Introduction to CSA

Our CSA guide introduces users to key concepts of the safety and compliance program.

Sections:

CSA Overview

Compliance, Safety, Accountability (CSA) is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce crashes, injuries, and fatalities that are related to commercial motor vehicles. 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. Rolled out in December 2010, the program establishes a new nationwide system for making the roads safer for motor carriers and the public alike.

FMCSA’s mission is to improve safety by reducing crashes. Over the past few years, 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 is the result of this comprehensive examination. CSA enables FMCSA and its state partners to assess the safety performance of a greater segment of the industry and to intervene with more carriers to change unsafe behavior early.

Public users, including shippers and insurers, have access to SMS results very similar to the way they did before with SafeStat. Public access have similar limitations to those that were in place before CSA for the public display of SafeStat results. 

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CSA Scores: Understanding SMS & BASICS

SMS evaluates the safety of individual motor carriers by considering all safety-based roadside inspection violations (not just out-of service violations) as well as State-reported crashes, using 24 months of performance data.

SMS assesses each carrier's safety performance in each of the Behavior Analysis and Safety Improvement Categories (BASICs).

The BASICs represent behaviors that can lead to crashes. The categories were developed based on information from a number of studies that quantify the associations between violations and crash risk, as well as statistical analysis and input from enforcement subject matter experts. The Safety Measurement System (SMS) assesses carriers in each of seven BASICs. Below are the seven BASICs and their corresponding Code of Federal Regulations (CFR) parts:

  • Unsafe Driving
    FMCFR Parts 392 & 397
  • Fatigued Driving / Hours-of-Service (HOS)
    FMCFR Parts 392 & 395
  • Driver Fitness
    FMCFR Parts 383 & 391
  • Controlled Substances/Alcohol
    FMCFR Parts 382 & 392
  • Vehicle Maintenance
    FMCFR Parts 393 & 396
  • Cargo-Related
    FMCFR Parts 392, 393, 397 & Hazardous Materials
  • Crash Indicator
    State-Reported Crashes

SMS calculates a measure for each BASIC by combining the time and severity weighted violations/crashes (more recent violations are weighted more heavily) normalized by exposure. For example, hybrid of number of power units/vehicle miles traveled or number of relevant inspections. Applying a similar approach to that used in SafeStat, SMS converts each carrier's BASIC measures into percentiles based on rank relative to carriers with similar safety event groupings (i.e. number of relevant inspections or crashes).

Vigillo begins updating your scorecards as soon as the FMCSA's monthly SMS update has occurred. This is generally within the first 10 days of the month. The Vigillo Scorecard updates are generally complete anywhere from three to five business days after the monthly SMS update - depending upon the cooperativeness of the FMCSA's systems. As soon as your scorecards are updated, Vigillo Support will send you an email alert.

  • To understand more about the BASICS, check out the SMS Factsheet and briefings on the CSA Website.
  • For even more detail, review the SMS Methodology document. 
  • The document details which values are assigned for each violation and how they are weighted in Appendix A, starting with A-4 located here.

Source: FMCSA CSA Website

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Drivers & CSA

The Safety Measurement System (SMS) uses all safety-based violations recorded during roadside inspections to evaluate safety. A list of these violations can be found in the Appendix A of the SMS Methodology document. All of the violations in Appendix A count against the motor carrier. A subset of these violations is applied to evaluate driver safety in cases where the commercial motor vehicle driver is also responsible in part for the occurrence. This subset of violations is noted in the “Driver Responsible” column in Appendix A of the SMS Methodology document. The driver safety assessment tool in the SMS, at present, is only used by enforcement personnel who are conducting carrier investigations. The new tool enables safety investigators to focus on drivers with poor safety performance histories when they are investigating a carrier. 

Source: FMCSA CSA 2010 Website

Vigillo reports information only for the time a driver is associated with your DOT up to 36 months of history. Your Vigillo Scorecards will show inspections and violations and crashes drivers incurred while working for you within the past 36 months.

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Roadside Inspections & Violations

Both CSMS and DSMS assess an individual entity's performance by BASIC and Crash Indicators calculated from information collected during on-road safety inspections and state-reported CMV crash records. These data are recorded in the Motor Carrier Management Information System (MCMIS). In addition, motor carrier Census data, also recorded in MCMIS, are used for the identification and normalization of safety event data.

Below are more detailed descriptions of each data source:

Roadside Inspections are examinations a Motor Carrier Safety Assistance Program (MCSAP) inspector conducts on individual CMVs and drivers to determine if they are in compliance with the Federal Motor Carrier Safety Regulations (FMCSRs) and/or Hazardous Materials Regulations (HMRs).

