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CSA - Compliance, Safety, Accountability

 

 About CSA - What Is It?

Compliance, Safety, Accountability (CSA) is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce crashes, injuries, and fatalities that are related to commercial motor vehicles. It introduces a new enforcement and compliance model that allows FMCSA and its State Partners to contact a larger number of carriers earlier in order to address safety problems before crashes occur. Rolled out in December 2010, the program establishes a new nationwide system for making the roads safer for motor carriers and the public alike!

In the development of the CSA program, FMCSA sought to incorporate several key attributes.

FLEXIBILITY – Adapt to a Changing Environment. Accommodates changes to the transportation environment, such as evolutions in technology and changes in programmatic responsibilities.

EFFICIENCY – Maximize Use of Resources. Improves Federal and State enforcement staff productivity, as well as the safety performance of members of the motor carrier community.

EFFECTIVENESS – Improve Safety Performance. Identifies behaviors associated with safety risk; focuses compliance, enforcement, and remediation efforts on those unsafe behaviors.

INNOVATION – Leverage Data and Technology. Improves safety through the innovative use of technology to track and update safety performance data.

EQUITABILITY – Be Fair and Unbiased. Assesses and evaluates motor carrier safety and enforces Federal laws and safety regulations to ensure consistent treatment of similarly situated members of the motor carrier community.

Why is CSA Needed

Since the 1970s, Federal and State enforcement agencies in partnership with many other stakeholders have progressively reduced the rate of commercial motor vehicle crashes resulting in injuries or fatalities on our Nation’s highways.

The rate of crash reduction slowed, prompting the Federal Motor Carrier Safety Administration (FMCSA) to take a fresh look at how the agency evaluates the safety of motor carriers and drivers and to explore ways to improve its safety monitoring, evaluation, and intervention processes. Compliance, Safety, Accountability (CSA) is the result of this comprehensive examination.

Limitations of the former Operational Model

FMCSA’s compliance and safety programs improve and promote safety performance and save lives. However, agency resources available for these efforts have remained relatively constant over time, despite increases in the regulated population and additional programmatic responsibilities. Given these constraints, FMCSA has identified limitations in both how safety is measured and how unsafe behaviors, once identified, are corrected.

  • FMCSA’s former compliance review (CR) program was resource-intensive and reached only a small percentage of motor carriers, which made it increasingly difficult to continue to improve motor carrier safety using existing tools.
  • Onsite CRs to determine a motor carrier’s safety fitness required an average of three to four days to complete. At program staffing levels, FMCSA could perform CRs on only a small number of the 700,000 active interstate motor carriers.
  • SafeStat was FMCSA’s former system for measuring safety performance. Though it proved effective, SafeStat grouped safety problems together to identify carriers for a one-size-fits-all CR. Moreover, it did not focus on the behaviors known to cause crashes.
  • The FMCSA Large Truck Crash Causation Study indicated that increased attention should be given to drivers of commercial motor vehicles.

CSA builds on FMCSA’s former processes for assessing and improving the safety performance of motor carriers and drivers through the new Safety Measurement System and a new suite of tools. These include an enhanced CR, in addition to more focused and efficient interventions tailored to address specific problems.

What are the results of the independent evaluation?

The U.S. Department of Transportation's Federal Motor Carrier Safety Administration (FMCSA) released the University of Michigan Transportation Research Institute (UMTRI) independent evaluation of the Compliance, Safety, Accountability (CSA) program’s Operational Model Test (Op-Model Test) on August 31, 2011. UMTRI’s findings confirm that CSA substantially improves FMCSA’s enforcement and compliance model. The results confirm that the CSA model enables FMCSA and its State Partners to contact more commercial motor carriers earlier to correct safety problems and ensure compliance with safety regulations in order to reduce crashes, injuries, and fatalities related to commercial motor vehicles.

