CSA scores are a big deal for regulated motor carriers. High CSA scores can lead to increased insurance premiums, lost business, and heightened exposure in highway accident litigation. Keeping your scores as low as possible is important, but how do you do it?
That's the million dollar question. Although the answer is pretty straightforward, it's unfortunately not what most fleets want to hear. Lowering your CSA scores (and keeping them low) takes time and effort. There is no magic wand. There are, however, proven steps you can take to improve your scores, which we'll discuss in this article. Ultimately, the ways you improve your CSA scores are (1) organically over time as you incur fewer or less weighty violations; or (2) through appealing erroneous roadside violations or accidents through the FMCSA's DataQs system.
What are CSA scores & how are they calculated?
Before you can improve your CSA scores, you must first have a handle on what they are and how they are calculated. In another article, we broke down exactly how the FMCSA calculates CSA scores. From a high level, the FMCSA calculates a motor carrier's CSA scores--also known as Safety Measurement System or SMS scores--with data gathered through roadside inspections, crashes, and investigations occurring within the past 24 months. Violations discovered through inspections and/or investigations are assigned to one of seven categories known as BASICs, and then weighted based, in part, on their severity and how recently they occurred. Each carrier's performance is then evaluated against similarly-situated motor carriers in each BASIC, and the carrier is assigned a percentile score in each BASIC. A score of 80% in any category, for example, indicates the carrier is performing worse than 80% of its peers in that particular category.
CSA Score Screenshot
The primary purpose of the CSA and SMS systems is to prioritize carriers for enforcement action. With this in mind, the FMCSA has set "intervention thresholds" for each BASIC. These thresholds are expressed in percentile form, and if a carrier's CSA score exceeds an intervention threshold in a particular BASIC on a given month, the carrier's score will show a warning triangle (see sample above), and the carrier will be at an increased risk for intervention (e.g., warning letter, safety audit, increased number of inspections, civil penalties). The intervention thresholds differ for each BASIC and are based upon whether the carrier hauls hazmat or passengers. Typical thresholds are 65% and 80%.
Carriers with scores in the so-called "alert status" (i.e., above the intervention threshold) are at an increased risk of FMCSA enforcement, typically in the form of an audit or compliance review. And, as noted previously, carriers with high CSA scores tend to have higher insurance premiums and more difficulty landing premium freight. For all these reasons, it's critically important that fleets keep their CSA scores as low as possible. But how??
Improving CSA scores organically
In a prior article, we provided 5 practical tips to help improve your CSA scores. But ultimately, CSA scores improve one of two ways. The first way is organically over time. If CSA scores are a function of the number and types of violations/crashes your fleet has incurred over the past 24 months, then it follows that those scores should improve over time as older violations "fall off" your account and you incur no new ones (or less weighty ones) to take their place. In fact, this is the primary way CSA scores improve. Of course, this is easier said than done.
Despite this being the main way scores improve, it's the one that nobody likes to accept because it takes time and effort. Too often, carriers call us looking for a quick fix. They are losing business and are desperate for a way to improve their scores. Unfortunately, that's just not how this works.
At its root, CSA is designed to identify and punish patterns of non-compliance. And the only way (aside from the DataQs option we discuss below) to right the ship, so to speak, is to eliminate those patterns. To do so, you must first understand what those patterns are and then prioritize them for correction.
For example, let's say I'm a carrier with a high score in the hours-of-service category. In order to fix that score, I need to first understand exactly what is causing that score to be elevated. To do so, I need to understand how to utilize the SMS system and see what drivers are incurring violations and what types of violations they are incurring. Fortunately, SMS is fairly intuitive to use and provides a wealth of helpful data.
Sample HOS Violation Summary from SMS
By simply navigating to the hours-of-service section of my SMS account, I can quickly see what types of violations are weighing most heavily on my HOS score. In the screenshot above, you can see that this particular carriers' drivers are incurring several "record of duty status not current" and "false log" violations. In SMS, I can then take this a step further and see which drivers are causing the most problems.
Sample Inspection Detail in SMS
Once you understand what types of violations are weighing most heavily on your scores and what drivers are causing the most problems, you can start to put together a game plan for addressing these issues and preventing them from reoccurring in the future. This is where the work comes in and so many carriers fail. It does little good to know where you have gaps if you don't take it the next step and earnestly work to fill those gaps.
In short, understanding your deficiencies and then prioritizing them for improvement is how you improve your CSA scores organically over time. As you start to work with drivers who are causing problems and start to fix the underlying issues that are leading to violations roadside, then you will naturally begin to incur fewer of those violations, which, in time, will drive down your scores.
Improving scores through DataQs appeals
I'm often surprised how many carriers either do not know about or do not use the FMCSA's DataQs system. The system exists within the larger CSA/SMS programs and is the exclusive means by which carriers can contest erroneous information or violations that are placed on its SMS account. For example, if you have reason to believe that an officer incorrectly assessed a violation during a roadside inspection, you can file a DataQs appeal of that violation--providing any information/documentation in your possession that supports your case--and, if you are successful, have that violation removed from your scores. Likewise, you can use the system to challenge the preventability of certain types of accidents and potentially have them removed from your scores as well. The DataQs system is free and easy to use, and is available at https://dataqs.fmcsa.dot.gov.
In a prior article, we provided 5 tips for successful DataQs appeals. Sufficed to say, if you are closely watching your SMS data and filing smart and successful DataQs appeals when the situation warrants it, your scores will improve as those violations are removed from your scores.
While there is no magic bullet to improve your CSA scores, there are proven techniques to help lower your scores over time. By keeping careful watch on your roadside inspection and accident data through your SMS account and then taking swift and deliberate action to curb any negative trends that you see, you will naturally keep your scores in check.
If you need assistance analyzing your SMS data and developing a plan to improve your scores, feel free to contact us. Also, if you're interested in comprehensive online training on DOT compliance topics like driver qualification, hours of service, vehicle maintenance, drug/alcohol testing, and more, be sure to check out our library of courses through our Trucksafe Academy.
About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a monthly live show on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who have assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube.