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Occupational Safety Blog

By Fred Rine, CEO of FDRsafety and former long-time Managing Director of Safety and Health at FedEx, Jim Stanley, President of FDRsafety and former No. 2 at OSHA headquarters and Mike Taubitz, Senior Advisor to FDRsafety and former Global Safety Director for General Motors.


Archive for the ‘CSA 2010’ Category

A year later: CSA on the road to success

January 20th, 2012 posted by Rose McMurray

Rose McMurray

It’s been one year since the Department of Transportation launched its CSA program to better monitor fleet safety and indicators of success have begun to emerge, although not everyone agrees that they are dramatic.

DOT reports that, in the first full year of CSA, safety-based violations during roadside inspections declined by 9% from 2010 levels, suggesting that drivers and vehicles might be more aware of avoiding violations that affect their overall CSA scores. There are also indications that trucking companies are focusing more attention on the driver hiring process and are more carefully scrutinizing a driver applicant’s record.

On the other hand, the research arm of the trucking industry says that the results of CSA have not been dramatic. But the American Transportation Research Institute also said that more than 50% of the carriers surveyed reported that while they had acceptable scores under the old SAFESTAT measurement system, they now have at least one of the seven safety BASICS over the intervention threshold.

The DOT issued its own report and one conducted by the University of Michigan that evaluated only early results gathered in 2008-2010 from test states. U of M concluded that carriers in the test states had generally higher compliance rates than the general motor carrier population. DOT will factor in the university’s findings as it makes further adjustments to CSA this coming year.

DOT also reported that, in the first full year of CSA, specific interventions being used by law enforcement and government investigators are yielding results. Especially effective are warning letters (40,000 last year) and the greater use of on-site focused investigations, which only review specific areas of non-compliance indicated by violation or accident histories and not the full menu of standards examined during complete reviews.

What’s ahead for CSA

After one full year of operating experience, DOT will make additional changes to CSA including fixing the Cargo Securement BASIC to reflect the current disproportionate impact on flatbed operators and to better isolate when violations are hazardous materials related. It is expected that load violations will now be recorded within the Vehicle Maintenance BASIC.

Doing this, in my view, dilutes the distinction between clear mechanical and vehicle-based problems that trigger a hard look at maintenance and vehicle inspection practices of a company versus unsafe securement violations that can usually be addressed through better training and monitoring of proper strapping and bracing.

Obviously, carriers can examine the individual violations and distinguish the maintenance issues from the securement ones and act accordingly, but it is important that motor carriers understand the problems that result in high BASIC scores and that the nomenclature of the BASICS are unambiguous and clearly define the category of violations. Same with hours of service violations. While fatigued driving (the current BASIC title) can result from hours of service violations, a more apt descriptor might have been to call this BASIC HOS violations as many in the industry have suggested this BASIC category really measures.

Also, in the past, the DOT’s Safety Measurement System which contains carrier and driver operating data, captured safety violations from all roadside inspections. In the future, vehicle violations discovered during a Level 2 (driver-only) review will NOT be entered into the Safety Measurement System. Likewise, driver violations found during Level 5 (vehicle only) inspections will not be uploaded into the system.

Other policy changes are planned for 2012, including a much-awaited process for dealing with accident accountability that provides carriers with due process to challenge crashes attributed to them in the official record. Carriers would also be wise to watch for a number of proposed rules planned for 2012 and to be alert to statutory requests DOT has made to gain greater legal authority to measure the safety performance of individual drivers that will be modeled after the carrier safety measurement system already embodied by CSA.

Considering the cost and extensive investment of DOT financial and staff resources to designing and deploying CSA, not to mention DOT oversight bodies’ interests in this project, there will continue to be ongoing evaluations, assessments and reviews of CSA to determine whether the program is achieving results, especially in reducing injuries and fatalities involving commercial vehicles. However, an initiative of this scale, especially one not yet fully completed, cannot effectively be measured after only a single year of operation. The most meaningful time to do a full-scale assessment would be 3-5 years after the full CSA initiative, with all its parts, is deployed. And even then the challenge will be to unequivocally conclude it is CSA and not other impacting events like economic activity, more survivable vehicles, traffic congestion lowering speeds, etc., that result in improved safety outcomes.

What fleet operators should do

The key advice here is to continue to monitor your CSA scores and take action to stay below DOT’s BASIC intervention thresholds. As well, ensure your system of hiring, training and monitoring driver’s performance is competent. It would also be wise to alert your drivers that maintaining good individual driving records and violation histories are important since one day in the future the DOT may be assigning a “score” to individual commercial drivers under the CSA program similar to how they are now assigning scores to truck and bus companies during CSA Phase 1. The government will continue to create programs directed at improving driver behavior since most roadway crashes result from driver behavior.

