What does CSA stand for?

During its development and testing, CSA 2010 stood for Comprehensive Safety Analysis 2010.  Upon its deployment in December 2010, FMCSA renamed its new safety enforcement program to be, simply, CSA − Compliance, Safety, Accountability. 

How do I know if CSA affects me?

 FMCSA’s regulations remained the same after CSA implementation in December 2010, though CSA does change how FMCSA prioritizes carriers for enforcement and how it enforces compliance.  Generally, CSA affects carriers subject to the Federal Motor Carrier Safety Regulations (FMCSR), carriers transporting passengers or cargo in interstate commerce, and carriers of hazardous materials in intrastate commerce, but may also include carriers whose State requires that they obtain a U.S. DOT number.

What is the CSA timeline?

The CSA rollout began in December 2010 with the following activities:

  • SafeStat was replaced by the SMS as the tool used by FMCSA/States to prioritize enforcement. SafeStat is no longer available.
  • Roadside inspectors are using the SMS results to identify carriers for inspection.
  • The SMS is available to the public, including shippers and insurance companies.

Beginning in early 2011, warning letters will be issued to carriers with Behavior Analysis and Safety Improvement Categories (BASICs) that exceed the FMCSA Intervention Threshold.

Where is the SMS available to the public and what can the public see?

The SMS was made public on December 12, 2010. A link to the public SMS is on the Analysis and Information (A&I) Online Website (http://www.ai.fmcsa.dot.gov/sms). The public can view five of the SMS’s seven BASICs. The SMS’s Crash Indicator, like SafeStat’s Accident Safety Evaluation Area (SEA), is only visible to the carriers themselves and to enforcement staff while the agency develops a long-term approach to determining crash accountability (see the FAQ below). In addition, as a result of a transparent and systematic process of input, testing, feedback, and refinement, FMCSA has determined that the Cargo-Related BASIC, while a solid indicator of safety performance, needs further analysis and refinement prior to public release. Therefore, at present, the Cargo-Related BASIC is used by enforcement and is only visible to motor carriers.  

How is crash accountability handled in SMS?
  • The structure of the new SMS is such that crash accountability is not automatically determined or considered. In fact, recordable crash reports that States submit to FMCSA do not include an accountability determination. Consequently, motor carriers are identified for possible intervention based on recordable crashes without consideration of accountability.
  • Why does FMCSA take this approach?
  • This approach is taken because data analysis has historically shown that motor carriers that are involved in crashes, regardless of accountability, are likely to be involved in more future crashes than the carriers that are not. Put simply, past crashes are a good predictor of future crashes.
  • Will this approach remain the same moving forward?
  • FMCSA recognizes this approach as a concern and is considering several short- and long-term ways to address it
  • The short-term: The plan is to exclude the Crash Indicator BASIC percentile ranking from public websites because FMCSA understands that some crashes are unpreventable on the part of the motor carrier. This is consistent with the agency’s decision not to display the Accident SEA of SafeStat on public websites in recent years. 
  • The long-term: FMCSA is assessing the feasibility of evaluating crashes for accountability/preventability before they are used by the SMS in the Crash Indicator BASIC. This would allow FMCSA to better concentrate intervention efforts on motor carriers that have high preventable/accountable crash rates.
  • In the meantime, FMCSA will continue to consider crash preventability prior to issuing adverse formal safety ratings.
When does the SMS update?

The SMS updates monthly. A snapshot of the data is taken on the 4th Friday of each month and then it takes approximately 10 business days to process and validate the data before it is updated on the website. These dates are estimates; if there are problems with the validation, the process can take longer than expected.  The release schedule is listed here:  http://ai.fmcsa.dot.gov/SMS/InfoCenter/#question5.

How can one of my BASICS move into alert status?

There are two ways a motor carrier can receive an alert in a BASIC.  First, the SMS analyzes a carrier’s on-road safety performance based on the new SMS methodology and that analysis results in a percentile for each BASIC. If the percentile is over the established intervention threshold, the BASIC is at alert and the percentile is presented within an orange outline and displayed in the On-Road column of the SMS. Second, if a serious violation was cited as the result of a carrier investigation within the past 12 months, the BASIC is at alert and the Investigation column displays the “Serious Violation Found” icon.  The alert icon will remain present for 12 months regardless of whether corrective actions have occurred.

How often does an MVR have to be requested for employed drivers?

Carriers must maintain a motor vehicle record for each driver in their Driver Qualification file. The carrier must request each driver’s MVR every 12 months and must keep the record for 3 years.

Can I keep Driver Qualification files and Drug and Alcohol files together?

FMCSAFETY recommends not keeping driver qualification and drug and alcohol files together. All DOT Drug and Alcohol test records must be maintained in a secure location with controlled access (in a separate file under lock and key). FMCSA does not make exceptions for carriers with one driver.

