The document summarizes upcoming changes to the Compliance, Safety, Accountability (CSA) program in the US. Major changes include: (1) Moving non-HazMat cargo violations from the Cargo BASIC to the Vehicle Maintenance BASIC, (2) Renaming the Cargo BASIC to the HazMat BASIC, and (3) Changing the definitions of violations and their severity weights. The changes aim to address biases in the previous system and better focus on safety priorities like hazardous materials compliance. The changes will take effect in December 2012 with the next SMS data update.

1. • Drew Anderson | d.anderson@vigillo.com | (503) 688-5100 ext. 101
• Sloan Morris | s.morris@vigillo.com | (503) 688-5100 ext. 106
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2012 Vigillo LLC.
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3. • CSA Goal & Timing
• 3 Major Changes in SMS 3.0:
1) Maintenance: Non-HazMat Cargo
violations move to Vehicle Maintenance
2) HazMat: Cargo BASIC is now HazMat
3) Violations: Changing Violations & Severity
• Other CSA Changes
• Looking Ahead...
• Q&A
Copyright 2012 Vigillo LLC. All Rights Reserved.

4. CSA GOAL: “Compliance, Safety, Accountability (CSA)
is a Federal Motor Carrier Safety Administration
(FMCSA) initiative to improve large truck and bus safety
and ultimately reduce crashes, injuries, and fatalities
that are related to commercial motor vehicles.”
TIMING: The FMCSA has stated that SMS 3.0 changes
will go live “December 2012.” Vigillo believes this is likely
to occur simultaneously with the SMS monthly update,
scheduled to happen the week of December 3rd.
Remember: “If you can’t see my mirrors, I can’t see you.”
Copyright 2012 Vigillo LLC. All Rights Reserved.

5. WHAT IS THE CHANGE?
All cargo violations (except for HazMat-related) are now in the
Vehicle Maintenance BASIC.
WHY MAKE THIS CHANGE?
Carriers hauling predominantly open
trailers (e.g., flatbeds) were subject to
bias in the old Cargo-Related BASIC.
Copyright 2012 Vigillo LLC. All Rights Reserved.

6. BOTTOM-LINE:
 Unfair bias against flatbeds/open-deck
carriers in the Cargo BASIC is eliminated
 Impact of Cargo violations severely diluted: Cargo violations are
now only 4% of all vehicle maintenance violations – additionally,
most cargo violations now have a lowered severity weight
4%
 Conflicts with CSA’s stated mission?
Copyright 2012 Vigillo LLC. All Rights Reserved.

7. Analysis of Vigillo customer data:
Top Cargo Violation does not appear in Maintenance until #41
Copyright 2012 Vigillo LLC. All Rights Reserved.

8. Cargo Violations Re-Weighted as
they enter the new Maintenance BASIC
CSA 3.0 CSA 2.2 CSA 3.0 Severity Severity %
Violation Group Severity Weight Severity Weight Change Decrease
Failure to Prevent Movement 8 3 -5 -63%
General Securement 7 1 -6 -86%
Improper Load Securement 10 7 -3 -30%
Securement Device 7 1 -6 -86%
Tie-down 8 3 -5 -63%
Towing Loaded Bus 10 10 0 0%
Warning Flags 4 1 -3 -75%
Copyright 2012 Vigillo LLC. All Rights Reserved.

9. WHAT IS THE CHANGE?
• Old Cargo BASIC is renamed HAZMAT, scores private for 1 year
• Includes 238 old Cargo violations + 111 new HazMat violations
• Intervention threshold is 80 for all carriers for this BASIC
WHY MAKE THIS CHANGE?
• HazMat can increase severity of crashes
• Better identify and address safety
compliance problems related to HazMat
• Increase the ability of first responders
to mitigate consequences of HazMat spill
Copyright 2012 Vigillo LLC. All Rights Reserved.

10. BOTTOM-LINE:
 HazMat BASIC contains even thinner data than the Cargo BASIC did
 HazMat BASIC is almost exclusively focused on placards and compliance -
not direct safety issues
Copyright 2012 Vigillo LLC. All Rights Reserved.

11. BOTTOM-LINE: Appears to
introduce a bias against large carriers
who do not specialize in HazMat (LTL and
others). Data Sufficiency gives odd results
– Alert Status for large carriers on very
few violations
1,900
183,000,000
2011
1,675
Interstate
Copyright 2012 Vigillo LLC. All Rights Reserved.

