Risk & Reward: How CSA’s data shows discrimination toward small carriers

By Todd Dills on

CSA'S DATA TRAIL

The article below is part of a yearlong, in-depth series on the U.S. Department of Transportation's Compliance, Safety, Accountability program that analyzes two full years' worth of data — December 2010 (the program's beginning) to December 2012. CCJ editors have built a site dedicated to hosting the stories, interactive maps and downloadable data at CCJdigital.com/csa.

inspectEDITOR’S NOTE: Working with CCJ and Overdrive publisher Randall-Reilly Business Media’s RigDig Business Intelligence unit, we analyzed inspection and scoring data at the end of the Compliance Safety Accountability program’s second year since going live in December 2010. Here we report the results of that analysis, offering insights into enforcement patterns and what you can do to keep your business in the clear. Here’s the first part in a five part series.

Based on analysis of data from the first two years of the Federal Motor Carrier Safety Administration’s Compliance Safety Accountability program, 20 percent of carriers now have a ranking in at least one of the seven Behavioral Analysis and Safety Improvement Categories that make up the Safety Measurement System component of CSA. That’s a marked improvement over the 12 percent – determined by CCJ – that was cited widely in the program’s early days.

Given their higher exposure, the largest carriers are from two to 30 times more likely on average than single-truck independents to have a score above an intervention threshold depending on the BASIC. But large carriers aren’t the only ones that find themselves in CSA’s crosshairs.

Inspections affect small carriers

The average CSA score for all of the smallest carriers is abnormally low because most small carriers have no public score. Of close to 470,000 carriers with U.S. Department of Transportation operating authority, fewer than half have any SMS data at all, according to recent estimates by Dave Kraft of Qualcomm. Just less than one fourth have a few inspections – but no SMS ranking or “score” in any BASIC.

CSA data graphicBut when they do garner enough inspections to be rated, smaller carriers showing public BASIC scores on average receive negative (higher) scores.

You don’t have to look far to find examples of carriers with fewer than 15 trucks that make their CSA scoring debut at the highest level possible – 99.9 – after a single inspection with a violation or two meets data-sufficiency requirements in a BASIC. This makes for no shortage of difficulty in score management.

“If the system is displaying ‘less than 5 inspections with a violation’ or ‘less than 3 inspections with a violation’ ” in any BASIC, FMCSA representatives say, “it doesn’t mean that they might not be on the ‘cusp’ of generating sufficient negative information for us to assign a high percentile score and intervene.”

Drill down into the data – just one click from your main carrier SMS results page – to “see how many inspections with violations that they do have and what those violations are,” FMCSA says. Then, “take efforts to avoid similar violations.”

Five-truck intermodal fleet owner Thomas Blake experienced this dynamic. He spent more than a year above the alert threshold in the Hours-of-Service (HOS) Compliance BASIC. Now his fleet is back to showing no score on its main SMS profile there. It went from showing a ranking in the 60s – close to the intervention threshold – to being below data sufficiency standard levels because he had less than three inspections with a violation.

What did it take to get there? He did what a large majority of large carriers have done – invested in electronic onboard recorders. Blake, who at the time had six trucks, spent $9,000 for an EOBR system. It eliminated minor “form and manner violations,” putting his operation a leg up in the HOS Compliance BASIC over his peers.

The only way to improve scores other than getting clean inspections is to wait. The weight value of inspections and violations in scoring falls after six months and again after 12 months. They drop out of the SMS after two years.

Installing EOBRs, a costly decision that seemingly would please inspectors and improve an independent’s score, in a sense backfired on Blake in the short term but paid off eventually. Because so many inspectors view EOBR-equipped trucks as not worth the time of an inspection, it was unlikely that Blake’s truck actually would get clean driver inspections to improve his score quickly. With time, however, Blake’s HOS Compliance BASIC score disappeared.

Click here to see Part 2 of this story.

Todd Dills

Todd Dills is Senior Editor of Overdrive magazine and writes from Nashville, Tenn. His Channel 19 blog covers a grab bag of on-highway hearsay, owner-operator news and driver views from the roadways the nation over. His work in trucking journalism builds on a background of news feature, fiction and other creative writing and editing. Find him here at the Channel 19 blog and via his Twitter feed, or send tips to tdills@randallreilly.com.

