CSA 2010 – Evaluation & Implementation
method OF EVALUATION
The basic scores and percentiles will be used to clarify which carriers warrant intervention and what level of intervention is appropriate. They will also be used to determine a carrier’s fitness to function.
The Safety Fitness Determination (SFD) methodology is currently being developed unprotected to rulemaking requirements. The consequence will be a methodology producing a carrier fitness determination of either unfit, marginal, or continue operation.
As opposed to the present situation in which the only option is a Carrier Review, CSA 2010 provides a method of intervention commensurate with the level of degree of difficulty in a specific area. There are three levels of intervention with various method within each level.
The method of early intervention, the lowest levels of action, are as follows:
1. WARNING LETTER harmonies that identifies a deficient BASIC area and the possible consequences of continued safety problems. It also provides instructions for accessing carrier data and measurement and a point of contact.
2. CARRIER ACCESS TO SAFETY DATA AND MEASUREMENT-This allows the charting of violations and improvement with monitoring for accuracy.
3. TARGETED ROADSIDE INSPECTIONS-Specific problems by BASIC area are identified.
This level is proactive and progressive, increasing in severity and degree of interaction based upon the risk posed by the carrier. The possible method of intervention in these middle levels are as follows:
1. OFF-SITE INVESTIGATION Documents are provided by a carrier for off-site review pursuant to the regulators’ request.
2. ON-SITE FOCUSED INVESTIGATION-This investigation is at the carrier, focusing on two or less BASIC problem areas.
3. ON-SITE COMPREHENSIVE INVESTIGATION-A carrier exhibiting general and complicate safety problems, continually deficient or worsening BASICs in three or more areas, a fatal crash, or a complaint may be unprotected to a complete investigation.
1. COOPERATIVE SAFETY PLAN (CSP)-This is a voluntary plan collaboratively produced by the carrier and FMCSA based upon a standard template to address inner problems resulting from the carrier’s substandard performance.
2. NOTICE OF VIOLATION (NOV)-This will be issued for a regulatory violation serious enough to warrant formal action, but not a civil penalty or when the violation is closest correctable and there is a high level of and desire for cooperation. The carrier must provide evidence of corrective action or begin a successful challenge to the violation.
3. NOTICE OF CLAIM (NOC)- These are issued for regulatory violations serious enough to warrant a civil penalty.
4. SETTLEMENT AGREEMENT This is a contract negotiated with the carrier to enact remedies that address the root cause of a safety problem, defer or reduce penalties, or terminate enforcement proceedings.
DRIVER SAFETY MEASUREMENT SYSTEM
This is the second major part of the Safety Management System intended to directly monitor the safety and performance of individual drivers. It is intended to monitor drivers based upon records across multiple employers.
This also enables investigators to estimate roadside performance of drivers across employers over a three year period. Safety investigators can clarify “high profile” drivers with overall poor safety histories.
Drivers will have scores and percentiles generated as a consequence of roadside inspections. Scores will be weighted by severity and time.
For drivers, the time weighting is over a three year period. Violations within the prior 12 months will be factored by three, during the prior 13 to 24 months by a factor of two, and from 25 to 36 months by a factor of one.
Testing of CSA 2010 began in four states in 2008. Several more were additional in 2009. CSA 2010 will be implemented in the remaining states in July, 2010.
PREPARING FOR CHANGE
What can you as a carrier or driver do to prepare for the changes imposed by CSA 2010. Here are some suggestions.
1. LEARN THE SCORING SYSTEM-Review the point system so you are aware of the violations that carry the greatest penalties and take action to avoid them.
2. KNOW THE CVSA CRITERIA Study the CVSA inspection and out-of-service criteria.
3. BE PROACTIVE WITH YOUR UNITS-Educated in the point system and CVSA criteria, inspect your units and re-press pretrip inspections.
4. aim AND EDUCATE DRIVERS-Redouble efforts for pretrip inspections, hours-of-service compliance, meeting medical requirements, and particularly cargo securement regulations and requirements.
5. analyze WAYS TO PREQUALIFY FOR INSPECTIONS analyze opportunities such a prepass to potentially reduce the number of roadside inspections and, ultimately, the possible for point producing violations.