12. Analysis of Vigillo customer data:
CSA 3.0 Methodology, Violations in Six BASICs
1.3% of all
violations
Copyright 2012 Vigillo LLC. All Rights Reserved.

13. Top 10 HazMat (CSA 3.0) Violations YTD 2012
2000+ Carriers in U.S. & Canada
Copyright 2012 Vigillo LLC. All Rights Reserved.

14. Also…Changing definition of “HazMat Carrier”
(a.k.a. “subject to placardable HM threshold”*)
*Determines Intervention Threshold for all BASICs except HazMat BASIC
Copyright 2012 Vigillo LLC. All Rights Reserved.

15. Also…Changing definition of HazMat Carrier
(a.k.a. “subject to placardable HM threshold”*)
*Determines Intervention Threshold for all BASICs except HazMat BASIC
Copyright 2012 Vigillo LLC. All Rights Reserved.

16. Is it possible for a non-HazMat Carrier
to get an alert in the HazMat BASIC?
xxxx
Yes. A motor carrier may not be subject to the placardable HazMat
threshold but still may have a score in the HazMat BASIC and, in fact,
have an alert. Strange – but true.
Copyright 2012 Vigillo LLC. All Rights Reserved.

17. WHAT CHANGED?
Violations have been added,
removed, and re-weighted.
SMS 3.0 lists 826 violations.
WHY MAKE THESE CHANGES?
With every SMS update, the FMCSA adds and removes some of the violations
listed, and also adjusts severity weights – FMCSA is listening to industry
BOTTOM-LINE:
 DON’T be surprised if there are no significant changes to CSA scores
 DO expect two rounds of violation changes in 2013
Copyright 2012 Vigillo LLC. All Rights Reserved.

18. HIGHLIGHTS
DRIVER FITNESS BASIC
Driving CMV while CDL is suspended/disqualified:
• Safety vs. Non-Safety
UNSAFE DRIVING BASIC
Speeding Violation Changes (retroactive):
• 1-5 MPH over limit are removed
• No MPH over limit listed = 1 point
FATIGUED DRIVING / HOS COMPLIANCE BASIC
Equal weight to paper and electronic logbook violations for
consistency (retroactive)
Copyright 2012 Vigillo LLC. All Rights Reserved.

19. Change the name of Fatigued
Driving (Hours-of-Service (HOS))
BASIC to “HOS Compliance BASIC”
Better align SMS with Intermodal
Equipment Provider (IEP) regulations
More accurately identify carriers
involved in transporting passengers
Copyright 2012 Vigillo LLC. All Rights Reserved.

20. Change SMS Display: Separate crashes with injuries
from crashes with fatalities
Change terms like inconclusive
& insufficient data to fact-
based descriptions
Eliminate vehicle violations Eliminate driver violations
&
from driver-only inspections from vehicle-only inspections
Copyright 2012 Vigillo LLC. All Rights Reserved.

21. Copyright 2012 Vigillo LLC. All Rights Reserved.

22. “We’re livin’ in the
future and, none
of this has
happened yet”
Bruce Springsteen
Copyright 2012 Vigillo LLC. All Rights Reserved.

23. • CSA Goal & Timing
• 3 Major Changes in SMS 3.0:
1) Maintenance: Non-HazMat Cargo
violations move to Vehicle Maintenance
2) HazMat: Cargo BASIC is now HazMat
3) Violations: Changing Violations & Severity
• Other CSA Changes
• Looking Ahead…
• Q&A
Slides, video, and reference material will be posted to the Vigillo Blog soon!
Copyright 2012 Vigillo LLC. All Rights Reserved.

24. Upcoming Events through March 2013
Week of Dec 3rd*  Vigillo live with SMS 3.0 updates
Dec 19th – 21st  WMCA Workers Compensation Seminar - Green Lake, WI
Feb 6th – 8th  NTTC Winter Membership & Board Meeting - Paradise Island, Bahamas
March 3rd – 6th  2013 TCA Annual Convention - Las Vegas, NV
March 10th - 14th  2013 TRALA Annual Convention - Naples, FL
Copyright 2012 Vigillo LLC. All Rights Reserved.

25. blog.vigillo.com
News & Updates at the Vigillo Blog
• Drew Anderson | d.anderson@vigillo.com | (503) 688-5100 ext. 101
• Sloan Morris | s.morris@vigillo.com | (503) 688-5100 ext. 106
Copyright
2012 Vigillo LLC.
Need Help? Vigillo Support: support@vigillo.com | (503) 688-5100 ext 102 All Rights Reserved.