Upcoming Changes of the CSA Program and Why it Matters to Your Business
Since its emergence in 2010, the Department of Transportation’s Federal Motor Carrier Safety Administration’s (FMCSA) CSA program has been both important and controversial for carriers, shippers and fleet operators alike. The CSA program has long teetered between conceptual support and heavy practical criticism. While the program’s objectives and safety potential remain points of solidarity throughout the industry, the ways in which scores are developed and used are a strong point of tension.
After a series of research-based revisions in 2012, the CSA continues to strive for improvement.
In 2014, the results of court rulings on carrier challenges of roadside inspection citations were added to the CSA database, while improvements to the CSA website are continually being planned. Yet there are a number of impactful issues to be addressed in 2015. Topics of interest include steps to simplify the CSA safety measurement system and crash accountability. Changes to safety fitness determinations are also on the sounding board as the year moves into full swing.
The CSA was designed as a “performance-based, data-driven safety enforcement program,” to track driver and carrier company performance data. CSA collects data annually from an estimated 100,000 crash reports and 3.5 million roadside inspections, ideally using this data to statistically predict and prevent future crash risks and unsafe behaviors. Acting as an initiative to help FMCSA research and efficiently enforce regulations, CSA aims to reduce commercial vehicle accidents and injuries. The program is intended to sweep up as many as 150,000 of the estimated 3 million long-haul truck drivers whose repetitive dangerous behaviors make them risk prone for accidents and fatalities.
Using a complex scoring system, trucking entities are rated on seven “Behavioral Analysis and Safety Improvement Categories” or BASICS. The categories are driving, fatigued driving, driver fitness, alcohol and drug use, vehicle maintenance, cargo security (currently HM Compliance) and crash history. The data collected by CSA allows carriers to be flagged for necessary enforcement action. However, debates loom over the validity of the CSA data collection methodology and the ways the data are being used in safety ratings. The following issues are just a few that will be addressed in 2015.
How to determine and rate crash accountability has been a visible issue for some time, but an upcoming CSA report is due to address the problem. The Federal Motor Carrier Safety Administration’s chief safety officer Jack Van Steenburg has said the agency will release its study on crash accountability in early 2015. The agency report is supposed to offer a possible solution to the outlined issue. The report will address three core questions:
- How accountable are police reports for identifying accountability?
- Will a system that includes accountability be a better predictor of future safety than one that does not?
- What better ways can the agency manage the process and gain public participation.
The study was prompted by concerns over the CSA’s Safety Measurement System (SMS). While individual driver data is shielded from the public, CSA truck safety data is available for public viewing, with the exception of scores in the Hazardous Materials and Crash Indicator BASIC categories. Such public transparency has been the focus of a long standing debate, causing carriers to petition Congress for legislation to hide CSA truck safety data from the public eye. The American Trucking Associations and other groups have raised concerns over the consistency and accuracy of the current rating system, with a specific focus on how the CSA accounts for fault in its recorded crashes.
Non-fault crashes are currently included in the SMS. Although the agency maintains that all crash histories are indicators of future crash risk, carriers hold that recording non-fault accidents is a detrimental false indicator of future safety performance. Although carriers bare the brunt of the responsibility under CSA regulations, shippers are becoming increasingly interested as well. Shippers are invested in safe transportation and keep a keen eye on the safest carriers to transport their goods, and a worse carrier score for any reason can hinder business. If the methodological shortcomings are not addressed, carriers could face increasing tensions with the CSA while dealing with unfair reputation damage. The results remain to be seen.
Safety fitness will also be in the spotlight in 2015. Motor carriers are currently classified by FMCSA as Satisfactory, Conditional, or Unsatisfactory. These ratings are not directly linked to a motor carrier’s CSA scores. Traditionally, CSA scores are used to identify targets in need of FMCSA intervention. However, the new Safety Fitness Determination rule report may change that. “Currently the SFD is only tied to onsite investigations and a revised SFD would use roadside data as well as investigative data,” Jack Van Steenburg, FMCSA’s assistant administrator and chief safety officer, explains.
The long planned Safety Fitness Determination SFD rule report will use roadside inspection data, BASIC performance data, and investigations to determine whether or not a carrier is fit for operation. In the January 2015 Department of Transportation (DOT) Significant Rulemaking Report, the new estimated Notice of Proposed Rulemaking (NPRM) publication date is June 17, 2015. Previously scheduled for publication in March 2015, DOT cited unanticipated issues requiring further analysis and additional coordination as reasons for the latest publication delay.
The additional use of CSA scores in a carrier’s safety rating has raised concerns over the CSA’s data and methodology problems that may importantly affect a carrier’s safety scores.
Rob Abbot of the American Trucking Associations (ATA) trade group noted that providing safety data to third parties like shippers while also highlighting necessary carrier interventions makes the focus on safety seem ‘muddied’. He suggests focusing on the operating environment of carriers, and revisiting the reliability of average industry scores in relation to individual carriers. With regional disparities in enforcement also an issue,
It’s clear that the CSA needs more uniformity in its evaluations. How exactly the upcoming report will affect carriers will depend on a variety of features. However, it is safe to expect that the new safety fitness guidelines will catalyze further changes in how safety is measured.
Across the board, there is widespread consensus that since its inception, the CSA has fostered a stronger culture of carrier safety and significantly reduced safety hazards. Carriers care about their drivers, risks, and their safety rating, and they want to make improvements. Although the CSA and carriers face several barriers in reaching a smoothly functioning regulatory system, this year, steps are being taken in the right direction.