CSA Score Success Strategies
Below is a full transcription of our popular webinar on maintaining a strong CSA Score called, “CSA Success Strategies: How to Stay Off the FMCSA’s Radar by Maintaining a Low CSA Score.”
Hi, welcome to Foley’s webinar on “CSA Score Success Strategies.” We have some folks that are still joining us, so we’ll give them a couple more seconds if you don’t mind, for some folks to jump in, but we’ll get started here shortly. Thanks.
Well, it looks like it’s slowing down, so everybody seems to be in. We’ve got a bunch of people. Thanks for joining us today. I see a lot of names that I recognize. So it’s nice to have you back and certainly welcome to everybody who’s joining us for the first time or joining me for the first time to do one of these.
As you know, today’s session is going to be on CSA Score Success Strategies, and as you see there in the subtitle, it’s very appropriate – how to stay off the FMCSA’s radar – by maintaining a low CSA score. This is what we’re going to cover here today.
My name is Steven Harz, and at Foley, I am an enterprise compliance consultant. I’ve been here for about a half a dozen years or so. I have worked with some of you before, and it is great to see you folks here. Hopefully, I will get a chance to work with some more of you down the road. What we do is work with all manners of driver compliance, whether it’s driver files, drug testing, physicals monitoring, what have you. So, we are very familiar with our topic today and have assisted a lot of folks with it over the years.
About Your CSA Score: What is Your CSA Score?
I want to start off with just getting into what your CSA score actually is. Some folks are very knowledgeable on this. Some folks are still a little curious about the ins and the outs, so that might be why some of you have joined us here today. The CSA score is a very important thing within DOT compliance. It stands for compliance, safety, and accountability, which says it all. And it is used to ensure that you are operating a program that is both safe and compliant with the DOT. Also, as you can see, there are a few things that make up your CSA score. It’s safety measurement system interventions and then a safety fitness component as well. So, we’ll get into these things as we move along here today.
How the Score is Measured
The score is measured or gathered from a few different components. Roadside inspections are a very big part of this, crash reports are too – we’ll spend a little more time later on this too. They’ve always carried weight, but they seem to be carrying a lot more weight recently than they had in the past. And then of course, there’s always information gathered from audits, whether they’re onsite audits or the new offsite audits. So, these are the things that make up your score. And as you can see down at the bottom, violation data that is gathered from these areas are organized into seven categories that the FMCSA calls BASICS.
The Behavior Analysis and Safety Improvement Categories (BASICS)
BASICS stands for Behavior Analysis and Safety Improvement Categories, so that’s what we’ll get into here in a bit. These are the seven things that make up the BASICS process: unsafe driving, crashes – as we talked about before – hours of service, maintenance, which is obviously important as well, substance abuse, things having to do with carrying hazmat, and then also driver fitness is a very big important topic as well. These are the things that we’ll expand upon as we go through this session today.
How Are CSA Scores Calculated?
As far as how the scores are compiled, again, violations and crash data are a big part of it. They’re really paying a lot of attention to crash data. Again, as I said before, they always have, but it seems to have ramped up quite a bit. The data is grouped by category within BASIC. Again, we saw them on the prior slide; we’ll get into them a little bit more. This information is available to enforcement officials, certainly it’s available to you as well, and they’ll ask you to use it to make yourselves comply better.
How Is CSA Score Date Used?
So with that being said; how’s the information used? Obviously, you want to keep a low score; the higher the score that you have, the more likely that you’ll be flagged for an intervention. And with regard to the interventions themselves, there are many forms of intervention; again, these help you comply with various safety requirements put forth by the FMCSA or the DOT. The process is really meant to determine why safety issues arise and to suggest ways to fix them. So you’ll want to use this information to see if there’s a pattern of violations that you have, or your drivers have. We mentioned crashes a couple of times. Is there any commonality among the crashes that you’ve had? Hopefully, you haven’t had any, but if you have: Is there any pattern, and if there’s a pattern, maybe use that pattern to help fix this from occurring in the future.
Interventions also encourage corrective action, and stiff penalties will be enacted for companies that don’t comply. That’s just flat out how it is. But again, if you meet the threshold for intervention, that little symbol will appear on your CSA score. And if it’s an acute or critical violation, it’s definitely going to be there. Getting into what these mean, I’ll give you a couple examples of acute violations and then critical ones. Acute violations – one of the big ones is companies that fail to implement a drug and alcohol testing program. One of the others is kind of piggybacked on this; it’s a company that doesn’t have a random program in place. Another acute violation is allowing a driver to operate with a license that’s suspended or revoked. This happens a lot. One other acute violation would be allowing a new driver to get behind the wheel prior to getting back the results of their pre-employment drug test. So, those are examples of acute violations.
