CSA - The Driver Fitness BASIC is all about 'qualifications'
This BASIC (Behavior Analysis and Safety Improvement Category) in the Compliance, Safety, Accountability (CSA) program has led to a considerable amount of confusion. It has nothing to do with "new" medical requirements, a driver's body mass indicator (BMI, a measure of how physically fit a person is), and it definitely has nothing to do with drivers exercising more. What is being tracked, measured, and evaluated is carrier and driver compliance with the "driver qualifications" regulations (driver training, licensing, and the "driver qualifications" discussed in Part 391).
What goes into the Driver Fitness BASIC?
The Driver Fitness BASIC uses violations related to driver training, licensing, and qualifications noted on roadside inspection reports to calculate driver and carrier performance. This has nothing to do with the driver receiving a "citation" or "ticket." Citations are a totally different matter and involve someone paying a fine for the violation. To sum this up, if a violation of a driver qualifications regulation is noted on a roadside inspection report, the violation will be entered into the driver's and carrier's Driver Fitness BASIC in the CSA 2010 data system.
Examples of violations that will be placed in the Driver Fitness BASIC include: Operating a commercial vehicle without the proper training (both general and hazardous material training), operating a commercial motor vehicle without the correct license and endorsements, operating a commercial vehicle while holding multiple licenses, operating a commercial vehicle when disqualified, suspended, or revoked, and operating a commercial vehicle when not medically qualified.
Tracking and measuring Fitness violations
Whenever a violation related to driver training, licensing, or qualifications is placed into the system, the violation is "valued" in the driver and carrier Safety Measurement Systems (SMS) using severity and time weighting. The severity weighting is based on the violation's relationship to crash causation (operating a commercial vehicle requiring a CDL while possessing more than one license is a 10, which is the maximum, while the driver not having a medical card with him/her has a severity of 1, the minimum). If the violation led to the driver being placed out of service, the severity weight is increased by two.
The high severity violations in this BASIC include operating after ordered out of service for a driver licensing or qualifications related violation, operating a commercial vehicle with multiple drivers' licenses, operating a vehicle without the correct license, failure to report convictions to the state and/or employer, and driving while disqualified, suspended, or revoked.
Time weighting involves placing more value on violations that have happened recently. All violations remain in the carrier's data for 24 months (36 months for drivers), but a violation's "value" reduces over time due to the time weighting system. Events that occurred in the last six months are given a time weight of 3, events that took place between 6 and 12 months ago are given a time weight of 2, and anything that happened over a year ago is given a time weight of 1.
To determine the "value" of a violation, the total severity weighting for the violation (the predetermined severity weight of the violation plus two if the driver was placed out of service) is multiplied by the time weighting to determine the "value" of the violation in the SMS.
For carriers with more than five driver level inspections and one that notes a violation of the driver training, licensing, or qualifications regulations, the value for all time and severity weighted violations is totaled, and then the total is divided by the "time weighted relevant inspections." The "time weighted relevant inspections" are the driver inspections the carrier has undergone (good and bad) that have been "time weighted" using the same time weighting discussed above.
This "normalizing" process generates a BASIC Measure (violation value per inspection) that allows all carriers to be compared to each other.
Once a carrier's BASIC Measure has been determined, the carrier is then compared to other carriers in its "Safety Event Group" (i.e., peer group). The Safety Event Groups are based on the total number of driver inspections. Carriers with 5 to 10 inspections are compared to all other carriers with 5 to 10 inspections, and then "Percentile Ranked" inside their Peer Group based on their BASIC Measure. The carrier with the lowest BASIC Measure in the Safety Event Group is ranked at 0, while the carrier with the highest BASIC Measure is ranked at 100. All other carriers in the Safety Event Group fit in between based on their BASIC Measure. This percentile ranking is the carrier's actual "BASIC Score."
If a carrier's BASIC Score is above a predetermined threshold, an intervention will be triggered. Interventions range from a warning letter to a full Compliance Review. The basic principle is the worse the carrier's score, the more severe the intervention.
Drivers' Driver Fitness BASIC Measures are determined by the same process. First, all violation values in the Driver Fitness BASIC are totaled and then divided by the "time weighted relevant inspections."
The BASIC Measures are then percentile ranked in Safety Event Groups based on the number of driver inspections the driver has undergone. Within each Safety Event Group, drivers are assigned percentile rankings from 0 (representing the lowest BASIC Measure) to 100 (representing the highest BASIC Measure). This Percentile Ranking is the driver's BASIC Score.
Two points about the driver's BASIC Measures and Scores: First, these are going to be confidential; no one will be able to view them but FMCSA officials and investigators, and second, the driver interventions are not directly based on the driver's score. Drivers found with high scores during other enforcement activity (such as during an audit) will be subject to interventions.
How do I keep this BASIC Score low?
The simple answer is to make sure your drivers are fully qualified when operating company vehicles.
This will require several actions, starting with initially "qualifying" the driver as part of the hiring process. The initial driver qualifications should include verifying that the driver:
- Is properly trained and/or experienced (including comparing the driver to your company standards and doing a road test).
- Has a valid license of the correct class with the necessary endorsements.
- Only has one license issued by the driver's home state.
- Can pass a physical (either has a valid medical card you can copy or passes a physical before driving).
- Understands the driver qualifications requirements and processes.
As part of this process you will want to complete a driver qualifications file on the driver when he/she is hired. A best practice in this area is to not dispatch the driver until all driver qualifications requirements in Section 391.23 and Section 391.51 are met (even the ones that the regulations say you have 30 days to complete).
Next, you must make sure that you have a "tickler" system that notifies you when a driver's qualification is about to expire. Once the company is notified, the driver should then be given a "deadline" to complete the necessary paperwork or activity (such as annual review paperwork, license renewal, undergoing a physical, etc.), or faced being taken off of dispatch.
Finally, have a mechanism in place that tracks driver performance and reviews the driver when the driver's performance may have an effect on the driver's qualifications. Many carriers have found that the regulatory mechanism (the annual review process) is not adequate and therefore check their drivers' performance every six months or even quarterly. Also, many carriers now recheck their drivers' qualifications following any significant event involving the driver ─ if a driver receives a ticket or is involved in an accident, injury, or has taken significant time off, the driver's MVR and physical qualifications are rechecked.