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
