WASHINGTON — The American Trucking Associations (ATA) fully supports CSA 2010’s objectives of targeting unsafe operators, but continues to urge rule makers to iron out several significant "flaws" in the program as its currently proposed.
Speaking before the House Transportation and Infrastructure Subcommittee on Highways and Transit, Transportation Corporation of America Executive Vice President Keith Klein expressed concern with how CSA records non at-fault accidents.
Klein said ATA applauds CSA’s focus on safety performance rather than compliance and paperwork requirements; as well as comprehensive on-site audits; and real-time, updated, safety performance measurements, but, he adds, the Federal Motor Carrier Safety Administration needs recognize the difference between at-fault accidents and non-fault crashes in its performance measurement system.
Klein called for the ability to 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.
As well, FMCSA should use vehicle miles traveled (VMT), not number of trucks or power units, as a carrier’s exposure measure and it needs to focus on using only actual citations for moving violations and not unadjudicated “warnings” issued by law enforcement.
"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 said. “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 illustrate his point, Klein showed a dramatic video of a tractor-trailer overturning into the oncoming lane of traffic. Upon close inspection, the video (which can bee seen here), shows that the truck is being forced over the lane by an automobile.
This accident, says Klein, would be recorded under CSA 2010 without recognition that it was not the trucker’s fault.
The intent of raising these concerns is two fold, 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."
In addition, ATA is also 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," he said. "Instead, it will create inequities for some safe carriers and inappropriately allow some unsafe carriers to avoid scrutiny and consequences."
Klein urged that FMCSA wait to implement the program after they have the opportunity to review an evaluation study of CSA 2010 currently underway by the University of Michigan Transportation Research Institute.
"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."
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