While the most comprehensive information about the Federal MotorCarrier Safety Administration's rollout of its Comprehensive SafetyAnalysis initiative is available on FMCSA's website, for thoseagents, insurance underwriters and motor carriers who don't havetime to wade through all the details, here are the "basics."

WHAT IS CSA?

According to information on FMCSA's website (https://csa2010.fmcsa.dot.gov),CSA 2010 is a new operational model that seeks to give a betterview of motor carrier and driver compliance with existing safetyregulations. It also seeks to intervene earlier with those who arenot complying.

The new model has three components:

1) Measurement

2) Evaluation

3) Intervention

HOW DOES THE MEASUREMENT SYSTEM WORK?

Contained in the CSA model is a Safety Measurement System (SMS)that uses on-road performance data. This new system actually hastwo systems–CSMS for motor carriers, and DSMS for drivers.

While driver evaluations will not result in the assignment ofsafety ratings (fitness determinations defined below) under theevaluation component of the model, they will impact carrierratings.

SMS replaces SafeStat, the measurement system of the oldoperational model. SafeStat did not contain a separate driverevaluation comparable to DSMS and relied on data fromout-of-service violations and selected moving violations only.

The SMS summarizes data on all safety-based violations indicated on roadsideinspections reports and data from state-reported crashes. CSMSincludes two years of data, and DSMS uses three prior years. Thedata is sorted into seven buckets or Behavior Analysis SafetyImprovement Categories (BASICs).

WHAT ARE THE BASICs?

There are six BASICs. They are:

o Unsafe Driving BASIC, which looks atspeeding, improper lane change and other violations indicating thatdrivers are operating commercial motor vehicles (CMVs) in adangerous or careless manner.

o Fatigued Driving BASIC, which includesviolations of regulations related to the complete and accuraterecording of hours of service in logbooks and other indicationsthat drivers are operating CMVs while ill or fatigued.

In general, a truck driver cannot drive more than 11 hours perday, or work for 14 hours without an eight-hour rest period.

o Driver Fitness BASIC, which includesviolations such as the lack of a proper driver's license–violationsindicating that drivers lack training, experience, or are unfit formedical reasons.

o Controlled Substances/Alcohol BASIC, whichincludes violations related to driver possession or use of alcohol,illegal drugs, and misuse of prescription or over-the-countermedications.

o Vehicle Maintenance BASIC, summarizingviolations for blown lights, bad brakes, or other mechanicaldefects

o Cargo-Related BASIC, summarizing violationsfor issues such as those for improperly secured loads or unsafehandling of hazardous materials

HOW ARE RESULTS EVALUATED?

Details of the formula used to convert the violation and crashdata into seven numerical measures–one for each BASIC and one forthe crash indicator–are included in a 94-page document at http://csa2010.fmcsa.dot.gov/Documents/SMSMethodology.pdf.

The document explains that violations and crashes are weightedbased on the severity, and that the time elapsed since theviolation or crash is also considered–giving less weight to eventsoccurring further back in the past.

After a measurement is determined, results are "normalized"–inother words, the motor carrier is placed in a peer group. Themethod for determining peer groups was recently revised, butreports from FMCSA in mid-August suggest that peer groups will bebased on a combination of miles driven and the number of powerunits.

For motor carriers, percentiles from zero-to-100 are thendetermined by comparing the BASIC measurements of the carrier tothe measurements of other carriers in the peer group. A score of100 indicates the worst performance.

A sample carrier summary measurement page–the CSMSscreenshot–included in FMCSA's methodology report (Fig. 5-1 on page5.2) shows a carrier with an "unsafe driving BASIC" percentile of98.6, indicating that the motor carrier performed worse than 98.6percent of its peers in this category. That result is highlightedin red, while the "fatigued driving BASIC" of 90.5 is shaded inyellow. A footnote reveals that the colors mean the "interventionthreshold" has been exceeded.

WHAT ARE THE INTERVENTIONS?

FMCSA and its state partners will use measurement results toidentify motor carriers that need CSA interventions, ranging fromrecommendations for corrective action to strong penalties. Thereare no driver interventions under CSA.

Carrier interventions CSA are broken into three categories:

o Early Contact includes warning letters andtargeted roadside inspections. Warning letters identify deficientBASICs, outline possible consequences of continued safety problems,and instruct carriers on how to access their carrier safety dataand measurement scores.

o Investigations include offsiteinvestigations, requiring carriers to submit documents to FMCSA ora state partner, related to specific problems identified throughthe SMS–such as drug testing records for deficientsubstance/alcohol BASICs. A carrier failing to submit requesteddocuments may be subject to an onsite investigations orsubpoenas.

Onsite investigations range from focused investigations (onparticular issues such as vehicle maintenance) to comprehensiveinvestigations addressing all aspects of the carrier'soperation.

Comprehensive investigations, similar to multiday,labor-intensive compliance reviews conducted in the past, will beused for carriers with continually deficient BASICs, worseningmultiple BASICs (three or more), or a fatal crash or complaint.

o Follow-ons include:

1) Cooperative Safety plans, which are voluntary safetyimprovement plans collaboratively developed with FMCSA to addressthe problems leading to a carrier's substandard safetyperformance.

2) Notice of Violation, which are formal notices of safetydeficiencies that require a response from the carrier–used whenregulatory violations discovered are severe enough to warrantformal action but not civil penalty.

3) Notice of Claim or civil penalty.

4) Operations Out-of-Service Order, requiring the carrier tocease all motor vehicle operations.

WHAT IS A SAFETY FITNESS DETERMINATION?

As part of the safety evaluation process, FMCSA is developing anew Safety Fitness Determination methodology, subject to ongoingrulemaking.

In the past, SFDs were only assigned after a full compliancereview was performed. Under CSA, SFDs will be based on the SMScalculations, and they will also include the results ofinvestigations when they are performed.

SFD assignments–"continue to operate," "marginal," or"unfit"–will be updated on a monthly basis for every motorcarrier.

WHAT DATA IS AVAILABLE TO INSURERS?

FMCSA envisions that public users, including shippers andinsurers, will have electronic access to SMS results that is verysimilar to the access to SafeStat they have currently. That meansprivacy-related information, such as driver names from individualinspections, will be removed for public viewing.

Public access is expected to begin in early December. Motorcarriers have been able to preview their results sincemid-August.