SAFETY CULTURE

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Its All About The BASICs CSA Program Overview
Keith Barrows Director, Global Health Safety
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Todays Agenda

• What is CSA?
• CSA Program Overview
• Behavioral Analysis Safety Improvement
  Categories (BASICs)
• The Safety Measurement System (SMS)
• The 7 BASICs
• FMCSA Interventions
• How to Research Your Score
• How to Contest a Violation (DataQs)
• Wrap Up/ QA

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Ask These Guys about CSA?
Operations suspended in March 2013
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Before we begin
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Test your knowledge of CSA

• FMCSA data is collected from which of the
  following sources?
• Roadside Inspections
• DOT recordable crashes
• FMCSA investigations
• All of the above

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We did mention this was interactive..right?

• A drivers BASIC scores ___________.
• Are not reset if they change carriers (jobs)
• Directly impact their CDL status
• Will never change
• Cannot be appealed or amended

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Are you impressing your colleagues?

• Data collection, Safety Measurement, Safety
  Evaluation and Intervention are_____________.
• The 4 BASICs of the CSA system
• The 4 statistical tools used to monitor drivers
• The 4 components of the CSA system
• The 4 categories of violations a carrier can be
  given

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Are the questions getting harder?

• Why are reckless driving violations given a
  higher severity weights by the FMCSA?
• Research has shown that drivers with a reckless
  driving violation are highly likely to be
  involved in a crash
• Research has shown that drivers with a reckless
  driving violation are highly unlikely to be
  involved in a crash
• Reckless driving violations are not given a high
  severity weight by FMCSA
• Reckless driving violations are only given a high
  severity weight when they result in a crash

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Last one I promise.

• The Hours of Service compliance BASIC includes an
  out-of-service penalty or kicker. What other
  BASIC includes this penalty?
• Unsafe Driving BASIC
• Controlled Substances and Alcohol BASIC
• Crash Indicator BASIC
• Hazardous Materials compliance BASIC

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What is CSA?
Compliance, Safety, Accountability (CSA) is a
Federal Motor Carrier Safety Administration
(FMCSA) initiative to improve both carrier
driver safety, as well as, reduce crashes,
injuries, and fatalities that are related to
commercial motor vehicles. Rolled out in
December 2010, the program uses the data and
information collected during Roadside Inspections
and carrier investigations to evaluate safety
performance and proactively address safety
problems before they lead to tragedies on the
highways.
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CSA Program Overview

• There are 4 components to CSA. They are
• Data collection
• Safety Measurement
• Safety Evaluation
• Intervention
• Well review
• How safety data is collected,
• What FMCSA does with the data and,
• How to keep your scores low

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CSA Program Overview - BASICs

• At the heart of the CSA safety measurement
  process are 7 categories of safety related
  behaviors called BASICs
• Unsafe Driving Speeding, following too close,
  texting while driving
• HOS compliance log violations, driving
• Driver Fitness not having proper license or
  endorsement, not having valid medical card
• Controlled Substances and Alcohol operating a
  CMV while impaired by or in possession of illegal
  drugs, alcohol or any other controlled substance
• Hours of service

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CSA Program Overview - BASICs

• Vehicle Maintenance Cargo securement, equipment
  inspections and maintenance regulations
• Hazardous Materials compliance Handling,
  securing and documentation of hazardous materials
• Crash Indicator Documents and tracks
  DOT-recordable crashes for both drivers and
  carriers

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CSA Program Overview - BASICs

• Knowing the BASICs means knowing
• What they are,
• How they are scored,
• What those scores can mean for you and your
  drivers
• Well come back to the BASICs but, first we need
  to review the Safety Measurement System (SMS)

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The Safety Measurement System (SMS)
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CSA Program Overview - SMS

• The Safety Measurement System (SMS) quantifies
  the on-road safety performance of carriers and
  drivers to identify candidates for interventions,
  determine the specific safety problems that a
  carrier or driver exhibits, and to monitor
  whether safety problems are improving or
  worsening.
• The SMS uses a motor carriers data from roadside
  inspections, State-reported crashes (DOT
  recordable), and the Federal motor carrier census
  to quantify performance in the 7 Behavior
  Analysis and Safety Improvement Categories
  (BASICs).