13 comments
17 years driver
17 years driver

We all forgot what is Freedom. Give me freedom or give me death ! If someone has 5 - 7 years on the road he needs no log books at all, Spend 5 -7 years in a college and you are a PHD. Can  anyone master driving at all, so no Log Book needed? I think I can, I am even ready to prove if you give me a chance.

oklaroadrunner
oklaroadrunner

"The average CSA score for all of the smallest carriers is abnormally low because most small carriers have no public score. Of close to 470,000 carriers with U.S. Department of Transportation operating authority, fewer than half have any SMS data at all, according to recent estimates by Dave Kraft of Qualcomm. Just less than one fourth have a few inspections – but no SMS ranking or “score” in any BASIC."

I own a small trucking Co.and the statement from this guy from Quallcom shows exactly how people who aren't actually on the front line has a skewed idea of SAFER scores. When we opened our doors in 2010 I had 1 truck. I got stopped and because my chains wasn't exactly 10' apart on a load that you could see putting the chains where he wanted would damage the cargo I got wrote up put out of service for it until I moved the chains. I had a 100% out of service. Not good for someone just starting out. It almost put me out of business before I got started. So this"BASIC scores for small carriers are abnormally low because most small carriers have no public score" is BS. Proof they are puppeting what FMCSA and DOT want them to say.

JoanDArc
JoanDArc

Actually, the larger carriers with subsidiaries are able to spread their BASIC score throughout the variety of their companies. Further, not all IEPs are registered and, therefore, don't get their share of the inspection process measured.

 

The companies with the horrific scores don't get shut down unless the FMCSA needs a bit of press and shuts down a bus company.  When you ask the FMCSA about a particular company it is either double talk or no response at all.

 

 

Tim Sherry
Tim Sherry

After reading this article there is one thing that keeps standing out.  The example of Thomas Blake, he had to spend a substantial amount of money on a small company in order to help keep compliant on his HOS.  I feel it was part of the gov's plan when they implemented CSA, they would make it such a financial burden that small companies go out of business. Thus, protecting the big corporate transporters.  You know the ones that fund their campaigns!

Tom Sanderson
Tom Sanderson

The opening paragraph is incorrect is stating that more carriers are now being measured. In every monthly CSA dataset from September 2011 to today, between 89,000 and 92,000 carriers have received a score in at least one BASIC.  The difference between 12% and 20% is simply whether you divide the 90,000 carriers with a score by the 770,000 carriers in the data downloaded from the FMCSA or by the 500,000 carriers believed to actually operate on the highways.

 

The reason small carriers fare poorly is that the sample size for these fleets is too small to be reliable and one or two failed inspections are impossible to overcome with offsetting clean inspections. Dr. James Gimpel of the University of Maryland published a review of CSA and stated that in any scientific study a sample size of less than 20 would be too small to be considered reliable and typically would not even be published. Fewer than half of the 89,000 carriers with a published score have had 20 or more inspections in the last two years. Almost no small carriers would have 20 roadside inspections in two years. Here is a link to the study.

 

 https://docs.google.com/file/d/0B6aiirmQGAQSb09jYUpQT3dTTlU/edit?usp=drive_web&pli=1

 

Tom Sanderson, CEO Transplace and Chariman ASECTT

DOTDoctor
DOTDoctor

CSA, despite the peer groupings, works on the same mentality of all trucking regs; one size fits all.  I don't care if it's clothes or trucks - one size does not fit all.  We need to determine adequate subgroupings for HOS, CSA and any other trucking "data" system.  The gov is over regulating; as usual.  The industry, as a whole, needs to step up and take back control.  Educate the law makers.  Stop letting MADD, insurance and all the special interest groups regulate trucking. 

jet1968
jet1968

Several large carriers have multiple fatalities on the records. yet very low scores. When a small carrier can have high scores and no fatalities. Fatalities mean DEAD people. I don't care how many miles a large company runs or how many trucks or drivers they have a DEAD person is a DEAD person. Safety my ass. Since when is killing someone better then not filling out a log sheet properly.

WebbKline
WebbKline

This fails to factor in the bell curve in which we are all rated on within our peer group. I am beginning to feel like Hotel California, where you can check out any time you want, but you can never leave. Hopefully, since our worst violations were caused by the same driver in April/May 2011, that we will lose our bad rating by then, but I am told by FMCSA personnel that this isn't necessarily so. Hypothetically, if everyone else in our peer group makes the same advances in the safety rating, we could wind up with a golden triangle even after losing these violations.

