CSA: Where do we go from here?

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Updated Dec 3, 2013
From left to right: CCJ Editor Jeff Crissey; FMCSA Senior Transportation Specialist Bryan Price; CVSA Deputy Executive Director Collin Mooney; FedEx VP of Safety Scott MugnoFrom left to right: CCJ Editor Jeff Crissey; FMCSA Senior Transportation Specialist Bryan Price; CVSA Deputy Executive Director Collin Mooney; FedEx VP of Safety Scott Mugno

A panel discussion held at the Great West Fleet Executive Conference Wednesday explored that very question, with the general theme being that fleets and drivers are willing to comply but that CSA still has many kinks that need to be ironed out, which the Federal Motor Carrier Safety Administration says it’s trying to do.

Scott Mugno, vice president of safety for Federal Express, said though FMCSA’s Compliance, Safety, Accountability program means well and has caused carriers to focus much more on safety, CSA scores many times do not correlate with a carrier’s future crash risk, as is the main intent of the program.

To that point, only three of the seven CSA BASICs (behavior analysis and safety improvement categories) reflect a carrier’s future crash risk. Also, referencing a chart referenced during his address, Mugno said there are enough outliers even in BASICs that do show correlation to distract from the BASICs’ most fundamental purpose of indicating future crash risk.

Mugno said that if the agency wants to use the BASIC scores — part of CSA’s Safety Measurement System — as an internal device to know which carriers to target, that’s fine, but the fact that the scores are public allows third parties to make decisions and “additional judgments” of carriers and their operation, with the problem obviously being that the scores are not indicative of a carrier’s safety.

FMCSA Senior Transportation Specialist Bryan Price said the agency is actually looking to unveil this summer a redesigned version of its Safety Measurement System website — where public scores are accessed — to help users differentiate between the BASICs and better highlight ones that have statistical correlations with crash risk.

Price did acknowledge too that there are “implications behind” the public nature of SMS scores, and he hopes the new site will “convey as accurately as [FMCSA] possibly can exactly what these scores mean and don’t mean,” he said. “We need to show they’re not a safety rating, but they simply establish a radar screen for us to see who is having compliance issues.”

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The redesigned website will also help mitigate industry concerns about lack of data for small carriers, which to this point has been perceived by many to mean bad scores.

The site should be ready by late summer, Price said, and it will be made available for public comment and feedback before it’s implemented.

Also in response to scores and severity weightings of different violations, Price said the agency is exploring the possibility of moving to a high-medium-low scoring system rather than a numeric-based system. The specificity in scoring, he says, draws attention away from the bigger picture of CSA’s goals.

Price says FMCSA has reached out to one of it subcommittees, the Motor Carrier Safety Advisory Committee, and asked for its help in establishing the new scoring system. “We think we can go there without impacting the system,” he says.

Price also addressed the oft commented upon crash weighting and accountability issue. As it stands, FMCSA uses all reported crashes in its scoring, even ones that are in no way the fault of a carrier or driver. The data is restricted from public view for that reason, Price said, but the data still used to the detriment of carriers, nonetheless.

Price says FMCSA uses it internally to “prioritize our resources,” and that the agency gets more than 100,000 crash reports from states each year. “When those crash reports come into our system, there’s no magic box or field that” denotes fault, Price says. “Since those 100,000-plus reports don’t have that information, we use the information to the best of our ability. We have to work smart with it.”

An FMCSA study however is underway, studying the concerns over crash accountability and its weight in CSA scores. It will be completed this summer.

One option the agency may look at to address crash accountability is using police reports, Price says, since they have more of a narrative as to what happened in a particular accident. The agency will have to determine the cost and overall benefit before implementing, though, Price said.

Lastly, Price said FMCSA hopes to propose a Safety Fitness Determination rule in January 2014, which would be a determination based on the company’s own data and not relative to other scores or companies, like the current SMS system is.

The issue of crash accountability, however, is something the agency hopes to resolve before issuing the rule, he said. “We’re not going to have a Safety Fitness Determination that doesn’t consider accountability of crashes,” Price said.

The issue of bottom-up data that is the foundation of CSA — data collected by inspectors during roadside inspections — also needs a good bit of tweaking, said Collin Mooney, deputy executive director of the Commercial Vehicle Safety Alliance.

The root of many of the problems Mooney discussed during the panel was basic inconsistency from state to state and inspector to inspector in how inspections are performed and then, more importantly, how violations are marked and inputted for reporting to FMCSA.

CVSA, FMCSA and states themselves don’t even have a uniform system in grouping and recording violations, Mooney said.

Before CSA, the lack of uniformity was not as apparent, because the data wasn’t being used in a centralized place to score all carriers relative to other carriers. CVSA is currently petitioning FMCSA to change its interpretations, regulatory guidance, operation policies and enforcement memos, Mooney said, which basically means clarifying violations that can be recording and not lumping so many items together.

The next step would be to hardcode inspection violations so when they’re inputted there’s no room for variation from inspector to inspector and from state to state.

Mooney also said CVSA is working to bring uniformity to the DataQ review process — the appeals process for violations brought against carriers and drivers — and ensure there’s an effective due process if a motor carrier and a state disagree on a violation.