A roadside inspection may begin with a single visible violation, but doesn’t always end there. The penalty points can add up quickly if the inspector conducts a thorough driver and vehicle review.
In this post…
- Why CSA Scores Matter
- Some Inexpensive Advice
- Dispelling CSA Score Myths
- How to Improve your CSA Scores
- CSA Scoring Made Easy
- Types of CSA Interventions
- CSA Changes Are Coming
Why CSA Scores Matter
If you’re a carrier with good Compliance, Safety, Accountability (CSA) scores, the benefits likely include at least some of the following:
- Lower annual insurance premiums
- A preference by customers who follow fleet rankings
- Fewer DOT audits or roadside inspections
- Easier driver recruitment efforts based on your reputation
On the other hand, if your CSA scores are subpar, the Federal Motor Carrier Safety Administration (FMCSA) is likely to keep close tabs on your operations. This can mean a requirement for corrective action. In some cases, it can even lead to an Out-of-Service Order (OOSO), barring you from operating.
But it’s not just the government’s meddling that matters; public perception plays a role too.
Even though some of your data is only visible to you (the carrier) and to law enforcement, make no mistake, much of your fleet’s safety and compliance data is publicly available for anyone to find—including your biggest customers and competitors.
What’s not available to the public, is your crash history, hazardous materials compliance, and BASIC percentiles.
Some Inexpensive Advice
One of the most valuable and affordable tools at your disposal is the FMCSA’s Pre-Employment Screening Program (PSP).
Never hire drivers without checking their PSP record.
Carriers (of all sizes) using PSP have decreased their crash rates an average of 8% and driver out-of-service (OOS) rates by 17%, according to a PSP safety analysis. In fact, carriers with 6-20 drivers decreased crash rates by over 20%.
PSP reports show you all of a driver’s FMCSA-reported crashes within the last five years and all roadside inspections within the last three years. It’s worth noting that every crash and inspection that the driver was involved in will be on the report, regardless of who was at fault.
Reviewing PSP reports helps you:
- Find honest drivers – This is an often overlooked benefit of PSP reports. For a few bucks you can make sure drivers aren’t lying on their applications or failing to mention previous employers or accidents.
- Find the safest drivers – Aside from the obvious, be sure to also look for violations on pre-trip inspections, logbooks, and speeding. Excessive violations like these are often signs of an unsafe driver.
How can I access PSP records?
To request PSP records, you need to be a PSP account holder. Carriers with 99 or fewer vehicles pay an annual subscription fee of $25 for a PSP account. The subscription fee increases slightly to $100 per year for carriers with 100 or more vehicles. You can sign up for a PSP account online or download the motor carrier enrollment agreement to sign up by mail, fax, or email.
Be aware that you can only request a driver’s PSP record for pre-employment screening purposes and you must have the driver’s permission. As long as you’re a PSP account holder, PSP records cost just $10 each. Drivers can also request their own PSP record from the FMCSA Motor Carrier Management Information System (MCMIS) at any time for $10 (no annual subscription required).
Dispelling CSA Score Myths
Before diving into ways to improve your CSA score, we need to dispel a few myths:
Myth #1 – Point totals determine whether or not the FMCSA will intervene.
Each violation adds anywhere from 1-10 points based on severity. Of course you want to keep your points as low as possible, but there’s no minimum point total that determines when the FMCSA will take action. Instead, the total points are used to rank your fleet with other fleets that have a similar number of crashes, inspections, and violations. It’s the resulting percentile ranking that determines your fate.
For instance, the intervention threshold for Hazardous Materials (HM) Compliance is 80%. If your HM Compliance score is higher than 80% of carriers similar to yours, the FMCSA will prioritize you for intervention.
Myth #2 – Your CSA score is based on violations found during inspections.
This is only partially true. There are a couple more components to your score.
- Crash reports provided by states to the FMCSA.
- Violations discovered during onsite and offsite investigations.
How to Improve your CSA Scores
As mentioned above, the FMCSA doesn’t actually generate or endorse any sort of score. This means that CSA “scores” aren’t really scores at all. They’re percentiles. BASIC percentiles to be precise – and there’s seven of them in total.
The seven Behavior Analysis and Safety Improvement Categories (BASIC) are:
- Unsafe Driving
- Crash Indicator – Not Public
- Hours of Service (HOS) Compliance
- Vehicle Maintenance
- Controlled Substances/Alcohol
- Hazardous Materials Compliance – Not Public
- Driver Fitness
Here are some practical ways to reduce the risk of violations and avoid penalty points in each BASIC:
Unsafe Driving / Crash Indicator
- Avoid drivers with a history of speeding (7-10 points).
- Eliminate or try to minimize in-cab distractions like texting and eating (10 points).
- 71% of large truck crashes are due to the driver doing something else while driving.
- Always wear seat belts (7 points).
- Never tailgate or change lanes without signaling (5 points).
- Always avoid the far left lane, regardless of state laws (3 points).
Hours of Service (HOS) Compliance and Fatigued Driving
- Establish a policy against driving while sick or fatigued (10 points).
- Use electronic logbooks to eliminate violations related to missing or incorrect driver logs. This accounts for over 30% of all driver violations found during roadside inspections. (5 -7 points).
- Ensure everyone is educated on HOS rules, including dispatchers.
31% of roadside inspections are triggered by observable vehicle defects such as lights and tires. These types of violations are much easier to avoid if you have Electronic Logging Devices (ELDs) that include Driver Vehicle Inspection Report (DVIR) software. Electronic DVIRs guide drivers through their pre-trip and post-trip inspections without paper forms.