Rose McMurray, former Chief Safety Officer of the Federal Motor Carrier Safety Administration, advises companies on how achieve best results under CSA. Contact her at rmcmurray@fdrsafety.com

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Choosing to be safe on the road, at work and at home

November 21st, 2011 posted by Rose McMurray

Rose McMurray

Recently, I attended two important annual meetings — the American Trucking Associations meeting and the National Safety Council Congress. As a safety professional, both meetings allowed me to catch up with my colleagues while getting updated on new safety developments and emerging issues.

At the Trucking Associations meeting, I was most intrigued by a survey it conducted a few months back that identified the top challenges its members are facing. Not surprisingly, one of the top five issues was the impact the US DOT’s new enforcement program, CSA, will have on carrier operations.

I have written many times before that CSA would become a “game changer” and, in fact, for the trucking industry it has become so. As freight demand is increasing, companies are anxious for more customers. However, companies with poor scores are being told that until they improve, customers will be giving their business to companies that perform better on safety.

At the conference, it was clear that a cottage industry of consultants and businesses has sprung up to help companies identify their safety weaknesses and improve their CSA performance. This help comes in the form of technologies capable of managing hours of service compliance to individual consultants skilled in improving safety culture and a company’s overall safety management program.

The demands of running a trucking operation can be overwhelming but the compliance requirements are the same whether a company has three power units or 30,000. The point is that solutions are available and many are affordable and within the reach of the small operator. To remain competitive, companies need to be mindful of their CSA performance and set a course to make improvements by either focusing time and attention on remedies or hiring someone who can help get them into a better safety position.

Home, community accidents on rise

Unintentional injury prevention is the main mission of the National Safety Council. It focuses on helping business and the public recognize the impact injuries/deaths have on business profitability and the wellbeing of families.

Surprisingly, the fastest rate of increase in preventable injury and death comes from abuse of prescription drugs, aka unintentional poisoning. We have all heard stories of people doctor-shopping, receiving highly intoxicating drugs and mixing drugs that unintentionally and tragically result in death.

In recent decades, workplace and motor vehicle deaths have been declining but home and community categories of death and injury have been on the rise. Other danger sources in the home include slips and falls. The challenge is how to create a better recognition of risk and then promote a sense of personal responsibility for oneself and one’s family that recognizes these risks and sets out to curb them.

Ladder safety, handrails in bathtubs, etc., are examples of measures that enhance safety. Adopting a mindset that says “this event can happen to me so I’m going to improve the odds by making the safe choice” is something we don’t often do. Always wearing a seat belt even when we drive the 10 minutes to the grocery store is a practice we all need to adopt.

These meetings provided me a sense of renewal and commitment to my safety journey and reminded me that there is still a great deal of work to be done to help us all be safer — whether it’s on the road, at our workplaces or in our homes. While we all can’t be at every conference that affirms our vocation, we can commit to making better choices and caring more about our personal and family’s well being.

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DOT making mid-course changes to CSA initiative

September 19th, 2011 posted by Rose McMurray

Rose McMurray

Even as the motor carrier industry and its customers get accustomed to the government’s new safety measurement system -—Compliance, Safety, Accountability (CSA) — the Federal Motor Carrier Safety Administration is making certain improvements to the program.

The most important revisions appear likely to come in the seven BASICS — the individual measures that calculate carriers’ on-the-road history and crash involvement.

Right now, five of the seven BASICS can be seen by the public while the Cargo Securement and Crash BASICS are withheld from public view (although available to the individual motor carrier using their DOT-issued PIN). DOT has indicated that it will likely make minor tweaks to the five public BASICS, significant changes to the Cargo Securement BASIC, and a process for improved validation of the Crash BASIC.

Changes to the Cargo BASIC

First, the Cargo BASIC was found to disproportionately affect certain operating segments, particularly flatbed carriers. In addition the severity weights that the government attached to violations that reflect the violation’s correlation with crash risk were assigned high values in this BASIC.

In the next few months, you are likely to see a major recalibration of the Cargo Securement BASIC which will reflect a more valid and fair measure of safety risk. In the meantime, carriers should not assume that the severity weights will be seriously diluted and should act now to remedy the conditions that have resulted in a high score in this area. Among other measures, load securement refresher training and better monitoring and checking of freight before it leaves the terminal by someone other than the driver/employee who originally secured the load can help contribute to better outcomes in this BASIC.

