On average, motor companies regulated by the Department of Transportation paid over $27 million in fines each year with an average fine per case costing a carrier over $5,000.
We hear it all the time, “I need help fixing a bad ‘score’, what do I need to do?”
The problem is the carrier doesn’t understand that there are different scores, they are based on different factors, and there are different ways to improve each type of score.
This article will break down the differences between scores three ‘scores’: CSA, roadside, and audit.
What is a CSA Score?
CSA stands for “Compliance, Safety & Accountability” and the “scores” are really part of the Safety Measurement System (SMS).
These “scores” are laid out in categories based on the FMCSA’s “BASIC system”. BASIC stands for “Behavioral Analysis and Safety Improvement Categories“. Roadside inspection violations, as well as investigation results, fall under 1 of 7 categories, including:
- Unsafe driving – moving and parking violations, such as speeding, improper lane changes, no seatbelt, cell phone/handheld device use, improper parking, etc.
- Crash indicator – DOT reportable crashes (injury, towaway or fatality)
- Hours of Service (HOS) compliance – falsifying your record-of-duty status, inadequate paperwork for ELD, driving, on-duty and rest break violations
- Vehicle maintenance – mechanical issues and not making required repairs
- Controlled substance/alcohol – driving under the influence
- Hazardous materials compliance – unsafe or incorrect handling and/or documentation of hazardous materials, including improper or inadequate placards
- Driver fitness – Unfit to drive due to physical health or lack of training (sickness, no medical card, driving a vehicle you are not qualified to drive (i.e.- tanker with no ‘N’ endorsement, etc.)
Data collected over the last 24 month from crash reports, roadside inspections, and DOT interventions are used to calculate a carrier score. The more recent events are weighted more heavily.
Each time you get a violation, depending on the category and severity of the violation, points are added to your CSA scores, and range from 1 to 10 (less to more severe).
The “safety scale percentages” (CSA scores) in each category are compared to other motor carriers with similar registration information and range from 0 to 100 percent. You want your percentage or CSA score to be as low as possible. For example, a 5% score in “vehicle maintenance” means that your company is safer than 95% of motor carriers on the road.
Each BASIC has an established percentage threshold that, if met or exceeded, will generate a DOT intervention action by first sending you a CSA warning letter.
The SMS system does keep other information available to the public. Things like previous fine history within the last 6 years, Overall Safety Rating (covered in other area), ISS Score, and any critical or acute violations found during an investigation are kept.
How to lower your CSA scores
You can improve your CSA scores by putting a system in place to check the BASICs regularly. Determine what categories you need improvement in and put training in place to improve in those areas.
Roadside inspections with no violations also cause your scores to lower faster. Violations will reduce in “severity” after 6 months, 13 months, and then are removed from your CSA record completely after 2 years.
If your CSA score is low, you can maintain it by hiring drivers with good PSP scores (the FMCSA pre-employment screening program, includes MVR information and all CSA violations a driver has had for 3 years), providing adequate on-board and recurring training, internal inspections, regular preventative vehicle maintenance, using an ELD solution to avoid maintenance violation, and consequences to drivers who receive violations.
What is a Roadside Score?
Did you know that different types of Roadside Inspections can affect multiple categories?
Levels 1 & 2 inspections would cover all of the BASICS whereas Levels 3 & 5 inspections would cover Driver Only or Vehicle Only.
Each category has different metrics in order to determine an overall “score” and Alert Thresholds are given to each category based on either total number of inspections as well as miles per power unit. This way carrier’s are judged as fairly as possible and Owner Operators are not compared to Large Carriers of 200+ Trucks.
To tackle this, let’s walk through rolling up to a weigh station.
When you first roll up:
- Cameras scan the side of your truck to pull your DOT number,
- DOT officer’s computer terminal loads a lot of different information including the ISS score or “Inspection Selection System” rating,
- If the score is bad, the inspector will likely flag the driver for a roadside inspection,
- After going through a roadside audit, the inspector may find violations,
- If violations, and depending on the severity, the inspector could place the driver or vehicle out-of-service (OSS) to have the issue fixed before being allowed to go on the road again, and
- Carrier will be given an audit score of satisfactory, conditional, or unsatisfactory (more on this later)
ISS Inspection Score
This is just one of many tools for inspectors at roadside.
An Inspection Selection System score is given to each carrier which is a combination of all of your BASIC scores and this is used by officers at inspection sites & weight stations to determine who they pull in for inspection along with each officer’s daily “random selection process”.
The ISS makes a pass/inspect recommendation based on the carrier’s previous safety performance or, if insufficient safety data, may inflate the ISS score so the inspector can audit at roadside to gather new safety data.
If an ISS score is elevated this will cause more roadside inspections whereas if it is lower, a carrier’s drivers will not be inspected as frequently.
Generally, unsafe driving, hours of service, driver fitness, controlled substances and alcohol, vehicle maintenance, and hazardous material help determine the ISS score.
