FMCSA planning major changes in the CSA program

Oct. 19, 2016

The Federal Motor Carrier Safety Administration (FMCSA) released proposed changes on October 5 to the Safety Management System of the CSA program. The same day, FMCSA made previews of carriers’ scores available to carriers only. Carriers can look up their new scores under the proposed changes by visiting the SMS preview page online.

Among the proposed changes, FMCSA said it would like to divide the Hazardous Materials Compliance BASIC into cargo-tank and non-cargo tank segments. “This change could negatively affect many tank truck carriers, and members of National Tank Truck Carriers are encouraged to view their new scores and contact NTTC,” said Boyd Stephenson, NTTC senior vice-president, government affairs.

NTTC plans to comment on the proposed changes, including the split between cargo and non-cargo carriers and reports from member carriers will be invaluable in doing so. NTTC will comment on these proposed changes. The comment period will remain open until December 2. To register views on the proposed changes, please contact Stephenson at 703-838-1784.

FMCSA proposed five changes to the CSA methodology in June 2015.  Those changes will be incorporated into the preview and FMCSA will also take further comment on them.

• Splitting the Hazmat Compliance BASIC into Cargo Tank and non-Cargo Tank Carriers: Carriers with hazmat inspections will now be classified as either Cargo Tank Carriers or Non-cargo Tank Carriers. To be classified as a Cargo Tank Carrier, the majority of a carrier’s hazmat inspections reports must indicate that the trailer inspected was a tank trailer. Carriers without a majority of tank trailer cargo inspections are Non-Cargo Tank Carriers. Cargo Tank Carriers will only be compared against other Cargo Tank Carriers and Non-cargo Tank Carriers will only be compared against other Non-cargo Tank Carriers. Because Cargo Tank Carriers tend to lack the form and manner violations more common to Non-cargo Tank Carriers, NTTC members should expect to see their Hazmat Compliance BASIC scores rise significantly as they are compared only to other carriers with better scores. Further, if the preview is adopted, these new Hazmat Compliance BASIC scores will be the ones used to determine whether or not a carrier may hold a Hazardous Materials Safety Permit.

• Making Hazmat Compliance BASIC scores public: Presently, Hazmat Compliance BASIC scores are visible only to enforcement officials and the motor carrier itself. FMCSA proposes to make these scores visible to the public. Because carriers’ scores are available only to them during the preview period, this proposal changes nothing unless FMCSA adopts the changes proposed into the CSA program officially.

• Changing intervention thresholds: FMCSA proposes to tighten some BASICs’ intervention thresholds and to loosen others. In general, FMCSA proposes to tighten the intervention thresholds for BASICs that have a strong correlation to crash risk, while loosening those that have a weaker relationship. This loosening includes the Hazmat Compliance BASIC.

• Moving violations for operating while OOS into the Unsafe Driving BASIC: Today, a violation for operating while under an out-of-service order is classified under the same BASIC as the underlying OOS order. The preview changes this to place all violations for violating the underlying OOS order into the Unsafe Driving BASIC. The underlying OOS violation remains in its traditional BASIC. Only violations for violating the OOS order move to Unsafe Driving.

• Increasing vehicle miles traveled (VMT) for the Utilization Factor: For those BASICs that are controlled based on vehicle-miles traveled, this will increase the utilization factor from 200,000 VMT per power unit to 250,000 VMT per power unit. This change allows carriers that more efficiently use their power units to significantly lower their scores.

In addition to the five changes FMCSA proposed in June 2015, it will also preview two new changes to the CSA program. Both of these changes are expected to be beneficial for NTTC members, resulting in lower scores and less likelihood of being targeted for an inspection, according to Stephenson.

• Crash Indicator to require three or more DOT reportable crashes in MCMIS: Presently, a carrier needs to have two DOT-reportable crashes over the last 24 months to generate a Crash Indicator score. Under the preview, this will be increased to three DOT-reportable crashes over the last 24 months. This is expected to lower the number of carriers with Crash Indicator scores while continuing to target carriers that have an elevated crash risk.

• Lookback period for HOS Compliance, Vehicle Maintenance, HM Compliance, and Driver Fitness BASICs shortened to one year: Under the current system, the various CSA scores consider violations that occurred in the last 24 months. The preview will shorten this period to 12 months for the HOS Compliance, Vehicle Maintenance, HM Compliance, and Driver Fitness BASICs. The other BASICs will continue to look back for 24 months.

FMCSA is barred by Congress from basing carriers’ safety ratings on their CSA scores until after the agency submits a report to Congress investigating the links between CSA scores and actual safety performance, Stephenson said. Any deficiencies must first be resolved before FMCSA can then issue carriers’ safety ratings based upon their CSA scores. 

FMCSA continues work on its CSA reports, which must also be reviewed by the Department of Transportation Inspector General.  Until this is done, carriers’ safety ratings will not be affected by their CSA scores. However, FMCSA retains the power to use CSA scores to prioritize motor carriers for roadside inspections. Changed scores in the CSA preview will not prioritize carriers, but if the proposed changes being previewed are adopted, those new scores will affect how carriers are targeted for roadside inspection.

FMCSA will also be holding online question and answer sessions about the program. Carriers can submit questions in advance.  Those interested in viewing an online session should register in advance with the National Training Center. If prompted to enter a username and password, hit “cancel.” You will be redirected to the session sign ups. Sessions are scheduled for the following times (all times Eastern): Thursday, October 20, 11:00 am-12:30 pm EDT.