What documents need to be in Driver Qualification file? How long are you required to retain the information in a Driver Qualification file?
  • Driver’s application for employment (§391.21) – retain during employment and for three years after termination
  • State agencies response concerning three-year driving record obtained as part of initial – retain during employment and for three years after termination qualification (§391.23(a)(1) & (b))
  • Record of Road Test form & Certificate of Road Test – retain during employment and for three years after termination or CDL in lieu thereof (§391.31(g))
  • Medical Examiner’s Certificate (§391.43(h)) – may be removed after three years from the execution date
  • State agencies response concerning annual driving record obtained as part of annual review – may be removed after three years from execution date (§391.25(a)&(c))
  • Certificate of Violations (§391.27) / Annual – may be removed after three years from execution date Review of Driving Record (§391.25(b) & (c))
  • Letter granting waiver of physical – may be removed after three years from execution date disqualification (§391.49)
What documents need to be in Drug and Alcohol file? How long are you required to retain the information in a Drug and Alcohol file?
  • Previous pre-employment alcohol and drug – retain per company policy test statement (§40.25(j))
  • Previous employer alcohol and drug test – retain during employment and for three years after termination information (§40.25, 391.23)
  • Drug and alcohol records request – retain per company policy (§40.329, 40.331)
  • Alcohol and drug employee’s certified receipt – retain until two years after driver ceases to perform regulated (§382.601(d)) function
  • Alcohol and/or drug test notification (§382.113) – retain per company policy
  • Drug test results (§40.163)  – retain for five years if result indicates a violation, or one year if negative or canceled
  • Observed behavior reasonable suspicion – retain for two years record (§382.307)
  • USDOT alcohol testing form (§40.225) – retain for five years if result indicates a violation, or one year if negative or canceled
  • Federal drug testing custody – retain for five years if result indicates a violation, or one and control form (§40.45) year if negative or canceled
What are the six authorized types of DOT drug testing situations?

Pre-employment, random drug and alcohol testing, post-accident drug and alcohol testing, reasonable suspicion drug and alcohol testing, return to duty testing, and follow up testing.

What drugs are tested for during a DOT drug test?

DOT drug tests require laboratory testing for the following five classes of drugs: marijuana, cocaine, opiates (opium and codeine derivatives), amphetamines and methamphetamines, and phencyclidine (PCP)

Who is required to have a Drug and Alcohol file?

Motor carriers that operate a vehicle weight of 10,0001 lbs or more, transport at least 8 passengers including the driver, or who transport hazardous materials that require placarding. 

When do you have to do a post-accident Drug and Alcohol test?
  • If there is a fatality
  • Disabling damage to any vehicle involved that requires a tow and the CMV driver receives a citation
  • If an involved party requires transport for medical attention away from the scene (not by request) and the CMV driver receives a citation
How long do you have to do a post-accident Drug/Alcohol test?

A post-accident drug test is required within 32 hours and a breath alcohol test is required within 2 hours from the time of the accident.

If a drug test is not done within 32 hours, what do I do?

If after 32 hours a driver is unable to test, all efforts must cease. The employer must prepare and update a file explaining in detail why the test was not conducted in a timely manner. Document failure to test on your MIS report.

If an alcohol test is not done within 2 hours what do I do?

If a driver is unable to do the test after 8 hours all efforts must cease. The employer must prepare and update a file explaining in detail why the test was not conducted in a timely manner. You must document failure to test on your MIS report.

What happens if you fail or refuse a test?

You fail a drug or alcohol test by testing positive to a drug test or registering a 0.04 or greater alcohol content. Either of these results requires you to be immediately removed from performing safety-sensitive functions such as driving a CMV until successful completion of the return to duty process with a DOT qualified substance abuse professional. Refusing to take a drug or alcohol test must be treated as a positive result.

Why are drivers required to take breaks? What are the FMCSA requirements for breaks?

The HOS rules are in place to minimize driver fatigue and improve safety on our roadways.

  • FMCSA requires CMV drivers take a mandatory 30-minute break after 8 hours of being on duty.
  • CMV drivers may drive a maximum of 11 hours after 10 consecutive hours off duty.
  • CMV drivers may not drive beyond the 14th consecutive hour after coming on duty, following 10 consecutive hours off duty.
When does the ELD mandate go into effect?

The ELD mandate fully goes into effect on December 16, 2019. All vehicles using AOBRDs – Automatic On-Board Recording Devices will be required to electronically track Hours of Service.

Who has to follow Hours-of-Service regulations?

Drivers of Commercial Motor Vehicles

What is a CMV? A CMV is a vehicle that is used as part of a business and is involved in interstate commerce and fits any of these descriptions:

Weighs 10,001 pounds or more, has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more, is designed or used to transport 16 or more passengers (including the driver) not for compensation, is designed or used to transport 9 or more passengers (including the driver) not for compensation, or is transporting hazardous materials in a quantity requiring placards.

What are the 7 CSA BASICs?

Unsafe Driving, Driver Fitness, Drug and Alcohol (Controlled Substances,) Vehicle Maintenance, Crash Indicator, Hours of Service, and Hazmat (hazardous materials compliance)

What does the acronym BASIC stand for?

Behavior Analysis and Safety Improvement Catagories

What is the SMS (Safety Measurement System)?

The SMS assesses motor carrier performance and compliance by organizing data into the BASICs.

Where does the data on SMS come from?

The SMS calculates the amount, severity, and date of violations, inspections, and crashes you have been involved in and assigns a weight to it. The more recent the date, the more weight is given. The SMS groups carriers by BASIC with carriers of similar fleet size with similar safety events (crashes, violations, and inspections.) The SMS ranks the carriers based on their BASICs and assigns them a percentile of 0-100. The higher the percentage score, the worse the safety performance.

How long does data remain on CSA?

CSA Violations and Roadside Inspection Results remain on a carrier’s CSA for 2 years and a driver’s personal CSA for 3 years.

Will violations and crashes stay on the company’s CSA if the driver goes to another company?

Yes