| |
 |
|
MENU |
|
|
|
|
|
|
|
|
|
|
|
|
|
 |
|
|
|
SCCA Magazine |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
 |
 |
 |
CSA ...
ignore it at your peril
|
 |
|
|
 |
|
 |
|
What you don't know can hurt you
There is no
way to avoid the
fact that the
Department of
Transportation’s
CSA 2010
fundamentally
rearranged the
safety
compliance
landscape for
any company that
operates heavy
trucks. In
states that
pilot-tested the
new program,
trucker safety
scores have
amply
demonstrated
that this new
program will
have a major
impact on the
way construction
fleets operate
dumps and other
support
vehicles, as
well as how
drivers drive
them.
Since
its adoption,
CSA 2010 has
become just CSA
(Compliance,
Safety and
Accountability),
and it has
completely
changed the way
safety data
feeds the
reporting
system.
Information
collected from
roadside
inspections,
truck crash
reports and
traffic reports
on moving
violations now
triggers
enforcement.
Previously,
truckers were
rated on
violations that
resulted from
out-of-service
orders, and
drivers were not
a factor.
CSA now takes
into account all
safety
violations a
company and its
drivers receive
and the analysis
goes
considerably
deeper into all
facets of the
operation. To
give it teeth,
the analysis is
accompanied by a
much more robust
and far-reaching
enforcement.
Violations that
used to be
statistically
insignificant
will now carry
major weight,
and fleets that
are not in
compliance will
hear from the
Federal Motor
Carrier Safety
Administration
(FMCSA), the
enforcement arm
of DOT.
The BASICs
Safety
violations are
now organized
into seven
categories.
Identified as
Behavior
Analysis and
Safety
Improvement
Categories, or
BASICs, they
are:
Unsafe
driving ‒
Operation of
commercial motor
vehicles by
drivers in a
dangerous or
careless manner.
Examples are
speeding,
reckless
driving,
improper lane
change and
inattention.
Fatigued driving
‒ Operation of
heavy trucks by
drivers who are
ill, fatigued or
in
non-compliance
with the
Hours-of-Service
regulations.
This includes
violations of
logbook
regulations and
management of
driver fatigue,
putting both
under scrutiny
as never before.
Driver
fitness ‒
Operation of a
truck by drivers
who are unfit to
operate these
vehicles due to
a lack of
training or
experience, or
medical
qualifications.
This includes
failure to have
a valid and
appropriate
commercial
driver’s license
(CDL) or being
medically
unqualified to
operate a truck,
even if it
simply involves
driving a truck
without a
medical card.
Controlled
substances/alcohol
‒ Operation of
trucks by
drivers who are
impaired due to
alcohol, illegal
drugs, or misuse
of prescription
or
over-the-counter
medications.
This, of course,
includes use or
possession of
controlled
substances or
alcohol.
Vehicle
maintenance ‒
Failure to
properly
maintain the
truck. Brakes,
lights, and
other mechanical
defects that are
found during an
inspection, as
well as general
failure to make
required
repairs, are all
likely to be
targeted and
even though the
condition is not
enough for an
out-of-service
order, they will
still count as
violations.
Cargo-related ‒
Failure to
properly prevent
shifting loads,
spilled or
dropped cargo,
overloading, and
unsafe handling
of hazardous
materials. This
includes cargo
retention
through improper
load securement
or use of
non-compliant
retention-equipment,
such as straps,
chains and load
binders with
incorrect
ratings. It also
includes
handling of
hazardous
materials.
Crash indicator
‒ Histories or
patterns of high
crash
involvement,
including
frequency and
severity. This
will be based on
information from
state-reported
crashes and from
police accident
reports.
The scores
Within each
BASIC, the score
depends on ‒ and
is weighted by ‒
● The number
of adverse
safety events
(violations
related to that
BASIC or
crashes)
●
The severity of
violations or
crashes
●
When the adverse
safety events
occurred. The
most recent
events are
weighted more
heavily.
It’s
worth noting
that these
BASICs are
populated by
reported
violations, i.e.
tickets, or by
officer reports
at an accident.
Whether or not a
carrier or a
driver is at
fault is not
recorded and
even when either
is exonerated,
the report
stands.
As
the data from
company or
driver
performance adds
up, the company
is placed in
what FMCSA calls
a “safety event
group,” which
includes
companies with
similar numbers
of roadside or
scale
inspections, and
accident
reports.
Percentiles from
0 to 100 are
then determined
by comparing the
BASIC
measurements of
the company to
the measurements
of similar
companies in the
safety event
group; 100 is
the worst.
The
enforcement
If one or more
of a truck
fleet’s BASIC
percentiles
exceeds a
pre-determined
threshold, the
company becomes
a candidate for
an intervention.
Typically, the
intervention
process starts
with a warning
letter, which
provides the
company with an
opportunity to
review its
performance and
make
improvements
without further
enforcement
involvement.
Thresholds vary
depending on the
type of
operation and
the BASIC
category. For
example, since
the consequences
of passenger or
hazardous
materials
crashes are
typically more
severe, lower
intervention
thresholds are
in place for
these types of
carriers.
