The Federal Motor Carrier Safety Administration said it’s moving ahead with changes to the Safety Measurement System (better known as CSA scores) that it proposed early last year, although it has not yet announced a date when they will be effective.

The agency published a notice on Nov. 20 outlining the changes, any tweaks it has made to them based on the comments it received on the proposal, and responding to some of those comments.

In February 2023, FMCSA proposed a number of changes, including:

• Reorganizing and renaming the SMS categories (known as “BASICs”).

• Organizing roadside violations into violation groups for prioritization purposes.

• Simplifying violation severity weights.

• Focusing on more recent violations.

• Adjusting some of the thresholds that identify companies for possible intervention.

• Changes aimed at better comparing similar motor carriers to each other.

It also made a preview website available so carriers could see what their scores would look like under the new system.

​Most of the comments the FMCSA received on the proposal were generally supportive of the proposed changes. The most comments came on the reorganized safety categories, consolidated violations, simplified severity weights, and greater focus on recent violations. 

What is SMS and Why Was Change Needed?

The SMS was introduced in 2010 under the Compliance, Safety, Accountability (CSA) program (at the time called CSA 2010) as a way for the agency to identify high-risk motor carriers for inspections and enforcement actions. 

The system analyzes safety data, including roadside inspections and crash records, to generate scores in specific safety categories (formerly called BASICs). 

SMS also provides motor carriers and other stakeholders with safety performance data, updated monthly, through the public website at https://ai.fmcsa.dot.gov/​SMS. 

But the SMS has been the target of a range of criticisms as far as its true ability to identify unsafe motor carriers. 

In 2017, Congress demanded FMCSA commission an independent study of SMS. After that research, the National Academy of Sciences recommended the agency use what they said was a better statistical model as the backbone of the system: Item Response Theory, or IRT.

The agency created a model and tested IRT, ultimately rejecting it, among other things because of its complexity.

But that process did bring insights into the shortcomings of SMS, which the FMCSA used to make changes it believes address many of the complaints.

Let’s dig into the changes as FMCSA outlined them in its November 20 notice in the Federal Register.

What Did BASICs Stand for, Anyway?

The SMS categories previously known as Behavior Analysis and Safety Improvement Categories, or BASICs. Now they will simply be called “Compliance Categories.” 

The original proposal called them “safety categories,” but FMCSA changed that in response to industry comments. (Since few people actually could remember what BASICs stood for anyway, this change seemed like a no-brainer.)

Brandon Wiseman, writing about the changes at Trucksafe.com, identified what he called two key structural changes:

• Combining Controlled Substances/Alcohol (CS/A) violations into the Unsafe Driving Compliance Category. 

• Splitting Vehicle Maintenance into two categories: Vehicle Maintenance and Vehicle Maintenance: Driver Observed.

Revised Unsafe Driving Category

A revised Unsafe Driving category is now called Unsafe Driving. It now incorporates Controlled Substances/Alcohol (CS/A) violations and all operating while Out-of-Service violations. 

In its comments, the American Trucking Associations called the change “logical.” Drug and alcohol-impaired driving is a form of unsafe driving, they said, and grouping all Operating while OOS violations under Unsafe Driving will help “enforcement personnel more easily identify motor carriers who have violated OOS orders.”

The National Tank Truck Carriers association, however, expressed concern that this change may dilute the severity of CS/A violations and make it harder to identify carriers that employ drivers engaged in unsafe behaviors related to the use of controlled substances and alcohol.

Splitting Vehicle Maintenance Violations Into Two Categories

The new methodology splits the vehicle maintenance BASIC, which is the largest, into two separate Compliance Categories:

• Vehicle Maintenance: Driver Observed (new)

• Vehicle Maintenance 

As Wiseman explained in an interview with HDT last year following the initial proposal (see clip below), “You can kind of think of maintenance violations in two categories. You can think of them as maintenance issues that could have been discovered by the driver had they done a thorough pre trip or post trip inspection, as the regulations require.”

But there are also vehicle maintenance violations that weren't necessarily discoverable by the driver in a routine inspection.

“Things that could only be discovered by a mechanic, for example, in a more thorough inspection of the vehicle.

“So we want to separate those out so that we can really get to the root of the problem.”

As ATA noted, the change “will allow for greater distinction between vehicle maintenance violations that are indicative of vehicles in poor maintenance condition regardless of the thoroughness of the driver performing a pre- or post-trip inspection that day.” 

Several commenters also noted that the change has the potential to protect drivers from being held accountable for violations that they could not have reasonably discovered during a pre-trip inspection.

Segmenting Driver Fitness and HazMat By Carrier Type

FMCSA plans to segmenting the Driver Fitness category based on whether motor carriers operate primarily straight trucks or combination vehicles. Similarly, it is segmenting the Hazardous Materials category by whether carriers operate tankers or not.

Straight carriers are defined as those with more than 30% of the total power units in their fleet being straight trucks/other vehicles. Combination carriers are defined as having 70% or more of the total power units in their fleet are combination trucks/motorcoach buses.

ATA noted that this new segmentation “addresses inequities that have existed in the current CSA SMS” and “will allow for greater accuracy in identifying safety controls.” 

