J.J. Keller & Associates Inc.
Separating fact from fiction
Posted August 7, 2010
Myths, rumors, and half-truths are always in abundant supply when the Federal Motor Carrier Safety Administration (FMCSA) comes up with new rules, programs, or procedures, and that’s certainly the case with the new Comprehensive Safety Analysis (CSA) 2010 program.
Now known simply as “CSA,” the new enforcement initiative “grades” motor carriers and drivers on seven safety-related categories known as the BASICs and results in enforcement action against the worst safety performers.
As the program is slowly phased in, now is the time to make sure that drivers are aware of CSA, how it will affect them, and what they can do to make sure their grades are good. It’s also a perfect time to dispel some of the many myths that are spreading about CSA, so drivers can separate fact from fiction.
Use the following information as a starting point for a discussion about CSA and the “truth” about the program.
Myth: CSA is dead!
Fact: CSA is alive and kicking. Though the FMCSA temporarily delayed portions of the program into 2011 and is periodically “tweaking” it, implementation is moving forward. There has been no indication from the agency that the program will be further delayed or suspended. In fact, beginning August 16, 2010, the FMCSA says carriers will be able to see their BASIC scores, a major step in the implementation process.
Myth: If a driver is overweight (has a high Body Mass Index) or has a large neck size, he or she could fail the new CSA Driver Fitness Standards and be pulled from the road.
Fact: There are no new fitness standards under CSA. One of the seven categories on which carriers and drivers will be judged, the “Driver Fitness BASIC,” simply tracks compliance with existing driver qualification rules. Of course, the FMCSA could adopt new qualification rules at any time, but that usually involves a lengthy rulemaking process. This myth may have formed because neck size and BMI relate to a person’s propensity to develop sleep apnea, a condition whose safety effects are currently under review. This myth may also relate to the fact that roadside violations for the vehicle being overweight (usually reported as a violation of §392.2W), were included in early versions of the CSA scoring process for the Cargo-Related BASIC.
Myth: If I collect too many CSA “points,” my CDL could be suspended.
Fact: The new scoring system for CSA relies on a severity rating (or “points” system) for each safety violation, but that has nothing to do with your license. The CSA scoring system and the CDL licensing system are separate systems. No matter how many severity points you collect, that in itself will not affect your CDL. Conversely, no matter how many points you accrue on your license, that in itself will not affect your CSA scores.
Myth: A moving violation will only appear in the CSA scoring system if it results in a conviction.
Fact: If a moving violation is noted on a roadside inspection report, then it will be used in the scoring system regardless of whether a ticket was issued.
Myth: The CSA program will mean a bunch of new safety rules and paperwork requirements.
Fact: CSA is used to track and enforce compliance with the existing regulations. If the current regulations don’t require it, neither will CSA.
Myth: The FMCSA has dropped the idea of scoring drivers.
Fact: The CSA model indicates that drivers will be individually scored in the seven BASICs, based on the past 36 months of data, and may be subject to certain types of intervention from the FMCSA if their scores are bad enough. Driver scores will only be available to enforcement personnel, however, and driver interventions will only take place during a carrier audit.
Myth: We'll have a "fresh start" once CSA is turned on.
Fact: Once the CSA program is implemented, carriers and drivers will be scored based on data that is already on the books. Driver scores will be based on the past 36 months of data, and motor carrier scores will be based on the past 24 months of data.
Myth: All roadside tickets/warnings/convictions/violations of any kind will affect our CSA scores.
Fact: The CSA scoring system will use violations that are reported on roadside inspection reports by qualified officers. If it doesn't get reported into the FMCSA's data system (MCMIS) via a roadside inspection form, the violation will not affect your CSA scores.
Myth: Having access to CSA scoring information and the new Pre-employment Screening Program will mean that carriers will no longer have to get drivers' driving records or perform background checks.
Fact: The CSA program will not affect carriers' obligations under Part 391 for qualifying drivers. Motor carriers will still need to contact previous employers and obtain drivers' driving records.
