The Federal Motor Carriers Safety Administration (FMCSA) is in the process of rolling out its new Comprehensive Safety Analysis program. Commercial tire dealers who understand the ins and outs of the new initiative can take serious advantage of using the program to promote their dealership’s service and support for commercial trucking fleets.

But first, let’s take a look back at the background of the CSA initiative. Until just recently, this new safety program for commercial fleets was known as CSA 2010. Since the program won’t officially begin until 2011, the feds have decided to change the program name to CSA (dropping the 2010).

There is also a change in what the “C” designation signifies – it is now “Compliance” in place of “Compre­hensive” – as well as what the “A” stands for – “Account­ability” rather than “Analysis.”

CSA is being implemented to improve the effectiveness of FMCSA’s compliance and enforcement programs using data to identify high-risk carriers and drivers. FMCSA currently uses a software program called SafeStat to measure fleet and driver performance. SafeStat has been around for years and will now be replaced by Safety Measurement System (SMS). You can tell the government is involved with this program, since there are new acronyms that we all will need to learn and understand.

The key to SMS is that every roadside inspection counts, not just the previous two years of crash data and roadside violations. The heart of SMS is another acronym called BASIC, or Behavioral Analysis Safety Improvement Category. There are seven categories within BASIC, and SMS assigns weights or numbers to each carrier and driver violation.

The seven BASIC categories are:

• Unsafe driving
• Fatigued driving
• Driver fitness
• Drug and alcohol use
• Load securement
• Crash history
• Vehicle maintenance

Tire dealers must understand the vehicle maintenance category in order to take full advantage of CSA in growing their businesses. There are seven categories within Vehicle Maintenance:

• Lights not working
• Conspicuity marking inadequate
• Brakes
• Suspension
• Steering
• Periodic Inspections
• Tires

The CSA scoring system for violations is quite involved and is weighted based on the relationship to crash risk. It is important to understand the overall scoring system to demonstrate how important tires are to the entire program.

Violations are ranked from one to 10, with 10 being the worst. Two points are added for the “bad” stuff, which includes cargo loading issues, driver fatigue and vehicle maintenance – tires are included under maintenance. In addition to the one to 10 ranking, violations are time weighted: three points for less than six months, two points for six to 12 months, and one point for more than 12 months. The actual point total is known as SFD, or Safety Fitness Determination.

If a trucking fleet reaches the bottom 23rd percentile in SFD points when compared to other fleets of similar size, the CSA intervention process begins. The intervention process becomes progressively more stringent if corrections are not made in a timely basis.

Quick Reference Guide

Remember the following acronyms and terms to aid in helping your fleet customers meet the new criteria:

FMCSA – Federal Motor Carrier Safety Administration

CSA 2010 – Comprehensive Safety Analysis

CSA (beginning in 2011) – Comp­liance Safety Accountability

SafeStat – Old Software program for drivers and fleet performance

BASIC – Behavioral Analysis Safety Improvement Category

SMS – Safety Management System

SFD – Safety Fitness Determination

Step one in the intervention process is a letter to the carrier notifying it of safety issues within its fleet that it must address and correct. Failure to correct these issues leads to step two, in which a red flag is raised for increased roadside inspections. Step three is an on-site inspection in which a Corrective Action Plan is published. Step four is a “cease operations order.”

Role of Tires
As a tire dealer, this is a huge opportunity to work more closely with commercial fleets to support their tire program. Fleets cannot afford to be penalized for the results of a poor tire maintenance program. Let’s take a closer look at the violations and points associated with tire issues.

Tires that are damaged or flat have a rating of eight (out of 10). If the lowest measured tread depth is below the legal limit of 4/32nds for steer tires and 2/32nds for drive/trailer tires, there is also an eight-point penalty. If any tire is found to be underinflated, a severity level of three is the penalty.

There still is a big question regarding underinflated tires: When is a tire considered underinflated? Industry standards regarding tires currently say when a tire is 20% under the recommended inflation pressure, that tire is considered “flat.” But there is no clear definition as to the magic number for how much a tire is underinflated before you get three points deducted. Whether this is two psi, five psi or 10 psi will have to be clarified by CSA.

Also consider the accuracy of the tire pressure gauge used by the “checker.” Tire pressure gauges are not very accurate; they provide +/-3% readings when they are brand new out of the box. As a pressure gauge wears, the spring tension changes and the accuracy decreases even further. And what about a “hot” tire, since the air pressure in truck tires increases about 15% when they are hot?

Here’s an example of an underinflated tire calculation (assume similar recent events occurred within the last three months):

• Three points for underinflated tire
• Two additional points since tires fall under the maintenance category
• Add three plus two and multiply by three, since the events occurred within the last three months
• The total is 15 penalty points

A fleet rating is determined by doing similar calculations for all BASIC categories. You clearly can see that the points can rapidly add up for even a single underinflated tire. Because of this fact, fleets will require serious support from their tire professional to optimize their tire programs. Tires will need to be monitored much more closely.

Inside dual tires, both tractor and trailer, are typically the underinflated tires on any vehicle because they require more work to check. Bending down and reaching inside the wheel hand hole is not a lot of fun – you get dirty and your back hurts.

Tires lose air from tire osmosis (1-3 psi/month), leaking valve core/stem, nail punctures or damage. Fleets will require help to ensure their tires are properly inflated, have the legal tread depth and are not damaged. Now is the time to visit your commercial fleet customers to explain CSA and the impact of tires within the program.

Studying Results
CSA will actually generate two types of reports. The first report is related to the fleet, while the second report is about its drivers. These two reports are based on input data from roadside inspections and crashes.

The driver report will help a fleet in its driver recruitment efforts. If a driver worked for five different fleets in the last four years and had an incident or accident at each of those carriers, all of that information will be available for a fleet to review prior to de­ciding if this driver would be a good candidate for its operation. CSA will not have the power to revoke a driver’s CDL based on the score in the report; only a state can revoke a CDL. However, driver intervention will take place when a specific driver’s score is in the lowest 10th percentile as compared with other drivers.

The second report is the overall fleet report, which gives a point total and lets the fleet know where it stands relative to similar fleets. When a fleet reaches the bottom tier, the intervention process begins.

As you can tell, CSA is a changing program. You can download the most recent version – currently a 95-page PDF – by visiting csa2010.fmcsa.dot.gov. Take advantage of understanding the entire CSA program so you can support fleets when it comes to tires.