Compliance and Safety Accountability (CSA) is a program of the Federal Motor Carrier Safety Administration (FMCSA) for the purpose of helping motor carriers comply with federal regulations. It institutes three levels of intervention known as Early Contact, Investigation, and Follow-On. CSA interventions help to determine the reason for safety issues and recommend solutions to correct them. It also issues penalties to non-compliant motor carriers. Below is a brief description of each of these forms of CSA intervention.
How does CSA intervention work?
One of the first forms of contact the CSA program makes with a motor carrier is a warning letter. The letter states specific problems regarding compliance and safety as well as consequences the motor carrier may face for not complying with the demand to correct specific issues. The most common consequence is the requirement to adhere to an onsite or offsite investigation.
A targeted roadside inspection is the second phase of early contact. This typically takes place at a temporary or permanent location for a roadside inspection. Before conducting this inspection, the CSA has received data indicating specific safety issues.
A safety investigator may conduct one of the following three types of investigations:
- Offsite Investigation: The safety inspector requests copies of documents from the motor carrier and reviews them at another location. The purpose of reviewing the documents is to detect specific compliance problems and safety performance issues.
- Onsite Focused Investigation: For this type of investigation, the safety inspector may interview employees, inspect vehicles for safety issues, and conduct other types of onsite research.
- Onsite comprehensive investigation: This in-depth review requires the safety inspector to conduct a review of the motor carrier’s entire business on location. Inspectors typically reserve this type of investigation for the most serious types of safety violations.
The follow-on phase of CSA intervention consists of these four phases:
- Cooperative Safety Plan: A motor carrier can voluntarily choose to draft a plan to address specific safety issues with input from a safety inspector. It can be submitted on its own or in addition to a Notice of Violation, but it cannot be submitted in place of a Notice of Claim.
- Notice of Violation: This formal notice informs motor carriers that a violation has sufficient severity for the CSA to take formal action but not impose any civil penalties. The motor carrier must perform corrective action at this point to avoid further sanctions from the FMCSA.
- Notice of Claim: This notice informs the motor carrier that its infractions are severe enough to receive a formal assessment and civil penalties.
- Operation Out of Service Order: This order indicates that the motor carrier must cease operation of all its motor vehicles immediately.
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