How to Remove CSA Points From Your Driving Record
How to Remove CSA Points From Your Driving Record
Staying on the road is your top priority as a driver because every minute you’re not on the road, you’re not making money. However, situations may arise that could sideline you. Some are due purely to dumb luck and others are due to avoidable errors or misjudgments. Whatever the reason, it could cost you CSA points.
What should you do if you gain too many CSA points? Can you remove them? What do they mean for your driving career? This primer will provide answers to these and other questions.
What are CSA Points?
CSA stands for Compliance, Safety, and Accountability and is a set of standards created by the Federal Motor Carrier Safety Administration (FMCSA) to improve overall safety of commercial motor vehicles. Launched in 2010, this safety program was designed to make roads safer for both the public and the driver by collecting data on carrier performance. CSA points are given to both the driver and the carrier so both assume responsibility for rectifying safety issues.
How do you get CSA Points?
CSA points are calculated in many ways, including infractions found during roadside DOT inspections, crash reports, and investigation reports. CSA points can only be assigned by people who are trained to give DOT inspections. This includes DOT inspectors and trained law enforcement officers.
The FMCSA organizes safety infractions into seven different categories known as the Behavior Analysis and Safety Improvement Categories (BASICs). Infractions in these seven categories are given a score between 1-10 with 10 being the most severe. The seven BASICs categories are:
- Unsafe driving infractions include speeding, reckless driving, and other traffic violations.
Crash indicators take into account the carrier’s history of crashes and the frequency at which crashes occur. The crash data the FMCSA gathers are taken from law enforcement reports, carrier reported crashes, and results from on-site crash investigations.
CSA points are given for hours-of-service compliance infractions which include violating 14-hour rule or break rule. This also includes any infractions with the log book or Electronic Logging Devices (ELD).
Notes: Automatic On-Board Recording Devices (AOBRD) are being phased out and by December 2019 will need to use self-certified, registered ELDs. At publication, FMCSA is currently considering an Advanced Notice of Proposed Rulemaking regarding HOS. Final ruling may or may not affect CSA point violation as noted here.
This category includes infractions to vehicle maintenance including failure to fix brakes, lights, and any other defect with the vehicle.
Any possession or use of alcohol or drugs while operating a commercial motor vehicle.
Hazardous Materials Compliance
These are any infractions to improper packaging of hazardous materials as well as any hazardous material leaks.
Infractions are given for any carrier with drivers who do not have their CDL due to physical or mental ailments which are discovered during the required DOT physical.
Do CSA Scores Still Matter?
The FAST (Fixing America’s Surface Transportation) Act highway bill, passed in December 2015, required FMCSA to remove CSA scores from public view until reforms were made to the system. After significant changes, five of the seven BASICs are once again publicly available (Crash Indicator and Hazardous Materials Compliance are not available to the public). Scores that remain available for viewing are still important for a number of reasons:
• Law enforcement officers can issue interventions, audits or inspections based on high scores.
• Shippers and brokers may use CSA scores as a condition of doing business.
• CSA scores can indicate where you need to put more emphasis on safety and compliance.
What are the most common infractions?
The best way to avoid CSA points is by avoiding the most common infractions.
Even though this is one of the easiest things to check, it is one of the most overlooked elements of your rig. During your pre-drive check, make sure to inspect every visible lamp on your rig front to back, including the headlights, brake lights, and even the license plate lamps.
Unlike lights, brake adjustments and air brake compressions are more tedious to inspect. If you’ve never performed a thorough inspection of your air brakes and need guidance, check out professional YouTube videos and Internet articles for refresher tips. Major truck stops also offer pre-CSA inspection week specials. Take the extra time to properly check brakes during your maintenance routine.
During your pre-trip check, make sure that the tires are in good condition by specifically checking for tread depth, inflation, and any other issues that make them a potential safety hazard.
The ELD mandate exempts all owners of 1999 and older model-year trucks and engines. However, traditional paper log books are still required on pre-2000 trucks. All drivers must completely understand the FMCSA guidelines for hours-of-operation and how an electronic logging device (ELD) automates most of the work. Carriers must provide training so that all of its drivers understand the hours-of-service (HOS) rules.
