"We are under CSA right now and have been for the past two years," said Don Osterberg, Schneider National Inc. senior vice president of safety, driver training, and security.

The CSA 2010 Rollout

Motor carriers are coming to grips with the new federal safety measurement system. They've seen several changes in it already.

Motor carriers say they agree with the goals of the Comprehensive Safety Analysis 2010 (CSA 2010) safety measurement system now being implemented by the Federal Motor Carrier Safety Administration. FMCSA Administrator Anne Ferro described CSA 2010 in a June speech as "a move from away from the current one-size-fits-all compliance review approach to a more frequent examination of key factors linked to commercial motor vehicle crashes," which she then listed: "unsafe driving; fatigued driving; driver fitness crash history; vehicle maintenance; improper loading and cargo; and drugs and alcohol."

Carriers had access to their CSA scores beginning Aug. 17, 2010, and scores (except the crash indicator BASIC score) will be available to the public as of November, said Don Osterberg, Schneider National Inc.'s senior VP of safety, driver training and security. The company's motor carriers employ about 15,000 drivers.

FMCSA intends to begin implementing CSA 2010 on a state-by-state basis late this year, with companies beginning to use it based on where they are headquartered, said Larry Bizzell, senior corporate safety advisor for FedEx Express.

Don Osterberg, Schneider National Inc. senior vice president of safety, driver training, and security"The thing that is clear, and I think it's important for people to understand -- there is no 'light switch' implementation. We are accruing CSA points today," Osterberg explained. "When the system does go live, if you will, or becomes publicly accessible, the previous 24 months of incidents for carriers and 36 months for drivers will be included in the score that is ultimately derived. So in my view, we are under CSA right now and have been for the past two years."

He said while he fully supports the objectives and intent of the new system, five elements of it are problematic. Some of those areas of concern are being addressed by FMCSA, he said. "I found them to be very engaging and very active listeners and seemed to be not defensive, as I might have expected them to be, but very open to suggestions. I'm actually quite optimistic that FMCSA understands the issues and will do something about it," he said. "Until I'm proven wrong about that, I'm still going to call myself supportive and optimistic about what they're going to do."

"We don't know where or how flexible, to this point, but they are at least considering," Bizzell agreed.

"It would be foolish to believe we're going to end up with a perfect system with CSA," Osterberg added. "It's not perfect. There are just too many variables and the environment we're operating in is too dynamic. . . . But there are some fundamental things we can do to make it much, much better" and to achieve its aggressive goals that increase public safety, he added. "Even if it were implemented in its current form, I do believe the awareness and the focus will improve public safety."

"I think it's a good change," Bizzell said. "It's a way for the Federal Motor Carrier [Safety Administration] to touch more companies on a regular basis, as well as the individual drivers. It still has some potential bugs to work out as far as the quality of the data, to make sure that the inspection data gets to the right company and to the right driver. But I do think it's going to be a positive."

Searching for Fairness
Among the problematic areas where they hope FMCSA will be flexible: In the proposed system's crash basic score, there's no attempt to assess whether a crash was the commercial driver's fault or not.

"I think that's unfair," Osterberg said. "I think there are some drivers who will become essentially unemployable in our industry not by virtue of their actual safety performance but by virtue of the fact that they were unfortunate enough to be in the wrong place at the wrong time and involved in a high-severity crash." He said instead, a crash for which a commercial driver wasn't cited should be weighted at zero or quite low.

Keith Klein, executive vice president and CEO of the Transportation Corporation of America, represented ATA when he testified June 23 about CSA 2010 before the U.S. House Transportation and Infrastructure Subcommittee on Highways and Transit. Klein, Bizzell, and Osterberg said using a carrier's power units as a measure of exposure is another problem with CSA 2010 because this would penalize carriers that utilize driver teams. They agreed vehicle miles traveled is a better indicator of risk exposure.

"We have so many trucks that are double utilized in a day because we have some part-time drivers. So somebody might drive it in the morning and somebody else in the afternoon," Bizzell said. "That only gets counted as one truck where it's actually two different people putting miles on the truck that day."

FMCSA announced Aug. 4 that it will use a combination of vehicle miles traveled and power units in the Unsafe Driving BASIC and Crash Indicator. The agency also said it will adjust some of the current severity weightings for roadside inspection violations.

Another concern is that CSA 2010 weights warnings for speeding as equal in severity to citations for speeding. "We actually did some research, and we had a couple of our very best drivers," Osterberg said. "When we looked at their projected CSA points, they looked to be problematic drivers relative to the other drivers in our fleet, and it was based exclusively on warnings for speeding. They had no moving violations, no citations for speeding, no accidents, and no other issues. The warnings alone were putting them into a category where it appeared they were problematic drivers, and I can assure you they are not."

He and Bizzell agreed warnings should not be counted or should be weighted much lower than citations and convictions.

Osterberg said he wanted the severity weightings for violations to be recalibrated. Any issue with tires has a severity weight of eight on scale of 10, which makes sense for low tread on a steering tire but no sense for trailer tires. They become more fuel efficient as their tread wears down, and Schneider National's tests found low tread depth on a trailer tire has virtually no correlation to crash causation, he said.

Osterberg said inconsistency in states' reporting of CMV crashes should be addressed. Because CSA 2010 will be used by insurance providers, shippers, and others, getting states to be more consistent in reporting crash data "is going to be critically important," he said.

He and other motor carriers' safety managers will manage using CSA 2010, and it will give them visibility into drivers' records they didn't have before. It will be better than the SafeStat system FMCSA is replacing, under which it was possible for drivers having poor records or bent on avoiding drug tests to move around, changing employers to stay in the industry.

Asked whether many drivers will be pushed out of the industry, making it even harder to hire, Osterberg answered, "I don't think anyone is saying that we need drivers so badly that we're willing to employ bad drivers. . . . Of course they will, and we shouldn't apologize about that. That will happen, there's absolutely no doubt in my mind that that will happen. It's very clear to me that some drivers will be forced out of our industry."

FMCSA has said its 2011 CSA actions will include its issuance of a Safety Fitness Determination Notice of Proposed Rulemaking and training of enforcement staff. The agency is taking comments until Nov. 30 at www.regulations.gov (Docket number FMCSA–2004–18898).

In his testimony, Klein pointed out that the U.S. large truck fatality and injury rates per million miles traveled fell in 2008 to their lowest levels since DOT began keeping statistics. "The trucking industry is the safest it has ever been and continues to get even safer," even as the number of trucks in use and total miles traveled have risen, he said.

He said motor carriers should be held accountable only for crashes they cause. ATA also is concerned about measuring carriers based on violations committed by drivers who have since been terminated, measuring carriers based on citations that have been dismissed in a court of law, inequitable measurement of open deck or flatbed carriers, and overly broad peer groups -- a carrier's safety performance should be compared against those of others with similar exposure, he said.

"Carriers who are rarely inspected may appear to be safer since they have less opportunity to be found in violation," he said. "A system that is based on inconsistent data and a flawed scoring methodology will not achieve its objectives. Instead, it will create inequities for some safe carriers and inappropriately allow some unsafe carriers to avoid scrutiny and consequences."

He recommended that FMCSA delay implementation until after it reviews an evaluation of CSA 2010 currently under way and due to be submitted in December 2010 by the University of Michigan Transportation Research Institute.

This article originally appeared in the September 2010 issue of Occupational Health & Safety.

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