Alterations to the Crash BASIC

There is perhaps no BASIC more important to the entire truck/bus/shipper/enforcement
community than the Crash BASIC. This is because the government’s premise is that “past crashes are the best predictor of future crashes” and the entire CSA program was developed to establish competent ways to identify and intervene with carriers that pose the greatest risk to the travelling public before they are involved in a crash. Find the highest risk operators, intervene aggressively with them, prod them into compliance or get them out of the transportation business.

Historically, though, there were problems caused by the limitations of the data source that populates the Crash BASIC and which records crash involvement, i.e., police accident reports. This is mainly due to the nature of crashes — usually local police respond, fill out the report, and do not always state on the report which driver(s) “caused” the crash.

So when the states report the crash, the report usually notes that a commercial vehicle was involved in the accident but the form does not always identify the accountable party. This often results in a carrier being coded in the government’s databases as having a recordable accident that may or may not have been the carrier’s fault. For decades, DOT has tried to find a resolution of this problem but, since it requires thousands of police units, the states, etc., all being willing to agree to a reasonable and simple process, including how to pay for it, the solution has been elusive.

It seems, though, that progress is being made to establish a way for carriers and drivers to ask DOT for a review of specific accident reports that would be conducted by a trained crash analyst. The government is working on a new procedure that will allow for a review and decision regarding fixing “fault” for individual accidents where the cause is unclear and allow for the carrier to have some degree of due process in establishing whether a particular crash could have been prevented by the truck/bus driver.

This opportunity to challenge crash reports, especially after the carrier/driver has exhausted its efforts at the state/local level, is something the industry has been persistently pressing the federal government to establish. It is unclear when this new procedure will be “open for business” but until it is up and running and includes time for the government to evaluate its workability, the Crash BASIC will likely remain private to the motor carrier.

Companies should analyze their crashes

Again, as earlier urged, companies should be analyzing their crashes and striving to reduce the risks of having any crashes at all by focusing on the full safety management strategies of the company. If you believe your drivers are not at fault and seem to “always be in the wrong place at the wrong time” when they get into accidents, you may want to reconsider that point of view. Evidence points to the fact that most accidents are, in fact, preventable.

If, for example, your drivers have many intersection crashes, explore if the driver is perhaps speeding through the yellow light and not clearing the trailer from the intersection before oncoming traffic enters; for rear end collisions, ensure all lamps and lights are properly working so that trailing traffic is warned the driver is braking. In the end, it is very unlikely that the other driver is always the culprit.

As always, carriers should continually monitor their CSA scores, take corrective action, and strive to earn BASIC scores that signal that safety is a core value and that customers can be confident that the carrier runs a safe operation.

Rose A. McMurray, former Chief Safety Officer at the Federal Motor Carrier Safety Administration, is Chief Transportation Advisor at FDRsafety and consults with carriers on improving their CSA scores and other motor carrier and road safety issues. She may be contacted at rmcmurray@fdrsafety.com or 1-888-755-8010.

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Customers threaten to cancel trucking contracts because of high CSA scores

July 26th, 2011 posted by Rose McMurray

Rose McMurray

It’s been a little over six months since the USDOT launched the public availability of its new truck and bus safety measurement system and some motor carriers are reporting unpleasant surprises.

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.

To keep up with developments on CSA, subscribe to this blog and have it automatically sent to your mailbox or reader.

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Learn how to improve your CSA score with these 5 tips

June 16th, 2011 posted by Rose McMurray

Rose McMurray

As former Chief Safety Officer of the Federal Motor Carrier Safety Administration, I led the design and implementation of CSA – the federal government’s new program to measure the safety performance of motor carriers, including truck and bus operators.

From that vantage point, it became clear that there were five key steps companies could take to achieve satisfactory CSA scores, and I’ll describe those a little later in this post.

Naturally, the most important reason for a company to operate its trucks or motor coaches safely is to protect the driving public, passengers and their own employees. But there are other implications as well: unsatisfactory scores can increase insurance premiums and result in lost business. In addition, the Federal Motor Carrier Safety Administration is using the scores to prioritize its enforcement actions. Companies with low scores will be targeted.

Following are five tips for succeeding under CSA – short for Compliance, Safety, Accountability. For more detail on how to execute on these five suggestions, see a full-length CSA article I have written that is posted elsewhere on the FDRsafety site.

And an important note: CSA covers not just truck and bus companies but also other organizations that use trucks and buses in their operations.

Guideposts for CSA success

1. Make safety a core, non-negotiable value of your company.
This doesn’t mean merely posting a sign in the workplace that “safety is important in our company.” It is communicated by the way the company is managed, the behavior and attitude of company officials and the actions management takes when a safety violation occurs.