Critical violations – using a driver that has multiple licenses, not making inquiries into employment records, or the results of these inquiries aren’t housed in their driver qualification file; maybe doing randoms, but not doing them at an applicable annual rate. These are things that would fall into a critical violation. And I have to correct myself. I mentioned using a driver before their pre-employment test comes back. That’s actually a critical violation, not an acute one, I apologize. So anyway, these are things that you want to steer clear of, obviously. You can go on to the DOT website and get the complete list of these acute violations and critical violations. I believe there’s a section on the website for that if I’m not mistaken.
A High CSA Score = Increase Audit Risk
I kind of referenced this before; a high score equals an increased risk for an audit – this goes without saying. We’ll also get into here, momentarily, the surprise enforcement events that occurred last year, and I’m sure are going to occur this year. And again, companies with issues are the companies that were subjective to these surprise events.
The Impact of a High CSA Score: A Push for Safety
Obviously, we want to go into what impacts the safety score has, so that you have a better chance of keeping it low. First of all, the reason for it – a huge push for companies to run a safer program and for drivers to operate more safely. With the industry, there’s a current push to improve the safety and compliance of any operator or company. They really want to take any unfit company off the road, and drivers as well. I mean, we’ve seen a push with that with things like the Clearinghouse; and not too long ago, a number of companies that were in danger of an intervention were sent warning letters. Hopefully no one here on this session had received those, but that was part of the processor or the beginning of this enforcement or greater enforcement situation.
Another Surprise Blitz
A minute ago, we talked about the surprise blitz that happened last year. Over a course of about seven weeks, the FMCSA contacted a lot of companies that they deemed to be unsafe. They were selected based on past history, large numbers of crashes, and a lot of drivers that were operating in an unsafe manner. These events were conducted both onsite, and most of them were done in an offsite fashion, which also created an issue for companies, because we still find a lot of companies out there have a paper compliance driver file process. If that’s the case, it’s going to be awfully hard to comply with the digital offsite audit. On top of being targeted for running a program that might not be as safe as it needs to be, it was compounded by having a paper process, so they’re not messing around.
1 in 3 carriers audited during the blitz were given a safety rating downgrade
During these audits, during the blitz, one in three carriers were given a rating downgrade. Makes sense. They were deemed to be unfit as it is, so it would stand to reason that you’d have a high percentage of them that would have their score further lessened.
Why Safety Ratings Matter
For safety ratings themselves, there are a number of reasons that you want to be able to keep your rating in an appropriate manner; the main thing is, if you do get into trouble, if you are deemed unfit, if you have an unsatisfactory rating, it takes a long time to dig out of that hole. It’s a tough process, and it’s not a guarantee that you will. There’s a department here within Foley that works with companies on corrective action, and we will always tell them, we will work our darndest, but it’s not a guarantee. So obviously, you certainly want to make sure that you keep your score at an acceptable level.
Other things that you want to keep in mind: CSA scores are used to determine what an insurance rate would be. Also, it may be hard to find customers if your CSA score is low. So, there are many things to keep in mind with this whole CSA score situation. Nice little quote here: “Certainly a solid program that allows you to keep an appropriate CSA score also means you’re going to be audit ready as well.”
The Basics of the CSA BASICS
Basics of BASICS. I mentioned before, we saw the seven bullet points with the different programs or the different aspects that make up BASICS. We’ll go through them a little bit more in depth. I will point out at this point in time that our marketing group does a great job. You’ll probably get a follow up after this session, and it may include a link to this presentation. There’s going to be information on the coming screens, specifically the last bullet point where there’s record-keeping requirements. These are really important, and these are things that you want to make sure that you have kept track of, so that if you are subjected to a surprise blitz event, or you are called for an audit, you have these things in place.
So, we will get you the link to this, and you can go and take these down at that point in time. You can do it now, obviously too, but I wanted to point that out to you. I should also point out too, if you have any questions, throw them in the chat, I’ll try to get to a couple at the end of the session. In other sessions that I’ve done like this, I couldn’t get to all of them, but I’ll try to pick out a few that maybe are recurring. Other than that, we will get back to everybody’s question after the event, so don’t worry about that if I don’t get to yours at the end of the session.
