For the past decade, DOT-regulated fleets have operated under SafeStat, but no longer. SafeStat has been replaced by Comprehensive Safety Analysis (CSA) 2010, which applies to all truck fleets that operate interstate and require a US DOT number. All vehicles that operate interstate with a 10,001-lb. combined GVWR or greater are covered by CSA 2010. This regulatory enforcement change will create a monumental sea change in how truck fleets manage drivers, their fleet operations, and remain DOT compliant.
To understand CSA 2010, it's important to understand what it's not. First, CSA 2010 isn't limited to CDL drivers. Second, CSA 2010 does not create any new driver regulations, vehicle regulations, or record-keeping regulations. CSA 2010 is an enforcement system, which tracks, measures, evaluates, and intervenes with motor carriers. It's a replacement for SafeStat.
Designed to more effectively target problem truck fleets, CSA 2010 is a proactive system, while SafeStat was a reactive process. Its purpose is to provide the Federal Motor Carrier Safety Administration (FMCSA) and states more tools to identify and intervene with potentially unsafe carriers. Under SafeStat, only out-of-service violations impacted the safety evaluation area. Under CSA 2010, all safety-related data from roadside inspections will be used to identify problem fleets, which will result in more enforcement. Already, fleets with long-standing satisfactory ratings have received warning and intervention letters.
"All indications are that CSA, instead of standing for Comprehensive Safety Analysis, will change to Compliance, Safety, and Accountability, which is certainly an accurate description of what this program intends to do," said Mark Catlin, national account executive, service sales, for J.J. Keller & Associates, in a recent industry Webinar on CSA 2010.
History Leading Up to CSA 2010
More than 20 years ago, the FMCSA instituted its compliance review and safety ratings: satisfactory, conditional, and unsatisfactory. This process triggered an audit based on a complaint or one or more fatal accidents. In the late 1990s, FMCSA developed SafeStat - a data-driven, performance-based algorithm that identified potentially high-risk motor carriers for compliance reviews. However, FMCSA has finite resources. Today, it can only audit about 2 percent of truck fleets, which, by default, means only high-risk fleets get real attention. Yet, the number of carriers has continued to increase over the years. In addition, FMCSA is experiencing additional demands on its limited resources related to homeland security issues.
In response to these resource constraints, FMCSA developed CSA 2010 to implement more effective and efficient ways to reduce commercial motor vehicle (CMV) accidents. CSA 2010 was designed to help FMCSA and its state partners contact more fleets and drivers, use improved data to better identify high-risk fleets and drivers, and apply a wider range of interventions to correct high-risk behavior. The system measures safety performance and compliance, determines safety fitness, recommends and applies interventions, and tracks and evaluates safety improvements for FMCSA-regulated fleets. A company's safety performance will be measured through data uploaded from fleet compliance activities and accident reports.
Increased Use of Off-Site Investigations
In its prior system, FMCSA's compliance review (CR) program was resource-intensive and reached only a small percentage of truck fleets. On-site CRs take one safety investigator an average of three to four days to complete. At present staffing levels, FMCSA was able to perform CRs on only a small portion of the 700,000 interstate motor carriers. In addition, an earlier FMCSA Large Truck Crash Causation Study revealed that increased attention should be given to drivers. The prior FMCSA systems did not evaluate the safety fitness of individual CMV drivers.
Under CSA 2010, there will be many more intervention options to enforcement personnel. The intent is to discover what the safety problems are, why they exist, and how to correct them. One of the biggest differences between CSA 2010 and the previous system is use of an off-site investigation. This allows CSA 2010 intervention steps to be less resource intensive for the enforcement agency and ultimately less time-consuming for carriers being investigated. Rather than always having to go on site from anywhere for three days to two weeks, FMCSA personnel and agents can intervene by telephone and ask for more information in a specific area, such as logs or drug testing.
The intent of CSA 2010 is to identify deficiencies before they turn into problems. If severe problems arise, FMCSA can initiate an on-site investigation. FMCSA's decision to intervene also can be triggered by high crash indicators, fatal crashes, or complaints, just as it does today.
Penalties range from initial warning letters to removing non-compliant vehicles from service. Violations remain on record for two years for fleets and three years for drivers. Fleets will be able to see an assessment of their violations based on the new Carrier Safety Measurement System (CSMS), which replaces SafeStat. In addition, non-crash CSMS data will be available to the public, including shippers and insurance companies.
It's a new world in terms of DOT regulatory enforcement and fleets need to adjust to it - quickly.
Let me know what you think.