Violations are recorded during inspections and are entered into the MCMIS database. A subset of these violations results in driver or vehicle Out-of-Service (OOS) orders. These OOS violations must be corrected before the affected driver or vehicle is allowed to return to service. The SMS assessments are based on the safety violations listed in Appendix A. These assessments, however, do not include those violations that are:

  1. A result of a crash.
  2. Assigned to another entity such as a shipper or Intermodal Equipment Provider.
  3. Only pre-existing violations from post-crash inspections are used in the SMS. Violations recorded in MCMIS as being attributed to the crash are not used.

NOTE: Some roadside inspections are performed following a traffic enforcement stop for a moving violation. Violations reported during such stops do not always result in the issuance of a citation to the driver, but are used in the SMS whether or not a citation is issued.

State-Reported Commercial Vehicle Crash Data are taken from MCMIS and provide information on crashes as reported by state and local police officials. The reporting of these crashes follows National Governors Association (NGA) standards.

Motor Carrier Census Data are first collected when a carrier obtains a USDOT number. The Census data are primarily collected from: (1) Form MCS-150, filled out by the carrier, and (2) Form MCS-151, filled out by law enforcement as part of an investigation. Carriers are required to update their MCS-150 information biennially. Carriers domiciled in states participating in Performance and Registration Information Systems Management (PRISM) Program update their Census data as part of the CMV registration process. The CSMS uses Census data for identification and normalization of safety-related data. Examples of Census data include USDOT number, carrier name, number and type of Power Units (PUs), annualized vehicle miles travelled (VMT), physical location, current status, and types of cargo hauled.

Source: FMCSA Safety Measurement System (SMS) Methodology v 2.1

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Clean Inspections

Where do clean inspections come into play in the CSA Behavior Analysis and Safety Improvement Categories (BASIC) measurement? Are they included in the "number of time weighted relevant inspections" formula? If so, are all clean inspection rated the same, or do different levels deserve a higher positive BASIC assessment. For example, are Level I clean inspections rated more positive than Level III? 

A "clean inspection" is when a relevant roadside inspection resulted in no violations for a particular Behavior Analysis and Safety Improvement Category (BASIC). A relevant inspection is one where the roadside inspector reviewed a particular area for evidence of violations (not all inspection types/levels look at all areas). For example, when a carrier has no BASIC violations related to the Fatigued Driving (Hours-of-Service) BASIC, Driver Fitness BASIC and/or Controlled Substance/Alcohol BASIC from a Driver Inspection (Level 1, 2, 3 or 6), this "clean inspection" will lower the associated BASIC measure. Similarly, when a carrier has no BASIC violations related to the Vehicle Maintenance BASIC and/or Cargo-Related BASIC from a Vehicle Inspection (Level 1, 2, 5 or 6), this "clean inspection" will lower the associated BASIC measure. The North American Standard Driver/Vehicle Inspection Levels are explained on the FMCSA webpage.

The Fatigued Driving (HOS), Driver Fitness, Vehicle Maintenance, Cargo-Related, and Controlled Substance/Alcohol BASICs all use "relevant inspections" as a denominator for assessment of carrier performance. For example, any time a driver is examined in an inspection, there is an opportunity for a violation that would impact the Driver Fitness BASIC. Since there is an opportunity for a violation, it is considered a "relevant inspection" for that BASIC. An inspection in which a driver was looked at with no Driver Fitness violations recorded (i.e. a "clean inspection") would have a positive impact on the Driver Fitness BASIC.

Put simply, "clean inspections" help prevent the Fatigued Driving (HOS), Driver Fitness, Vehicle Maintenance, Cargo-Related, and Controlled Substance/Alcohol BASICs from becoming deficient, or help to improve those BASICs if they are already deficient.

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Carrier Interventions

Carrier interventions are designed to be progressive, increasing in severity and interaction with motor carriers and their drivers. The goal is to use the interventions to reach a larger segment of the motor carrier industry.

The intervention process is triggered by: 

  1. One or more deficient BASICs, 
  2. A high crash indicator, or 
  3. A complaint or fatal crash. Intervention selection is influenced by (1) safety performance, (2) hazardous material or passenger carrier status, and (3) intervention history.
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Crashes

The structure of the new Safety Management System (SMS) under CSA is such that crash accountability is not automatically determined or considered. In fact, recordable crash reports submitted to the FMCSA by the States do not include an accountability determination. Consequently, motor carriers are identified for possible intervention based on recordable crashes without consideration of accountability. This approach is taken because data analysis has historically shown that motor carriers that are involved in crashes are likely to be involved in more future crashes than the carriers that are not. Put simply, past crashes are a good predictor of future crashes. 

