CSA 2010 Gap Analysis

Comprehensive Safety Analysis 2010, CSA 2010, is a Federal Motor Carrier Safety Administration (FMCSA) initiative to improve large truck and bus safety and ultimately reduce commercial motor vehicle (CMV)-related crashes, injuries and fatalities. 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. A good rule of thumb is to take your SafeStat score and add twenty (20) to twenty-five (25) points for an accurate estimation of your CSA 2010 score.

In preparation of CSA 2010 MCB Consulting has developed a Gap Analysis Assessment that will indentify the high risk areas for any organization operating under this new regulation. The assessment will identify and weigh the key factors. This will enable the organization to concentrate and correct the heaviest areas first that will potentially negatively impact their respective score. The seven (7) categories are Unsafe Driving, Fatigued Driving (Hours of Service), Driver Fitness, Controlled Substances, Vehicle Maintenance, Cargo Security, and Crash Indicators.

CSA 2010 BASICs:

  • Unsafe Driving — Operation of commercial motor vehicles (CMVs) by drivers in a dangerous or careless manner. Example Violations: Speeding, reckless driving, improper lane change, and inattention. (FMCSR Parts 392 and 397)
  • Fatigued Driving (Hours-of-Service) — Operation of CMVs by drivers who are ill, fatigued, or in non-compliance with the Hours-of-Service (HOS) regulations. This BASIC includes violations of regulations pertaining to logbooks as they relate to HOS requirements and the management of CMV driver fatigue. Example Violations: HOS, logbook, and operating a CMV while ill or fatigued. (FMCSR Parts 392 and 395)
  • Driver Fitness — Operation of CMVs by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualifications. Example Violations: Failure to have a valid and appropriate commercial driver’s license and being medically unqualified to operate a CMV. (FMCSR Parts 383 and 391)
  • Controlled Substances/Alcohol — Operation of CMVs by drivers who are impaired due to alcohol, illegal drugs, and misuse of prescription or over-the-counter medications. Example Violations: Use or possession of controlled substances/alcohol. (FMCSR Parts 382 and 392)
  • Vehicle Maintenance — Failure to properly maintain a CMV. Example Violations: Brakes, lights, and other mechanical defects, and failure to make required repairs. (FMCSR Parts 393 and 396)
  • Cargo-Related — Failure to properly prevent shifting loads, spilled or dropped cargo, overloading, and unsafe handling of hazardous materials on a CMV. Example Violations: Improper load securement, cargo retention, size and weight, and hazardous material handling. (FMCSR Parts 392, 393, 397 and HM Violations)
  • Crash Indicator— Histories or patterns of high crash involvement, including frequency and severity. It is based on information from State-reported crashes.

A carrier’s measurement for each BASIC depends on:

  • The number of adverse safety events (violations related to that BASIC or crashes)
  • The severity of violations or crashes
  • When the adverse safety events occurred (more recent events are weighted more heavily).

After a measurement is determined, the carrier is then placed in a peer group (e.g., other carriers with similar numbers of inspections). Percentiles from 0 to 100 are then determined by comparing the BASIC measurements of the carrier to the measurements of other carriers in the peer group. CSA scores follow the same format as golf, the lower the score the better, however, there is no handicap.

The enactment of CSA 2010 will in due time turn the transportation industry on its proverbial head and change the way the industry does business. It will play out like any other new regulation that has come down the pike. It’s much like sports, you play against good competition and you as well as your competition both improve. The transportation industry is a leading economic indicator so good transportation companies must have a nibble business plan to enable them to change with the shift of the economy. Those who didn’t with the recent economic down turn went out of business and will become part of organizations that did survive. Hence, everyone gets better. The enactment of CSA 2010 will mirror this impact on the weak players in the industry; they will either adapt or go out of business. As previously mentioned the good companies are already adapting their business operations to comply with new regulations. Like any change initiative, some things they try will work and some won’t but at least they are trying. Many managers in the transportation don’t understand that it costs much less to comply then not to comply and low maintenance costs, good drivers, and sound equipment are not mutually exclusive. CSA 2010 will increase driver’s wages, and it will have a negative impact on the driver shortage. However, the enactment of the regulations will entice more drivers into the field due to better working conditions. To proactively prepare for CSA 2010 let MCB Consulting assess you operations and determine the areas for improvement as well as cost reductions that will mitigate your risk and prevent FMCSA intervention.


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