 

But that isn't the half of it. The offending driver's only error in both cases was that he didn't have his log up to date. Upon the 2nd incident, I tore his lease up. But, he fought his battles in court and had his charges dismissed. He really was innocent. But when I appealed on DATA Q, they went back to the arresting officers, who didn't want to look bad so they got to have their day in court once again, this time without the driver or his attorney there to defend and explain why he had his charges dropped. In essence, we now live in a system where you are not only innocent until proven guilty, but guilty even after being proven innocent..

 

So, despite all that unfairness, look at these facts: Initially, we had 103 points accumulated. Since the first 3 inspections were the ones that hurt us, we were told we needed more inspections. So, after nearly 2 years, we have finally managed to find a few DOT willing to inspect the trucks and we now have more good than bad inspections. Secondly, our points are down to 56, nearly half of what they were in the beginning, yet, even with all the good inspections, and with losing half our points, we have only lost 10% and are now at 89%. How's that for fuzzy math?

 

Meanwhile, not a single one of our drivers has had a single violation or failed inspection in over 10 years. They are all home in their own beds every night, and never drive long enough to have an HOS violation. In fact the combined driving time of all 3 incidents where we earned 14 hour and falsification charges only amounted to 4.5 hour driving time. The 2 guys who had the problems are now working for companies who will no longer load our trucks because of our score, while we continue to suffer economically because of what they've done. We lost over $1.5 million worth of business last year because of this.

 

I think we arguably may have one of the most compliant companies out here, we've literally designed our operation around the new compliance regulations, yet it has nearly broken our bank. This system has a long, long way to go int terms of fairness.

kellyfrey
kellyfrey

Great article.  There are some other things that can be done as well in the short term to improve CSA scores for small carriers, without spending $1,500/cab.  For example, to eliminate the possibility form and manner issues on Drivers Logs you can download a free driver log app called BigRoad.  It works on an Android device (Apple soon) and helps do all the calculations for the driver as well as highlighting missing information (shipping docs, mileage, tractor # etc.) as well as automatically suggesting duty status changes when movement is detected (for example 'driving' to 'on duty' when no speed is detected after 3 minutes).  

Over 52,000 drivers have downloaded and are using BigRoad to keep their logs error free.  It is the #1 daily driver log app on Gppgle Play and the highest rated 4.6 stars out of 5 stars.  To get the app just go to www.BigRoad.com or Google Play and search for BigRoad.

Many fleets using the paid BigRoad dispatch app to get all their driver logs coming into one spot, plus tracking and messaging etc have seen their CSA scores rebound within a short period of time @bigroadinc 

WebbKline
WebbKline

 @oklaroadrunner The Qualcomm guy is getting DOT rating and CSA rating confused. If you look at DOT rating, most carriers don't have a rating, but it has nothing to do with FMCSA's SAFER scores, which DOT does not recognize. Yeah, you heard me right, they don't even recognize their scores. And here's another dirty little secret--Qualcomm and Verizon have a ton of dough invested in EOBR equipment at the Fed's guarantee that EOBR's will be imminent, yet now it appears they are backing off and focusing on electronic logging rather than EOBR's after courts have determined that EOBR's are used for driver harassment by big carriers, and FMCSA agrees with the findings and has backed off from implementing them. This is a win win for us, and a lose lose for a couple of very big crooked corporations who prbably dumped as much money into this CSA regulatory process an anyone.

WebbKline
WebbKline

 @Tom Sanderson Thanks, Tom. That certainly affirms the trouble the system has made for us. Our drivers have gone into inspection stations voluntarily for the past two years in order to get the number of good inspections up to compensate for the damage of 3 bad inspections--one of which the driver beat in court, but which FMCSA responded to in Data Q's saying that they didn't have to agree with the court. In over 50 requests, our drivers were turned down every time. DOT figures that there is no reason to waste time inspecting trucks and drivers if they are that confident that they have no violations. In the past two years, we have only had 3 roadside inspections, and passed all of them. In that time, we've had no violations, nor do we have a single driver who has had a violation in over 10 years. We lost $1.5 million in sales last year alone, so you've guessed it: I'm bitter.

Must Clicks

Events