Comprehensive Safety Analysis 2010 - Regulatory Changes, Enforcement Measures and More!

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Comprehensive Safety Analysis 2010 - Regulatory Changes, Enforcement Measures and More!

This webcast will cover ...• CSA 2010 Background,• CSA 2010 Compliance Essentials,• Old Castle’s CSA 2010 Compliance

Program, and• Question & AnswerModeratorDr. Gary Petty, President & CEO, NPTC

PanelistsTom Moore, Vice President of Education, NPTCTom Bray, Editor – Transportation Management,

J. J. Keller & Associates, Inc.Larry Ahlers, VP Transportation, Oldcastle

Architectural, Inc.

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Dr. Gary PettyPresident & CEO

National Private Truck Council


Introduction• CSA 2010 Background – Tom Moore• CSA 2010 Compliance Essentials – Tom Bray• Oldcastle’s CSA 2010 Compliance Program –

Larry Ahlers• Housekeeping issues:

You will be muted during the event. Please use the Question feature to text questions to the Q&A

Panelist. We’ll try to answer them during the Q&A period if they are not covered in the presentation.

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Gary Petty National Private Truck Council


Introduction and Disclaimers

• Bulk of today’s webcast will be on FMCSA’s Comprehensive Safety Analysis 2010

• The content in this webcast is intended for information purposes only and should not be construed as providing legal advice.

• This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth.



Tom Moore, CTPVice President of Education

National Private Truck Council


Why Comprehensive Safety Analysis 2010?

Tom MooreNational Private Truck Council


Then and NowPre-CSA CSA

Data All crash, roadside inspections (OOS and select moving violations),

All crash, roadside inspection (all safety violations), and intervention data

System SafeStat (organized around SEAs, which target failing carriers)

Safety Measurement System (organized around BASICs, which expands interventions to marginally risky carriers)

Interventions Compliance Review 9 options from Warning Letter to “Unfit” Suspension

Outcomes Evaluation (safety rating; acute and critical violations)

Determination (No rating, Marginal, Unfit)



CSA 2010 Operational Model



FMCSA Next Steps• Further validate data integrity and timeliness in 9

test states: Colorado, Georgia, Missouri, New Jersey, Minnesota, Montana, Kansas, Maryland, Delaware

• Train staff nationwide• Pass SFD/Comprehensive

Review/Unfit regulations (proposal due out May 2010)



Next Stages of Rollout• 2nd quarter 2010 — CSA 2010 data “visible”• Roughly July 2010 — CSA 2010 SMS takes over for

SafeStat• SMS startup to December 2010 — State FMCSA offices

begin using new interventions



Tom BrayEditor, Transportation Management

J. J. Keller & Associates, Inc.


CSA 2010 Summary of Changes

CSA 2010 essentially has two components:• Replacement for SafeStat/Compliance Review

process of selecting carriers for interventions (no rulemaking required)

• Use data to “rate” carriers and place poor-performing carriers out of service based on the data/rating system (requires rulemaking)

Tom BrayJ. J. Keller &

Associates, Inc.


CSA 2010 Process• Data collection• New Safety Measurement System (SMS)• Safety Evaluation based on SMS• Comprehensive interventions


Associates, Inc.


Data Collection• All DOT recordable crash data• Roadside inspection data• Intervention data


Associates, Inc.

Motor Carrier Compliance Activities &

Crash Reports

Safety Data


Safety Measurement System (SMS)

• Uses seven “BASICs” (Behavior Analysis and Safety Improvement Categories) to analyze carriers

• Measures safety performance using all violations discovered during inspections

• Violations are weighted based on time and severity


Associates, Inc.MEASUREMENTOn-Road Safety Performance

(BASICs)•Unsafe Driving•Fatigued Driving (HOS)•Driver Fitness•Controlled Substances and Alcohol•Vehicle Maintenance•Cargo Related•Crash Indicator

Intervention Findings•Essential Safety Management Violations•Fundamental Violations


Seven BASICs• Unsafe Driving (Part 392, 397, and traffic laws)• Fatigued Driving (Parts 392 and 395)• Driver Fitness (Parts 383 and 391)• Controlled Substances/Alcohol (Part 382 and 392)• Vehicle Maintenance (Parts 393 and 396)• Cargo (Part 393, Subpart I and HM regulations)• Crash Indicator


Associates, Inc.


SMS BASIC Process• Relevant intervention, inspection, violation and crash

data assigned to the carrier• Violations and crashes are classified into the

correct BASIC • Events are severity weighted and time weighted• Data totaled, normalized, and peer grouped• Percentile assigned (BASIC Score)


Associates, Inc.


SMS BASIC Process• Events are severity weighted

Violations 1 to 10 Accidents 1 to 3

• Events are time weighted 0 to 6 months = 3 6 to 12 months = 2 12 + months = 1

• Full value is determined by these formulas: Violations = Severity + OOS x time weight Crash = Severity + 1 if HM spilled x time weight


Associates, Inc.


SMS BASIC ProcessExample of violation weighting:

A driver is placed out of service for an over-hours violation in the last six months.

7 Severity weighting + 2 Out-of-service 9 Total severity weighting

Time weighting = 3 (occurred in last six months)

9 Total severity weightingx 3 Time weighting 27 total Fatigued Driving BASIC value.


Associates, Inc.


SMS BASIC Process• BASIC Scoring Process

Event values in each BASIC are totaled Each “BASIC Measure” determined by dividing total event

scores by “normalizing factor” (vehicle count or number of inspections)

Peer grouped in each BASIC based on measure (groups are based on vehicle count or number of inspections)

Percentile ranking in peer group assigned in each BASIC (this is the “BASIC Score”)


Associates, Inc.


