Supply Chain Managers To See Changes in CSA Program

The Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) recently announced various changes it its much maligned government-mandated CSA program, which stands for “Compliance, Safety, Accountability.”

CSA was designed to weed out as many as 5 percent—or 150,000—of the nation’s 3 million or so long-haul truck drivers that the feds believe are involved in a disproportionately high number of truck accidents and fatalities. CSA uses a complex scoring system to rate the nation’s nearly 700,000 DOT-registered interstate trucking entities on seven “Behavior Analysis and Safety Improvement Categories,” known as “BASICs.”

The seven BASICs are driving, fatigued driving, driver fitness, alcohol and drugs, vehicle maintenance, cargo security (now HM Compliance) and crash history. Carriers are given “scores” in each category—higher the score, worse the performance. So-called “warning letters” go out to fleets with scores above 65 (which means that only 35 percent of carriers in their class have worse scores). For hazmat carriers, the cutoff score is 60.

FMCSA officials said that these changes were based in part on public comments received from a preview of proposed changed to its Safety Management System (SMS) Web site, and they noted that in the first year of CSA enforcement violations per roadside inspection and driver violations per inspection decreased by their largest amounts in ten years at 8 percent and ten percent, respectively, coupled with 30 million visits to the SMS site.

The FMCSA said it will implement the new SMS site in December. In testing it said it found that motor carriers identified as “high risk” by the SMS have future crash rates that are more than double that of all active carriers.

The SMS changes taking effect include:
-strengthening the Vehicle Maintenance BASIC (Behavior Analysis and Safety Improvement Categories) by incorporating cargo/load securement violations from today’s Cargo-Related BASIC;
-changing the Cargo-related BASIC to the HM (hazardous materials) Compliance BASIC to better identify HM-related safety and compliance problems;
-better aligning the SMS with Intermodal Equipment Provider regulations; and
-more accurately identifying carriers that transport significant quantities of HM, among others.

Along with these SMS-specific changes, FMCSA has identified four other changes that will take effect in September, including:
-removing 1-to-5 mph speeding violations;
-lowering the severity weight for speeding violations that do not designate MPH range above the speed limit;
-aligning paper and electronic logbook violations; and
-changing the name of the Fatigued Driving Hours-of-Service (HOS) BASIC to the HOS Compliance BASIC
Even with these pending changes, in many trucking circles, the general consensus more than a year after being introduced is that CSA is an ill-conceived plan that is doing nothing more than making it difficult to get things done in an already-challenging environment.

Earlier this year, the American Trucking Associations said that CSA scores are unreliable, have a loose and sometimes inverse connection to crash risk, coupled with the fact that they say the FMCSA is demonstrating an unwillingness to discuss CSA’s flaws.

What’s more, the ATA has identified many CSA-related issues that need to be reformed, including: crash accountability, the lack of research proving increased crash risk for all of CSA’s various violation categories and the publication of carriers’ scores in those categories.

Jeff Tucker, CEO & Founder at QualifiedCarriers.com & CEO Tucker Company Worldwide Inc. said there are mixed benefits to the coming CSA changes.

“The 1-5 mph speeding violations [being removed] has a chance to be a positive,” he said. “There are many state police pulling carriers over at 1-2 miles over the limit and then tagging them with other violations. It would appear that FMCSA acknowledging one of the bigger issues.”

The cargo-related BASIC, which was changed to HM Compliance Basic, is no longer near the top of the CSA list for safety violations, whereas it was previously its own BASIC category.

Tucker explained this change brings some “credibility” moving forward in the sense that FMCSA may have been overstating the value of certain BASICs. But he said that while these two changes stand to improve CSA, he still remains critical of the program overall on various fronts.

He cited studies from Wells Fargo securities, which note that it is not clear whether the carrier safety performance measures in CSA accurately portray either the risk profile of individual carriers or the likelihood of an accident.

“In fact, according to our analysis of the 200 largest carriers in the CSA database, we find no meaningful statistical relationship between actual accident frequency and BASIC scores for Unsafe Driving, Fatigued Driving or Driver Fitness,” stated a November 2011 Wells Fargo study. “Regardless, carriers must still bear both direct and indirect costs of compliance.”

And a July 2012 Wells Fargo study expanded its carrier dataset to the 4,600 largest North American trucking companies with a minimum of 25 trucks and 50 inspections. The firm said this dataset enabled it to capture both large and small carriers and also ensure that the prescribed regulatory measures are represented and analyzed.

But it found that the findings from the larger dataset only strengthened its conviction that its previous finding from the November 2011 study remained intact and demonstrates more dispersion in the intended results and unintended consequences of the CSA methodology.

“This shows that the BASICs are not driven by any data or science to be good indicators for people to judge driver ratings,” said Tucker. “FMCSA needs to act on this, because as far as I am concerned they are basically instilling fear into the marketplace rather than drive safety. Instead of doing a full compliance review to inspect carriers, FMCSA is using BASICs to determine what carriers they are going to go after and specifically address certain things like HOS or cargo-related things. They have sent out far more warning letters than they ever have before, and they are seeing far more carriers in a given year. What is happening as a result is safety ratings are changing faster than they have ever changed before. They are sending out more letters and intervening more quickly than they ever have before. I think if they admit that BASICs are not meaningful it lessens the threat and thereby carriers will feel the threat is an empty one.”

The ATA said the steps FMCSA is taking in regards to CSA are mostly positive, explaining that in looking more closely at violation severity weights, as an example, FMCSA is taking some steps to make sure CSA achieves its stated goal of targeting carriers with increased crash risk.

But it added that more work needs to be done, too.

“These changes, while appreciated, point to the issue ATA has been urging FMCSA to address for some time: CSA scores are not necessarily indicative of elevated crash risk,” ATA President and CEO Bill Graves said in a statement. “Several studies have told us this, and FMCSA’s changes indicate they believe it as well. ATA supports CSA’s original goal of reducing crashes by targeting unsafe carriers, but too often, the system highlights violations that bear little direct - or even indirect - relationship to crash risk. FMCSA must continue to hold true to CSA’s original goal and make changes to the program as necessary to do so.”

A FMCSA spokeswoman, in an email response to Logistics Management —SCMR’s sister publication—questions about the program this April, admitted CSA is in the “early stages” of efforts to better educate shippers, insurers and other stakeholders about truck safety data. She added that FMCSA is “committed to continually improving and refining” the relevant truck safety statistics “as better technology, new data, and continuing analysis provide the means and opportunity for refinement.”
 
The federal government’s truck safety statistics can be read two ways. Truck-related fatalities per 100 million miles traveled are at their second-lowest point since the government began compiling that data in 1975, but rose last year. Truck-related crashes jumped 9.4 percent over 2010’s figures, according to preliminary DOT figures released recently. The number of truck-related fatalities rose 8.7 percent to 3,675, compared with a record-low of 3,380 in 2010, according to numbers compiled by the National Highway Traffic Safety Administration.