Fleet Execs Wary of CSA 2010
By Rip Watson and Daniel P. Bearth
Senior Reporters
This story appears in the Jan. 4 print edition of Transport Topics.
Some freight executives say they are concerned that the Department of Transportation’s new Comprehensive Safety Analysis 2010 program — which is intended to boost carrier and driver safety — could be undermined by inaccurate data, flawed methodology and unintended commercial consequences when it begins in July.
The Federal Motor Carrier Safety Administration has been working on the program, commonly referred to as CSA 2010, for several years. It is designed to replace FMCSA’s existing safety rating and data collection system known as SafeStat, which includes violations information from state and federal inspectors.
FMCSA will use CSA 2010 to assign safety ratings to all carriers based on their highway performance, rather than infrequent compliance reviews that are currently done by agency inspectors and included in SafeStat.
In addition, CSA 2010 will rate the nation’s more than 3 million drivers for the first time, also using a performance-based formula. No date has yet been set for active enforcement efforts based on driver ratings.
Freight executives, all of whom said they supported the program’s goals, used words like “flawed,” “a challenge,” “huge impact” and “terrible” to illustrate their concern about the effect of the new rating procedure, which incorporates questionable SafeStat data.
Data Issues
“Everything I have heard about CSA 2010 in general pleases me,” said Jeff Tucker, president of Tucker Cos., a third-party logistics company in Cherry Hill, N.J. His comments were echoed by all officials interviewed for this article.
“There are certain adjustments that have to be made,” he said. “The general understanding by anyone looking at the data is that it is flawed, and most likely incomplete. It’s better than nothing, but we need states to regularly and promptly update their data. Certain states are notoriously poor at that.”
“There is a wide variability of data today,” said Don Osterberg, senior vice president of Schneider National, Green Bay, Wis. “Over time, FMCSA will have to work hard to ensure timely and accurate reporting. Will CSA 2010 make that issue worse? Definitely not.”
SafeStat has been criticized since 1999 for inaccurate and incomplete data in government reports, including one in October by DOT’s inspector general.
A 2006 study commissioned by FMCSA found that just half of accidents that occurred in nine surveyed states were actually reported. Today’s SafeStat’s Web site contains a disclaimer saying the data “may produce unintended results and not be suitable for certain uses.”
FMCSA acknowledged when launching CSA 2010 that only about 2% of fleets per year get a safety rating through those compliance reviews that include on-site inspections of carriers.
FMCSA did not respond to requests for comment on the companies’ concerns, though officials in charge of implementing the program said during two webinars last month that data is becoming more accurate and the methodology will be effective (see related article, p. 10).
Driver training and education will be a key focus as implementation approaches; pilot tests of the program are drawing mixed reviews, and American Trucking Associations has raised many questions about the program (see related article, p. 10).
During the second half of 2010, FMCSA will begin training law enforcement officers and issuing warning letters to carriers, as well as using the new data system. Driver ratings will begin at an unspecified future date.
“The data reporting is a challenge — this is not something the states can wave along and fix quickly,” said Dave Osiecki, vice president for safety, security and operations at American Trucking Associations.
Osiecki said he’s concerned about data accuracy because it is so uneven. For example, he said, state police typically are better trained in accident investigation and reporting techniques than are local police departments, and submit more and better qual-
ity information.
ATA, which supports the CSA 2010 concept, also is concerned about the formula used to create the new carrier ratings.
Data from SafeStat will be turned into a new three-tiered rating system, using a formula based on severity of violations, with the worst violations rated 10 and the mildest rated 1.
The new ratings will be “continue to operate,” “marginal” and “unfit,” supplanting the current “satisfactory,” “conditionally satisfactory” and “unsatisfactory” rankings.
That formula essentially will count the number and severity of infractions and divide by the number of trucks a fleet operates.
Methodology
Using the number of trucks as a basis for safety ratings is wrong, Osiecki said, because safety performance is measured by the National Highway Traffic Safety Administration and throughout the trucking industry on the basis of vehicle miles traveled.
Using fleets’ truck count for safety ratings “is a terrible decision,” Schneider’s Osterberg said. “It is not an effective relative measure of carrier safety.”
In addition, Osiecki said, the number of trucks listed on a form that must be filed every two years isn’t likely to match the number of trucks a fleet actually has in service.
Severity ratings also are an issue.
Osterberg highlighted inconsistency in rating tire defects, such as exposed ply belts that are an 8, whether the flawed tire is on a tractor’s steer axle, which is critical to safety, or on a trailer, where that defect is unlikely to cause
a crash.
On the other hand, potentially serious problems such as cracked wheel rims are a 2, while driving without a commercial license is a 3, he said.
Commercial Effects
“This is going to have a huge impact on the industry,” said Harry Kimball, vice president of risk management for Freymiller Inc., an Oklahoma City, trucking company.
“There will be driver loss,” he said. “When the smoke clears, however, the drivers left will reap the rewards” because it probably will lead to a smaller driver pool.
Stephen Renshaw, director of safety for broker and carrier Megatrux Inc., Rancho Cucamonga, Calif., said carriers could be taken off the road because a failure to carry proof of preventive maintenance is a 10. That score can put a cash-squeezed owner operator in a tight spot.
“To the extent CSA 2010 identifies unsafe drivers, it may tighten capacity, but it will improve safety,” said Osterberg. “If it serves to elevate the standards of commercial drivers, that will be a good outcome.”
A spokeswoman for the Owner-Operator Independent Drivers Association said she feared a different outcome from increased driver scrutiny.
“We are concerned about drivers not being provided with documentation of good inspection results that could help with having a good overall score,” said Norita Taylor, an OOIDA spokeswoman. “In other words, only the ‘bad’ things are reported and never the ‘good’ things.”
Taylor cited other fairness issues — the lack of recourse to challenge violations and the fact that crashes that aren’t the driver’s fault still will count against his score.
Osterberg agreed.
“If a drunk driver crosses the median and is killed in an accident with a truck, the truck driver will be hit with the full effect” under CSA 2010, Osterberg said. “The onus should be on law enforcement to say who is at fault. FMCSA has to try to come up with a solution to that.”
CSA 2010 also will affect competition.
“The vast majority of the carrier industry is made up of small businesses,” said Mark Walker, senior vice president of C.H. Robinson Worldwide Inc. “We feel strongly that FMCSA needs to ensure that CSA2010 does not unfairly cause safe, good operators to inadvertently become uncompetitive.”
He said carriers without a rating today will need to be especially concerned about how CSA 2010 affects them.
“FMCSA should clearly articulate to the public if they feel that ‘marginal’ carriers pose a greater safety risk to the public than those in the ‘continue to operate’ category,” Walker said.
Tucker said that as carriers, brokers and shippers increase use of CSA 2010, they probably will choose not to use carriers with poor ratings and those choices eventually will drive unsafe carriers out of business.
