Proposed CSA Changes…and Focused Purpose



Douglas B. Marcello
Shareholder, Trucking and Commercial Transportation

Proposed CSA Changes…and Focused Purpose

The Federal Motor Carrier Safety Association (FMCSA) proposed revisions to CSA that “prioritizes” companies for enforcement instead of it being a safety score. It’s all about “prioritization” of FMCSA’s limited resources for most effective enforcement of crash-potential carriers.

Why it Matters
The weighted violations will be gone. Companies will be measured in a new format.

The Specifics
The FMCSA proposes changes that are as follows:

  1. Bye, bye “BASICS”, hello “Safety Categories” – The scores are now in separate “Safety Categories”. The label “BASIC” is gone.
  2. “Unsafe Driving” additions: No more “D & A BASIC” (or “safety category”). This category, with the lowest violations, will be merged into “Unsafe Driving”.

    Also added to “Unsafe Driving” will be all operating while “out of service” violations. This is regardless of the underlying violation that resulted in the OOS.

  3. Split Vehicle Maintenance Category – The FMCSA will split the vehicle maintenance “safety category” into two separate ones.

    The first is “Driver Observed”: What a driver should discover in a pre-trip. These equate to a Level 2 inspection type violation.

    The second is “Vehicle Maintenance”: What should be found and addressed by the shop.

  4. Roadside Violation Reorg – The current 959 roadside violations will be consolidated into 116 groups of similar violations. This is to address the quirks from inspection-to-inspection where one violation could be written under different sections.

    You can still be written up 959 different ways. But if you are written up with multiple violations in the same group it will only count as a single violation for that category, such as multiple HOS violations equaling 1 violation for that category.

  5. Severity weight slimdown – No more 1-10 weighting of violations.

    The “2’s” are OOS violations of any category (except “Unsafe Driving”) AND Driver Disqualifying violations (apply to “Unsafe Driving” only as defined by Section 383.51). Anything else is a “1”.

  6. Intervention Threshold Adjustment – The thresholds for intervention will be changed as follows:

    – Driver Fitness
    – General Carriers= 90%
    – Hazmat Carriers= 85%
    – HM Compliance= 90%

    Vehicle maintenance (both “categories”) will stay at 80% for general carriers.

  7. Proportionate Percentiles will use the exact number of inspections and crashes rather than cutoffs in SMS established by safety event groups. The purpose is to have the carrier’s percentile impacted by its events.
  8. One Year Lookback – Carriers will only be assigned a percentile in a “safety category” if that carrier has received at least one roadside violation in that “category” within the last 12 months. Nothing in that category in the last year – no percentile in that category.
  9. Utilization factor – would be moved from 200,000 vehicle miles traveled (VMT) to 250,000 VMT.
  10. There will be segmentation within “categories”, not to be confused with split “categories.”

    Hazmat Compliance will be “segmented” into “cargo tanker” and “cargo non-tanking” segments. “Cargo tanker” group is if more than 50% of a carrier’s inspections involve a tanker.

    Driver Fitness will be “segmented” into “straight trucks” and “combination” carriers.

  11. Non-preventable accident program has no change.

How will it change your score? You can find out at CSA Prioritization Preview – Home ( as well as see the FMCSA summary and videos.

The Bottom Line
The FMCSA is changing CSA into an enforcement “prioritization” analysis to focus its limited resources on the carriers exhibiting the conduct that its analysis shows the most indicative of crash potential.

CSA will no longer have the pretext of a safety score card. Severity of violations will be virtually indistinguishable – “1” or “2”.

The FMCSA target is narrowed – interventions raised, binary scores, time of violations reduced. It’s about the enforcement.


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