Keith Klein testifies on behalf of ATA. Photo courtesy of Brad Stotler/ATA.

CSA 2010 is Flawed, ATA Tells Congress

With the Federal Motor Carrier Safety Administration nearing the conclusion of the data collection phase of its Comprehensive Safety Analysis 2010 (CSA 2010) initiative and the implementation date nearing, the American Trucking Associations said Wednesday it has "serious concerns" with how the program will actually work.

Introduced as a pilot program among select states in February 2008 with planned nationwide implementation sometime later this year, CSA 2010 is a federal program designed to reduce commercial vehicle crashes by using a motor carrier rating system based on seven measurable, results-oriented behavior analysis and safety improvement categories. Drivers who do not measure up or are otherwise deemed unfit by the new guidelines could be forced to cease operations.

ATA said it fully supports the program's objectives of targeting unsafe operators, changing their behavior, and removing the most egregious actors from the road, but the association also said the current design of CSA 2010 is flawed and that, if not corrected, the forthcoming guidelines could negatively affect both the motor carrier industry and highway safety in general.

Representing ATA before the House Transportation and Infrastructure Subcommittee on Highways and Transit, Keith Klein, executive vice president and CEO of the Transportation Corporation of America, on Wednesday said the association supports the CSA 2010 initiative because it is based on safety performance rather than compliance with paperwork requirements; it focuses limited enforcement resources on specific areas of deficiency, rather than on comprehensive on-site audits; and because it will eventually provide real-time, updated, safety performance measurements. "All three of these attributes address long-standing problems with the Federal Motor Carrier Safety Administration's current monitoring and enforcement program," Klein said.

"FMCSA deserves to be applauded for its development and implementation of CSA 2010 to date. The agency has gone to great lengths to test the program, develop and implement an extensive outreach and education program, and demonstrated a willingness to accept stakeholder input," Klein added, in his testimony before the committee. "However, ATA has a number of serious concerns relating to how CSA 2010 will work that, if not addressed, will have a dramatic impact on motor carriers and on highway safety."

To address the primary concerns it has with CSA 2010, ATA recommends that FMCSA:

  • Make crash accountability or "causation" determinations on truck-involved crashes before entering them into a carrier's record so drivers and carriers are held accountable only for crashes they cause.
  • Use vehicle miles traveled (VMT), not number of trucks or power units, as a carrier's exposure measure.
  • Focus on using only actual citations for moving violations and not unadjudicated "warnings" issued by law enforcement.

The intent of raising these concerns is twofold, Klein said: "The first is a matter of safety, to ensure that unsafe carriers are selected for interventions, and the second is a matter of equity, to ensure that relatively safe carriers are not selected for interventions."

Klein said that in addition to the primary concerns, ATA also is concerned about how the severity weights for violations are assigned; 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; overly broad peer groups; and inconsistent state enforcement practices.

"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," Klein said.

To avoid these consequences, Klein recommended that FMCSA wait to implement the program after it has the opportunity to review an evaluation study of CSA 2010 currently underway by the University of Michigan Transportation Research Institute. FMCSA also should make the corrections based on ATA's three primary concerns before the initial implementation of CSA 2010 and before making the information publicly available, he said.

"Any system based on evaluating motor carrier safety comparatively must be grounded in sound data, sound math, and consistent measurements to be both equitable and effective," Klein said.

On its website, FMCSA says that between now and full implementation it is launching an outreach effort to inform carriers and drivers of the upcoming changes and to encourage all stakeholders to become more involved. The agency adds that support of FMCSA leadership and continued outreach to stakeholders such as the National Transportation Safety Board, Congress, the Government Accounting Office, safety advocate groups, industry, and the Commercial Vehicle Safety Alliance paves the way for successful implementation of CSA 2010 nationwide.

Klein's complete testimony is available online at

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