Make sure that driver and carrier certificates are current and renewed if expired. The driver and the carrier are responsible for ensuring that drivers are fit to drive and do not have any illnesses that will affect the safety of the driver and everyone on the road. Certificate violations are minor infractions, but driving while ill could carry the maximum CSA infraction points.
What happens when you get CSA points?
There is no set threshold that would deem a driver or carrier out of service. Also, CSA points have different consequences if you are a driver versus a motor carrier operating under your own trucking authority.
First things first: drivers do not get CSA points per se. CSA points are only assigned to trucking companies that own the motor carrier (MC) authority. This does not mean drivers are free from consequences. Although you don’t gain CSA points as a driver, all infractions from DOT inspections are logged in a driver’s pre-employment screening program (PSP) log.
Too many infractions in your PSP log can negatively impact your future employment with motor carriers or your ability to broker contracts. If you want to work for a different MC, that MC may think twice about hiring you if you have too many infractions. Too many infractions will also directly impact your ability to be insured which will caution motor carriers from hiring you due to the high cost of insuring you. Bottom line: keep your record clean.
Unlike drivers, CSA infraction points will stay with the motor carrier. In fact, CSA points given to a driver will stay with the motor carrier even if the driver leaves the carrier.
How Many CSA Points Can You Have?
So how many CSA points can you accrue before the FMCSA intervenes? Unfortunately, there is no magic number that trucking companies have to stay under to avoid any penalties. The FMCSA uses points to rank your fleet with other similar fleets. A fleet in a high percentile of infractions will be deemed unsafe which may likely trigger an FMCSA investigation.
What are the risks of accruing too many CSA points as an owner-operator? For starters, many shippers set a maximum CSA score in order to do business with owner-operators.. This maximum CSA score is usually based on a national average which means too many CSA points will hurt your chances of getting jobs from shippers. Also, a high CSA score will be factored into the cost of your fleet’s insurance.
In the worst case scenario, a high CSA score will increase the likelihood of an FMCSA intervention. If your company’s CSA points puts you in the 90th percentile of frequent offenders during a one-month period, the CSA can notify you of a targeted inspection. During this inspection, they may perform thorough vehicle inspections or business investigations, including auditing business documents, and even interviewing drivers and employees. The best outcome from an intervention is the FMCSA asking for a voluntary compliance plan and a Notice of Violation (NOV) that requires you to take corrective action or contest the violation. In the worst case scenario, the intervention may result in civil penalties and even an Operation Out of Service Order (OOSO or OOS).
A high CSA score can have very costly consequences for you as an owner-operator. To avoid these consequences, steps must be taken to ensure that both your drivers and the company as a whole are compliant.
How do I lower my CSA score?
Following are some steps you can take as an owner-operator to improve your company’s situation.
One of the best ways to avoid CSA infractions is to take preventative action. Start by having drivers do pre-trip inspections focusing on areas where most violations occur: lights, tires, brakes and speeding. Make sure your drivers know exactly what to look for when doing a pre-trip inspection. Create a plan for your company or make a checklist of all potential violations your drivers should look for. Additionally, do an internal audit of your log books or ELD to make sure your drivers are properly logging their hours and are not out of compliance.
Another way to avoid CSA infractions is to slow down! 90% of a motor carriers’ problems are from speeding. Speeding may get a driver to a destination faster, but, if pulled over, that driver will be stopped dead in his or her tracks.
Lastly, mount forward-facing cameras to your trucks. Video footage of a possible accident that is not your fault is powerful objective evidence of your innocence. What’s more, this investment could potentially save you money and headaches in the long run.
Within two years, owner-operators can challenge a CSA violation to remove points or reduce the severity of the citation. After two years, violations are completely removed from a motor carriers record. All citations can be looked up in FMCSA’s DataQ system, and a Request for Data Review (RDR) can be submitted. Be prepared to provide any supporting documents.
Last, consider hiring legal representation for moving violations. These services have proven success rates for removing points from your record for a relatively small fee such as TVC ProDriver.
Work the plan. Knowledge of the most common violations and operating preventively can improve CSA scores over time. Being a trucker is tough enough as it is, but with determination and a compliance plan in place, you can protect your CSA score.