#1: Vehicle Maintenance
So, vehicle maintenance – again, a big part of the compliance process. I think, based on conversations that I have, sometimes it’s overlooked. So obviously, it’s something that you want to make sure your drivers are on top of, you as a company are on top of, and your maintenance department is on top of.
#2: Unsafe Driving
Next would be unsafe driving. And this is just basic – unsafe driving is unsafe driving. So speeding, driving recklessly, and texting and driving which is gigantic one that will heavily impact your score if your drivers are caught doing that. So again, we reference patterns of behavior. If you see patterns in the driving, some commonality in what the violations are, often that’s an easy way to fix it. If you see texting and driving a lot, that’s an easy one to fix; you know what you’re going after, and the same goes for speeding, etc. At the bottom, you see the various recordkeeping items.
#3: Crash Indicator
We’ve touched upon this a couple of times. They’re going to look at any type of crash history. I’ve referenced patterns. If there’s some commonality in any type of crashes that you or folks have had, you want to try to mitigate that as quickly as possible. There’s an important note at the bottom to do with your MCS-150 biennial update; make sure that that’s up to date too.
#4: Hazardous Materials Compliance
Hazmat compliance – now, not everybody who is DOT regulated is hauling hazardous materials, obviously, but for those who are, it’s a big deal. Drivers need to be educated; they need to have their hazmat endorsement. We do sometimes see drivers pulling hazmat that don’t have the endorsement; obviously that is going to weigh heavily on your score in a negative fashion. And you want to make sure the drivers understand what it is that they’re carrying, what the material is; so if there is a leak, a spill, a crash, what have you, they can lend a hand to first responders. I’ll give you an example from my own experience. When I’m not here at Foley, I’m a firefighter. And we certainly go to our share of hazmat incidents. Sometimes, it’s simple, a motor vehicle accident. It’s gasoline. We know what it is, or its antifreeze, etc. However, we also have a highway that runs through our town, and we will have some larger hazmat situations. There have been times that the driver was helpful, letting us know what it was, and had their data sheets available. It always made the situation, which was bad in and of itself, not quite as horrible. So, drivers really have to be knowledgeable with that. You have to make sure that they’re actually allowed to be pulling hazmat.
#5: Driver Fitness
Next is driver fitness. The driver needs to be healthy enough to do this job; they have to be physically qualified. Obviously, they’ve got to, at least every two years, if not more frequently, have their physicals. And I do want to point out the record keeping requirement here on this slide because we see that this is oftentimes missing. You want to make sure that the meds cert is in the driver file, and it is up to date. One of the things that we do here at Foley when we bring on a new client is we take their current driver files and import them onto our driver compliance portal. And I can’t tell you the number of times that we get the med card and the driver’s license for that matter, and they’re already expired before they get to us. This is critical because in the last 18 to 24 months, this is one of the big things that the DOT or the FMCSA have been cracking down on; folks operating with licenses or med cards that are already expired, and also licenses that are in the wrong class do fall into that as well.
#6: Controlled Substances/Alcohol
Controlled substances are certainly an issue – one of the reasons we now have to comply with the DOT Clearinghouse. You certainly want to make sure that your drivers understand the situation. To me, one of the bigger things in the last few years that’s popped up is the use of CBD products, and the fact that in many States now marijuana is legal to use. Drivers have been warned about CBD products. And even if the label says, hey, there’s no THC in this, don’t believe it because many drivers have taken CBD products, usually for joint pain or things like that, and then have been dinged at a drug test because it actually did have THC in it, and now they’ve failed a drug test.
The other thing, and I get conversations like this once in a while, is folks not understanding the marijuana situation. Thinking, well, hey, I’m in Massachusetts or here in Connecticut where I am or Colorado or wherever. And the assumption is because marijuana is legal in a State where the driver is, is that either the company, or the driver, or both think that it’s okay to use marijuana. And that’s not the case. We have to remember that you and the drivers are under US regulations, not State regulations, and at a federal level, marijuana is illegal so you cannot use it. Sometimes, it’s confusing for folks, but you want to make sure that your drivers are aware of that.
#7: Hours of Service
Hours of service is another big one. Obviously, we had a bump in this a few years ago, but it is still in play. You just want to make sure that, again, the drivers understand what their requirement is as it pertains to hours of service, and they have to keep their record of duty status up to date and accurate. It’s not anything new, but it is a critical part of this.
