Getting Ready For CSA 2010

by James Menzies

TORONTO, Ont. –Mere months before a new carrier safety rating system is rolled out in the US, many Canadian carriers remain blissfully unaware of the impending changes and how they will be affected by them. But Jeff Davis, vice-president of safety and human resources for Dayton, Ohio-based Jet Express, recently ventured to Canada to warn attendees at the most recent Driving for Profit seminar that “we’re about to embark on the biggest change in safety and compliance in the US that we’ve had since the early ’30s.”

That, incidentally, was when logbooks were first introduced. The impending changes are known as Comprehensive Safety Analysis (CSA) 2010 -a new carrier safety rating system that will score carriers and drivers based on their roadside performance. It’s already being tested in eight states and in the process, Canadian carriers that operate there may already have been given a CSA 2010 rating.

CSA 2010 brings about three major changes, Davis explained at the Nov. 3 seminar. 1) Driver abstracts will be replaced by a continuously- updated driver performance file that lists all violations over a 36-month period. Davis likened it the back of a baseball card, which clearly displays all the player’s vital stats. 2) A driver’s performance will be the determining factor of his or her employability. “You’ll be able to go in, once the driver signs a waiver, and see that driver’s whole history of safety performance,” Davis explained, adding in some cases “it may get to the point where you’re not able to utilize them.” And 3) carriers will have to help their drivers adapt to the increased scrutiny. “This is a huge change they’ve never faced,” said Davis. Under CSA 2010, drivers as well as carriers will be electronically rated every 30 days by the FMCSA.

“That driver holding onto the wheel literally has his hands around your safety rating in the US, so you have to learn how to work with him and teach him to bring him into compliance -it’s a huge job,” said Davis.

Once a month, CSA 2010 will score both carriers and drivers and assess them one of three ratings: Continue to operate; Marginal; or Unfit. They’ll be assessed based on their performance in seven categories known as the BASICS: Unsafe Driving; Fatigued Driving; Driver Fitness; Drugs and Alcohol; Vehicle Maintenance; Cargo Securement; and Crash Experience.

The first two -Unsafe Driving and Fatigued Driving -are weighted more heavily than the others, Davis warned.

“These two BASICS are so significant that if you are deficient in one of these, you are automatically ‘unfit’ as a motor carrier,” he warned, adding a simple logbook violation could be enough to get a carrier in trouble under CSA 2010.

In the lead-up to CSA 2010, the Federal Motor Carrier Safety Administration (FMCSA) has “severity-weighted” 3,589 different trucking violations which will help determine driver and carrier safety ratings. For instance, falsifying logbooks is worth seven points, having insufficient brake lining nets four, etc. with all points scored against both the driver and the carrier.

“Under SafeStat (the current system), any inspection that was not an out-of-service inspection was a good inspection,” said Davis. “In CSA 2010, every defect they look at will count against the motor carrier and the driver.”

If a carrier runs afoul of the FMCSA under CSA 2010, a number of measures will be taken and carriers will be held more accountable to address their problem areas.

“CSA 2010 intervention could be as little as a letter and then it goes from there,” said Davis, noting that in extreme cases, the frightening-sounding term of “maximum civil forfeiture” can be applied following just one violation. “Intervention increases in severity as time goes by.”

When a driver or carrier becomes deficient in any of the seven BASICS, the FMCSA opens an intervention file and will likely send a letter advising the carrier to immediately correct the problem.

“If that doesn’t happen, they come in and do an on-site review of that deficient BASIC,” explained Davis. Fines are likely to accompany interventions and in some cases a “consent order” will be have to be filed by the carrier, promising to exceed minimum compliance requirements.

Carriers will be held more accountable than in the past when promising to take corrective measures, because under CSA 2010, their drivers’ on-road performance will be under constant scrutiny, telling the true story of that carrier’s ongoing safety performance. No longer will a carrier be able to rest on its laurels between satisfactory inspections.

“It’s going to be all about roadside performance, it’s not going to be about how good you polish and it’s not going to be about how good that safety rating was you got five years ago -it’s going to be what have my drivers done to me this month?” Davis explained.

So what exactly should a carrier be doing to ensure it’s ready for CSA 2010? For starters, Davis said they should log onto the SafeStat Web site, enter their DoT pin number and check out their current SafeStat rating. This will give you an idea of how well your company is currently doing.

Next, carriers should take steps to trigger fewer roadside inspections. Davis said nearly all roadside inspections are triggered by an event, notably speeding, observable defects or being red-flagged for having a high inspection selection number (ISN).

The ISN is the ranking enforcement agencies use to determine which trucks to flag down for inspection. Davis summed it up this way: 0-49 = green light; 50-74 = yellow light; and anything above, “the red lights are flashing and the inspectors are foaming at the mouth because they have a criminal coming in.”

Carriers should be ensuring they lower their ISN number by giving enforcement officers little reason to inspect their vehicles in the first place, Davis suggested. He warned said many carriers get caught in a vicious cycle: “The more inspections you get, the more violations you get, the more violations you get, the higher your ISN goes, the higher your ISN goes, the more inspections you get,” he said. “The only thing that changes it is clean inspections and the passage of time.”

Passing inspections will slowly allow a carrier to lower its ISN score, resulting in fewer inspections. (Here’s another good incentive to reduce the number of inspections your trucks are subjected to: Davis said the productivity loss incurred for each inspection costs about $102.05 -and that’s for a pass).

“Every inspection is avoidable, that’s got to be your goal -especially under this program,” Davis advised.

CSA 2010 will be launched in earnest in July 2010 and rolled out right across the US by the end of next year.

All information generated by CSA 2010 will be accessible through the FMCSA’s Compass portal (https:// portal.fmcsa.dot.gov/), which is still a work in progress. Davis pointed out that ratings will be available online to shippers and competitors.

“If your numbers are bad, your competitors will take their good numbers in (to your customers) and say ‘why are you using that unsafe carrier from Canada’?” Davis warned.

Davis said if all goes according to plan, CSA 2010 will provide a more effective way to identify and address risky behaviour by commercial drivers and carriers.

“CSA 2010 is such an incredible program, if the US government pulls it off,” said Davis. “Sometimes, things don’t always work out the way they’re designed, but it appears the (FMCSA) is on the right track through the use of technology to pull something off we’ve never experienced before in trucking.”

However, he had this final warning for Canadian carriers with high ISN numbers that are subjected to lots of inspections while operating in the US: “There are carriers in the US and Canada, big name carriers, that have high numbers and when this rock hits the pond, they’re going to be in trouble. The tide’s going to go out and we’re going to see who’s been swimming nak
ed.”

-To see Jeff Davis’ presentation in its entirety, sign up for the Driver’s Seat video series powered by CarriersEdge. Subscriptions begin at just $7.99 per month. Visit www.TheDriversSeat.caor call CarriersEdge at 905-530-2430 to sign up.

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“The tide’s going to go out and we’re going to see who’s been swimming naked”


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