A R T I C L E S E R I E S

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1 Comprehensive Safety Analysis Initiative A R T I C L E S E R I E S BASIC 1: UNSAFE DRIVING Staying on top of safety and compliance under the CSA 2010 initiative will mean getting back to the BASICs. This synopsis will focus on the Unsafe Driving BASIC. Unsafe driving practices will lead to commercial motor vehicle (CMV) accidents. Reckless driving, speeding, failing to yield the right-of-way, and other violations are closely related to a driver s risk of getting into a crash. In fact, drivers issued a violation for driving recklessly are 325% more likely to be involved in a future crash. That s why the Federal Motor Carrier Safety Administration (FMCSA) places so much emphasis on unsafe driving under its Comprehensive Safety Analysis (CSA) 2010 program. The CSA 2010 initiative is designed to monitor driver and motor carrier safety performance and stop unsafe behaviors before they result in a crash. Unsafe driving is seen as such a major contributor to crashes that unsafe driving violations alone can lead to a carrier or driver being deemed unfit to operate. To survive and thrive in 2010 and beyond, it s important to understand how unfit driving fits into the CSA 2010 puzzle. What is Unsafe Driving? The FMCSA defines unsafe driving as operating a CMV in a dangerous or careless manner, comprising 36 distinct violations. Among them: Speeding or reckless driving Improper lane changes Inattention Using a radar detector Operating a bus unsafely Smoking within 25 of a hazmat vehicle Your performance on unsafe driving is measured using violations of certain Federal Motor Carrier Safety Regulations and state traffic control laws recorded on roadside inspection reports. A violation can be logged even if a citation or ticket is not issued even if the violation simply appears on the inspection report and even if the driver is not placed out of service. Unsafe driving violations are entered into the FMCSA s Safety Measurement System (SMS), which is the agency s replacement for the current SafeStat system. The SMS is used to grade both carrier and driver performance on unsafe driving and the other BASICs. Unsafe driving violations that may have had a minimal effect on your safety rating in SafeStat may have a huge effect on your rating in the new SMS, and may lead to contact from the FMCSA. Just the BASICs Unsafe driving is one of seven violation categories in which your company and drivers will be graded under CSA The seven Behavioral Analysis and Safety Improvement Categories, or BASICs: Unsafe Driving Fatigued Driving Driver Fitness Drugs & Alcohol Vehicle Maintenance Cargo & Hazmat Crash History x

2 How Do You Measure Up? Unsafe driving violations are used to grade your performance in the unsafe driving BASIC, which contributes to your overall safety rating. Carriers and drivers with the poorest grades relative to their peers become the targets of the FMCSA s intervention process, in which the agency takes action to try to correct the unsafe behaviors and prevent crashes. Here s the process used to figure out how you measure up in the unsafe driving BASIC: 1 2 Every 30 days, all of your unsafe driving violations from the past 24 months will be assigned a severity, from 1 to 10, based on how likely the violation is to result in a crash. A severity of 1 represents the lowest crash risk, and 10 the highest, relative to other violations within each BASIC. For example, reckless driving is assigned the highest severity while failing to wear a seatbelt scores a 1 (see accompanying table). The severity of each of a carrier s unsafe driving violations is multiplied by a 1, 2, or 3 depending on its age. If the violation was within the past 6 months, it gets a weight of 3; within 6-12 months, a weight of 2, and within months, a weight of 1. The result: violations recorded within the last 6 months are three times as damaging to a carrier s grade as violations recorded between 12 and 24 months ago. The older the violation, the less weight it carries. PERFORMANCE GRADING EXAMPLE ABC Trucking had four inspections in the past two years. Among the violations found was one for reckless driving (severity = 10) and one for using a radar detector (severity = 5). The reckless driving violation was committed last month, so the severity of 10 gets increased by a factor of 3, making it 30. The radar detector violation was 18 months ago, so the severity is not increased due to age; it remains as a 5. The total weighted severity is 35. The company had an average of 3 power units over the past 18 months, so their unsafe driving measure is 35 3, or By itself, this raw score means little until it is compared to the scores of other carriers (see below). 3 Example of Unsafe Driving Violations by Severity VIOLATION SECTION SEVERITY Reckless driving Failing to obey a traffic control device Following too close Improper lane change Improper passing Speeding Improper turn Failing to yield right of way Scheduling a run that requires speeding Failing to stop at a railroad crossing when required Failing to use caution for a hazardous conditions Using or equipping a CMV with a radar detector (a) 5 Failing to use a seat belt Failing to use hazard warning flashers (a) 1 Transporting unauthorized passengers (a) 1 The above violations were cited almost 355,000 times in 2008, or about 15% of all traffic enforcement violations cited. To account for each carrier s size, the total violation severity is divided by the average number of power units the carrier had in the past 18 months. That way, a small carrier with a lot of violations, for example, will score worse than a large carrier with the same number of violations. The average number of power units is calculated using data you supply to the FMCSA on the MCS-150 / MCS-151 forms. Drivers are graded in a similar way except that violations from the past 36 months are included, and there is no adjustment for company size. The Ranking Process Your unsafe driving measure is not your final grade. Rather, the measure is used to judge you against other carriers of similar size to determine your percentile in terms of unsafe driving. Think of it as being graded on a curve, where the best-performing carriers (no matter how good or bad they actually are) automatically get an A+ and x

