Roadmap for CSA 2010

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All too often those of us in the safety business fail to adequately explain to political leaders and the public the importance of … reducing crashes and how it impacts on people’s lives as well as their economic situation, not to mention some of the other benefits such as reducing congestion, pollution, fuel usage and health care costs.” –Steve Keppler, interim executive director, Commercial Vehicle Safety Alliance (CVSA)

Following a ton of Congressional testimony this week, we’ve got a clearer picture of how the Federal Motor Carrier Safety Administration (FMCSA) is going to re-shape how it measures safety in the trucking industry via its new Comprehensive Safety Analysis 2010 (CSA 2010) program.

More importantly, we’ve now got a timeline governing CSA 2010 implementation – as well as a “heads up” on new regulations FMCSA is going to introduce to help support its new approach to motor carrier safety oversight.

Anne Ferro, FMCSA’s administrator, laid this all out in testimony this week before the House of Representatives Committee on Transportation and Infrastructure.

[She also endured some tough questioning from several members of Congress on how FMCSA manages trucking safety, including that of the committee’s chairman, James Oberstar (D-MN), which kicks off the clip below.]

Here are some of the critical parts of CSA 2010, how they will affect trucking, and when they’ll start going into full effect:

• A new Carrier Safety Measurement System (CSMS) will replace the current safety “scoring” system known as SAFESTAT. CSMS will use ALL available safety violation data, weighted by crash risk, to give inspectors what Ferro called a “more robust tool” for identifying high risk trucking companies for review. It also will be the basis for the Selection System roadside enforcement officers will use to focus their roadside inspections.

• CSA 2010 introduces a new strategy known as an “intervention,” framed four distinct levels: comprehensive on-site review (much like today’s compliance review); focused on-site investigations; off-site investigations; and warning letters. “Through a mix of these interventions, combined with roadside activity, we will increase the number of carriers we ‘touch’ and catch unsafe behaviors before it leads to a crash,” said Ferro.

• For CSA 2010 to reach its “maximum effect,” Ferro noted, a new piece of regulation is required, dubbed the “Safety Fitness Determination” or SFS rule. “This rule will ‘decouple’ a carrier’s safety rating from today’s on-site compliance review, enabling FMCSA to propose carrier safety ratings through CSMS, thereby increasing the number of carriers we rate annually ten-fold,” she added, pointing out that a notice of proposed rulemaking (NPRM) for the SFS rule is expected in early 2011.

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• Finally, the timeline: The official “roll-out” of CSA 2010 began in April this year with the launch of the data preview. The actual safety measurement system, though, gets previewed in late August, followed by full view to the public at the end of the year, said Ferro. All of CSA 2010’s remaining components – warning letters, NPRM, intervention process and more – will be established in stages through the end of fiscal year 2011. By that time, Ferro added, CSA 2010 is going to change its name and only be known by the initials “CSA,” which will stand for “Compliance, Safety, Accountability.”

FMCSA believes it’s on the right track with its new CSA 2010 system – a program it’s spent six years developing. This June, Ferro said her agency wrapped up a 2 ½ year, nine-state field test of CSA 2010, and Ferro told the committee FMCSA’s preliminary findings show that it achieved a 35% increase in investigations using this approach.

“We reached more carriers AND did so with greater efficiency,” she stressed. “We [also] have anecdotal evidence of carriers who examined and changed their business practices as the result of a CSA 2010 contact and improved their safety … further confirming the old adage, ‘what gets measured gets done.’”

There’s support for CSA 2010 within several corners the industry, based on safety performance rather than compliance with paperwork requirements; it focuses limited enforcement resources on specific areas of deficiency, rather than on comprehensive on-site audits; and because it will eventually provide real-time, updated, safety performance measurements.

However, there are a lot of concerns, too – especially as to how CSA 2010 affects the carrier-driver relationship, and not always for the better.

[For a really good overview of these worries, check out the clip shot by Canada’s TruckNews.com during a presentation last March given by Jet Express to review the difficulties CSA 2010 is going to impose on carriers.]

Keith Klein, CEO and executive VP of TL carrier Transportation Corporation of America, testified on behalf of the American Trucking Associations (ATA) and laid out some of the industry’s issues with FMCSA’s new safety program:

• The agency should make crash accountability or “causation” determinations on truck-involved crashes before entering them into a carrier’s record so drivers and carriers are held accountable only for crashes they cause.

• FMCSA should use vehicle miles traveled (VMT), not number of trucks or power units, as a carrier’s exposure measure.

• The agency must focus on using ONLY actual citations for moving violations and not un-adjudicated “warnings” issued by law enforcement.

The intent of raising these concerns is twofold, Klein said: “The first is a matter of safety, to ensure that unsafe carriers are selected for interventions, and the second is a matter of equity, to ensure that relatively safe carriers are not selected for interventions.”

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ATA has others concerns as well: how the severity weights for violations are assigned; measuring carriers based on violations committed by drivers who have since been terminated; measuring carriers based on citations that have been dismissed in a court of law; inequitable measurement of open deck or flatbed carriers; overly broad peer groups; and inconsistent state enforcement practices.

