Compliance, Safety and Accountability (CSA)
Compliance, Safety and Accountability (CSA) is the most recent way the FMCSA has established to determine if a carrier is meeting the requirements to be compliant under the FMCSRs. While older programs attempted to establish a carrier’s compliance, the older systems left out the most important variable in the process, the driver. CSA now has features which not only affect the carrier but also drivers who are operating for a carrier.
CSA has two distinct areas which focus on the carrier’s ability to comply with the FMCSRs. One is roadside inspections and the other is reportable accidents.
Accidents: A reportable accident is one where there has been (a) a fatality, (b)an injury where at least one person involved in the accident has been transported away from the scene to receive medical treatment or (C) any vehicle involved in the accident that must be towed from the scene because it is inoperable. While this accountability of an accident might seem to be unfair, it has been a long standing policy for any reportable accident involving a commercial motor vehicle (CMV) to be considered a factor in CSA, even if the accident was not the fault of the CMV driver. Later, during a Focused Review or Compliance Review, if the State FMCSA Federal Programs manager determines the accident was not the fault of the driver, the accident may be removed from any further consideration by the FMCSA. However, once a Federal investigation has begun the review, the review will continue.
Roadside Inspections: The other factor which puts CSA in effect is roadside inspections performed by authorized and certified enforcement personnel. Violations discovered during roadside inspections can be devastating to a carrier, especially if they contain violations which may place the driver Out-of-Service or may involve violations which are considered extremely dangerous to the public, such as texting, using a cell phone or violating the HOS rules and regulations.
Each violation discovered is normally assessed points and those points add up. There is also a multiplier factor which is attached to these points. An inspection conducted today has a multiplier of 3 which remains for 6 months. The factor is reduced to 2 is from 6 months to a year and a half and a factor of 1 for assessed for the final six months. After 24 months on the CSA roadside inspection report, the inspection is removed and the inspection points are eliminated.
There are seven different categories which CSA addresses for roadside inspections. Any category which exceeds the percentage threshold will cause a yellow triangle to appear above that category. A yellow triangle is something no carrier wants. Two categories with triangles above them will cause the FMCSA to take a long look at your operation to determine why you are having so much trouble trying to comply with the FMCSRs. A triangle above three or more categories will usually cause a Focused or Compliance review by an investigator. The results of reviews of this kind can cause the carrier to be required to pay enormous fines or be placed Out-of-Service until compliance can be assured.
ITI can help you become compliant. Our consultants are retired from enforcement and understand the accident and roadside inspection processes. If you believe you as a carrier are having trouble maintaining compliance, let ITI come in and review your programs and determine what new policies or procedures need to be implemented. This avenue is a much more desirable path and gives the carrier time to do things right and become compliant.