You may recall that this new enforcement regime referred to as CSA for Compliance, Safety, Accountability, changes the way government assesses the on-the-road performance of thousands of companies falling within DOT’s oversight. While it’s still too early to know the impact and effectiveness of the new system, I can report on some of the early experience carriers are reporting with the conversion to CSA.
Perhaps the most surprising development, just like the government had been warning for years, is that the CSA system is capturing a great deal more operating information about truck and bus companies, including the activities of their drivers. That data, in turn, is impacting the company’s safety scores posted on the government’s websites.
I have spoken to several company officials who are “unpleasantly surprised” to see driver violations posted to the company safety profile. Surprising because it is the first time the company has become aware of certain driver(s) receiving citations or tickets. This has caused many companies to reemphasize their requirements for drivers to fully disclose to them their driving infractions.
Remember that in CSA the most serious weight is given to the measures dealing with driving actions—crash involvement, unsafe driving and fatigue or hours of service violations—since those measures have been proven to be the greatest predictors to a driver having a future crash. And crashes are what the government is seeking to prevent.
Customers threaten to cancel business
Another area of surprise to some firms, particularly the ones with poor safety scores, is the reaction of some of their customers. I recently received a frantic call from a Midwest trucking company asking for help in driving their scores down to below intervention threshold levels.
This company has a contract with a very large shipper that is threatening to break the contract because the carrier has all 5 publicly posted CSA measures above the intervention thresholds. The customer fears it is at risk if it continues to conduct business with a carrier that is seen as having serious safety challenges. If this customer were to cut its business with the carrier, it is highly likely the trucking company will be forced out of business.
One other interesting aspect of the changeover to CSA is the peer grouping concept where companies are compared to similarly situated companies so that comparisons are fairer. Because CSA measures are time and severity weighted, older violations lose their emphasis over time.
For example, a violation that occurred in October 2009 would be weighted “less” in the CSA Safety Measurement System than one incurred in October 2010. However, the algorithm that calculates all of this also takes into account whether others in your peer group are improving at the same time. If they are (and you have no way of knowing it), your individual score could increase from one month to the next because others in your peer group improved “faster” even though your company has received no new violations since the last data update.
How to get out of the CSA doghouse
So, what’s a company to do to get themselves out of the CSA “doghouse?” I will address that answer in more detail in my next CSA blog. However, for now my advice is to ensure your employees fully understand the importance of abiding by the DOT requirements so that, to the extent possible, inspection reports are clean and without violations. Drivers should be reminded that, more than ever, any traffic or roadside violations, including warnings, are being emphasized more in CSA.
In short, stay informed and engaged in the safety operations of your company.
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