Coming later this year as a Notice of Proposed Rulemaking by DOT is the next “leg” on the CSA stool. This rule — the ”Safety Fitness Determination” Rule — will propose to satisfy the Congress’ mandate that all motor carriers have an up-to-date safety rating.
DOT plans to meet this obligation by using the CSA scoring system to categorize carriers using unambiguous adjectival ratings likely to be some form of “satisfactory, continue to operate (or equivalent language indicating no evidence to indicate safety issues), marginal and/or unsatisfactory.”
As opposed to the old SAFESTAT system, CSA scores have the advantage of reflecting a more current picture of a carrier’s safety performance since it compiles the past 24 months of on road activity, and its severity and time-weighting features provide a more recent assessment of a company’s safety condition.
As carriers know, in the old rating scheme, receiving an unsatisfactory or conditional rating after a full government-conducted audit could be devastating to their business. What is expected from DOT later this year is a proposed new rating system that will use the CSA scores and the relative scoring of data within CSA, to be the basis for a de facto rating system for each carrier.
There will likely be no audit to verify scores are accurate. A carrier’s CSA scores, then, translated by a formula reflecting risk, are what will probably be proposed as the current safety rating. That provides plenty of reasons to seriously review and correct any mistaken data now and in the future, address CSA deficiencies and continue to prod DOT to competently fix the crash accountability issue it is currently reviewing so that the carrier profile data reflects the true safety condition of a company.
Changes not immediate
These changes to the safety rating requirement will not happen overnight. It typically takes around two years for rules to become final after public comment, the need for government oversight reviews and the press of competing workload by the rule writers. But be warned that because the CSA model is so central to DOT’s mission to identify high risk carriers and goad them into better on road performance, finalizing this rule after its first public comment period may be given higher priority within its very heavy rulemaking agenda.
Motor carriers are also urged to read and react, in writing, to the proposed rule. Because of competing pressures, carriers often rely on others to comment on their behalf. While associations typically submit very useful comments, the rule writers also look for commenters representing all classes and sizes of carriers to get a better sense of the impact the rule will have across the industry, including the shipper community.
With CSA, many companies were caught “flat-footed” and have suffered business reverses as a result. They should not let the prospect of a new rule on safety ratings catch them a second time.