News of the ELD Mandate, which becomes active across the country on December 18, is abuzz. Earlier this month, officials from the FMCSA announced at the Southern Regional Road Show that any ELD violations found at road stops before April 1 would not count against a carrier’s CSA score. If violations are found, the infraction will be marked as a “No-points-cite”, which will not impact the Safety Measurement System used for CSA. This is great news for carriers who are still preparing for the big switch to electronic logging devices.
Most carriers and truckers are likely familiar with the CSA, but further explanation is always helpful. The purpose of the Compliance, Safety, and Accountability program (CSA) created by the FMCSA is to enforce safety guidelines. Together, the CSA and the SMS point system track which motor carriers and truck drivers are most at risk for safety violations and offer interventions to avoid future accidents. The point system uses seven prioritization categories, referred to as Behavior Analysis and Safety Improvement Categories (BASICs). These seven categories fall under Driver Fitness, Vehicle Maintenance, Hours of Service Compliance (HOS Compliance), Crash Indicator, Hazardous Materials Compliance, Controlled Substances and Alcohol, and Unsafe Driving. Carriers are evaluated in these categories through on-road performance evaluations from roadside inspections and crash reports as well as investigations, which include results from violations in the last 12 months. Carriers are arranged in safety event groups, organized by a similar number of safety events. Then, carriers are ranked on a percentile scale of 0 – 100 in each safety event group; the higher the score, the worse the safety performance.
In addition to the previously mentioned BASICs, acute violations and critical violations are also used to prioritize carriers for safety interventions. If a carrier is in violation of more than one or more acute or critical violations, they will receive an alert in their BASICs report. Acute violations refer to violations that are so severe that they only have to occur once for immediate intervention to take place. Critical violations occur when a carrier has violated a safety procedure several times, resulting in a pattern of violation. The last category used for safety prioritization is the Insurance/Other Indicator, which can appear when insurance standards expected by the FMCSA are not met.
If a motor carrier or driver accumulates too many points, they are at risk for an out-of-service order or a negative safety rating. Infractions can stay on a carrier’s safety history up to two years. Severity weights, time weights, and occasional out-of-service weights are applied within each BASIC depending on the violation. A severity weight of 1-10 is applied depending on the violation. The higher the weight, the more severe the incident. Once the total severity weight in a category reaches the maximum of 30 points, time weights are applied and multiplied by the total severity weight, increasing the total SMS score. Time weights range from 1-3. The more recent a violation, the higher the time weight. In addition to BASICs points and weights, intervention thresholds for each category are used to determine whether an intervention should be made. For example, in the Unsafe Driving Basic, intervention thresholds apply to each smaller category. For instance, if a motor carrier exceeds the intervention threshold of 50% in the passenger carrier subset of the Unsafe Driving Basic, they will receive a warning symbol in the BASIC and further intervention such as a warning letter or increased roadside enforcement. Additional interventions that CSA can take are off-site and on-site investigations; participation in a cooperative safety plan; notice of a claim, penalty or settlement agreement made against the offending party; or an out-of-service order.
The easiest way to avoid the implications of violating CSA standards is to follow them as close as possible. Check your SMS score regularly through the SMS website. Check your trucks and drivers for possible violations before they are found during a road-stop. The CSA’s website offers great resources for understanding your safety rating and performance. Additionally, you have plenty of time to integrate ELD updates before they begin to impact your CSA score starting April 1.