“CSA Prioritization Review”. That’s the name of the website for the proposed changes to CSA. That says it all.
The FMCSA proposed revisions to CSA are to “prioritize” enforcement rather than being a safety score. “Prioritization” of FMCSA’s limited resources for most effective enforcement of crash-potential carriers.
As you recall, the National Academy of Science studied the program and recommended an IRT program. FMCSA responded, “Thanks…but no thanks.”
However, FMCSA learned from the IRT analysis. In the Federal Register for this proposed revision, FMCSA notes that “the IRT modeling revealed areas in which SMS could be improved to better identify high risk carriers for intervention, without complications inherent in adopting an IRT model.” This CSA proposal appears to be the product of those revelations.
I see the program skewing further away from litigation relevance. In a binary scoring system that doesn’t distinguish disparate violations, what does it mean for a company’s safety score?
Gone will be the weighted violations. Everything will either be a “1” or “2” pointer—like basketball in the ‘70”.
Violations are grouped. Multiple violations in a group are only scored as a “1”.
The BASIC with the least violations (“Drug & Alcohol”) is gone, merged into “Unsafe Driving”. The one with the largest violations (“Vehicle Maintenance”) is split, treated like “aces and eights”.
Intervention levels are raised in categories. This throttles down the focus for enforcement. Can I get a “prioritization.”
No violation in a category in the last 12 months? No worries. No percentile for you in that category.
So how is this going to impact your company? Check what you new score would be on website at CSA Prioritization Preview - Home (dot.gov). I would be interested in how you would make out.
THE SPECIFICS: The FMCSA proposes changes that are as follows:
1. Bye, bye “BASICS”, hello “Safety Categories”—The scores are now in separate “Safety Categories”. The label “BASIC” is gone.
2. “Unsafe Driving” additions: No more “D & A BASIC” (or “safety category”). This category, with the lowest violations, will be merged into “Unsafe Driving”.
Also added to “Unsafe Driving” will be all operating while “out of service” violations. This is regardless of the underlying violation that resulted in the OOS.
3. Split Vehicle Maintenance Category—FMCSA will split the vehicle maintenance “safety category” into two separate ones.
The first is “Driver Observed”--what a driver should discover in a pre-trip. These equate to a Level 2 inspection type violation.
The second is “Vehicle Maintenance”—what should be found and addressed by the shop.
4. Roadside Violation Reorg—The current 959 roadside violations will be consolidated into 116 groups of similar violations. This is to address the vagaries from inspection-to-inspection where one violation could be written under different sections.
You can still be written up 959 different ways. But if you are written up with multiple violations in the same group it will only count as a single violation for that category. Example—multiple HOS violations equal 1 violation for that category.
5. Severity weight slimdown—Violations are losing weight. Specifically, no more 1-10 weighting of violations. Now down to a binary scoring—either a “1” or a “2”. Like in “Hoosiers”.
The “2’s” are OOS violations of any category (except “Unsafe Driving”) AND Driver Disqualifying violations (apply to “Unsafe Driving” only as defined by Section 383.51). Anything else is a “1”.
6. Intervention Threshold Adjustments—The thresholds for intervention will be changed as follows:
-Driver Fitness
=General Carriers=90%
=Hazmat Carriers=85%
-HM Compliance=90%
Vehicle maintenance (both “categories”) will stay at 80% for general carriers.
7. Proportionate Percentiles—will use the exact number of inspections and crashes rather than cutoffs in SMS established by safety event groups. Purpose--have the carrier’s percentile impacted by its events.
8. One Year Lookback—Carriers will only be assigned a percentile in a “safety category” if that carrier has received at least one roadside violation in that “category” within the last 12 months. Nothing in that category in the last year—no percentile in that category.
9. Utilization factor—would be moved from 200,000 vehicle miles traveled (VMT) to 250,000 VMT.
10. Segmentation—There will be segmentation within “categories”, not to be confused with split “categories” we talked about earlier.
Hazmat Compliance will be “segmented” into “cargo tanker” and “cargo non-tanking” segments. “Cargo tanker” group is if more than 50% of a carrier’s inspections involve a tanker.
Driver Fitness will be “segmented” into “straight trucks” and “combination” carriers.
11. Non-preventable accident program—easiest to remember. No change.
Under the proposed revisions, the FMCSA focus is narrowed—interventions raised, binary scores, time of violations reduced. It’s about the enforcement.