CSA Enforcement Varies Widely from State to State, Study Says

This story appears in the Aug. 11 print edition of Transport Topics.

Carriers’ profile scores in the Compliance, Safety, Accountability program can be dramatically affected by varying state enforcement priorities, a new study found.

“While CSA is a national initiative, it relies on data from state enforcement activities to calculate safety scores,” according to the American Transportation Research Institute. “With wide latitude given to states to set their own commercial motor vehicle enforcement agenda, this has resulted in disparities in enforcement activities across the states.”

The ATRI study, made public late last month, said that, while states need flexibility in developing enforcement strategies, those differences can create wide disparities in scores.

“Despite the uniformity of the [CSA] Safety Measurement System in its calculation of BASIC scores, the intensity and focus of enforcement activities is largely at the discretion of each state,” the study said.

“This has resulted in 50 or more different enforcement programs and strategies that are used to populate a uniform score of nationwide performance.”

ATRI’s analysis is the latest in a series of studies that generally have supported complaints from carriers and trade organizations that the Federal Motor Carrier Safety Administration’s system does not accurately compare safety scores.

“Safety is our top priority, and analysis shows that CSA’s Safety Measurement System is effectively working to target high-risk carriers for interventions including more frequent inspections, warning letters and comprehensive investigations,” an FMCSA spokeswoman said, commenting on the study.

“We will continue to consider options to enhance this important tool and work with our law enforcement partners to analyze and improve the quality and consistency of safety data across the country,” she said.

“The study confirms American Trucking Associations’ long-standing contention that states have vastly disparate enforcement practices,” said ATA spokesman Sean McNally. “This raises significant implications for carriers’ CSA Safety Measurement System scores which are intended to be measures of relative performance.”

The seven Behavior Analysis and Safety Improvement rating categories, or BASICs, quantify the on-road safety performance of carriers and drivers to identify candidates for interventions, determine the specific safety problems that a carrier or driver exhibits and monitor the progress of safety issues.

The BASIC scores, five of which are visible to the public, also are important because shippers and brokers often use them to assess the safety performance of carriers.

“Until these disparities are rectified, peer-based comparisons within CSA’s scoring system will continue to be flawed and of little value as a tool for monitoring carrier and driver safety performance unless accounted for properly,” said Brett Sant, Knight Transportation’s vice president of safety and risk management and a member of ATRI’s research advisory committee.

To determine the effect of differing safety priorities in the states, ATRI staff collected data from seven motor carriers.

One carrier had slightly less than 7% of its annual vehicle miles traveled in a particular state, yet over 32% of that carrier’s unsafe driving violation points were issued by that same state.

Among all driver violations reported in 2010, the share of violations for speeding varied significantly from state to state, representing 31.7% of all violations in Indiana, 16.9% in Ohio and 4.2% in Arizona, the study said.

ATRI also said the effect on SMS scores is greater on carriers that have their miles concentrated in fewer states.

“What we discovered is, if you’re being compared against your peer group and you happen to be operating a lot of miles in those states that have extremely high violation rates, you’re going to look substantially worse than your peers,” Dan Murray, ATRI’s vice president of research, told Transport Topics. “Not because your crash rates are high or you’re engaged in riskier behavior. It’s just because you’re operating in states that are issuing substantially more violations in the peer group.”

But Stephen Keppler, executive director of the Commercial Vehicle Safety Alliance, said that there are valid reasons for differing enforcement priorities.

Those factors can range from a state’s geography and weather to the type of fleets that operate and the level of funding for enforcement.

“We call them enforcement differences, not disparities,” Keppler told TT. “Different states have different problems.”

For example, in some states commercial vehicle enforcement is done by sworn officers, while others may use non-commissioned inspectors that don’t have full police powers, and others might even use civilians to conduct CMV inspections, Keppler said.

“But the end game is we’re trying to reduce crashes,” he said.