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Safety & CSA

Conditional safety rating: what it means for your fleet and how to fix it

By the Off Duty Not Driving Rewards teamOctober 202611 min read

In this article:
  1. What is a conditional safety rating?
  2. How FMCSA assigns a conditional rating
  3. Worked example: three fleets, three outcomes
  4. The conditional rating timeline
  5. What triggers a compliance review?
  6. How long does a conditional safety rating last?
  7. Conditional vs unsatisfactory: what each one does
  8. How to fix a conditional safety rating
  9. Administrative review: when FMCSA got it wrong
  10. How to check a carrier's safety rating
  11. Safety rating vs CSA score
  12. MVR checks and the Driver factor
  13. Is the safety rating system changing?
  14. Where a driver rewards program fits
  15. Glossary of acronyms
  16. Rebuild with recognition, not shortcuts

A conditional safety rating is the Federal Motor Carrier Safety Administration's (FMCSA's) middle rating. Under 49 CFR 385.3, it means a carrier lacks adequate safety management controls, and that gap "could result" in the problems listed in 385.5. As of October 2026, it does not stop you operating. You can request an upgrade at any time under 385.17.

The rest of this guide shows how FMCSA scores the rating, the clock that starts with the notice, and the upgrade request, step by step.

A rewards program won't fix a rating. Fixing it means repairing the controls named in your notice. Off Duty Not Driving Rewards is a rewards program for trucking fleets. Contact our team to learn more.

What is a conditional safety rating?

A safety rating is FMCSA's judgment of whether a motor carrier meets the safety fitness standard in 49 CFR 385.5. There are three ratings plus "unrated." As of October 2026 (final, in effect), 385.3 defines them:

RatingDefinition (49 CFR 385.3)
SatisfactoryThe carrier "has in place and functioning adequate safety management controls" to meet the 385.5 standard
ConditionalThe carrier "does not have adequate safety management controls in place to ensure compliance with the safety fitness standard that could result in occurrences listed in § 385.5"
UnsatisfactoryThe same lack of controls, "which has resulted in occurrences listed in § 385.5"
UnratedNo safety rating has been assigned

The difference between Conditional and Unsatisfactory is two words: "could result" versus "has resulted."

The occurrences in 385.5 cover commercial driver's license (CDL) violations, inadequate insurance, unqualified drivers, improper driving, unsafe vehicles, missing accident registers, fatigued drivers, poor inspection and maintenance, hazardous materials (hazmat) violations, and crashes. "Safety management controls" are, in 385.3's words, "the systems, policies, programs, practices, and procedures" a carrier uses to stay compliant. A "conditional DOT rating" is the same thing; FMCSA is the Department of Transportation (DOT) agency that assigns it.

How FMCSA assigns a conditional rating

A carrier gets a rating after a compliance review: an examination of records such as hours of service, maintenance, driver qualification, insurance and accidents (385.3). New-entrant safety audits do not produce ratings. FMCSA applies the factors in 385.7 through the methodology in Appendix B to Part 385, and issues the rating within 30 days of the review (385.9).

Appendix B works like this, as of October 2026:

  1. Acute and critical regulations. Acute violations are so severe they need immediate correction. Critical violations point to a breakdown in management controls. Appendix B lists every one.
  2. Points. One point for each acute violation, and one for each pattern of critical violations. A pattern is more than one violation, and when documents are sampled it means at least 10% of those examined. A pattern of hours-of-service (HOS) critical violations counts two points.
  3. Six factors. General (Parts 387, 390); Driver (382, 383, 391); Operational (392, 395); Vehicle (393, 396); Hazmat (397, 171, 177, 180); and Accident.
  4. Factor ratings. 0 points = Satisfactory, 1 point = Conditional, 2 or more = Unsatisfactory.
  5. Two special factors. The Vehicle factor starts at Conditional if the vehicle out-of-service rate is 34% or more (with at least three inspections). The Accident factor applies only with two or more recordable accidents in the prior 12 months, and is Unsatisfactory above 1.5 recordable accidents per million miles (1.7 for urban carriers).

Then the factor ratings go into the rating table:

Unsatisfactory factorsConditional factorsOverall rating
02 or fewerSatisfactory
0more than 2Conditional
12 or fewerConditional
1more than 2Unsatisfactory
2 or more0 or moreUnsatisfactory

Worked example: three fleets, three outcomes

These three fleets are invented to show the arithmetic in Appendix B. Illustration only.

Fleet AFleet BFleet C
FindingPattern of false logs (395.8(e)(1), critical)Pattern of missing driving-record inquiries in driver files (391.51(b)(2), critical) and pattern of not requiring DVIRs (396.11(a), critical)Fleet A's false logs + Fleet B's two findings + pattern of missing accident report copies (390.15(b)(2), critical)
Points by factorOperational: 2 (HOS counts double)Driver: 1; Vehicle: 1Operational: 2; Driver: 1; Vehicle: 1; General: 1
Factor ratings1 Unsatisfactory2 Conditional1 Unsatisfactory, 3 Conditional
OverallConditionalSatisfactoryUnsatisfactory

Two lessons for a safety director. A single HOS pattern can produce a Conditional rating on its own, because HOS patterns score double. And the line between Conditional and Unsatisfactory can be a handful of paperwork patterns in other factors.