Launched in 2008, the CSA Op-Model Test divided motor carriers from four test states (Colorado, Georgia, Missouri, and New Jersey) between test and control groups. UMTRI evaluated the effectiveness of the new Safety Measurement System (SMS) and CSA interventions, and compared the cost and efficiency of the CSA compliance and enforcement model to the previous model. They found effectiveness and efficiency gains that fully support the ongoing national implementation of CSA, as outlined below. FMCSA added additional states, Delaware, Kansas, Maryland, Minnesota, and Montana, to the test to demonstrate full implementation challenges and to provide a validation dataset for evaluation purposes.

CSA’s SMS better identifies motor carriers for safety interventions than the previous SafeStat system.

  • “The results showed that the SMS is a significant improvement over the SafeStat system in identifying unsafe carriers. (p. xiv)”
  • Crash rates were higher for motor carriers identified with safety problems in the SMS’s seven Behavior Analysis and Safety Improvement Categories (BASICs) than for motor carriers that were not identified with safety problems in the seven BASICs.
  • The crash rate for motor carriers that were identified with safety problems by the SMS in the Unsafe Driving BASIC was more than three times greater than the crash rate for motor carriers not identified with any safety problems by SMS.

CSA interventions are effective in improving motor carriers' safety behavior.

  • “The effect of the warning letter intervention is likely one of the most significant findings in this evaluation. (p. xviii)” Twelve months after receiving a warning letter, SMS results showed that 83% of test carriers had resolved identified safety problems and only 17% continued to have safety problems.
  • The new CSA Onsite Focused Investigations proved to be effective. Almost 20% fewer motor carriers continued to show safety problems 12 months after an on-site focused investigation, as compared with those receiving traditional Compliance Reviews (CRs).

CSA interventions use enforcement resources efficiently.

  • More intensive interventions were used on carriers that exhibited higher crash risk confirming that the rules guiding intervention selection are operating to ensure effective and efficient safety interventions.
  • Warning letters, which were found to be very effective in improving safety behavior, had only a nominal cost.
  • CSA Onsite Focused Investigations cost approximately 53 percent less than CRs and were effective in producing compliance.
  • The average cost of CSA interventions was $754 per motor carrier, as compared to $1438 for motor carriers receiving CRs.

CSA reaches more carriers to improve safety compliance.

  • CSA interventions contact approximately three times the number of motor carriers contacted using the previous model which relied primarily on CRs.
  • Among the CSA test group, the annual percentage of motor carriers contacted was 9.9 percent, compared with the 3.2 percent of motor carriers that received full CRs in 2009.

The evaluator identified some areas that require improvement and FMCSA is firmly committed to a continuous improvement process for this very important program.

SMS’s BASICs are significantly related to underlying motor carrier safety, although the Cargo-Related and Driver Fitness BASICs show a weaker relationship to crash risk.

  • The evaluator’s findings are in line with FMCSA’s effectiveness findings; as a result, at the end of the Op-Model Test FMCSA adjusted how it identifies motor carriers for intervention to ensure BASICs with the strongest relationship to future crashes receive the most emphasis. However, FMCSA continues to address motor carriers with patterns of noncompliance in the Cargo-Related and Driver Fitness BASICs, which include carrier requirements for being properly licensed, carrying medical cards to allow verification that a driver meets the medical qualification standards, adequately securing cargo, and properly packaging and handling hazardous materials.
  • As part of its ongoing commitment to continually assess and improve the SMS, FMCSA has a study underway that may result in improvements to some BASICs, with particular effect on the Cargo-Related BASIC.

There was lag time in measureable safety performance improvement after CSA investigations, and for carriers with the most serious safety problems, improvement rates were similar to those of the control group.

  • FMCSA expects the upcoming Safety Fitness Determination rule-making to accelerate return to compliance or removal from service for motor carriers with the worst safety problems.
  • Based on lessons learned in the Op-Model Test, FMCSA improved the CSA investigative process and training in the Safety Management Cycle for its Federal and State Partner investigators. The enhanced investigative process allows investigators to systematically identify motor carriers’ safety problems and to recommend remedies to help carriers to quickly become safer.