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CSA Program Overview - SMS

• Roadside Inspections (RSI) occur at weigh
  stations or as a result of moving violations.
• 3.5 Million RSIs performed/year
• RSIs generally have two outcomes
• No violations or clean inspection
• Violations noted/written

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CSA Program Overview - SMS

• When a violation is written, it is assigned a
  numerical value for CSA scoring purposes. The
  value is obtained as follows
• Severity weighting Using a scale of 1 10,
  each violation is assigned a value based on its
  correlation with crash causation (a value of 10
  is most severe)
• If the violation also results in an Out of
  Service (OOS) order there is a penalty or
  kicker of 2 points applied to the severity.
  (applies to HOS, Driver Fitness, Vehicle
  Maintenance and Hazardous Materials BASICs)

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CSA Program Overview - SMS

• A Time weighting is then applied to the
  violation. This value ranges from 1 3 (more
  emphasis is placed on recent violations)
• The Full Violation Value (FV) is calculated as
  follows
• FV Severity weight ( OOS penalty) x
  Time weight
• The total of all FVs yields the Basic
  Measure

The Basic Measure is not your score!
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CSA Program Overview - SMS

• After the BASIC measure is determined, the
  carrier is then placed in a Safety Event Group
  (SEG) or peer group (e.g., other carriers with
  similar numbers of inspections and fleet size).
• Percentiles from 0 to 100 are then determined by
  comparing the BASIC measurements of the carrier
  to the measurements of other carriers in the peer
  group.
• A percentile of 100 indicates the worst
  performance
• Like golf a lower score is BETTER.

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CSA Program Overview - SMS

• In summary
• Safety Measurement and BASIC score is influenced
  by
• The number of adverse safety events (violations
  related to that BASIC or crashes)
• The severity of violations or crashes
• When the safety events occurred (more recent
  events are weighted more heavily).

Important fact! Driver scores are
confidentialCarrier scores are PUBLIC
information!
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Behavior Analysis Safety Improvement Categories
(BASICs)

• Unsafe Driving Operation of commercial
  motor vehicles (CMVs) by drivers in a dangerous
  or careless manner. Example violations Speeding,
  reckless driving, improper lane change, and
  inattention. This is a standalone BASIC, meaning
  it is most associated with crash causation.
  Violations tend to have more severe weightings
• Hours-of-Service (HOS) Compliance
  Operation of CMVs by drivers who are ill,
  fatigued, or in non-compliance with the HOS
  regulations. This BASIC includes violations of
  regulations pertaining to log books. This is
  also a standalone BASIC
• Driver Fitness Operation of CMVs by
  drivers who are unfit to operate a CMV due to
  lack of training, experience, or medical
  qualifications. Example violations Failure to
  have a valid and appropriate drivers license,
  endorsement and/or being medically unqualified to
  operate a CMV. This BASIC has nothing to do with
  physical fitness. It should be called Drive
  Qualification.

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Behavior Analysis Safety Improvement Categories
(BASICs)

• Controlled Substances/Alcohol Operation of
  CMVs by drivers who are impaired due to alcohol,
  illegal drugs, and misuse of prescription or
  over-the-counter medications. (FMCSR Parts 382
  and 392)
• Vehicle Maintenance Failure to properly
  maintain a CMV and/or properly prevent shifting
  loads. Example violations Brakes, lights, and
  other mechanical defects, failure to make
  required repairs, and improper load securement.
• Hazardous Materials (HM) Compliance Unsafe
  handling of HM on a CMV. Example violations
  Release of HM from package, no shipping papers
  (carrier), and no placards/markings when
  required. (Hazardous Materials Regulations Parts
  171, 172, 173, 177, 178, 179, and 180)
• Crash Indicator Histories or patterns of
  high crash involvement, including frequency and
  severity. It is based on information from
  State-reported crashes regardless of fault

