FMCSA Proposes New CSA Changes

On June 29th, the FMCSA unveiled its proposed changes to the Compliance, Safety, Accountability (CSA) program. The purpose of these proposed changes is to "better reflect the seriousness of the crash risk associated with vehicle maintenance issues." Essentially, the FMCSA is seeking to ensure its safety rating categories intervention thresholds more closely correlate with actual crash risks.

The goal of the proposed Safety Measurement Systems (SMS) changes is to improve prioritization and intercede with motor carriers who present the highest safety risk. After analyzing the correlation of each BASIC as compared to crash risk, the FMCSA has created three levels of crash risk correlation:

• High: Unsafe Driving, Crash Indicator, Hours-of-Service (HOS) Compliance
• Medium: Vehicle Maintenance
• Low: Controlled Substances/Alcohol, HM Compliance, and Driver Fitness

While the proposal would keep in place the current threshold of 65% for the "High" level BASICs, it would lower the "Medium" (Vehicle Maintenance) Basic from 80% to 75%. This would result in a new group of carriers receiving warning letters to address issues of non-compliance before crashes happen. In addition, the "Low" level BASICs would rise from the current 80% to 90%.

Other Proposed Changes

An additional section of the proposal addresses concerns raised by industry stakeholders regarding the Hazmat Compliance BASIC. Previously large non-cargo-tank hazmat carriers have had difficulty improving their HM Compliance BASIC because they were being compared to cargo tank HM carriers. After examining the possibility of breaking down HM Compliance by business type, the FMCSA discovered that among cargo tank carriers, cargo tanks make up most of their inspections. Since non-cargo-tank carriers don't have cargo tanks, they often receive different violations than those who do have cargo tanks. With these differences in mind, the FMCSA is proposing to segment the HM Compliance BASIC to reflect these inherent differences, thus improving the SMS's ability to more accurately address safety issues among cargo-tank and non-cargo-tank carriers.

The FMCSA also proposed additional changes to the SMS including increasing the maximum Vehicle Miles Travelled used in the Utilization Factor to precisely reflect the operations of high-utilization carriers and reclassifying violations for operating while out-of-service. This proposed change would move OOS violations to the Unsafe Driving BASIC rather than the Underlying OOS violation BASIC.

You may review and submit feedback on the FMCSA's proposed SMS edits in the Federal Register Notice within the 30-day feedback period (ending July 29, 2015). After that date, the FMCSA will preview the recommended edits in a second Federal Register Notice.