September 13, 2013
WHY YOU NEED TO KNOW YOUR CSA BASIC SCORES
Good CSA BASIC scores will keep the DOT and FMCSA off your back, saving you time, expense and headaches. The DOT uses BASIC (Behavior Analysis and Safety Improvement Category) scores to identify carriers for CSA interventions (Interventions Are Bad). If you are above the threshold in one of the BASIC measures, there is a high probability the DOT is going to get to know you better and make your life more difficult. There are three levels of intervention: Early Contact, Investigation and Follow-on. We’ll go into a bit more detail for each one.
Early Contact means you probably don’t have a huge problem yet, but you are traveling down the wrong path and the DOT wants to know why. Your BASIC scores aren’t too bad yet but you probably have one or more basic scores a little bit above the threshold. The DOT is going to start getting to know you better by doing one of two things or possibly both. They will probably send you a Warning Letter explaining which BASIC you are high in and the possible consequences if your safety problems continue. Here is where the real kicker comes in; they are probably going to target your trucks for extra Roadside Inspections. As you know, that is going to increase downtime with your trucks and drivers as they are sitting at more and more ports regularly getting inspected instead of moving down the road. If you haven’t fixed the violations that caused your high BASIC score and you’re now getting inspected more often, your score is going to continue to get worse and worse and there is a good chance you will be bumped up to the next level of intervention,Investigation.
Investigation means you probably have a really high BASIC score, scores above the threshold in multiple BASIC’s, and/or you have a history of being above the threshold scores. There are three types of investigations, none of which is pleasant. First, is an Offsite Investigation where the carrier is required to submit documents directly to the FMCSA or their State Partner. The requested documents are typically relevant to the BASIC(s) the carrier is scoring poorly in. The second type is an Onsite Focused Investigation, which involves a visit to your place of business where the investigator will review the records related to the carrier’s problem areas. Finally, the third type is the Onsite Comprehensive Investigation. This is the granddaddy of them all, and is a visit to the carrier’s place of business and involves a complete review of the carrier’s records. You’d probably rather go through a root canal.
Follow-on intervention typically occurs after an investigation has been completed and the DOT determines additional steps need to be taken. The DOT has four courses of action they can choose from. They can require the carrier to complete a Cooperative Safety Plan; which is developed in conjunction with the DOT to address the underlying problems resulting from the carrier’s substandard safety performance. The DOT can also give a Notice of Violation, which requires a formal response from the carrier in the form of aCorrective Action Plan (CAP). The CAP explains in detail what the carrier is doing to remedy their safety issues. In my experience, a notice of violation usually results in the carrier’s safety rating being downgraded to Conditional. A Notice of Claim can also be issued when the carrier’s violations are severe enough to warrant a fine, which is usually substantial. Finally, if the DOT determines the carrier’s safety compliance is so egregious that they feel the carrier is a potential hazard to the public, they will place an Operations Out-of-Service Order requiring the carrier to cease all motor vehicle operations.
The bottom line is, an ounce of prevention is worth a pound of cure. Knowing your CSA scores and taking measures to keep them below the threshold will positively impact your business in two main ways. First, doing so will save your trucks time by reducing how often they are pulled aside at ports to be inspected. Second, it will save valuable administrative time needed to prepare for and go through an investigation.
You can check the CSA BASIC scores of any carrier here. In the near future, I will be posting a YouTube video for those of you who don’t know how to log on and check your CSA scores. If you have any questions about CSA feel free to post a comment and I will do my best to answer them.