Page 40 - Oil and Energy January 2013

40 • OIL&ENERGY
CSA Rewrite Goes Into Effect
Carriers’ scores will change under new compliance monitoring system
By Matthew Wrobel, Foley Services
THE FEDERAL MOTOR CARRIER SAFETY
Administration (FMCSA) has moved to
make changes to the CSA compliance
monitoring system. CSA, the centerpiece
of FMCSA enforcement activity, first went
into effect in 2010 and has been a “work in
progress” ever since.
This new wave of changes, however,
represents by far the largest revision made
yet, changing a wide variety of the program‘s
fundamental factors.
REWRITTEN BASICS
The most obvious changes are aimed
at the Behavior Analysis and Safety
Improvement Categories (BASICs). The
Cargo-Related BASIC has been
removed and replaced, while
the Fatigued Driving BASIC has
undergone a rebranding.
To replace the Cargo-Related
BASIC, FMCSA has added a new
category, Hazardous Materials
Compliance, which will, unsur-
prisingly, focus only on hazmat
violations. The end result will be
a very different CSA dashboard.
HAZARDOUS MATERIALS
COMPLIANCE
The new BASIC, Hazardous
Materials Compliance, or HM
Compliance, focuses on carriers
hauling or packaging hazmats.
Many of the violations in this
BASIC have been pulled from
the now defunct Cargo-Related
BASIC, but the system has been
refined to point a laser-eye on
hazmat carriers.
According to FMCSA, “the
HM Compliance BASIC identifies
carriers with higher HM violation
rates (33.8 percent versus 29.1
percent) and HM out-of-service
rates (5.4 percent vs. 4.0 percent)
than the current Cargo-Related
BASIC.
For now, the HM Compliance
BASIC will only be available to
logged-in motor carriers and
enforcement personnel. Further
study over the next year will be
conducted before it “becomes
available to the public.”
TWEAKS AND FIXES
Other changes include aligning the
Safety Measurement System (SMS) with
the Commercial Vehicle Safety Alliance’s
inspections program. This eliminates
vehicle violations from driver-only inspec-
tions and driver violation from vehicle-only
inspections.
Furthermore, the Agency is removing
speeding violations for infractions that were
1-5 mph over the limit. This is a nod to
the fact that the regulations only require a
speedometer to be accurate within 5-mph,
thereby allowing some drivers to be ticketed
without being able to tell that they were
(slightly) speeding. Also related to speeding,
the severity weight for a generic speeding
violation has been dropped to one.
VEHICLE MAINTENANCE
While Vehicle Maintenance has been a
part of CSA from the beginning, the latest
changes give it a huge boost in importance.
Many violations from the old Cargo-Related
BASIC have been ported over to Vehicle
Maintenance. FMCSA has also taken steps
to make the weight of the violations in
the new BASIC to be a little more fair and
accurate than the old one.
One of the issues the agency cited was
that the weights of the violations were
causing the agency to issue interventions
on a disproportionate number of
flatbed carriers. That, and similar
issues, should now be fixed. With
the violations recalibrated to this
degree, carriers should expect
big changes to their Vehicle
Maintenance scores.
HOURS-OF-SERVICE COMPLIANCE
TheHours-of-Service Compli-
ance BASIC – or HOS Compli-
ance – is simply a rebranding
of the old Fatigued Driving
BASIC with very few changes.
However, FMCSA has, for the
first time, given paper log and
electronic log violations the same
weight. This is, perhaps, a nod
to the future in which FMCSA
would like to see more usage
of EOBRs and electronic time-
management.
CHANGING SCORES
The best advice that Foley
can offer regarding CSA is to
check your scores and check
them frequently. With new
BASICs, and revised weights, it
is very likely that you will have
a different CSA profile from what
you had a week ago.
Furthermore, for the first
time, cargo-related violations will
be public. That means, customers
and insurers can see them. If you
have problem areas of compliance,
call 1-800-253-5506 to discuss
ways to improve your scores.
Fleet Management