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EXECUTIVE SUMMARY –
The U.S. DOT is preparing to finalize a new
system for determining motor carrier safety
ratings. The new program, known as
Comprehensive System Analysis (CSA 2010),
replaces the current SafeStat data
collection system. CSA 2010 collects a more
comprehensive array of motor carrier data
for use in determining safety ratings than
the current SafeStat system and incorporates
new early intervention enforcement tools
such as warning letters to reduce the
incidence of unsafe operation and accidents
involving motor vehicle transports. CSA 2010
does not impose any new compliance
obligations. However, petroleum transporters
must monitor and manage their transportation
safety program much more carefully to
prevent a downgrade in motor carrier safety
ratings. The CSA 2010 program launch date
has not been announced but is expected to
occur between July and December of 2010.
U.S. DOT to Roll Out New Motor Carrier
Safety Rating Program by Year’s End
The U.S. DOT’s Federal Motor Carrier Safety
Administration (FMCSA) is preparing to roll
out its new motor carrier safety rating
program sometime during the second half of
2010. The new program imposes no new
compliance obligations on petroleum
marketers but changes the way the DOT
determines motor carrier safety ratings.
Many petroleum marketers are hearing about
the new program now due to an advance
outreach effort by the DOT. The new program
called CSA 2010 will replace the current
SafeStat motor carrier safety rating. All
interstate and intrastate petroleum
transporters are subject to the FMCSA motor
carrier safety rating program. Under the
current SafeStat system, data is taken from
roadside inspections and used to target
motor carriers for DOT safety compliance
audits. In turn, the safety compliance
audits are used to determine motor carrier
safety ratings. These safety ratings are
important to petroleum marketers because
they determine operating authority and are
used by insurance companies to set premiums
for trucking operations. The CSA 2010
introduces a more comprehensive safety
rating system based on a wider range of
ongoing data from roadside inspections and
driver safety violations collected
continuously over a three year period.
I. New CSA 2010 Program Introduces
Changes to Safety Rating in Three Areas
Safety data is collected from road side
inspections rather than from safety
compliance audits giving a more
comprehensive safety profile of motor
carriers and drivers in real time.
Information from roadside inspections is
collected in a central database for
immediate evaluation. The safety
measurement data system pinpoints the
source of safety problems and identifies
high risk behavior in real time.
New enforcement process employs early
intervention tools to motor carriers
when collected data reveals unsafe
performance. Enforcement interventions
(a combination of corrective actions and
compliance assistance) match the level
of safety risk of the violation and
range from initial warning letters to
on-site inspections or out of service
orders. The more violations that occur,
the greater the degree of enforcement
intervention.
Larger number of motor carriers will be
evaluated in real time with safety
ratings updated continuously based on
new safety data from roadside
inspections and driver performance.
Violations will, for the first time, be
weighted based on safety risk. Driver
violations will be directly monitored
and factored into carrier safety ratings
for the first time (only those
violations occurring during employment
with the carrier).
II. Side by Side Comparison of How Safety
is Measured Under Current and New Safety
Rating Systems
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CURRENT “SAFESTAT”
SAFETY MEASUREMENT SYSTEM
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NEW CMS 2010 “SMS”
SAFETY MEASURMENT SYSTEM |
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1. Organized around four broad
safety evaluation categories:
accidents, drivers, vehicles,
safety performance management.
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1. Organized around seven
specific safety performance
categories: unsafe driving,
fatigued driving, driver
fitness, drug and alcohol
requirements, accidents, vehicle
maintenance and cargo related
violations (spills, unsafe
handling, etc). |
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2. Data is used to identify
carriers who must undergo a
safety compliance review based
on past safety violations. |
2. Data is used to identify
safety problems in real time,
determine where to focus safety
investigation and set motor
carrier safety rating. |
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3. Uses only out of service and
traffic violations identified
through roadside inspections to
determine need for compliance
audit. |
3. Uses all safety based
roadside inspection violations
to determine safety rating. |
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4. Has little to no impact on actual
safety rating. Only identifies
carriers that are targeted for a
compliance review. Safety data
from the compliance review then
determines the motor carrier
safety rating. |
4. Used to determine safety
fitness rating based on
carrier’s current on-road safety
performance. |
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5. Violations not weighted based
on safety risk |
5. Violations are weighted in
relation to the risk of an
accident. |
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6. Assesses performance of carriers
only when determining carrier
safety rating. |
6. Assesses performance of
drivers and carriers when
determining carrier safety
rating |
III. Steps Petroleum Transporters Can
Take to Prepare for CSA 2010
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Understand the new Safety Measurement
System methodology (under green column
above).
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Understand the following Behavior
Analysis and Safety Improvement
Categories (B.A.S.I.C.S) that affect
motor carrier safety ratings: unsafe
driving (speeding, driving on an invalid
or expired CDL, etc), fatigued driving (HOS
violation), drug and alcohol (use or
possession), vehicle maintenance (faulty
lights, brakes, etc), cargo related
(improper load, handling, marking etc),
accident history.
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Educate drivers about their driving
records and how their performance
affects their driving records and the
safety assessment of the carrier.
Emphasize that every roadside inspection
and violation counts towards the motor
carrier safety rating.
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Ensure your U.S. DOT Number (MCS-150
Form) is up to date. The MCS-150 form
and instruction can be downloaded at:
http://www.fmcsa.dot.gov/registration-licensing/print-forms/print-forms.htm.
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Review roadside inspection, violation
and accident history for the past two
years to identify areas for improvement.
These records can be viewed at
http://ai.fmcsa.dot.gov.
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Keep detailed records of all roadside
inspection results, and driver
violations as evidence to contest
improper safety rating determinations.
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Make any necessary safety performance
improvements now.
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Sign up for CSA 2010 e-mail updates at
http://csa2010.fmcsa.dot.gov/Stay_Connected.aspx
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Visit the CSA 2010 website for a variety
of fact sheets, tutorials and PowerPoint
presentations on the new safety rating
program at
http://csa2010.fmcsa.dot.gov.
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Visit
http://csa2010.fmcsa.dot.gov/yourrole/motorcarriers.aspx
and click on “Frequently Asked
Questions”. Check the box next to “Motor
Carrier” for a comprehensive list of
questions and answers on the CSA 2010
program.
Should you have any questions about these
new forms or drug and alcohol testing
requirements, please contact
Mark S.
Morgan, Esq., PMAA Regulatory Counsel at
202.364.6767.
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