“A system that is based on inconsistent data and a flawed scoring methodology will not achieve its objectives,” he said. “Instead, it will create inequities for some safe carriers and inappropriately allow some unsafe carriers to avoid scrutiny and consequences.”

As CSA 2010 is going to be a “data driven” safety endeavor, several industry observers believe carriers need to gird themselves with specific technologies in order to cope.

Dale Reagan, vp-sales for software provider Tenstreet LLC and a 30-year trucking industry veteran who has worked as a recruiter, safety manager and driver for several private and for-hire fleets, says truckers should invest in programs that automate the collection of a potential driver’s work history, background checks, and more to quickly and accurately identify quality drivers.

He also believes trucking recruiters need to forego the unorganized and cumbersome paper file system and multiple fax communications that are still widely prevalent today.

“Instead they need to get properly organized by using a state-of-the art online program that is flexible and versatile,” he explained in a recent white paper Tenstreet put together on CSA 2010. “You obviously want to identify and hire the best possible drivers, processing and qualifying them to make certain those are the drivers you’re getting because, unfortunately, those best drivers don’t stay on the market very long.”

One key aspect of Tenstreet’s systems is digital signature technology, which “captures” a script signature as opposed to an electronic signature, which is not allowed.

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“Our customers are using these thousands of times a day, on their releases, to get employment transgressions, such as drug and alcohol violations, from previous employees,” said Reagan. “This new technology eliminates the old, time-consuming and paperwork-intensive hiring practices of the past, and more and more fleets are beginning to take notice.”

Reagan added that Tenstreet is offering fleets an option within its software system to create their very own “scoring system” to help weed out drivers that won’t qualify under CSA 2010 guidelines during the application process. “

It’s customizable and can include anything like moving violations, accidents, weight violations and more,” he noted. “Once a predetermined score or grade, is met, the system automatically rejects the applicant. Recruiters won’t even know the guy applied. Conversely, a quality applicant is quickly identified and jumps to the top of the list.”

More importantly, hanging onto the elite drivers in the era of CSA 2010 is going to be just as important as hiring them, Reagan stressed.

“Many trucking companies are so focused on how to recruit employees that they neglect to work to retain them afterwards,” he explained. “They need to know that programs are available to reach out to employees during vulnerable periods of their tenure and capture employees' perspective on how things are going.”

Training is yet another discipline that is slowly making the transition from pen and paper to mouse and computer screen, and this, too, will become all the more important as fleets search for new ways to cope with CSA 2010.

“There's a lot of data out there when it comes to CSA 2010, so the more communication and training you have with drivers, the safer your fleet is going to be,” added Tim Crawford, president of Tenstreet.

“Fleets were telling us they wanted a solution to help them better track communication with drivers, so that way, they could show responsiveness to the government’s new safety regime,” he noted. “They were telling us ‘CSA 2010 is really raising the stakes,’ particularly because under the new system, there's going to be more data that's discoverable and admissible. “

Perhaps the most important part of the CSA 2010 debate, said Steve Keppler, interim executive director for the Commercial Vehicle Safety Alliance (CVSA), is that this program can not only keep safety statistics moving in the right direction but save the nation a lot of money, too.

“First, there is some good news to report. The large truck fatality rate dropped by 12.3% in 2008, and is down 20.8% since 2005. There were more than 1,000 fewer deaths in 2008 from large truck crashes than there were in 2005,” he said in his Congressional testimony.

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“[Yet] The downturn in the economy certainly has played a role in this, and my fear is that as it begins to recover, as thankfully it looks to be the case, we will not have adequate resources to maintain these numbers, much less improve upon them,” he cautioned.

Most Americans, and in particular those employed in the truck and bus industries, are very conscious and concerned about the congestion that many of us live with and how it impacts our lives and commerce, said Keppler. What most do not realize, however, is that the cost of safety far outweighs the costs of congestion.

Traffic congestion is not only exasperating, it is costly. In Optimizing the System, the American Association of State Highway Transportation Officials (AASHTO) references a 2001 Texas Transportation Institute report examining the costs of congestion in America’s 85 largest urban areas.

“An astronomical 3.5 billion hours of people’s time and 5.7 billion gallons of fuel were wasted in 2001 because of congestion. The cost of these squandered resources is a staggering $69.5 billion,” the report noted.

However the AASHTO report goes on to say something else, Keppler stressed: “As bad as this is, there’s an immeasurably more costly and tragic measure of the system’s performance: the human toll. Every year, more than 43,000 people are killed and nearly 3 million are injured in crashes on our nation’s roads and highways – and the annual economic cost of vehicle crashes is over $230 billion dollars.”

That, in his view, is but another example of why new safety efforts such as CSA 2010 are needed.

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And on that note, ladies and gentlemen, this reporter is taking a VERY necessary break from this blog (oh my aching fingers!) We’ll see you back here July 6 – and may any journey you take on our nation’s highways be completed safe and sound.

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