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Interventions

• Before CSA the primary, if not sole, form of
  intervention was a comprehensive on-site audit
• Under CSA, a DOT intervention is now typically
  issued when a carrier exceeds the established
  safety threshold for a particular BASIC
• Other intervention triggers include
• Complaints
• High crash rates
• Fatal crashes

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Interventions

• Interventions increase in severity as more
  serious safety issues are identified
• There are 3 categories of interventions
• Early Contact
• Warning Letter
• Targeted Roadside Inspections
• Investigations
• Off site
• Focused on-site
• Comprehensive on-site
• Follow-on
• Cooperative Safety Plan
• Notice of Violation
• Notice of Claim
• Operations Out of Service Order

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CSA Navigating the Portal

• Lets spend a few minutes reviewing CSA scores.
  Well view both the private and public data
• Because the lawyers and media definitely will!
• http//ai.fmcsa.dot.gov/sms/

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DataQs Are You Up For A Challenge?

• If a carrier believes a citation was issued in
  error or due to extenuating circumstances beyond
  a drivers control, a request for data review
  (RDR) can be filed using the DataQs website.
• This process helps ensure the accuracy of the
  information collected and tracked by the FMCSA
  and itll help make certain that youre not being
  penalized for something your driver didnt do.
• Before filing a DataQs challenge, be sure youre
  keeping an eye on your CSA score. Its a good
  idea to set a regular schedule for reviewing your
  score and follow up with a process for
  challenging any scores that dont seem
  legitimate.
• https//dataqs.fmcsa.dot.gov

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DataQs Tips for Successful Challenges

• Make the request as timely as possible. While
  there is no time limit on challenging a piece of
  information contributing to your CSA score,
  getting the challenge in before two years is up,
  when it falls off the CSA radar is a no-brainer.
• 2. Specify the correct RDR Type. When inputting
  your RDR, make sure you select the appropriate
  action type, delineating that it has to do with a
  particular violation, an inspection, crash, etc.
• 3. Provide the accurate report number. This
  refers to your inspection report giving the
  accurate number will help the reviewing state
  agency determine whether this inspection or
  crash actually belongs to their agency. Is it a
  valid report number?

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DataQs Tips for Successful Challenges

• 4. Provide a clear and detailed explanation of
  what you want reviewed. In the event that the
  initial category is insufficient to cover the
  full scope of what is needed in your review, use
  the Explanation section to elaborate on problems.
  There may be two or three other things incorrect
  on the inspection report. Its important to have
  the reviewing state agency correct them all.
  Remember, they have just as much interest in
  ensuring all the data on that report is as
  accurate as possible.
• 5. Keep RDRs professional and detailed. 
• 6. Make factual statements. Whenever possible,
  stick to the facts of the case without injecting
  opinion/emotion into the request.

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DataQs Tips for Successful Challenges

• 7. Ask for additional time as necessary. If
  youre waiting on information, simply fire off
  an email to the reviewer to let him/her know
  youre working on getting the data. More likely
  than not, they will work with you.
• Provide as much possible supporting documentation
  that is valid and relevant. Pictures documenting
  a supposed maintenance violation, for instance.
• In events where a violation or inspection is
  wrongly assigned to your own DOT number or the
  wrong driver, providing bills of lading, truck
  registration documents and/or drivers license,
  rental or lease agreement copies may be
  appropriate.
• This is one of the most important things that
  you can do to help resolve an RDR.

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DataQs Tips for Successful Challenges

• Follow up as appropriate. It is your right to
  appeal any final decision made by a states
  DataQs handler.
• Two states, Arizona and New Hampshire, have set
  up official boards with industry representatives
  in addition to law enforcement reps to review
  these appeals. The remainder of states handle
  them less formally, but will re-review your
  information.

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Thank You!

• Questions?