Comprehensive Safety Analysis Initiative
ARTICLE
SERIES
Article 2 of 8 – BASIC 1: Unsafe Driving
BASIC 1: UNSAFE DRIVING
Staying on top of safety and compliance under the CSA 2010
initiative will mean getting “back to the BASICs.” This synopsis
will focus on the Unsafe Driving BASIC.
Unsafe driving practices will lead to commercial motor vehicle (CMV) accidents. Reckless driving,
speeding, failing to yield the right-of-way, and other violations are closely related to a driver’s risk
of getting into a crash. In fact, drivers issued a violation for driving recklessly are 325% more likely
to be involved in a future crash.
That’s why the Federal Motor Carrier Safety Administration (FMCSA) places so much emphasis on
unsafe driving under its Comprehensive Safety Analysis (CSA) 2010 program. The CSA 2010
initiative is designed to monitor driver and motor carrier safety performance and stop unsafe
behaviors before they result in a crash. Unsafe driving is seen as such a major contributor to crashes
that unsafe driving violations alone can lead to a carrier or driver being deemed “unfit to operate.”
To survive and thrive in 2010 and beyond, it’s important to understand how unfit driving fits into
the CSA 2010 puzzle.
What is Unsafe Driving?
The FMCSA defines unsafe driving as operating a
CMV in a “dangerous or careless manner,”
comprising 36 distinct violations. Among them:
Speeding or reckless driving
Improper lane changes
Inattention
Using a radar detector
Operating a bus unsafely
Smoking within 25’ of a hazmat vehicle
are entered into the FMCSA’s Safety Measurement
System (SMS), which is the agency’s replacement
for the current SafeStat system. The SMS is used to
grade both carrier and driver performance on
unsafe driving and the other BASICs. Unsafe driving
violations that may have had a minimal effect on
your safety rating in SafeStat may have a huge
effect on your rating in the new SMS, and may lead
to contact from the FMCSA.
Just the BASICs
Your performance on unsafe driving is measured
using violations of certain Federal Motor Carrier
Safety Regulations and state traffic control laws
recorded on roadside inspection reports.
A violation can be logged even if a citation or ticket
is not issued — even if the violation simply appears
on the inspection report — and even if the driver is
not placed out of service. Unsafe driving violations
Unsafe driving is one of seven violation categories in which your
company and drivers will be graded under CSA 2010. The seven
Behavioral Analysis and Safety Improvement Categories, or BASICs:
Unsafe Driving
Vehicle Maintenance
Fatigued Driving
Cargo & Hazmat
Driver Fitness
Crash History
Drugs & Alcohol
1 888 473- 4638 x 2010 • www.jjkellerservices.com
1
©2010 J. J. Keller & Associates, Inc.
AN OVERVIEW // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNS
Article 2 of 8 – BASIC 1: Unsafe Driving
How Do You Measure Up?
Example of Unsafe Driving Violations by Severity
Unsafe driving violations are used to grade your
performance in the unsafe driving BASIC, which
contributes to your overall safety rating. Carriers
and drivers with the poorest grades relative to
their peers become the targets of the FMCSA’s
“intervention” process, in which the agency takes
action to try to correct the unsafe behaviors and
prevent crashes. Here’s the process used to figure
out how you “measure up” in the unsafe driving
BASIC:
1
2
VIOLATION
Every 30 days, all of your unsafe driving
violations from the past 24 months will be
assigned a severity, from 1 to 10, based on
how likely the violation is to result in a crash.
A severity of 1 represents the lowest crash risk,
and 10 the highest, relative to other violations
within each BASIC. For example, reckless
driving is assigned the highest severity while
failing to wear a seatbelt scores a 1 (see
accompanying table).
The severity of each of a carrier’s unsafe
driving violations is multiplied by a 1, 2, or 3
depending on its age. If the violation was
within the past 6 months, it gets a weight of 3;
within 6-12 months, a weight of 2, and within
12-24 months, a weight of 1. The result:
violations recorded within the last 6 months
are three times as damaging to a carrier’s
grade as violations recorded between 12 and
24 months ago. The older the violation, the
less weight it carries.
PERFORMANCE GRADING EXAMPLE
ABC Trucking had four inspections in the past two
years. Among the violations found was one for
reckless driving (severity = 10) and one for using a
radar detector (severity = 5). The reckless driving
violation was committed last month, so the
severity of 10 gets increased by a factor of 3,
making it 30. The radar detector violation was 18
months ago, so the severity is not increased due to
age; it remains as a 5. The total “weighted” severity
is 35. The company had an average of 3 power
units over the past 18 months, so their unsafe
driving measure is 35 ¸ 3, or 11.7. By itself, this “raw”
score means little until it is compared to the scores
of other carriers (see below).
