FMCSA promises more punch with CSA 2010
By Matthew A. Daecher
Later this year Comprehensive Safety Analysis (CSA) 2010 and its Safety Measurement System will replace the current Motor Carrier Safety Status Measurement System (SafeStat) used by regulators to identify and target unsafe operators. The new system has been in the works for many years, with testing occurring in several states since 2008. With planned implementation in mid-2010, awareness, public outreach and chatter about the new system has reached critical levels.
There has been a lot of speculation on what data the new system will track and how it will affect carriers and drivers. And, as with any change, many operators appear to be uneasy with the new system. Well, I have good news––those operators and drivers who mind their Ps and Qs have little to worry about. In fact, they may find some of the new tools made available through CSA 2010 useful.
Enforcement has always fought the uphill battle of resources versus tasks. In simple terms, the current system uses enforcement, inspection and accident data to rank carriers based on size demographics, thereby identifying those carriers who pose the highest risk. Enforcement would then commit resources to investigating and addressing these carriers via the on-site compliance review process. The problem is (and has always been) that the number of operators/carriers needing attention far outweighs the resources available.
Enter CSA 2010. The new Safety Measurement System (SMS) is really designed to simply do more with less. It will provide enforcement personnel with a larger arsenal of tools to identify and assist carriers who are not performing well (i.e. complying with regulations), all while minimizing face-to-face time spent with each identified carrier. Eventually, the system is designed to allow operators/carriers to have their Safety Rating (Safety Fitness Determination) evaluated and assigned on a monthly basis based purely on on-road safety performance and intervention findings.
The SMS is similar in many ways to Safestat, yet more detailed. On-road safety performance will be categorized into seven Behavioral Analysis Safety Improvement Categories (BASICs). Each carrier’s results will be compared to demographic-determined peers and those with the poorest scores in each category will be targeted for intervention actions. The detail in which the data collected is categorized will help regulators more specifically identify areas where a carrier is having issues. Intermediate interventions, such as warning letters to carriers, are designed to evoke carrier action and response to correct identified issues before issues escalate to the point where an on-site compliance review is warranted. In addition to carrier rankings, regulators will also be keeping tabs on individual driver history which should allow for more effective targeted roadside enforcement inspections as well as assist in identifying carriers who have a propensity to use drivers with less than stellar histories.
In short, CSA 2010 will allow for more detailed attention to be paid to more carriers. This should be nothing new to passenger carriers, who have been under the microscope now for several years. This scrutiny won’t change with the implementation of CSA 2010. In fact, under the SMS, passenger carriers will have lower intervention thresholds than property carriers and fewer intervention steps before on-site, full-blown compliance reviews are triggered.
CSA 2010 poses some potentially big benefits for those carriers who play by the rules. For one, driver safety performance histories compiled will be available for carriers to use during the applicant screening process. This can provide additional insight into a potential driver’s behaviors, honesty, and propensity to follow established rules and processes – which, not surprisingly, have all be linked to crash risk. Likewise, the new system could potentially alert operators of a current driver who has not been forthcoming with information related to traffic or regulatory violations.
And finally, it should allow for those operators with issues to be identified more quickly and appropriate actions to be taken if they aren’t corrected. For those that play by the rules and manage their drivers, fleet and compliance functions well, there really shouldn’t be any additional enforcement or regulatory scrutiny—in fact, there may be even less. If CSA 2010 works as designed, more enforcement personnel time will be able to be devoted to safety data collection and roadside enforcement. And more eyes and feet on the roadways is what is ultimately needed to catch and curtail illegal operations, and prevent unnecessary accidents and negative publicity for the passenger carrier industry.
Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, CA.