The conditional rating timeline

The clock starts at the compliance review. As of October 2026 (final, in effect):

StepTimingRule
Written notice of the rating, with the list of deficiencies to correctNo later than 30 days after the review385.11(a)
A proposed Conditional rating becomes final60 days after the notice (45 days for placardable hazmat and passenger carriers)385.11(c)
Request a rating change based on corrective actionAny time385.17(a)
Request administrative review for an FMCSA errorWithin 90 days of the proposed or final rating385.15(c)(2)

One wording conflict to know about. The sample notice text in Appendix B to Part 385 (section III.B) still says a proposed rating becomes final "45 days after receipt of this notice" for every carrier. Section 385.11(c), the operative rule, says 60 days for carriers that don't haul placardable hazmat or passengers. Go by 385.11 and the date on your own notice. (A Conditional rating that improves an earlier Unsatisfactory is final on the notice date, under 385.11(b).)

One timing gap matters. 385.17(e) gives FMCSA 30 or 45 days to answer upgrade requests from carriers rated Unsatisfactory. The regulation sets no deadline for answering a Conditional carrier's request, so don't plan around one.

What triggers a compliance review?

A compliance review is not random. Under 385.3, FMCSA may conduct one "in response to a request to change a safety rating, to investigate potential violations of safety regulations by motor carriers, or to investigate complaints or other evidence of safety violations." In practice, the CSA program feeds the second category: FMCSA lists offsite and onsite investigations among its interventions for carriers whose data flags them (FMCSA CSA: Intervene). A review can also lead to an enforcement case, separate from the rating.

How long does a conditional safety rating last?

Part 385 sets no expiration date for a safety rating. As of October 2026, a Conditional rating stays on your record until FMCSA assigns a new one. That happens after a new compliance review, or when FMCSA grants a change request under 385.17. Waiting it out is not a strategy: the rating changes only when your documented operations do.

New carriers are a separate case. A new entrant is monitored for 18 months, and its safety audit must happen within 12 months of receiving its USDOT number for property carriers (120 days for passenger carriers). That audit is pass or fail, and safety audits "do not result in safety ratings" (385.3). A new carrier can stay "unrated" while passing its audit.

Conditional vs unsatisfactory: what each one does

Conditional and Unsatisfactory carry very different consequences in Part 385:

ConsequenceConditionalUnsatisfactory
Prohibited from operating CMVsNoYes, from day 61 after the proposed-rating notice (day 46 for hazmat and passenger carriers) (385.13(a))
Federal agencies barred from using the carrierNoYes (385.13(b)–(c))
Out-of-service order and revocation of operating authorityNoYes, when the rating becomes final (385.13(d)–(e))
Rating shown publicly on SAFERYesYes

Nothing in Part 385 bars a Conditional carrier from operating. Brokers, shippers and insurers may have their own policies about Conditional carriers, but those are private business decisions, not regulation, and they vary.

How to fix a conditional safety rating

You fix a Conditional rating by correcting the deficiencies and then asking FMCSA to re-rate you under 49 CFR 385.17. The steps, as of October 2026:

  1. Read the deficiency list. The notice under 385.11(a) lists the regulations you must correct. That list is your scope.
  2. Find the broken control behind each item. A pattern of false logs is a symptom. The cause is usually a missing log-audit process, a dispatch practice that pushes drivers past their hours, or untrained staff.
  3. Correct it and keep proof. New policies, training records, audit logs and corrected files.
  4. Write the request. 385.17(c) requires "a written description of corrective actions taken" plus any documentation you want considered. It must show your operations now meet 385.5 and 385.7.
  5. Send it to the right office. Requests go in writing to the FMCSA Service Center for the region of your principal place of business (385.17(b); addresses in 390.27).
  6. Wait for the decision. FMCSA decides on the documents and any other relevant information (385.17(d)). It notifies you in writing of an upgrade (385.17(h)) or a denial (385.17(i)).
  7. If denied, you may request administrative review within 90 days of the denial (385.17(j)).

Our safety management plan template for a conditional rating turns steps 2 to 4 into a fill-in document.

Administrative review: when FMCSA got it wrong

Administrative review is for disputing the rating itself. Use 385.15 if you believe FMCSA made an error, not if you've fixed problems since. Plain version: 385.17 says "we fixed it, re-rate us"; 385.15 says "you got it wrong."