SECTION
SEVERITY
Reckless driving
§392.2
10
Failing to obey a traffic control device
§392.2
5
Following too close
§392.2
5
Improper lane change
§392.2
5
Improper passing
§392.2
5
Speeding
§392.2
5
Improper turn
§392.2
5
Failing to yield right of way
§392.2
5
Scheduling a run that requires speeding
§392.6
5
Failing to stop at a railroad crossing when required
§392.10
5
Failing to use caution for a hazardous conditions
§392.14
5
Using or equipping a CMV with a radar detector
§392.71(a)
5
Failing to use a seat belt
§392.16
1
Failing to use hazard warning flashers
§392.22(a)
1
Transporting unauthorized passengers
§392.60(a)
1
The above violations were cited almost 355,000 times in 2008, or about 15% of all traffic enforcement violations cited.
3
To account for each carrier’s size, the total
violation severity is divided by the average
number of power units the carrier had in the
past 18 months. That way, a small carrier with
a lot of violations, for example, will score
worse than a large carrier with the same
number of violations. The average number of
power units is calculated using data you
supply to the FMCSA on the MCS-150 /
MCS-151 forms.
Drivers are graded in a similar way except that
violations from the past 36 months are included,
and there is no adjustment for company size.
The Ranking Process
Your unsafe driving measure is not your final
grade. Rather, the measure is used to judge you
against other carriers of similar size to determine
your “percentile” in terms of unsafe driving. Think
of it as being graded on a curve, where the
best-performing carriers (no matter how good or
bad they actually are) automatically get an A+ and
1 888 473- 4638 x 2010 • www.jjkellerservices.com
2
©2010 J. J. Keller & Associates, Inc.
AN OVERVIEW // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNS
Article 2 of 8 – BASIC 1: Unsafe Driving
For Helpful Guidance on CSA 2010 Preparation, call J. J. Keller Business Services
1.888.473.4638 x 2010
FLEET TECHNOLOGY • OUTSOURCE SERVICES • ADVISEMENT & TRAINING
Don’t wait for FMCSA enforcement. Getting your records organized now will make a difference. We can help.
www.jjkellerservices.com/csa2010
the worst-performing get an automatic F. The
difference with CSA 2010, however, is that the
highest score is 0% and the lowest is 100%, with
everyone else somewhere in between. For
example, if your unsafe driving percentile is 60%, it
means you’ve demonstrated worse performance
on unsafe driving than 60 percent of your peers.
If you’ve received fewer than three inspections in
the past 24 months with at least one unsafe
driving violation per inspection, OR if your unsafe
driving violations are all older than 12 months,
then you are “off the hook” for this BASIC. That is,
you will not receive a percentile on your unsafe
driving performance..A high percentile in unsafe
driving could have two consequences:
1
If your percentile is above the threshold for an
intervention (i.e., your performance is
“marginal”), then the intervention process will
begin, with a focus on unsafe driving. For
example, depending on your percentile, you
might be the target of:
2
If your percentile places you into the “failing”
category for unsafe driving, you may automatically be deemed unfit to continue operating
commercial motor vehicles. That’s because
unfit driving is a “stand-alone” BASIC, meaning
that if you receive a failing grade in the unsafe
driving BASIC alone, you will receive an overall
failing grade as a company. For most other
BASICs, you need a failing grade on two or
more BASIC categories to receive an overall
failing grade.
Interventions
Once a carrier’s percentile in the unsafe driving
BASIC is high enough to exceed the thresholds set
by the FMCSA, the company and/or drivers could
be subject to an FMCSA intervention. Carrier
interventions increase in severity as follows:
1 warning letter
2 targeted roadside inspection
A warning letter, informing you of a poor
score in unsafe driving and what you need
to do better (you would also be instructed
on how to challenge any incorrect data);
3 off-site investigation
Increased roadside inspections that target
unsafe driving
6 notice of violation
An on-site audit that targets your problems
with unsafe driving.
8 notice of claim/settlement agreement
4 focused on-site investigation
5 cooperative safety plan
7 comprehensive on-site investigation
9 unfit suspension
Note that carriers who may have good scores
under the current SafeStat system could find
themselves on the intervention list under CSA
2010, because each BASIC is scored separately.
1 888 473-4638 x 2010 • www.jjkellerservices.com
3
©2010 J. J. Keller & Associates, Inc.
AN OVERVIEW // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNS
Article 2 of 8 – BASIC 1: Unsafe Driving
INTERVENTION REVIEW
Intervention #1: The Warning Letter
The warning letter is sent to a motor carrier when safety performance data exceeds the threshold for
intervention in one or more BASICs. The letter advises the carrier of the apparent safety problems, and the
potential consequences of continued operation in that way. It also refers the motor carrier to online
educational tools and information for self improvement, along with instructions on how to challenge safety
data if the motor carrier believes it is in error.
ARE YOU PREPARED?
Your score on unsafe driving — and the consequences of a failing grade — will be
based on data that is being collected today. Now is the time to make compliance a
priority and put safety management controls in place that will help prevent unsafe
driving. Here are some key points to keep in mind:
Because unsafe driving is a stand-alone BASIC, it’s important to focus on the
violations that could hurt the most, both for the company and for individual
drivers. Figure out where your drivers stand on the unsafe driving BASIC and
train appropriately. Remember: violations will affect drivers’ scores for 3 years,
and the company’s for 2 years. The passage of time will decrease the impact of
the oldest violations. Organize and track all safety data, so you understand your
level of exposure.
All violations noted in roadside inspection reports will count, not just the ones
that place a driver out of service. Begin tracking all moving and roadside
violations, along with “near misses,” to identify possible trends and improvement opportunities by driver and vehicle.
Make sure the FMCSA has accurate data! Get in the habit of keeping your
MCS-150 / MCS-151 form up to date (you don’t have to wait for the two-year
filing cycle), and verify that the violations assigned to your company are
actually yours. Use the FMCSA Portal system (https://portal.fmcsa.dot.gov) to
review your data.
The fewer the violations and the more “clean” inspections you have, the better
your score and/or the better the chance that you won’t be graded at all. Have
your drivers ask for documentation of all “clean” inspections, to ensure that they
get recorded. In some cases, clean inspections can significantly improve your
scores!
Use refresher and new-driver training programs to help prevent unsafe driving
and its consequences.
Be proactive! Use the right tools and resources to understand your exposure to
risk and unsafe practices.
1 888 473-4638 x 2010 • www.jjkellerservices.com
4
©2010 J. J. Keller & Associates, Inc.
AN OVERVIEW // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNSAFE DRIVING // BASIC 1 • UNS
Article 2 of 8 – BASIC 1: Unsafe Driving
Comprehensive Safety Analysis Initiative
The BASICs
Unsafe Driving | The operation of CMVs in a dangerous or careless manner.
Examples: speeding, reckless driving, improper lane change, inattention.
Fatigued Driving | The operation of CMVs by drivers in non-compliance with the hours of
service regulations.
Examples: violation of the driving limit, driving while fatigued, failing to maintain complete and accurate logs.
Driver Fitness | The operation of CMVs by drivers who are unfit to operate a CMV due to lack
of training or medical qualifications.
Examples: failure to have a valid license, being medically unqualified.
Drugs and Alcohol | The operation of CMVs by drivers who are in possession of alcohol or
illegal drugs, or impaired due to alcohol, illegal drugs, or misuse of prescription or over-the counter medications.
Examples: the use or possession of drugs or alcohol.
Vehicle Maintenance | CMV failure due to improper or inadequate maintenance.
Examples: defective brakes or lights, failure to make required repairs.
Improper Loading/Cargo Securement | CMV incidents resulting from shifting loads, spilled or
dropped cargo, and unsafe handling of hazardous materials.
Examples: improper load securement, cargo retention, and hazardous material handling.
Crash | Histories or patterns of crash involvement, including frequency and severity, based
on information from state-reported crashes.
Safe & Smart Driver Training
Our popular on-site training helps drivers improve skills, be prepared for roadside inspections and reduce accidents!
Hands-on, high energy training and your location!
Led by experienced transportation professionals!
• Driver Attitude – stress management, goal setting
• Hazard Perception – speed & space management,
reaction time, scanning techniques
• Driving Skills – turning & backing, merging, intersections
• Defensive Driving – habits, distractions, road rage
• Roadside inspections – know how to prepare
• More!
Crash history is not
specifically a behavior. Rather,
it is a consequence of a behavior
and may indicate a problem with the
entity that warrants intervention.
FMCSA Safety Measurement System
Methodology Version 1.2 April, 2009
J. J. Keller Business Services • 1-888-473-4638 x 2010 • www.jjkellerservices.com/csa2010
1 888 473- 4638 x 2010 • www.jjkellerservices.com
5
©2010 J. J. Keller & Associates, Inc.