NTTC said segmenting the hazmat category this way could “tremendously reduce the opportunity for a cargo tank truck to get more violations than a van truck due to many inherent trailer differences.” 

FedEx in its comments encouraged the agency to explore further segmentation between small package and palletized freight.

Consolidating Violations into Groups

In an effort to simplify the SMS system, FMCSA is reorganizing the existing 959 roadside violations into 116 violation groups.

This is designed to make the system easier for carriers and other stakeholders to understand and help improve consistency in enforcement of violations with similar underlying safety issues. 

FMCSA analyzed the overall effectiveness of the proposed changes compared to the current SMS and found that these changes would increase the number of carriers prioritized for intervention by 3% — and that this group of prioritized carriers would have a crash rate 10% higher than those currently prioritized by SMS.

Simplified Violation Severity Weights

Up until now, violations in the SMS have been assigned weights ranging from 1 to 10, based on severity. The FMCSA now plans to use a simplified scale of 1 or 2, with higher weights for out-of-service violations and severe infractions. 

“Another major criticism with the current program is how subjective the severity weights are,” Wiseman said. “Obviously the more serious ones carry a heavier weight, and therefore they impact the motor carrier scores more dramatically than the more minor violations. It makes sense to have something like that built into the system, because you don't want to be penalized for a more minor violation in the same way that you're penalized for a significant violation. But the way that it was done currently was very subjective and it was overly complicated.”

Commenters had mixed reactions to this one. Many agreed with moving away from the 1 to 10 scale but were concerned that a 1 or 2 weighting simplifies it too much.

FMCSA explained that in its analysis, it found that assigning a customized weight to all violations was not as important as noting that the violation occurred. The number of violations a carrier has is a strong indicator of its safety compliance, or lack thereof, it said. Carriers with poor safety management practices have patterns of violations across the compliance categories — regardless of each violation's level of egregiousness. Conversely, carriers with strong safety management practices have fewer violations per inspection.

Moving to Proportionate Percentiles

The “safety event groups” that have been used in the SMS to try to group similar carriers together are being replaced with a calculation that determines “proportional percentiles.”

The Owner Operator Independent Drivers Association noted in its comments that this change “should help protect small-business truckers from witnessing radical jumps in their [percentile] without reason.”

In analyzing the proposal last year, Wiseman said he found this to be the most complex part of the potential changes. But he explained why FMCSA was making the change:

The “safety event groups” were the way FMCSA tried to avoid comparing a small carrier that may have only a handful of inspections or violations in a year with a big carrier that may have thousands.

In each of the seven BASIC categories, fleets are placed into a safety event group based on how many inspections you have had with violations in that particular category.

“So for example, a carrier that has had 10 inspections with hours of service violations over the last two years will normally be compared against other carriers that have a similar number of inspections,” Wiseman explained.

“But what we found is that sometimes, [getting] one more inspection, for example, would jump them up to the next safety event group, and then we would see wild swings in their CSA scores… [because suddenly] they're being compared against an entirely different set of motor carriers. So that has a big impact on their CSA scores. And many argued that that wasn't fair.”

Improved Intervention Thresholds

The thresholds that determine when carriers are prioritized for interventions were adjusted in specific categories – both maintenance categories, driver fitness, and hazardous materials. 

OOIDA expressed concern about the high thresholds for the driver fitness and hazmat categories.

FMCSA responded that its analysis shows some categories have a higher correlation to crash rate than others. 

Greater Focus on Recent Violations

FMCSA will calculate percentiles only for carriers with cited violations in the past 12 months, allowing enforcement efforts to focus on carriers with more recent safety issues.

This change applies to the Hours of Service, Vehicle Maintenance, Vehicle Maintenance: Driver Observed, Hazardous Materials, and Driver Fitness Compliance Categories. 

Commenters were generally in favor of this change, saying it will be a more accurate assessment of the motor carrier's current safety performance and keep fleets, especially smaller ones, from being unfairly penalized by past mistakes.

ATA suggested this approach be applied to all categories.

Updated Utilization Factor

FMCSA is extending the cap on the Utilization Factor to 250,000 vehicle miles traveled per average power unit, up from the previous 200,000.

The Utilization Factor uses a carrier's VMT per average number of PUs, or vehicles, to account for different levels of on-road exposure to inspections and crashes.

Other Changes to SMS:

FMCSA has implemented further refinements based on comments received on the proposal. Wiseman summarized them as follows: 

• Reorganization of Violations: Some violations were reclassified to better align with their root safety issues. 

• HOS and Brakes Adjustments: Overlapping violation groups were consolidated for consistency. 

• Frequency of Updates: FMCSA is exploring more frequent updates to the SMS website to reflect real-time safety data.

What’s Next for Motor Carriers?

“FMCSA’s enhanced SMS methodology will be a significant shakeup in the way CSA scores are calculated,” Wiseman said. 

He recommended that motor carriers familiarize themselves with the new methodology, engage in available training, and evaluate their safety practices in light of the planned changes. 

Opportunities for more information, including a webinar series on the changes, will be announced on the Prioritization Preview website in the coming months.

A follow-up notice in the Federal Register will announce the launch date of the enhanced SMS website.

Watch my full 2023 interview with Brandon Wiseman on the proposed changes: