As those of us in the Mid-Atlantic States finally see some relief from the snow, I would like to spend some time this month writing about the new programs from the FMCSA: the CSA 2010 Initiative and the Pre-employment Screening Program. I’m sure many of you have heard at least a few sound bytes about the CSA program, but I would like to share with you some more detailed information about the audit process of the initiative. Concorde had the opportunity to assist one of our clients with an audit since we provide the Company with driver qualification files services via our DQ-it application. Here are some interesting takeaways from our involvement in the audit:
Let me start by giving a brief overview of the CSA 2010 Program. The focus of the program is to begin enforcing drivers for serious rule violations of the following categories: Driving while disqualified (as determined under §391.15 for drivers operating vehicles 10,001 pounds or more & § 383.51 for drivers operating vehicles 26,001 pounds or more), Driving without a valid commercial driver’s license, Making a false entry on a medical certificate, and/or Committing numerous Hours-of-Service violations. The enforcement focus will be on the driver, however, the FMCSA will also look to determine if the carrier has any responsibility in the violation.
In addition, the program includes 3 major components:
1) A more comprehensive carrier safety measurement system "CSMS"; to replace SafeStat
2) A farther reaching intervention process that will extend beyond on-site inspections.
3) A new safety fitness determination system More information about the CSA 2010 initiative can be found at http://csa2010.fmcsa.dot.gov/.
The FMCSA announced that Component 1 of the CSA 2010 initiative will begin November 30th, 2010. Beginning April 12th - November 30th, 2010, Carriers will have access to the Data Preview Event. This will allow motor carriers to review their BASICs data before the official launch of CSA 2010. The Data Preview can be viewed at https://csa2010.fmcsa.dot.gov/login.aspx.
What will change on November 30th, 2010?
1) SafeStat will be replaced with CSMS
2) Warning letters will be sent to carriers nationwide
3)Improvements to the documentation of roadside inspections that will integrate into CSMS
The 9 states currently running the CSA 2010 Test Model (CO, DE, GA, KS, MD, MN, MO, MT, and NJ) will run all 3 CSA 2010 Program Components beginning June 2010. The remaining 41 states will be phased into the complete CSA 2010 program starting 2011.
Although the CSA 2010 program has a primary focus on large truck drivers and bus operators (as defined in Part 383 The Regulation), in some instances small truck drivers (as defined in Part 390 The Regulation) are also subject to the oversight and subsequent audit process. This all depends upon whether or not your company operates in interstate vs. intrastate commerce and/or if the states you operate in have adopted Part 390-391 of the regulations.
Here are some of the thoughts from Art Cohen, VP of Operations, who attended the CSA 2010 Audit:
The auditor identified, as a result of discussions with the carrier staff, that the Company had “small” truck drivers (i.e. drivers who may or may not have CDLs but only operate trucks weighing more than 10,001 but less than 26,001.) None of these “drivers” were in the DQF system although they are required to have DQF files. (Note: there are a set of facts and laws that affect this requirement; this includes intra v. inter state driving and to what extent, a state has adopted the FMCSR.)
• The CSA 2010 Audit does not extend to areas which are not known to be problematic. For example, if the audit was triggered by numerous roadside inspections uncovering drivers with invalid medical cards, there would be no inquiry into hours of service, accidents, or drug testing. All of these would have been reviewed in a regular compliance audit.
• In the CSA 2010 audit, the auditor reviewed both current cards and the prior card and identified several drivers that had gaps between when their last card expired and they received a new card. The auditor made a point of suggesting that carrier utilize a system that would provide advance reminders of the need to update these items.
• Terminated drivers would be included for a specific year or period.
• The auditor asked for a great deal of DQF data on many more drivers than would have normally been reviewed in a full audit. This created a need to be able to quickly produce documents from a file.
• Because a CSA audit focuses on a driver’s qualifications as evidenced in the DQF, this creates a strong need to have a system that provides reminders to help ensure that a driver is qualified at all times.
• There were some questions related to expired driver’s licenses.
It should be noted that many of the issues mentioned above were specific to the carrier undergoing the audit, but it does provide some insight into how the CSA Audits are conducted. A standard FMCSA Audit can be categorized as a mile wide and an inch deep, whereas a CSA 2010 audit is an inch wide and a mile deep.
The other new program being released by FMCSA in the Spring/Summer of 2010 is their Pre-employment Screening Program. This service will allow carriers to run searches on new hire drivers to get 5 years of crash data history and 3 years of inspection data. This information DOES NOT contain conviction information, just the raw inspection and crash data. The data is the same data you may currently receive from FMCSA’s Driver Information Resource (DIR). The difference with the PSP program is that FMCSA is offering a streamlined version of the DIR.
Concorde is currently working with the FMCSA to develop an interface for you to order the PSP on a new driver and receive the information. If this is a program that you might be interested in, please contact Josh Rosenzweig at 215-587-6268 or josh@concorde2000.com for enrollment information. We are currently seeking guidance on how our clients might want to use the service.
As always, I encourage everyone to check out our new Online Supervisor Training. We offer classes on the first Friday of every month at 10:00 AM EST and can also create Company specific trainings for your organization. Visit http://www.concorde2000.com/Page.aspx?ID=57 for more information.
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