TORONTO, Ont. - Compliance, Safety and Accountability (CSA) is a robust initiative sponsored by the US Department of Transport's FMSCA to monitor and mitigate high-risk driver and carrier behaviour across America. This, of course, includes...
TORONTO, Ont. – Compliance, Safety and Accountability (CSA) is a robust initiative sponsored by the US Department of Transport’s FMSCA to monitor and mitigate high-risk driver and carrier behaviour across America. This, of course, includes Canadian carriers running internationally.
The program is the successor to the DoT’s Safestat, and the short-lived CSA 2010 (which stood for Comprehensive Safety Analysis), and has just gone nation-wide in December, 2010. Violations and alerts noted during inspections are entered instantaneously into a motor carrier databank.
The violations are given a point score through the regulator’s SMS (Safety Measurement System), and are supposed to be based on the relationship to crash risk. The records of citations and violations are kept on file for two years. Too many accrued points can lead to warning letters and interventions, and potentially make some drivers and fleets uninsurable.
CSA is a broader approach than Safestat and is defined by seven “Basic” categories (Safestat only had four). Much of the focus is concerned with driver behaviour. Cargo securement, however, which includes the handling of hazardous materials, has been given its own section and makes up the bulk of the potential violations.
Load securement was not part of the original Safestat program, and there is some concern among carriers about the severity of the weight given to the cargo tie-down category. CSA did make some changes to some of the load securement methodology in December of 2010, dropping the severity of a loose or unfastened tie-down from 10 points to eight, and upping some of the HazMat violations to six points.
Initially, FMCSA was publishing carrier load securement point scores on its CSA Web site. But strong objections from the ATA, among others, caused the regulator to block those scores from public view. According to Duane DeBruyne, spokesperson for the FMCSA, “We appreciate that when you have flatbed trailers where the load is exposed it’s easier to see those issues. We recognize the difference in flatbed versus box container and that the results could potentially be misread.”
However, the date, location, licence plate and VIN of the offence are still accessible on the site.
One thing’s certain, it’s not just flatdeck haulers that are under increased scrutiny by US regulators. “They have been opening trailers and looking inside,” says Rick Geller, director of safety and signature programs for truck insurer Markel. “In the past it wasn’t an issue. Even some of your stake and rack trailers they never looked inside. But now they’re interested.”
Tom Boehler, safety manager for Erb Transport of New Hamburg, Ont., says some of his trucks have been stopped in New York State and written up for not having load bars at the back of the trailer. The irony is not lost on Boehler: “They will give you a fine if you don’t have load bars but no one will put a load rating on load bars.”
Besides the introduction of the CSA program, increased vigilance of load securement has gone continent-wide as of Jan. 1, 2011, when most Canadian provinces began enforcing the National Safety Code in the use of cargo tie-downs. In Canada, load securement devices including straps and chains are required to display a Working Load Limit or they will be considered to be zero.
Recently in Ontario, a Purolator driver was written up for having an insecure load when an MTO officer noticed a bag of salt on the truck’s catwalk strapped down by bungee cord. Since bungee cord has no working load limit, the rating was considered to be zero. The driver could have avoided the problem by using a one-inch ratchet strap with a stamped WLL. Even so, Geller suggests that the MTO official may have been over-zealous in writing up the Purolator driver.
“The issue of using bungee cords was something that was reviewed a couple of years ago and most states and provinces agreed to an interpretation that allowed the use of bungee cords,” he says.
“What first raised the issue was the fact that it was a common practice for carriers to secure dunnage in the landing gear using bungee cords. An agreement was reached that allowed the use of bungee cords. This speaks to the issue of consistency and you have officers who have not been properly trained, applying the rules the way they believe they should.”
Straps and chains do not have to display load limits in the US, where the limit is calculated differently. Cut or damaged straps should never be used. Even a slightly chewed up strap, installed as an extra tie-down for supplemental security, will be scored as a violation.
Carriers running north-south are advised to do their research. The number of tie-downs required for a load can also vary internationally, according to Rolf Vanderzwaag, manager of maintenance and technical issues for OTA.
“We’ve had carriers with enough tie-downs in Canada, but when they hit the states they need to add some more.”
Goods shipped on pallets are expected to be wrapped to the pallets and fitted snugly against each other running towards the bulkhead. Other commodities that cannot be palletized have to be secured to the floor or the sides of the trailer, even if the conveyance is not equipped with logistic tracks and anchors.
But reefers and heated loads pose another problem since they require space to be left between the goods so that air can circulate. Reefer loads are also not supposed to touch the sides of the trailer.
“There’s the rub,” says Geller. “When it comes to temperature-controlled loads you’re relying on air flow in that trailer. Most of the loss we see in temperature-controlled loads occurs because the temperature gets too hot or cold, and that’s usually caused by either an improper load pattern or not enough air circulation. Take those inflatable air bag pillows that some shippers use. They’ll keep your load from walking, but at the same time they impede air circulation.”
Claude Robert, president and CEO of Groupe Robert thinks that only 1% of dry van trailers are equipped with any kind of securement features.
“In the past, drivers hammered nails in the floor but you can’t do that with a reefer. Shippers are now concerned that trailers have the proper attachments. One customer suddenly realized they needed 175 trailers with anchors and straps.”
Geller of Markel points out that unlike the movement of dangerous goods (HazMat in the US), where the shipper shares some responsibility along with the driver and carrier, when it comes to load securement, the shipper bears no responsibility whatsoever.
“Container freight is a perfect example,” says Geller. “How can you hold a driver responsible when he can’t even check the load?”
Canadian drivers and carriers may have little say in how trucks are loaded, but they may end up getting a ticket for something beyond their control.
“We’ve heard anecdotally that there is a great deal of disparity and variance from state to state and jurisdiction to jurisdiction,” says Rob Abbott, vice-president of safety policy for the ATA.
A report on CSA 2010 issued by the Minnesota Trucking Association (Minnesota was one of the states involved in the original CSA pilot project) seems to substantiate Abbott’s assertion that the regulations can and have been arbitrarily and unevenly applied.
One carrier whose primary lane runs between Minnesota and Pennsylvania found that the states of Ohio and Indiana, although only representative of 19% of its miles, accounted for 47% of its violations.
Geller also suggests that there is a problem with the “probable cause” states (of which there are about a dozen).
In these states, truckers were stopped for speeding, even one or two miles per hour over the limit, and then the officer would use the opportunity to check the driver and load. If there were no problems the driver was allowed to go on his way without any point violations.
“Under the old rules, the ‘speeding’ aspect was ignored because there
was no violation notice issued and no conviction,” says Geller. “Under the new rules, the ‘speeding violation’ is pointed against the carrier’s profile, even though there is no conviction and no violation notice issued.”
On the whole, however, Canadian carriers and drivers applying due diligence to their securement procedures should have no difficulty with the new regimen.
“Canadian drivers, already familiar with programs like the CVOR in Ontario and the PEVL in Quebec, should have no problem with CSA,” says Robert. “Most of our drivers are already held to a higher standard.”
Geller thinks that after all the bugs are worked out, CSA will be a benefit to the trucking industry.
“What you’ve got right now is a novelty factor – something new applying across the US. Once it’s applied equally across the board it will be a benefit to the industry. The one thing that needs to be addressed is the responsibility of the shipper, which remains the wild card in this equation.”