What’s in a name?
Given that Comprehensive Safety Analysis 2010 has been a hot topic for only a couple of years, you might be surprised to learn that the Federal Motor Carrier Safety Administration began talking about the program publicly more than six years ago. Interest in CSA 2010 grew gradually until everyone agreed it was a huge deal – especially FMCSA itself, carriers that might benefit competitively and vendors that stood to make a buck or two.
Having staved off a last-minute legal challenge, FMCSA finally replaced SafeStat with the new Safety Measurement System on Dec. 12, and Comprehensive Safety Analysis 2010 ceased to exist. The new name is Compliance, Safety, Accountability – a phrase that seems to be more of a list than a name; it appears reverse-engineered to match the initials CSA. And what’s with the commas? That’s so strange that CCJ has decided not to use them – except in this column – in order to avoid confusing sentence constructions.
FMCSA dropped “2010” for obvious reasons. But why change Comprehensive Safety Analysis – a solid name that seems to describe what the program does – to Compliance, Safety, Accountability?
The agency’s rationale isn’t clear. To be fair, FMCSA had used the tagline Compliance Safety Accountability with the CSA logo for a while, so the name change wasn’t a total surprise. But not until Nov. 30 did FMCSA refer to the program formally by the new name. In the frequently asked questions section of the CSA website, FMCSA states: “Originally, CSA stood for ‘Comprehensive Safety Analysis 2010.’ However, as national implementation of CSA rolled out in December 2010, FMCSA transitioned the program, dropping the ‘2010’ and renaming the initiative ‘Compliance, Safety, Accountability.’” Yes, but why?
Asked this question, an FMCSA spokesperson responded that “Compliance, Safety, Accountability are the principles this new safety enforcement program is designed to support.” Satisfied? Asked to elaborate, the spokesperson said CSA had gone through a number of interim steps – listening sessions, a pilot test, release of a new methodology and carriers’ review of their data – all leading up to the actual rollout. “With the rollout, there was a name change. It’s as simple as that.” Clear?
Barely 12 percent of carriers are ranked in CSA.
Getting a frank explanation for dropping the name Comprehensive Safety Analysis appears to be a fruitless endeavor, so perhaps we can guess at one reason by examining the data FMCSA uploaded last month. A CCJ analysis of SMS percentile rankings and alerts shows that only 92,182 of the 758,682 motor carriers in FMCSA’s database are ranked in any of the five publicly disclosed Behavior Analysis and Safety Improvement Categories (BASICs). That means nearly 88 percent of motor carriers don’t have enough inspections to be included in any safety event group.
To be fair, many of those 758,682 motor carriers aren’t even operating or are local operations that are unlikely ever to be inspected. As part of the effort to establish the Unified Carrier Registration fee, FMCSA itself pegged a more realistic number of active interstate carriers at 433,279. But even using this more conservative figure, nearly 79 percent of all motor carriers aren’t captured by CSA aside from just a few thousand that have drawn BASIC alerts solely because FMCSA discovered a serious violation in the past year.
So CSA doesn’t seem very comprehensive – and with the name change it no longer has to be. Nor does it fulfill FMCSA’s original goal of reaching far more carriers than the 2 to 3 percent that were audited each year. Only 7 to 12 percent of motor carriers have an alert in any of the five public BASICs, and it is an alert that triggers an intervention.
Call it what you will, CSA suffers from a lack of data. FMCSA and its state partners should inspect far more drivers and trucks than they do today. Eventually, the agency can tackle this challenge through wireless roadside inspections and similar technologies. For now, however, a fix would require much more money than federal and state governments have to spend. n
Avery Vise is Editorial Director of Commercial Carrier Journal.
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