Separating fact from fiction
Posted August 7, 2010
Myths, rumors, and half-truths are always in abundant supply when the Federal Motor Carrier Safety Administration (FMCSA) comes up with new rules, programs, or procedures, and that’s certainly the case with the new Comprehensive Safety Analysis (CSA) 2010 program.
Now known simply as “CSA,” the new enforcement initiative “grades” motor carriers and drivers on seven safety-related categories known as the BASICs and results in enforcement action against the worst safety performers.
As the program is slowly phased in, now is the time to make sure that drivers are aware of CSA, how it will affect them, and what they can do to make sure their grades are good. It’s also a perfect time to dispel some of the many myths that are spreading about CSA, so drivers can separate fact from fiction.
Use the following information as a starting point for a discussion about CSA and the “truth” about the program.
Myth: CSA is dead!
Fact: CSA is alive and kicking. Though the FMCSA temporarily delayed portions of the program into 2011 and is periodically “tweaking” it, implementation is moving forward. There has been no indication from the agency that the program will be further delayed or suspended. In fact, beginning August 16, 2010, the FMCSA says carriers will be able to see their BASIC scores, a major step in the implementation process.
Myth: If a driver is overweight (has a high Body Mass Index) or has a large neck size, he or she could fail the new CSA Driver Fitness Standards and be pulled from the road.
Fact: There are no new fitness standards under CSA. One of the seven categories on which carriers and drivers will be judged, the “Driver Fitness BASIC,” simply tracks compliance with existing driver qualification rules. Of course, the FMCSA could adopt new qualification rules at any time, but that usually involves a lengthy rulemaking process. This myth may have formed because neck size and BMI relate to a person’s propensity to develop sleep apnea, a condition whose safety effects are currently under review. This myth may also relate to the fact that roadside violations for the vehicle being overweight (usually reported as a violation of §392.2W), were included in early versions of the CSA scoring process for the Cargo-Related BASIC.
Myth: If I collect too many CSA “points,” my CDL could be suspended.
Fact: The new scoring system for CSA relies on a severity rating (or “points” system) for each safety violation, but that has nothing to do with your license. The CSA scoring system and the CDL licensing system are separate systems. No matter how many severity points you collect, that in itself will not affect your CDL. Conversely, no matter how many points you accrue on your license, that in itself will not affect your CSA scores.
Myth: A moving violation will only appear in the CSA scoring system if it results in a conviction.
Fact: If a moving violation is noted on a roadside inspection report, then it will be used in the scoring system regardless of whether a ticket was issued.
Myth: The CSA program will mean a bunch of new safety rules and paperwork requirements.
Fact: CSA is used to track and enforce compliance with the existing regulations. If the current regulations don’t require it, neither will CSA.
Myth: The FMCSA has dropped the idea of scoring drivers.
Fact: The CSA model indicates that drivers will be individually scored in the seven BASICs, based on the past 36 months of data, and may be subject to certain types of intervention from the FMCSA if their scores are bad enough. Driver scores will only be available to enforcement personnel, however, and driver interventions will only take place during a carrier audit.
Myth: We'll have a "fresh start" once CSA is turned on.
Fact: Once the CSA program is implemented, carriers and drivers will be scored based on data that is already on the books. Driver scores will be based on the past 36 months of data, and motor carrier scores will be based on the past 24 months of data.
Myth: All roadside tickets/warnings/convictions/violations of any kind will affect our CSA scores.
Fact: The CSA scoring system will use violations that are reported on roadside inspection reports by qualified officers. If it doesn't get reported into the FMCSA's data system (MCMIS) via a roadside inspection form, the violation will not affect your CSA scores.
Myth: Having access to CSA scoring information and the new Pre-employment Screening Program will mean that carriers will no longer have to get drivers' driving records or perform background checks.
Fact: The CSA program will not affect carriers' obligations under Part 391 for qualifying drivers. Motor carriers will still need to contact previous employers and obtain drivers' driving records.