2. Get educated on CSA and explain it clearly to your employees.
Ensure that drivers, maintenance shop staff, trainers, executives, etc. understand CSA and its impact on the company’s bottom line and how each of them contribute to the scores earned by the company.
 
3. Examine the data maintained by the government that underpin your CSA scores and ensure the data is accurate.
Aggressively pursue data correction through the DOT DataQ’s process and get your record correct. Ensure your registration data (MCS-150) information is updated. 

4. Implement specific, competent countermeasures to address your safety deficiencies.
If any of your measures exceed the “alert” threshold, put into place known effective measures that correct the reasons your company is receiving violations.
 
5. Recruit, train and vigorously monitor drivers.
Driver performance is a backbone of the CSA system since violations in the three driver categories (Unsafe Driving, Fatigued Driving and Crash History) are given added emphasis in the measurement calculations.

Rose McMurrary, Senior Transportation Advisor for FDRsafety, retired earlier this year as Chief Safety Officer of the Federal Motor Carrier Safety Administration. She now consults with companies on improving their CSA scores and other transportation safety issues. Rose can be contacted at 615-370-1730 or rmcmurray@fdrsafety.com.

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Rose McMurray, just retired as DOT’s motor carrier safety chief, joins FDRsafety

April 25th, 2011 posted by Fred Rine

Fred Rine

I am pleased to announce that Rose McMurray, who retired in January as Chief Safety Officer of the Federal Motor Carrier Safety Administration, has joined FDRsafety.

Rose, who is one of the most distinguished figures in the world of transportation safety, will have the title of Chief Transportation Advisor and will, together with me, lead our Transportation Safety Division.

The regulatory environment for motor carriers is in the midst of big changes as a result of a program that Rose implemented – CSA 2010. This program is changing the way the safety performance of motor carriers is measured. Those measurements will in turn guide enforcement priorities for the Department of Transportation, a matter of considerable concern for carriers.

Rose will advise FDRsafety clients on how to insure that they have good ratings on the new system. She will also be contributing to our Workplace Safety blog.

We are very excited to have Rose on our team and invite you to read her first blog post, which follows.

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A view from the inside: New member of FDRsafety team will explain DOT programs and policies

April 25th, 2011 posted by Rose McMurray

Rose McMurray

I am pleased to be a part of this professional team because of FDRsafety’s passion and demonstrated commitment to safety. Having spent 38 years working at the U.S. Department of Transportation, focusing on all aspects of highway and road safety, it is important to me to continue that work, joining forces with seasoned professionals who share the same zeal in helping companies find competent solutions to the challenges American businesses face every day while not compromising their employees’ safety.

I was a regulator and program manager and I generally understand the aims of government and the pressures it faces in safeguarding the traveling public. I am hoping that I will be able to come full circle from having been responsible for developing good public policies to better understanding the impact those policies have on businesses and their employees.

For several years, I was the senior executive responsible for seeing the new Comprehensive Safety Analysis 2010 (CSA 2010) project to implementation. CSA 2010 (now simply called CSA) is the DOT’s new measurement and enforcement scheme for commercial motor carriers that was implemented four months ago after seven years of design and two years of testing and adjustments.

While there are still critical pieces remaining to come into effect, especially the safety rating regime, the new CSA system has replaced the previous SAFESTAT data base. I will dedicate future posts to the importance of this game-changing way the federal and state governments assess a company’s safety and will offer some insights about how wise companies can earn scores that don’t trigger an enforcement intervention.

And while my most recent government service dealt with commercial vehicles, I also was responsible for the government’s driver behavior programs across the board. Issues like drunk and drugged driving, use of safety belts, older and teen driving challenges, pedestrian, and motorcycle and bicycle safety all fell within my responsibility. I will write also about how attention to these issues by workers and their families is important to promoting positive employee productivity.

Recently, the preliminary highway fatalities for 2010 were released by DOT. Amazingly, despite an increase of 21 billion miles driven in 2010 over 2009, roadway deaths fell 3% to their lowest levels in 62 years. While not released with as much fanfare, deaths involving large trucks fell a whopping 20% from 2009 levels.

The economic downturn surely accounts for some of the reduction in truck-involved road deaths, but it also suggests that safer vehicles, increased use of occupant restraints, more vigorous enforcement of traffic laws and the contributions of thousands of responsible, safety-focused companies are resulting in fewer tragedies. Everyone should celebrate this good news.

I look forward to sharing with you recent transportation safety developments and the emerging issues affecting your industries and the bottom line. Remembering the old adage “safety doesn’t cost, it saves,” I am pleased to be a part of the FDRsafety team and in helping you pursue your own successful safety strategies.

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