A revolution in safety?
CSA 2010 represents a delicate opportunity for major change
Over the past couple of years, American Central Transport has found that drivers are conducting much more thorough pre- and post-trip inspections. The Liberty, Mo.-based company’s maintenance facility has seen a rise in traffic for minor repairs, and breakdown calls have increased, says Aaron Thompson, ACT’s vice president of operations and former vice president of maintenance. And drivers are reporting shipper-caused damage to trailers far more often than in the past.
And it’s not just vehicle maintenance. ACT has seen increased awareness on hours of service, Thompson says. The number of load turndowns has risen, and many drivers have volunteered to use electronic onboard recorders for hours compliance. Many of these drivers have seen increased utilization due to better trip planning, he says.
To understand the sudden conscientiousness among ACT’s drivers you have to know that the company has been part of the Comprehensive Safety Analysis 2010 test in Missouri for the past two years. Thompson described ACT’s experience with CSA 2010 last month at the CCJ Spring Symposium in Birmingham, Ala. ACT has educated its drivers thoroughly on CSA 2010.
Fairness and consistency will be keys to success.
The changes that the Federal Motor Carrier Safety Administration hopes to accomplish through CSA 2010 potentially are revolutionary. By converting a rare compliance review into a monthly fitness determination based on live data, the agency essentially would deputize everyone working for motor carriers – managers and drivers alike – as safety and compliance personnel. The focus on specific Behavior Analysis Safety Improvement Categories, or BASICs – unsafe driving, fatigued driving, vehicle maintenance and so on – is sound in concept, and the graduated intervention process is essential to the whole concept. And by giving carriers access to drivers’ inspection data during the hiring process, the new Pre-Employment Screening Program strongly reinforces driver accountability.
As usual, however, the devil is in the details. CSA 2010 will achieve its lofty goals only if drivers and carriers find that the data captured and reported reflects their true performance accurately and fairly. If in design or implementation the new Safety Measurement System (SMS) seems arbitrary, inequitable or unpredictable, carriers and drivers might grow to be less vigilant over time.
In February, the American Trucking Associations raised three major concerns with SMS methodology:
• Reliance on recordable crashes regardless of preventability or fault;
• Use of the number of power units rather than vehicle miles traveled as a measure of risk exposure; and
• Inclusion of all recorded moving violations without considering whether a citation was issued.
In April, FMCSA Administrator Anne Ferro responded to ATA by agreeing to consider specific changes that might address all three concerns to some degree. But she also stood by use of all recordable crashes in the SMS methodology. “Simply, FMCSA analysis indicates that past crashes are a good predictor of future crashes, irrespective of preventability.” Ferro defended use of warnings as well as citations on basically the same grounds.
Ferro’s points are well taken, but there’s a big difference between how FMCSA uses data today and how it will be used once it completely implements CSA 2010 with the new monthly fitness determination. The standards for accuracy, precision, fairness and due process should be much greater once FMCSA will be, in effect, rating carriers directly from a monthly update of inspection data.
Fortunately, FMCSA has time to get CSA 2010 right. The SMS doesn’t go live until December, and conversion to the monthly fitness determination is farther down the road. As of now, the agency doesn’t plan to publish a proposed rule until early next year. FMCSA has a great deal of work to do before carrier ratings based on data alone will be fair and equitable. n
Avery vise is Editorial Director of Commercial Carrier Journal.