Violations Will Negatively Impact Your SMS Results for 24 months: Improving Your Score
I referenced this a bit ago. You have a violation; you have an impact to your safety management results; it is going to haunt you for quite some time. Let’s get into maybe what it is that we can do to improve a score.
Hire Safe & Experienced Drivers
First thing, driver hiring. You want to make sure that you hire safe drivers and experienced drivers. I mean, this is not rocket science, I know. However, we have found that this practice, in and of itself, will assist quite a bit. What else can you do? Hair follicle testing. It’s certainly going to catch a lot more incidents of drug use. The next two bullet points, a CDLIS or a PSP, cover this, although not required by the DOT. When I’m working with clients, whether current or new ones here at Foley, I’m always discussing this with them. It is a very good way to ensure that the driver is operating or has operated safely. And as you can see down at the bottom, companies that use a PSP have 17%, fewer incidents, and 8% fewer crashes than a company that just runs an MVR. It’s cheap, it’s easy to do, and you can find a lot of good or bad, I guess, depending upon how you look at it, information on the driver that will be critical to assisting you down the road with your safety score.
Monitor Drivers’ MVRs
MVR monitoring – many of you I’m sure are familiar with this. I’m sure a lot of you do it already. We’ve been doing it here at Foley for, I don’t know, five years, maybe a little bit more than that. And just like the CDLIS and the PSP, it’s a relatively inexpensive way to ensure that your drivers are operating safely. Certainly, if you’re just using an MVR alone and you ran a driver’s MVR today and he had a DUI tomorrow, you’re not going to find that out for 364 days. But with monitoring, as soon as that infraction hits the State’s system, you’ll know about it. So, it is something that you may want to consider. Sometimes, an insurance carrier will even provide a discount to you if your drivers are enrolled. So if you are doing motor vehicle report monitoring now; it might be worth making a phone call to your insurance company. I’m not telling you that they’re going to give you a discount, but it certainly does occur, so it’s probably worth making that call just to see. We even have people call us here at Foley because their insurance company has told them they have to enroll their people in motor vehicle report and monitoring programs; sot is a great tool. With what we do here at Foley, we’ll find any change in the status of their license, whether it’s driving-related or non-driving related. As you can see at the bottom of the screen, 34% of common violations can be prevented with this type of program. So this is something, that if you’re not doing, is certainly worth looking into.
Automate Your Compliance
Other items that will assist with the process, assist with your score – automating your compliance program. There are still folks out there, as I had alluded to earlier, that have a paper program, and everything’s done manually. It’s just tough. You want to make sure that you have something that’s automated. You want to make sure that you have a system that will notify you ahead of time when a driver’s license is due to expire, when their med card is due to expire, when a motor vehicle report needs to be run. Also from an automation perspective, you can manage your drug testing and alcohol testing program this way. It just makes life easier, less things fall through the cracks than in a manual program. And again, it can obviously impact your score in a positive fashion.
Recordkeeping Is Key
We had mentioned record keeping a while ago and were saying that you want to maybe look at with the seven aspects of BASICS regarding what the recordkeeping requirements are. Record keeping is key. You want to keep track of everything. Going into an automated process on the prior slide – piggybacking on that – having a digital process and an online process these days is critical. First of all, if you’re called for an offsite audit, everything’s going to need to be digital anyway, so you probably should do it if you haven’t already. But, it also allows you to keep your documents in one location.
And we certainly had a situation two years ago when COVID first brought itself to us, and everybody was forced to go home and work; not many people anywhere, and not many people stayed in the office. We saw, all over the place, folks that had a paper process – their driver files were back in the office, yet all the personnel were working remotely, so they couldn’t do anything with the driver files. They couldn’t keep them updated; they couldn’t do anything. They couldn’t create new files. And it was bad. A lot of folks just assumed that the DOT was going to lighten up on them because COVID had hit. And that was not the case. So, to have the files in a digital online program would make it easy. If everybody’s working remotely, they can still have access to the files and do the work that they need to do on the files from wherever they are working remotely from home. It just makes for a quicker process, it makes for a more thorough process, it makes for a stronger safety program.