However, FMCSA recognizes this as a concern and is considering several short-term and long-term approaches to address it. Initially, because FMCSA understands that many crashes are not preventable on the part of the motor carrier, the short-term plans are to exclude the Crash Indicator Behavior Analysis and Safety Improvement Category (BASIC) percentile ranking from public websites. This is consistent with the Agency’s decision not to display the Accident Safety Evaluation Area of SafeStat on public websites in recent years. In addition, for the longer term, FMCSA is assessing the feasibility of evaluating crashes for accountability/preventability before they are used by SMS in the Crash Indicator BASIC. This would allow FMCSA to better concentrate intervention efforts on motor carriers that have high preventable/accountable crash rates.

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MCS-150

For example: 
The driver name and other privacy related material from individual inspection results will be remove.
The “assessment/score” related to the Crash Indicator BASIC will not be displayed because the data includes all crashes, including those where the carrier was not at fault.

According to the FMCSA, all regulated entities are required to update their registration information every 24 months under 49 CFR 390.19.  This includes: private and for-hire motor carriers of passengers and freight, freight forwarders, brokers, intermodal equipment providers, hazardous materials safety permit applicants/holders, and cargo tank facilities. 

CSA requires the use of "average power units" (APU) in calculations. This is different than current power unit count.

Average Power Units is a new term under CSA that is the average of a carrier's MCS-150 reported power units from three time periods:

  • Power Units reported on current MCS-150
  • Power Units reported on MCS-150 6 months ago
  • Power Units reported on MCS-150 18 months ago
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Insufficient Data

Why do we show "Insufficient Data" for one of our carrier-level BASICs?

Based on the BASIC measures, the CSMS applies data sufficiency standards and safety event grouping to assign a percentile rank to carriers that can then potentially receive a CSA intervention or detrimental SFD.

"The CSMS employs data sufficiency standards to ensure that there are enough inspections or crashes to produce meaningful measures of safety for carriers. In instances where the safety performance of a carrier can potentially lead to CSA interventions or a detrimental SFD, additional data sufficiency tests are employed. These tests ensure that a carrier has a "critical mass" of poor performance data or a pattern of violations before adverse action is taken."

  • Unsafe Driving requires at least three inspections with at least one violation.
  • HOS requires at least three relevant driver inspections.
  • Driver Fitness, HazMat, and Vehicle Maintenance require at least five relevant driver inspections.
  • Controlled Substances/Alcohol does not have any threshold, any violation will count against the carrier.
  • Crash Indicator requires two applicable crashes.

A driver with inspections and violations in a BASIC can show as "Insufficient Data" for the percentile rank in the BASIC. This is because the CSA Methodology has "data sufficiency thresholds" that require a driver to have at least 3 "relevant" inspections for the Driver Fitness, HOS Compliance, HM Compliance and Vehicle Maintenance BASICs before that driver can be given a percentile rank.  Relevant inspections for Driver Fitness and HOS Compliance are any driver-only or full inspection.  Relevant inspections for HM Compliance and Vehicle Maintenance are any vehicle-only or full inspection.

In other words, a driver with a percentile rank of "insufficient data" may indeed have inspections and violations. You can see the inspections and violations by reviewing the driver's individual driver scorecard detail.

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CSA Methodology

Vigillo is able to provide estimated national carrier and driver percentile rankings using the CSA Methodology. Vigillo uses a three-prong approach to calculate CSA measures and rankings for customers - including peer groups and percentile ranks. 

Vigillo gathers FMCSA data (public & private) for Vigillo customers. We calculate which peer group each customer is in for each BASIC by the number of average power units or the number of relevant inspections.
Vigillo gathers FMCSA data (public) for thousands of additional fleets, including all carriers in the largest peer group based on 500+ vehicles.

This data gathering is done on a monthly basis.

This data is run through a series of automated data cleaning and calculation algorithms by peer group developed by Vigillo based exactly on the published FMCSA CSA Methodology. This provides a first estimate result of BASIC measure and percentile ranking (based on the sampling above) for all carriers in the Vigillo database. 

As a third step, Vigillo reviews the actual FMCSA CSA data available to Vigillo customers in the nine pilot states for the "correct answer" from the FMCSA. We feed this data back into our calculations and re-run all numbers so that our calculated results are closer to the actual FMCSA result. We repeat this process over and over until Vigillo's calculated scores are nearly identical to the FMCSA results.

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Severity & Time Weights

For CSA Scorecards, Vigillo uses the time weightings as described in the FMCSA's CSA published methodology: 

Carrier Time Weight under Carrier Safety Measurement System (CSMS) Methodology: 

  • 0 - 6 months = 3X 

  • 7 - 12 months = 2X 

  • 13 - 24 months = 1X 

Driver Time Weight under Driver Safety Measurement System (DSMS) Methodology: 

  • 0 - 12 months = 3X 

  • 13 - 24 months = 2X 

  • 25 - 36 months = 1X 

All carrier level information is computed using the Carrier (CSMS) time weights. If you are viewing information for a specific driver, then you are seeing the Driver (DSMS) time weighting.

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