The
warning letter
is intended to
be a wake-up
call and make
companies aware
of safety
performance
issues so they
can address them
early, before
they become
habitual.
Ignoring a
warning letter
is never wise,
as it will only
escalate the
level of
intervention.
Next steps
in CSA’s
intervention
process are off-
and on-site
investigations
and/or focused,
on-site
comprehensive
investigations.
The drivers
Undoubtedly, the
biggest change
in the new
regulations is
the fact that
the rating
process is
ongoing and
delves deeply
into the truck
operator’s
performance.
Under the old
system, a
company might or
might not be
selected for an
FMCSA safety
audit as a
result of a
safety issue.
Now the scores
are entered and
reviewed
automatically,
and reports are
issued at 30-day
intervals.
About the only
way a company
with trucks
flies under this
new radar is if
there are too
few trucks in
the fleet to
trigger very
many roadside or
moving
violations. But
if drivers are
getting ticketed
for speeding or
other moving
violations, the
company will
soon become a
target for an
intervention.
If ever there
was a reason for
carriers to
monitor and
discipline
drivers, CSA is
it.
The impact
When the rules
were first
proposed, it was
assumed that the
driver fatigue
BASIC would be
the most
troublesome. The
fact that
drivers cheat on
their logs is
widely known and
tolerated by
managers when
either it suits
them or the
infraction is
minor. Under CSA
– and especially
with the pending
on-board
recorder
legislation –
this is going to
put a company at
significant
risk. A company
only has to be
found deficient
in one or two
BASICs to
initiate an
intervention.
More recently,
it has become
apparent that
the vehicle
condition
category may
also result in
FMCSA
interventions. A
number of
third-party
suppliers that
help companies
manage their
data and
operations found
that in the
pilot-state
programs vehicle
maintenance was
a strong #2 in
triggering
interventions.
And the
violation can be
something as
insignificant as
a
non-functioning
light or a torn
mud flap.
Now
that drivers are
being scored by
the CSA system,
and their scores
will be in the
public domain,
you can bet
drivers will be
a lot more
conscientious in
their Vehicle
Inspection
Reports at the
end of a shift.
Also, drivers
will almost
certainly want
to verify that
the shop has
signed off on
any problems
identified in
the inspection
report.
This
change in
emphasis could
result in trucks
on the “ready”
line not being
ready at all,
and the
resulting rework
will be a major
frustration for
dispatch. Because some
types of
violations are
weighted,
companies that
operate trucks
must stay on top
of each category
to guard against
problems. For
example, the
cargo restraint
category that is
critical for
companies that
move
construction
equipment can
easily reach
levels that will
trigger an
intervention.
The future
Third-party
providers of
fleet management
products offer
modules that
track the bigger
truck fleets’
BASIC scores and
alert the
company when
there is a
problem.
Communication
providers, such
as Qualcomm and
People-Net, and
driver
management
software
providers, like
Vigillo and
TenStreet, can
help big
operations with
trucks track
scores and
respond
appropriately.
For smaller
operations, it’s
likely going to
be up to local
managers to
maintain CSA
profiles. For
information on
available tools
to accomplish
this or to find
reports on your
fleet’s current
performance,
visit
www.fmcsa.dot.gov.
A Google, Yahoo
or similar
search on CSA or
CSA 2010 will
also point you
to relevant
resources.
Most important
is to recognize
that this new
safety
initiative is
here to stay,
and state and
federal agencies
are now far
better equipped
to hone in on
the
less-than-safe
operator, as
well as the
merely careless
one.
For most
companies,
staying out of
FMCSA’s sights
is going to
require an
internal culture
change. In areas
where the
program is being
tested,
companies that
received warning
letters used the
letters as a way
to get all
personnel on the
same page.
Drivers were
reminded of
their
responsibilities
to the company.
Maintenance
managers and
mechanics were
alerted to the
necessity of
taking care of
the finer
details, as well
as the big
maintenance
items.
Dispatchers were
expected to be
more diligent
about helping
drivers keep
legal hours and
clean logbooks.
On the other
hand, companies
quickly found
that if they are
going to attract
and keep quality
drivers, they
are going to
have to provide
quality
equipment that
is
well-maintained
and dispatch
drivers so they
can stay within
the
Hours-of-Service
rules. At the
same time,
managers must
work with
drivers to
minimize
violations, and
offer training
that
demonstrates
that the company
is cognizant of
a problem driver
and is doing
what it can to
retrain and
rehabilitate
that driver.
Under CSA, a
driver that
leaves your
company doesn’t
carry violations
received while
in your employ
to a new
employer.
Rather, those
violations stay
on your record
for three years.
A crash stays on
your company’s
profile for five
years.
CSA
has been
referred to as
the game-changer
in truck safety,
and it’s all
that and more.
It will
certainly be a
game changer in
many operations,
as managers
develop new
processes that
hone in on the
finer details of
operating and
maintaining
equipment, and
begin to
dispatch drivers
so that they can
continue without
enforcement
intervention or,
in the ultimate
case, being shut
down entirely.
-By Steve
Sturgess, consultant, speaker and
writer in the
trucking
industry, can be
reached at (949)
338-6425 or sturgess@aol.com.
| |
 |
|
 | | | |