- 20% of vehicle violations are related to lights (2-6 points).
- 20% of violations are due to issues with brakes (4 points).
- 9% are for tire issues, half for tread depth (3 -8 points).
- Understand how to properly inspect their vehicle (2- 4 points).
- Be familiar with CSA inspection data.
- Submit DVIRs before and after every trip (required by FMCSA) to ensure there’s no issues with their vehicle.
- Make it a habit to regularly check lights, flashers, and reflectors.
- Keep equipment clean to decrease chances of inspection.
Controlled Substances & Alcohol
- Never hire drivers without checking their PSP record.
- Institute a zero-tolerance policy for drugs / alcohol (10 points).
- Train supervisors to recognize drivers under the influence (10 points).
- Make sure no one drinks alcohol within 4 hours of being on-duty (5 points).
Hazardous Materials Compliance
- Ensure that drivers always know how to properly secure their cargo (1-8 points).
- Don’t shy away from adding more straps or chains – too many is safer than not enough (1-7 point).
- Never use bungee cords by themselves to secure cargo (1-7 points).
- Ensure drivers always stop at railroad crossings (5 points).
- Use edge protectors when hauling cargo with sharp corners.
- Of course, drivers should always carry their commercial license (8 points).
- Hire drivers that can speak English – 6% of driver violations are due non-English speaking drivers (4 points).
- Drivers should always carry their medical certificate and renew their DOT physical early. This issue accounts for 8% of all driver violations (1-2 points).
With common sense and some discipline, you can reduce your points for each BASIC and improve your percentile rankings.
CSA Scoring Made Easy
When your fleet has enough safety data in a BASIC, you’re given a BASIC percentile ranking from 0-100 based on your fleet’s violation rate. The percentiles rank your fleet relative to other carriers that are similar to yours, and they’re used to decide if your fleet is having trouble with safety performance. If one of your BASIC percentiles reaches a predefined threshold, you’ll be hearing from the FMCSA in the form of warning letters and/or investigations.
The seven BASICs consist of over 900 different violations. The three main factors that ultimately decide your fleet’s ranking are:
- Number of violations
- Severity of violations
- Date of violations (recent violations carry more weight)
Here’s how it works:
- Violations increase your CSA scores anywhere from 1-10 points based on severity (higher scores are bad).
- Because the weights reflect the relative importance of each violation within each particular BASIC, they cannot be compared meaningfully across the various BASICs.
- Points are multiplied depending on how recent the violation was.
- 3x – Within the past six months.
- 2x – Within the past six to twelve months.
- 1x – Within the past twelve to twenty-four months.
- The sum of all violations in any one BASIC during a single inspection is capped at 30. However, the cap is before the time multiplier. This means that a penalty of 30 points will be 90 for the first six months and 60 for the following twelve months, due to the 3x and 2x multipliers.
- If a violation results in an Out-of-Service Order (OOSO), 2 additional points are added to the severity score.
- Two years after the violation, it stops being used to assess your fleet’s safety.
Can I challenge the results of a DOT inspection?
Yes. If you discover incorrect/incomplete information on your record, the FMCSA’s DataQs is where you submit your request for a review. We suggest checking out the DataQs Help Center for more information on how to review your safety data, how to submit a Request for Data Review (RDR), and much more.
What happens if I fall below one of the BASIC thresholds?
The DOT will initiate an intervention if your BASIC score drops below a certain threshold. Interventions are meant to catch safety problems before they become a reoccurring issue. Thresholds vary from 50%-80% depending on the BASIC and carrier type (passenger, hazardous material, and general).
Types of CSA Interventions
- Warning Letters (view a sample letter)
- Targeted Roadside Inspections
- Offsite Investigation – A Safety Investigator will review documentation remotely to determine safety and compliance issues.
- Onsite Focused Investigation – A Safety Investigator will focus on specific safety and compliance issues at your physical location. They may choose to interview your employees and inspect their vehicles.
- Onsite Comprehensive Investigation – This is similar to the Onsite Focused Investigation, except the investigator will review your entire safety operation onsite.
- Cooperative Safety Plan (CSP) – This is a voluntary plan intended to address safety issues with the help of a Safety Investigator.
- Notice of Violation (NOV) – You’re notified that your fleet has severe violations. To avoid fines you must take corrective action and provide evidence of it. You can also choose to contest the NOV if you feel it’s incorrect or inaccurate.
- Notice of Claim (NOC) – This notice means your violations are severe enough to warrant fines.
- Operation Out of Service Order (OOSO) – This is the most serious intervention. You must stop all motor vehicle operations if you receive an OOSO.
CSA Changes Are Coming
For years, trucking industry groups argued that CSA thresholds by BASIC group do not accurately correlate with safety risks.
With the passage of the FAST Act (Fixing America’s Surface Transportation) in December 2015, the CSA percentiles were removed from public view as potential changes are evaluated. The change wasn’t received well by insurers and customers who used those percentiles as a quick way to determine a carrier’s safety performance. Some are now turning to consultants who offer programs similar to CSA scoring.
Examples of Proposed Threshold Revisions
- Driver Fitness, Hazardous Materials Compliance, and Controlled Substances/Alcohol have thresholds of 80%. The proposal is to increase them to 90%. The argument is that these types of violations don’t reflect a carrier’s safety as reliably as previously thought.
- Vehicle Maintenance thresholds could be lowered from 80% to 75% due to a stronger correlation to fleet safety.
These are just a couple of the proposed changes, with no date set to finalize.