Foley’s Solution: Foley’s Platform
So, that’s our industry information as it has to do with CSA scores. If you’ll bear with me for a minute, I wanted to get into just some of the things that we do in this area. Some of you know already, but for those that don’t, first of all, there is our platform; we have of a driver compliance and qualification portal. This is where all of our clients’ information is housed. It’s all online. The entire program is run from here – drug testing, alcohol testing, MVR monitoring, Clearinghouse, program management, and driver files, obviously. Everything is in this Foley portal that we work in on behalf of our clients, which obviously our clients also have access to.
A minute ago, we talked about automation; our program certainly does this. We keep track of expiration in information, random drug and alcohol testing, what have you. Our clients don’t have to manually keep track of anything. They’re going to be notified; we do it 60 days in advance of expiration. They’ll be notified, and we find that a two-month window is plenty of time to make sure that the document can be renewed and uploaded.
Now, sometimes we get asked questions about security. Our platform is secure. Nothing gets in or out of the portal in an unsafe fashion. We’re not exposing your applicants’ or employees’ information. We take this part of the process very seriously; as a consumer reporting agency, we have to. And we see out there, within the compliance industry, situations where a vendor might ask an applicant or an employee to scan and email personal information. So if I’m an applicant, I fill out my application and then I scan a copy of my med card and my driver’s license and I email it to the vendor. That’s a violation of Federal Law, and here at Foley, we’re not going to subject anybody’s personal information to that type of exposure.
Fully Electronic MVR Monitoring
Again, this is something that we do. It has become much more prevalent, I think, in the last 18 to 24 months. It’s probably the number one thing that our existing clients add to their program, and we’ve had many inquiries in the last couple of years for companies that hadn’t been doing business with us that wanted to do a monitoring program. Again, it’s a relatively inexpensive program that can really ensure that you’re keeping track of what’s going on with your drivers from a safety perspective.
Have a Question? (860) 815-0764
So that’s our presentation. I appreciate your joining us today. I’m going through the questions here. Let me get to a couple of them. I can’t get to them all, but I appreciate you guys asking them; we’ll get back to you with answers. But let’s see if there some commonality among them/ A couple on the surprise blitz. I would say that a couple of months ago we did a webinar on the surprise enforcement events. I actually did that one. And if you would like a link to it to listen to that session, let me know, you can send me an email directly – it’s firstname.lastname@example.org. If you send me a note and ask for that link to the surprise enforcement event webinar, I’ll send it to you. Again, we put them on YouTube for folks who want to listen to them afterwards.
One of these events happened for seven weeks last year – everything points to the thought that it’s going to occur again this year. It was, I was going to say successful. I don’t know if that’s the right word. I guess it was successful for the FMCSA and maybe not successful for the folks that they targeted. But again, they went after companies that they felt were on the verge of being unfit. And they weren’t just going after companies; they were going after drivers as well.
So you might be a company with a pretty good safety rating, but maybe you have a few drivers that aren’t operating as safely as they need to be. They went after the drivers. It almost seemed to me like it was a Trojan horse. Hey, let’s get to this driver so we can get into the company. But again, I think it is a safe bet that they’ll do that again this year, so certainly you want to make sure that you’re off their radar there. We had a couple questions that came in to do with the Clearinghouse. One of them said: ”Does the Clearinghouse play into this?” And it certainly can. Going through the presentation here, we saw a number of times drug and alcohol was brought up. You want to make sure you’re doing your due diligence with the Clearinghouse; you’re running your pre-employment queries, you’re running your annual queries, you’re reporting everything that you need to, to the Clearinghouse – any infraction, you’re keeping track of the results of all your queries.
And if you’re audited, just like drug and alcohol testing has always been a big part of an audit, Clearinghouse is now too. And believe it or not, I still talk to people today, 25 months into this regulation who haven’t registered. I can’t even imagine what’s going to happen to them when and if they get audited. But absolutely, the Clearinghouse and your adherence to the regulation can positively impact your score. You’re going to have drivers that are safe, you’re not having anybody behind the wheel that shouldn’t be there.
One other thing that just came to with the Clearinghouse is I even have clients that do annual queries more than annually. They’ll do them two, three times a year just to make sure. You could have a situation where somebody’s driving for you and maybe they go and apply somewhere else, and during that application process they fail their pre-employment test, so now they just stay driving with you. That’s obviously going to show up the next time you run a query, but because of that, sometimes companies will run a query more often than once every 365 days. So I’ll keep it at that. I want to be cognizant of the time commitment that you’ve put in here today. Again, I thank you for your participation. Any of the questions that you did submit that we didn’t get to, we will. And other than that, I hope you have a very good rest of the day. Thanks.