How are carriers really doing with CSA?

I received some interesting information from a member of my safety/compliance roundtable group. How is the CSA program really working?  Here are some facts:

The Safety Rating is everything to a Motor Carrier.  In 2010 (pre-CSA) the FMCSA issued 13000 Safety Ratings during Compliance Reviews (CR's).  In 2011 they issued Safety Ratings to 9000 motor carriers.  In 2012 (remember, the Fed's year starts in September) they are on track to issue 6000 Safety Ratings. 

The Agency does not have to issue a rating during a Compliance Review.  In 2010, 139 CR's resulted in no Safety Rating.  In the first quarter of 2012 alone, 569 CR's resulted in no Safety Rating.  Could it be that no Safety Rating is issued if the carrier has no serious violations? It appears that safety investigators are staying on site as long as necessary to find critical or acute violations.  It has been reported that investigators are staying from 3-11 weeks on site. You can find the information here: 

http://www.ai.fmcsa.dot.gov/SafetyProgram/spRptReview.aspx?rpt=RVFR

I was reminded by my colleague that CSA rates on a curve.  You may be OK, and drop to"not OK" in a single month - if those below you go out of business or improve. 

What can you do?  Have written policies regarding driver discipline, speed limits, drug and alcohol testing, cell phone use, load securement or bulk cargo containment, and Driver Vehicle Inspection Reports.  Monitor and measure your drivers' performance.  Only operate equipment when necessary, cut down on deadhead and non-revenue producing miles.  If possible, route vehicles around congested times and roadways.  Always think in terms of minimizing exposure.