your Unsafe Driving and Crash scores are being calculated correctly.
FMCSA CSA Changes: New Segmentation
This is another minor change.
Currently, trucking companies are “segmented” when calculating the Unsafe Driving and Crash BASIC scores.
Under the new FMCSA SMS changes, the Hazardous Materials and Driver Fitness Safety Categories will also be segmented.
The Hazardous Materials Safety Category will be segmented by Cargo Tank and Non-Cargo Tank Carriers
The Driver Fitness Safety Category will be segmented by Straight and Combination Carriers.
Again, no major changes here. We don’t expect that many carriers will see any impact from this.
FMCSA CSA Changes: Accounting for Not Preventable Crashes
No major change here.
The FMCSA will continue to use the Crash Preventability Determination Program (CPDP) to make non-preventable determinations for trucking companies.
Crashes that are judged to be not-preventable will continue to be excluded from SMS calculations.
These will also continue to be recorded differently on a truck driver’s PSP report.
FMCSA CSA Changes: Timeline
So, these are currently proposed changes. When will this all take place?
The FMCSA will accept comments to the newly proposed FMCSA SMS changes until March 15, 2023.
After that time, the ability for the public to comment will end.
Then, the FMCSA will analyze and consider making changes to the new prioritization methodology over the next few months.
After deciding which, if any, changes to make the FMCSA will announce the final changes.
All in, don’t expect to see these taking effect until probably Q3 2023 at the earliest. We believe that it will be Q4 2023 or perhaps a bit later.
You can read the entire Federal Register Notice and make any comments that you would like until 3/15/2023. You can do that by clicking this link.
FMCSA CSA Changes: Wrapping Up
So, that’s a lot to unpack…and we’re still going to dig deeper into unwrapping these changes further as well in the coming weeks and months.
The most important changes are:
The CSA BASIC score categories are being re-organized a bit and renamed.
How we calculate CSA BASIC scores are going to be dramatically impacted.
More recent and more severe violations are going to have trucking companies prioritized higher for FMCSA intervention.
Outside of that, the changes are more minor in nature and shouldn’t have much of an impact on most carriers.
When these changes are enacted, expect to see a far greater number of compliance reviews and Conditional Safety Ratings!
Regardless, expect to see CSA near the top the list of top industry concerns again this year!
More to come soon, so stay tuned.
About My Safety Manager:
We want our clients to be “Audit Ready” at all times. So, we handle their fleet safety and DOT compliance programs for them. Our specialized safety management solutions help deliver results—safe drivers out on the road who are staying compliant with FMCSA regulations.
We’re a leading provider of fleet safety and trucking compliance services for fleets of all sizes.
We work with you to create compliance systems that meet your unique needs, taking what’s typically far too much work off your plate so you have more time to grow your business.
For more information about how we may be able to help you with this or similar issues, please reach out to us at www.MySafetyManager.com.
You must be logged in to post a comment.