Truck Topics
Big Safety Changes in 2010: A Primer--Part 1 of 4
The chances are reasonably close to 100% that you've heard about the
Comprehensive Safety Analysis (otherwise known as CSA 2010) and that it
will be bringing some pretty drastic changes to the trucking industry
in terms of on-the-road safety and how both drivers and carriers will
be looked at for the foreseeable future. The official document is
roughly 100 pages, give or take, so we thought it a good idea to try to
break its elements down into somewhat easily digestible pieces so that
you've got a good primer on what's going to be required beginning in
June of this year.
We'll be breaking this down into four
parts. The first, represented here, will be a brief, general overview
of the CSA and how it's set up, as well as a little information about
how it differs from the current safety measurement standards, which are
known as SafeStat. The second part will deal specifically with how the
standards are applied to drivers, the third will cover how they're
applied to carriers, and the fourth will be dedicated to carrier and
driver reactions to the differences between SafeStat and CSA, as well
as some talk from them on how they'll balance following the standards
with maintaining their earnings, profits, and productivity.
How CSA 2010 is structured
I
wish that the structure of CSA were dead simple, but it isn't. If
anything, it's a bit more complicated than the system that's in place,
though it is significantly different and measurably more comprehensive
as well. There are four separate "phases" to CSA 2010, and each of
them work together to assess the level of safety of drivers and
carriers and correct issues where they might exist.
In a
nutshell, the Safety Measurement System (SMS) portion of the CSA will
measure carriers and drivers according to seven categories known as
Behavioral Analysis and Safety Improvement Categories, which the FMCSA
refers to as BASICS. These categories will be used in measuring the
safety of both carriers and drivers. The seven BASICS are as follows,
along with FMCSA's definitions for each:
Driver
fitness-"Operation of commercial motor vehicles by drivers who are
unfit to operate them because they lack training, experience, or
medical qualification."
Unsafe driving-"Dangerous or careless operation of commercial motor vehicles."
Fatigued driving-"Driving commercial motor vehicles while fatigued."
Controlled
substances/alcohol-"Operation of a commercial motor vehicle while
impaired by or in possession of alcohol, illegal drugs, or any other
substance that renders the driver incapable of safely operating a motor
vehicle."
Crash indicator-"Histories or patterns of high
crash involvement, including frequency and severity. Miles carrier logs
verses number of accidents."
Vehicle Maintenance-"Failure of commercial motor vehicle due to improper or inadequate maintenance."
Improper loading/Cargo securement-"Shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. "
Once
the measurement phase of CSA 2010 is complete, interventions will be
made where necessary on an event-by-event basis. By "Where necessary,"
I mean to say, "Times where you're not meeting the BASIC standards set
by FMCSA." There are several levels existent in this intervention
phase. They are:
Warning letters
Targeted roadside inspections
Off-site investigations
On-site investigations
Comprehensive notice of claim/Settlement agreement(s)
The
third phase of CSA 2010 is Safety Evaluation, which differs from
measurement and intervention in that evaluation provides each carrier
and driver with a grade or rating based on their BASIC scores. This
evaluation, according to FMCSA, may or may not be tied to any current
compliance reviews, and where there is data to be reviewed, these
evaluations are to be updated every 30 days. There are three ratings
in these evaluations, and it's reasonably easy to figure out what each
means:
Continue to operate;
Marginal (these cases are where the above-noted interventions begin);
Unfit.
The
fourth phase of CSA 2010, though it's not really a phase, per se,
refers to COMPASS, which will track and regulate the information flow
of CSA 2010. In essence, it's a continuance of FMCSA's IT
modernization intiative, and they're extending it to CSA 2010. In a
nutshell, COMPASS is slated to receive safety data, link that data to
the proper entities, validate it, and provide the mechanisms for
correcting data, as well as providing support for the intervention
process of CSA 2010.
Why?
It's a simple
question, but it's a good one: why is FMCSA doing this now as opposed
to ten years from now, or even ten years ago? As far as I can tell,
there are two primary elements to the answer to this question. The
first is that CSA 2010 is intended to be a better, more efficient use
of FMCSA's resources. With it, they'll be able to more easily track
and regulate the on-road safety of carriers and drivers. The second is
that the safety assessment, measurement, and intervention process is
much updated and now better reflects the world we're now living in from
top to bottom.
So, what's the real difference?
So,
what we know at this point is that FMCSA is changing to a new safety
measurement system and what that new system will look like. But what
are the real differences from the old system (SafeStat) and the new
one? http://www.csa2010.com lists the differences as such:
SMS
is organized by seven specific behaviors (BASICs) while SafeStat is
organized into four general Safety Evaluation Areas (SEAs).
SMS
identifies safety problems in the same structure in which CSA 2010
addresses those problems, while SafeStat prioritizes carriers for a
compliance review.
SMS uses all safety-based inspection
violations while SafeStat uses only out-of-service violations and
selected moving violations.
SMS uses risk-based violation weightings while SafeStat does not.
SMS impacts the safety fitness determination of an entity while SafeStat has no impact on an entity’s safety fitness rating.
SMS assesses individual drivers and carriers, while SafeStat assesses only carriers.
So there you have it...
This
is, of course, just a quick overview of what you'll be able to expect
with the implementation of CSA 2010. In the next couple installments,
we'll take a closer look at how it will affect drivers and carriers,
and we'll get our hands a little more dirty to that end. In the
meantime, if you've got any questions about CSA 2010 or would like to
learn a bit more about the coming changes, check out
http://www.csa2010.com, where you'll be able to find quick summaries
and easily-accessible information about the CSA and its guidelines.