There’s an adage that says, “What gets measured, gets done.” If something is being measured, it is being monitored, and something that is monitored stays in focus. When monitoring, deviations from the plan can be immediately addressed. This is why so many individuals and companies use credit monitoring and identity monitoring services. They simply cannot afford to find out that there is a problem after the damage is done. Monitoring DOT registrations is done for much the same reason. It allows carriers to catch changes to their filings before adverse events occur – like being prohibited from operating.
MONITOR OPERATING STATUS. The federal rules state that a motor carrier must have an active USDOT number to engage in interstate transportation and must have for-hire operating authority in order to haul property that is not their own or people who are not employees. Absent monitoring, carriers likely will not know that they can no longer legally operate until one of their vehicles has been shut down at a roadside inspection point.
MONITOR REGISTRATION STATUS. The most common non-safety related way to lose an active registration is by not providing the FMCSA with timely updates. Due to the required biennial updates, this can easily happen after a move because the mailing address has changed or the individual that was responsible for the updates was reassigned or is no longer with the company. In addition to the required updates, you should also provide interim updates when the operation changes in size, scope or commodities transported.
MONITOR VEHICLES AND MILES. The number of power units and the number of miles traveled annually factor into two of the seven Compliance Safety Accountability (CSA) Behavior Analysis and Safety Improvement Categories or BASIC scores. It stands to reason that the more vehicles a company operates and the more miles they travel, the higher the likelihood that their drivers may have a moving violation or an accident. By monitoring and accurately reporting the miles traveled and vehicle count, companies can ensure that they are fairly compared with other carriers.
MONITOR INSURANCE STATUS. All carriers must have liability insurance in place or be able to demonstrate an equivalent level of financial responsibility. All carriers need to file on behalf of the operation proof of these coverages with the FMCSA. If the coverage is canceled for any reason, the provider will notify the FMCSA. If coverages are not reestablished, the carrier will no longer be able to transport commodities or passengers. This is the most common way that for-hire property and passenger carriers lose their authority.
MONITOR PROCESS AGENTS. A process agent serves as a carrier’s “statutory agent” and is the conduit between the legal system and the company. This enables court actions to be served in the jurisdiction in which the event occurred and eliminates the need to search for the location of a carrier domiciled in another jurisdiction. Process agents are designated for each state in which a carrier is authorized to operate in or traverse through. Private carriers operating in the United States transporting between points in a foreign country also need to file a designation for each state traversed. In addition, brokers designate process agents for each state in which their offices are located and in states where agreements will be written. Like having insurance in place, having process agents designated is a condition to operate when they are required. If, for whatever reason, an entity loses a process agent, they lose the ability to operate.
By continually monitoring your DOT registrations – or having a third party monitor them for you – you’re able to catch and react to changes before they become problems. Now, let’s switch gears to another hot topic in the industry – CSA points.
Many stakeholders in the transportation industry say that a lack of data undermines the Safety Measurement System (SMS) and does not establish a link between a carrier’s SMS scores and their crash risk, and that carriers are put in comparative groupings that are inaccurate. While there have been many positive updates to the program, such as eliminating scores from public view and amending the weighing of some violations, there are still some areas that require regular clarification and attention. One of these areas is the impact the CSA points have on a driver’s record. A question often asked is how long CSA points stay on your record.
The goal of the SMS program is to incorporate safety-based regulations related to motor carrier operations. The SMS assesses carrier and driver compliance and prioritizes carriers and drivers for interventions based on their performance. “On-road performance” relates to data collected from roadside inspections and crash reports, while “investigation results” relate to violations. The SMS assesses motor carrier performance by organizing data into 7 Behavior Analysis and Safety Improvement Categories (BASICs): 1) Unsafe Driving; 2) Crash Indicator; 3) Hours of-Service Compliance; 4) Vehicle Maintenance; 5) Controlled Substances/Alcohol; 6) Hazardous Materials Compliance; and 7) Driver Fitness.
In each BASIC, the SMS calculates a quantifiable measure of a motor carrier’s performance. The SMS groups carriers by BASIC with other carriers that have a similar number of safety events (crashes, inspections, or violations). The SMS then ranks these carriers in their group based on their BASIC measure, assigning them a percentile from 0‒100, with the higher percentile meaning a worse safety performance, compared to other carriers in the group.
Regarding how long CSA points stay on your record, it is important to note there are different time thresholds for carriers (companies) and for individual drivers. For carriers, any violation or crash that occurred within the previous 24 months of performance data is considered when determining the BASIC measure. For drivers, it is any violation that has occurred within the last 36 months. In addition, inspections, violations and crashes are time weighted when they are included in the SMS calculations. Events that have occurred within 6 months of the SMS run date receive the highest time weight (X3), events greater than 6 months but less than or equal to 12 months are less (X2), and events that occurred greater than 12 months from the SMS run date are assigned the smallest time weight (X1). The FMCSA updates the SMS once per month, so the data and points assigned to a carrier can change on a fairly regular and consistent basis.
How do these violations (points) impact your SMS evaluation as a carrier? Carriers are evaluated only on inspections and crashes that occur under their DOT number. So, only violations that a driver receives while working for a motor carrier apply to the carrier’s SMS evaluation. Therefore, the driver’s violation history before the driver is hired and after the driver’s employment is terminated will not impact a motor carrier’s SMS results. However, even if a motor carrier terminates a driver, all the driver’s crashes and inspection results that he or she received while operating for that carrier still apply to the carrier’s SMS evaluation for 24 months from the date of occurrence. Because the data is time-weighted, the effect of those occurrences on the carrier’s percentile rank will diminish over the 24 months.
So, there is a rundown of how long CSA points stay on your record. If you need more information or have questions, we strongly urge you to visit the CSA website (csa.fmcsa.dot.gov). They recently added a section for new carriers that is very helpful.