The Comprehensive Safety Accountability (CSA) {changed from Comprehensive Safety Analysis} is here and soon to a state near you! To better understand the CSA and its implications, you the driver must become well acquainted in how it works.
An overview of the seven (7) grading areas known as BASIC - Behavior Analysis Safety Information Categories is:
1. Unsafe Driving
2. Drug and Alcohol
3. Fatigued Driving
4. Driver Fitness
5. Vehicle Maintenance
6. Cargo Loading / Securement
7. Crash History
Violations are weighed for both CARRIERS and DRIVERS:
Carrier: </= 6 months - 3 points Driver: </- 12 months - 3 points
6 - 12 months - 2 points 12 - 24 months - 2 points
12 - 24 months - 1 point 24 - 36 months - 1 point
To ensure that there is no confusion... points assessed by CSA may not be on your state drivers license, however, they are on a scale to determine further action for review by the FMCSA. Points assessed, times the severity equals total points for infractions of the rules.
Please understand that truly "Random Inspections" only comprise about 4% of the total inspections performed. The other 96% of the inspections comes from observed traffic enforcement issues, obvious defects in faulty equipment or loading issues. Out of 54 possible fatigued driving violations, 53 are directly assigned to the driver. Among the violations of this BASIC (#3) include:
* Driving while ill/fatigued;
* Failing to complete or retain logs;
* Violating the Hours-of-Service (HOS) limits (11/14; 10/15 and 60/70 hr violations);
* Failing to include all required items on the log (Form and Manner);
* Violation of an HOS related Out of Service (OOS) order.
Specific parts of the FMCSR's includes 392, 395 & 398. This is a "STAND ALONE" BASIC - which means that failing this section, you could receieve an overall failing grade for a comprehensive review.
Remember that the lower the score, the better for both the driver and the company. Companies are placed in size peer groups :
* 3 - 10;
* 11 - 20;
* 21 - 100;
* 101 - 500; or
* more than 500.
These sizes allow for more accurate measurement, by ranking in order based on unsafe driving reports. Ranking ranges from 0 - 100. Carrier are removed for which no violation was recorded in the fatigued driving BASIC during the previous 12 months and no violation in this area during the latest relevant inspection.. All other carriers are assigned a percentile between 0 - 100% depending upon their fatigued driving measurements of three or more. (Less than 3 are removed from the ranking process)
Relevant inspections under this BASIC are Level 1, 2, 3, or 6 in the previous 24 months, OR any vehicle inspection in the past 24 months that resulted in a fatigued driving violation. The one company violation under this BASIC is the EBOR does not display required information.
Drivers, for you, fatigued driving could consist of:
* Operating a CMV while ill/fatigued;
* Driving after being declared OOS (395.13)(d)(1);
* Driving after being declared OOS (395.13)(d)(2);
* Violation of HOS - Migrant workers (398.6);
* False report of driver record of duty status (395.8);
* State and local HOS (392.2H);
* 15, 20, 70/80 HOS violations (Alaska Property);
* 15, 20, 70/80 HOS violations (Alasks Passenger);
* Adverse driving conditions (Alaska);
* Requiring or permmiting a driver to drive more than 11 hours;
* Requiring or permitting a driver to drive after 14 hours on duty;
* 60/70 hour rule violation;
* 34 hour restart violation (Property);
* 10 hour rule violation(Passenger);
* 15 hour rule violation (Passenger);
* 60/70 hour rule violation (Passenger);
* No drivers record of duty status;
* Drivers record of duty status not current;
* Failing to maintain previous 7 days' logs; and
* Failing to submit record of duty status within 13 days.
There are many more lesser violations including many form and manner or EBOR related issues.
Drivers with less than three relevant inspections, or no fatigued driving violations are removed from the ranking process. The remianing drivers' are sorted into ascending order, according to amassed violation totals and given scored from 0 - 100 %. The drivers that are the worst are placed into a "High Profile" status and they are watched by the FMCSA for total performance. These drivers who do not perform well, may receve intervention measures by the FMCSA.
The relevant inspections under this BASIC, include Level 1, 2, 3 or 6 in the previous 36 months and no inspections resulting in at least one fatigued driving violation. As a reminder, drivers will acquire a safety history that stays with you for a rolling 36-month period. Do it right the first time and NOT become a "High Profile" driver with the FMCSA. Your work ethics will follow you around - good or bad, and that will reflect on the carrier that you work with, too! Becoming a truly road professional requires you to think outside the box as your actions do affect others.