HIGH CSA SCORES?
WHY HIGH SCORES SHOULD CONCERN YOU
High CSA scores in your BASIC categories create concern from customers and insurance companies along with increased attention from regulatory authorities. BASICs with CSA scores over the intervention threshold can trigger action ranging from a warning letter to a full audit. Carriers that have been evaluated as needing interventions will be subject to a wide range of reprimands. The specific intervention will depend on the carrier’s BASIC scores and enforcement history. The interventions include the following:
–Warning letter. This puts the carrier on notice that a BASIC has gone above the threshold and correction is necessary. FMCSA is not required to send a warning letter prior to an intervention.
–Increased roadside enforcement. This will function much like the present ISS system. Carriers with a BASIC over a threshold will be flagged in the Inspection Selection System used by roadside inspectors to select carriers for inspection. The system will also tell the inspectors which BASIC score (or scores) has placed the carrier on the “Inspect” list.
–Focused off-site investigation. This intervention will check a carrier’s compliance with the regulations and verify performance in BASIC areas in which the carrier has struggled. The carrier will send investigators requested records and respond to any follow-up requests. For example, if the carrier has a poor BASIC score in Driver Fitness, the focused off-site investigation would concentrate on Driver Fitness issues.
–Focused on-site investigation. Involves a “narrow” on-site audit of a carrier based on areas of poor performance. For example, if the carrier has a poor Vehicle Maintenance BASIC score, the focused on-site investigation would concentrate on vehicle and cargo securement issues.
–Cooperative safety plan. Following a focused investigation or comprehensive review, FMCSA may request that the carrier develop a cooperative safety plan intended to correct performance. The plan needs to be submitted to FMCSA and approved.
–Notice of violation. The notice of violation would serve as a formal mechanism to inform carriers that the carrier must address compliance deficiencies.
–Comprehensive on-site investigation. This is the equivalent of FMCSA’s present Compliance Review (audit). It would only be used when other interventions have failed or if there are grounds for it (very poor BASIC score, accident follow up, valid complaint, an earlier investigation found larger problems, etc.).
–Notice of claim, penalty, and settlement agreement. These would be the steps used by FMCSA following an intervention that did not go well. Involves fining the carrier or driver.
INCREASED INSURANCE PREMIUMS
Insurance companies will review BASIC scores during their evaluation of a carrier’s overall risk profile. Higher CSA scores can lead to higher premiums, deductibles, or even denial of coverage. Insurers will pay close attention to the Unsafe Driver, Crash Indicator, and Hours-of-Service Compliance BASIC. They also pay attention to the Vehicle Maintenance BASIC. The Vehicle Maintenance BASIC is among one of the BASICs insurance companies review thoroughly because it allows them to gain insight into whether a motor carrier properly maintains their equipment. A CSA Vehicle Maintenance BASIC score over 80 would be considered problematic and could result in an audit. There are over 200 items contained within the Vehicle Maintenance BASIC. A full list, along with their assigned point values, can be found here. In general, this particular BASIC includes violations such as brakes, lights, and mechanical defects and failure to make required repairs. A high FMCSA percentile ranking in this BASIC could be an indication of a company or driver that does not take proper care of their equipment or uses equipment that is older and in poor shape. In both cases, FMCSA believes that these correlate to a higher risk such as a crash. Whether that is true or not, it is something that will influence insurance premiums.
The Unsafe Driving BASIC is reviewed for obvious reasons. Unsafe Driving Violations with related point values can be found here. Some examples of Unsafe Driving Violations include operating a CMV while texting, following too close, inattentive driving, speeding, reckless driving, and failure to maintain lane. Insurance carriers use the data found in a trucking company’s Unsafe Driving BASIC to decide whether their company exhibits safe driving behavior or if their past behavior may become a nuisance to them in the future.
Hours-of-Service BASICS are evaluated by insurers to determine if motor carriers require their drivers to operate within the HOS limits mandated by FMCSA and if the drivers belonging to the motor carrier are permitted to operate while fatigued. The National Transportation Safety Board estimates that 30 to 40 percent of all tractor-trailer accidents involve some element of driver fatigue. Hours-of-Service violations and point values can be seen here.
The Crash Indicator BASIC is assessed by insurance companies for the same reasons they review a trucking company’s loss run report. The Crash Indicator methodology can be found here. Although crashes that aren’t the motor carrier’s fault are listed on their Crash Indicator, this BASIC’s score is still taken into consideration by insurance carriers. This may seem unfair, but the good news is there is a way to eliminate the number of violations throughout all your CSA BASICs.
HOW FMCSAFETY CAN HELP
A partnership with FMCSAFETY will bring expertise in FMCSA Rules and Regulations, proficiency in challenging CSA violations and crashes with proven strategies to have them removed from your CSA profile, experience to examine past practices, assistance in developing an improvement plan and recommended solutions. Our expert consultants create solutions customized to your company’s individual needs and construct and provide specific strategies to implement that plan.
The benefits of partnering with FMCSAFETY are:
- Distinctive and unique safety and compliance programs that are developed after discovering the areas in which your company’s scores need improvement and defining a clear set of goals
- A full-time firm that manages every aspect of your company’s safety and compliance programs
- Assistance from consultants qualified in all components of safety, compliance, and regulations
- Reduced personnel costs
- Additional time for you to devote on the operations of your business