- Inspect (score 75-100)
- Optional (score 50-74)
- Pass (score 1-49)
The actual ISS score can be seen through your FMCSA Portal or if you log into SMS with a PIN.
How to improve ISS Score
This is simple.
If you do not have enough safety information, make sure you pass your roadside audit by making sure the driver conducts thorough pre-trip inspections and keeps their hours-of-service clocks in compliance.
If your score is high, and drivers are getting pulled in frequently at roadside, that means you have had a bad inspection or two (or more) in the last 2 years. If inspected, be sure to be in compliance and eventually those bad inspections will fall off the score.
If there is incorrect data in the CSA system, you can often challenge it through the DataQ system to remove it.
What is an Audit Score?
Carriers face a lot of different types of DOT audits, no matter if the audit was done at roadside or not.
For example, a carrier’s roadside scores being elevated into “Alert” status will typically be followed by some sort of intervention by the FMCSA, most often this is going to be an audit of some kind.
While technically not a “score”, the outcome of the audit will be:
- Conditional, or
If the audit or investigation goes poorly and critical or acute violations are discovered, these may “downgrade” a carriers Overall Safety Rating into Conditional or Unsatisfactory.
The problem with a bad audit is that carriers with a Conditional rating receive higher insurance rates, are paid less, get restricted loads from brokers, and good drivers do not apply for work with conditional carriers.
Each time you get a violation, depending on the category and severity of the violation, points are added to your CSA scores, and range from 1 to 10 (more on this shortly).
How to fix a bad audit score
When downgraded to Conditional or Unsatisfactory, carriers will receive a Notice of Claim (see an example) and will need to go through a Safety Rating Upgrade.
A Safety Rating Upgrade is the process of correcting your Conditional or Unsatisfactory Safety Rating by literally upgrading your rating back to Satisfactory.
Conditional: Needs to be addressed ASAP! You can technically still operate, but the FMCSA does want to see the violations corrected. If you fail to correct these, you could receive an unsatisfactory in your next compliance review.
Unsatisfactory: This is Critical! You only have 60 days until you are put OUT OF SERVICE and can no longer operate under your authority. In that time, you need to remedy all the violations from your recent DOT Compliance Review and show proof that you have corrected acute or critical violations.
Our DOT Safety Rating Specialists can help if your DOT Safety Rating was downgraded from Satisfactory/Non-Rated to Unsatisfactory or Conditional.
- First, we look at the compliance review (see an example) from the audit to understand the violations and the documentation that will be required to submit for proof that violations have been corrected.
- Next, your Safety Rating Upgrade specialist will lay out the steps sequentially to follow and work through a corrective action plan, all addressing the acute and critical violations. Documents and files relative to critical and acute violations will be audited and reviewed by a CNS specialist before submitting, ensuring that you will get upgraded on the first try.
- Then, once we are ready to submit, we will send the Safety Rating Upgrade request and Corrective Action Plan to your state and service center to be entered into their queue for review by an FMCSA analyst.
We will do everything we can to get you upgraded, but also suggest our DOT Compliance Programs to stay in good standing with the FMCSA.
Over the past 5 years CNS has upgraded more carriers and submitted more corrective action plans than any other DOT service-based consultant.
Want to challenge a violations? If so, you just need to start the DataQ process!
The DataQ Process is meant to challenge violations that result from things like Roadside Inspections or Accidents where you receive violations that you believe are incorrect.
What will Proactive Safety Management lower my CSA score?
Carriers being proactive will put them in a better position to mitigate risk, improve efficiencies, reduce costs, and spend more time with their drivers in an effort to manage a safe and compliant fleet.
With proactive safety, carriers will be more organized and will have a measured plan to lower motor carrier Safety Measurement System (SMS) scores.
While data and paper management can be crucial, using a third-party partner will help you be prepared for audit representation, provide document storage, and offer up-to-date company policies and handbook of FMCSA rules and regulation changes.
Not only will proactive safety help your fleet with DOT compliance, but it is proven to lower insurance premiums as you will have documented ways to show a reduction in risk.
Our safety management programs are perfect for combining multiple services and can be tailored to fit your needs, whether you are a new owner operator or a seasoned trucker or business owner.
When partnering with a third-party program, your fleet has a team of experts that costs much less than hiring a safety director or team and can receive constant monitoring to keep your operation FMCSA compliant. Driver management will be simplified and the driver hiring process will shorten.
At CNS, our DOT Compliance Programs focus on Proactive Safety Management (PSM), a mindset that will ensure your fleet’s safety and compliance is always in order and ahead of the FMCSA.
Our PSM Motor Carrier Program includes:
- ELD management
- Driver Qualification File Management
- New driver on-boarding
- Driver safety meetings
- CSA score management
- Policies and handbooks
- Vehicle maintenance
- and more