The request must explain the error and list "all factual and procedural issues in dispute," with supporting documents. It goes to the Assistant Administrator, ATTN: Adjudications Counsel, at FMCSA headquarters, within 90 days of the proposed or final rating. FMCSA may ask for more data or a conference, and the decision is final agency action.

How to check a carrier's safety rating

Safety ratings are public. FMCSA's Safety and Fitness Electronic Records (SAFER) System at safer.fmcsa.dot.gov shows a carrier's current rating, or you can call (800) 832-5660 (385.13(a); 385.19). Search by carrier name or USDOT number. If you're checking carriers with a conditional safety rating before you contract with them, the rating and its date are the facts to record.

Safety rating vs CSA score

Your Compliance, Safety, Accountability (CSA) results are not your safety rating. The rating comes from a compliance review under Part 385. CSA's Safety Measurement System (SMS) is a separate monthly ranking built from the last two years of roadside inspections and crash reports, plus investigation data (FMCSA CSA: Measure).

What "CSA score" actually means, as of October 2026:

  • There is no single CSA score. SMS gives a separate percentile in each of seven Behavior Analysis and Safety Improvement Categories (BASICs): Unsafe Driving, Crash Indicator, HOS Compliance, Vehicle Maintenance, Controlled Substances/Alcohol, Hazardous Materials Compliance and Driver Fitness.
  • Higher is worse. For most trucking fleets, FMCSA's intervention thresholds are 65% for Unsafe Driving, Crash Indicator and HOS Compliance, and 80% for Vehicle Maintenance, Controlled Substances/Alcohol and Driver Fitness (SMS Methodology v3.21, June 2026, Table 2-2).
  • Property carriers' percentiles aren't public. Under the FAST Act, FMCSA removed them from public view; checking your CSA score means logging in to see your own (89 FR 91874).
  • FMCSA says SMS is not a rating. Its site warns: "Readers should not draw conclusions about a carrier's overall safety condition simply based on the data displayed in this system" (FMCSA SMS).
  • The CSA program is changing, but not yet. FMCSA announced an enhanced SMS that renames BASICs as "compliance categories" in November 2024 (89 FR 91874). As of October 2026 it has not launched.

High BASIC percentiles can lead to warning letters or investigations, and a compliance review is what produces a rating. Our guides cover how to improve CSA scores and whether CSA scores affect insurance.

MVR checks and the Driver factor

The Driver factor (Parts 382, 383 and 391) is where motor vehicle record (MVR) checks show up in a review. As of October 2026 (final, in effect):

  • At hire: request an MVR report within 30 days from every state where the driver held a license in the preceding 3 years (391.23).
  • Every year: run an MVR check and review it "at least once every 12 months," giving "great weight" to violations such as speeding, reckless driving and driving under the influence (391.25).
  • Keep it on file: the driver qualification (DQ) file stays for the length of employment plus 3 years (391.51).

Appendix B lists "failing to maintain inquiries into driver's driving record" in the DQ file (391.51(b)(2)) as a critical regulation. A pattern of missing MVRs is one point on the Driver factor.

Is the safety rating system changing?

Not yet. FMCSA opened a rulemaking on Safety Fitness Determinations with an advance notice of proposed rulemaking (ANPRM) at 88 FR 59489 (Aug. 29, 2023), followed by a notice of data availability at 89 FR 2195 (Jan. 12, 2024). As of October 2026 we found no proposed or final rule in the Federal Register. The three-tier system and Appendix B methodology above still apply.

Where a driver rewards program fits

A rewards program does not fix a safety rating, and no vendor should tell you it does. The upgrade comes from correcting the specific controls in your notice and documenting them.

What a recognition program can do is support the culture after the fix. FMCSA's Safety Management Cycle for the Unsafe Driving BASIC lists six safety management processes. The sixth, Meaningful Action, says to "design and implement incentives and/or recognition programs in order to reward and encourage safe driving behavior." It also warns: "Do not use on-time delivery incentives, which could encourage speeding" (FMCSA SMC, Unsafe Driving). FMCSA's guidance is a recommendation, not a requirement, and does not endorse any vendor.

Off Duty Not Driving Rewards is a rewards program for trucking fleets. Contact our team to learn more.

Glossary of acronyms

TermMeaning
BASICBehavior Analysis and Safety Improvement Category
CDLCommercial driver's license
CFRCode of Federal Regulations
CMVCommercial motor vehicle
CSACompliance, Safety, Accountability (FMCSA's enforcement program)
DOTU.S. Department of Transportation
DQ fileDriver qualification file
DVIRDriver vehicle inspection report
FMCSAFederal Motor Carrier Safety Administration
HOSHours of service
MVRMotor vehicle record
SAFERSafety and Fitness Electronic Records System
SMCSafety Management Cycle
SMSSafety Measurement System

Rebuild with recognition, not shortcuts

Fix the controls first. When you're ready to recognize the drivers who keep your record clean: Off Duty Not Driving Rewards is a rewards program for trucking fleets. Contact our team to learn more.