SMS BASIC Process “Safeties”

• Minimum required to activate scoring• Stacking prevented• Per BASIC limit


Associates, Inc.


Driver Safety Measurement System (DSMS)

• Will use same principles as Carrier SMS Data collection Safety measurement (BASICs) Safety evaluation Intervention if necessary

• Interventions under development• Driver BASIC Measures and BASIC Scores will be confidential


Associates, Inc.


Safety Evaluation v. Determination

• Presently “Evaluation” is performed, in future “Determination” (rating) will be given

• BASIC Score over intervention threshold triggers an intervention

• Evaluations/Determinations Continue to Operate (no contact) Marginal (progressive interventions) Proposed “Unfit Determination” (correct or cease operations)


Associates, Inc.


Interventions1. Warning letter2. Targeted roadside enforcement (ISS-D)3. Focused off-site investigation4. Focused on-site investigation5. Comprehensive review

(compliance review)6. Cooperative (corrective)

safety plan7. Notice of Violation8. Notice of Claim/Consent

Agreement9. Declare Unfit/Suspend (proposed)


Associates, Inc.


Getting Prepared• Learn the system• View your existing data through the “CSA 2010 lens”• Get good data going in now

Good data means good inspections (no violations) and no preventable crashes

Stop “foolish” inspections• Appeal incorrect data• Train and track drivers on:

CSA 2010 awareness Defensive driving Compliance with the safety regulations (hours, qualifications, etc.) Vehicle inspection Roadside inspection performance


Associates, Inc.


Larry Ahlers, CTPVice President of Transportation

Oldcastle Architectural, Inc.


Oldcastle Fleet Operations• Fleet consists of :

557 Power Units of varied types 402 Trailers 526 CDL Drivers

• Oldcastle transportation operations include everything from raw material pickups to finished

goods deliveries primarily on flatbeds from 212 plants and distribution centers within the U.S. and eastern Canada.

Larry AhlersOldcastle

Architectural, Inc.



Architectural, Inc.

Impact of CSA 2010 on Oldcastle

• Conducted an Impact Assessment Reviewed SMS process (BASICs, weighting, measurement) Met with local motor truck association Met with local DOT officials Studied “high severity” violations

• Revising Policies and Procedures

• Developing Specific Communications

• Including SMS Focus in Training

• Revising Data and Reporting


Driver Policies and Procedures

• Driver Qualification - due diligence (FMCSA Pre-employment Screening Program)

• Rewards - add rewards for clean roadside inspections

• Coaching and Training - emphasis on critical areas (e.g., HOS, defensive driving, roadside inspections)

• Disciplinary Action and Termination


Architectural, Inc.


Maintenance Policies and Procedures

• Monitor and Audit Vehicle Inspections and Repairs Documentation

• Acknowledgement – recognize clean roadside inspections

• Update Periodic Maintenance Intervals

• Technician Coaching and Training

• Disciplinary Action and Termination


Architectural, Inc.


Data Accuracy Measures• Review and update MCS 150 profile at regular

intervals: https://www.fmcsa.dot.gov/registration-licensing/gettingstarted/forms.htm

• Review roadside inspections data frequently: https://portal.fmcsa.dot.gov

• Challenge inaccurate data: https://dataqs.fmcsa.dot.gov


Architectural, Inc.

https://www.fmcsa.dot.gov/registration-licensing/gettingstarted/forms.htm



https://portal.fmcsa.dot.gov/

https://dataqs.fmcsa.dot.gov/


FMCSA’s CSI System


Architectural, Inc.




Architectural, Inc.




Architectural, Inc.




Architectural, Inc.




Architectural, Inc.




Architectural, Inc.




Architectural, Inc.




Architectural, Inc.


Focusing Compliance Efforts

• CSI system is a good start in identifying deficiencies Driver Management Equipment Management Load Management

• Benchmark your ratings against others Peer Group Outside Carrier Assessment

• Download data and identify at risk BASICs Interact with drivers, maintenance, and operations


Architectural, Inc.


Carrier Compliance Efforts• Focused on Safety of Employees and Contractors

• Study “high severity” violations of Carriers

• Policy is to “not use unsafe Carriers”

• Developing Specific Communication with Carriers

• Offer Carriers support and alternatives for assistance

• Revised Data and Reporting on Carrier Compliance


Architectural, Inc.


Driver Training• CSA 2010

• Defensive driving

• Compliance with the safety regulations (hours, qualifications, etc.)

• Vehicle inspection

• Roadside inspection performance

• Avoiding roadside inspections conducted due to Speeding and other traffic violations Entering scale with lights not working or overweight

• Notification of any citations /warnings with response


Architectural, Inc.


Question & Answer

Please submit questions to “Q&A” using the Q&A tool




Architectural, Inc.


Associates, Inc.


Closing Remarks• Past CSA 2010 webcast recording (12/3 air date):http://www.jjkeller.com/CSA_2010• Checkout the archive of past topics at:

http://www.jjkeller.com/nptcinfo PowerPoint slides up in 1-2 days Recording up in 1 week

• Topics for 2010: June 2 – Enhanced Driver Qualification – Testing, Physicals and

Background Checks August 25 – Fleet Excellence – Customer Service October 20 – Fleet Excellence – Driver Recruiting & Retention


http://www.jjkeller.com/CSA_2010

http://www.jjkeller.com/nptcinfo

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Comprehensive Safety Analysis 2010 - Regulatory Changes, Enforcement Measures and More!