3 the worst-performing get an automatic F. The difference with CSA 2010, however, is that the highest score is 0% and the lowest is 100%, with everyone else somewhere in between. For example, if your unsafe driving percentile is 60%, it means you ve demonstrated worse performance on unsafe driving than 60 percent of your peers. If you ve received fewer than three inspections in the past 24 months with at least one unsafe driving violation per inspection, OR if your unsafe driving violations are all older than 12 months, then you are off the hook for this BASIC. That is, you will not receive a percentile on your unsafe driving performance..a high percentile in unsafe driving could have two consequences: 1 If your percentile is above the threshold for an intervention (i.e., your performance is marginal ), then the intervention process will begin, with a focus on unsafe driving. For example, depending on your percentile, you might be the target of: A warning letter, informing you of a poor score in unsafe driving and what you need to do better (you would also be instructed on how to challenge any incorrect data); Increased roadside inspections that target unsafe driving An on-site audit that targets your problems with unsafe driving. For Helpful Guidance on CSA 2010 Preparation, call J. J. Keller Business Services Note that carriers who may have good scores under the current SafeStat system could find themselves on the intervention list under CSA 2010, because each BASIC is scored separately x 2010 FLEET TECHNOLOGY OUTSOURCE SERVICES ADVISEMENT & TRAINING Don t wait for FMCSA enforcement. Getting your records organized now will make a difference. We can help. 2 If your percentile places you into the failing category for unsafe driving, you may automatically be deemed unfit to continue operating commercial motor vehicles. That s because unfit driving is a stand-alone BASIC, meaning that if you receive a failing grade in the unsafe driving BASIC alone, you will receive an overall failing grade as a company. For most other BASICs, you need a failing grade on two or more BASIC categories to receive an overall failing grade. Interventions Once a carrier s percentile in the unsafe driving BASIC is high enough to exceed the thresholds set by the FMCSA, the company and/or drivers could be subject to an FMCSA intervention. Carrier interventions increase in severity as follows: 1 warning letter 2 targeted roadside inspection 3 off-site investigation 4 focused on-site investigation 5 cooperative safety plan 6 notice of violation 7 comprehensive on-site investigation 8 notice of claim/settlement agreement 9 unfit suspension x

4 INTERVENTION REVIEW Intervention #1: The Warning Letter The warning letter is sent to a motor carrier when safety performance data exceeds the threshold for intervention in one or more BASICs. The letter advises the carrier of the apparent safety problems, and the potential consequences of continued operation in that way. It also refers the motor carrier to online educational tools and information for self improvement, along with instructions on how to challenge safety data if the motor carrier believes it is in error. ARE YOU PREPARED? Your score on unsafe driving and the consequences of a failing grade will be based on data that is being collected today. Now is the time to make compliance a priority and put safety management controls in place that will help prevent unsafe driving. Here are some key points to keep in mind: Because unsafe driving is a stand-alone BASIC, it s important to focus on the violations that could hurt the most, both for the company and for individual drivers. Figure out where your drivers stand on the unsafe driving BASIC and train appropriately. Remember: violations will affect drivers scores for 3 years, and the company s for 2 years. The passage of time will decrease the impact of the oldest violations. Organize and track all safety data, so you understand your level of exposure. All violations noted in roadside inspection reports will count, not just the ones that place a driver out of service. Begin tracking all moving and roadside violations, along with near misses, to identify possible trends and improvement opportunities by driver and vehicle. Make sure the FMCSA has accurate data! Get in the habit of keeping your MCS-150 / MCS-151 form up to date (you don t have to wait for the two-year filing cycle), and verify that the violations assigned to your company are actually yours. Use the FMCSA Portal system ( to review your data. The fewer the violations and the more clean inspections you have, the better your score and/or the better the chance that you won t be graded at all. Have your drivers ask for documentation of all clean inspections, to ensure that they get recorded. In some cases, clean inspections can significantly improve your scores! Use refresher and new-driver training programs to help prevent unsafe driving and its consequences. Be proactive! Use the right tools and resources to understand your exposure to risk and unsafe practices x

5 Comprehensive Safety Analysis Initiative The BASICs Unsafe Driving The operation of CMVs in a dangerous or careless manner. Examples: speeding, reckless driving, improper lane change, inattention. Fatigued Driving The operation of CMVs by drivers in non-compliance with the hours of service regulations. Examples: violation of the driving limit, driving while fatigued, failing to maintain complete and accurate logs. Driver Fitness The operation of CMVs by drivers who are unfit to operate a CMV due to lack of training or medical qualifications. Examples: failure to have a valid license, being medically unqualified. Drugs and Alcohol The operation of CMVs by drivers who are in possession of alcohol or illegal drugs, or impaired due to alcohol, illegal drugs, or misuse of prescription or over-the - counter medications. Examples: the use or possession of drugs or alcohol. Vehicle Maintenance CMV failure due to improper or inadequate maintenance. Examples: defective brakes or lights, failure to make required repairs. Improper Loading/Cargo Securement CMV incidents resulting from shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. Examples: improper load securement, cargo retention, and hazardous material handling. Crash Histories or patterns of crash involvement, including frequency and severity, based on information from state-reported crashes. Safe & Smart Driver Training Our popular on-site training helps drivers improve skills, be prepared for roadside inspections and reduce accidents! Hands-on, high energy training and your location! Led by experienced transportation professionals! Driver Attitude stress management, goal setting Hazard Perception speed & space management, reaction time, scanning techniques Driving Skills turning & backing, merging, intersections Defensive Driving habits, distractions, road rage Roadside inspections know how to prepare More! J. J. Keller Business Services x Crash history is not specifically a behavior. Rather, it is a consequence of a behavior and may indicate a problem with the entity that warrants intervention. FMCSA Safety Measurement System Methodology Version 1.2 April, x

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