Letters: Safety Scoring, Bathwater/Benefits, HOS (Cont.’d)

Safety Scoring

On behalf of the Transportation Loss Prevention and Security Association and the Alliance for Safe, Efficient and Competitive Truck Transportation — and also in reference to the article in the Jan. 9 Transport Topics beginning on page 5 (“Agency Safety Scoring Seen as Unfair to Fleets, Brokers”) — I submit the following remarks on an issue significant to the transportation industry:

For years, a growing number of trucking industry representatives have been attempting to convince the Federal Motor Carrier Safety Administration that its Compliance, Safety, Accountability program is fatally flawed. Publicizing these flawed statistics creates confusion in transportation markets, improperly demonizes carriers and usurps FMCSA’s mandate to be the agency that determines safety fitness.

Except for waving the safety flag, there has been little response from FMCSA, even though the industry continues to run more miles with fewer accidents.

When FMCSA was sued in the U.S. Court of Appeals by three representative trade associations seeking to postpone publication of percentile rankings and deferring the entire system pending formal rulemaking, the agency entered into a settlement agreement.

Among other things, it agreed to a formal disclaimer indicating that the public should not draw conclusions about a carrier’s overall safety condition simply based on the data displayed in the system. This disclaimer reconfirmed that only FMCSA can determine carrier fitness, and unless a carrier received an unsatisfactory rating or was put out of service, it was authorized to operate.

Despite the settlement, representatives of FMCSA have been traveling around the country advising shippers and brokers to use flawed CSA methodology to qualify carriers.

And FMCSA continues to ignore evidence disputing the reliability of CSA.

Recently, a Wells Fargo study concluded that there was no meaningful statistical relationship be-tween a carrier’s actual accident incidence and the BASIC scores for unsafe driving, fatigued driving or driver fitness.

More startling yet, Wells Fargo found that only 12% of the 758,682 carriers in the FMCSA database had enough inspections to be included in any safety event group.

As if this was not enough to give the agency pause, FMCSA’s own advisory committee now suggests that the agency should collect more data to ensure that its safety measurement system is based on science and not on the intuition or opinions of experts. The advisory committee questions whether CSA statistics are accurate predictors of crash risk or are merely unsubstantiated guesses.

We call upon the FMCSA to suspend any public display of these flawed CSA percentile numbers and go back to the drawing board to create a system that will pass muster under formal rulemaking.

We also call on the FMCSA to formally acknowledge that only the agency can qualify carriers and that shippers and brokers must

be able to rely solely on the agency itself. Moreover, any methodology approved after rulemaking should be used by FMCSA only as an internal guide to qualify carriers.

After all the evidence is weighed, there is only one conclusion: CSA in its present form is not a trustworthy tool for either the FMCSA or the public at large to use in qualifying carriers.

William Bierman

Executive Director

Transportation Loss Prevention and Security Association Board Member

Alliance for Safe, Efficient and Competitive Truck Transportation

Hackensack, N.J.

Bathwater, Benefits

It seems to me that op-ed writer Richard Kuehn has conveniently ignored one powerful aspect of benefits packages in general (“The Bathwater, Not the Baby,” 1-2, p. 9). While it may be true that, per his example, his company would benefit upfront by ditching its health-care coverage and saving $2.3 million, how many of those 900 employees would leave the company and seek employment at a company that offers full benefits?

Even fiscal conservatives have to admit that attracting talented workers is the foremost reason for offering any benefit, and that calculation probably would prove the cost of retraining a substantial number of new workers, coupled with the disruption in the company’s functioning, would not be worth the upfront dollars saved.

Valerie Klauscher

Purchasing Associate

FedEx Ground

Moon Township, Pa.

Hours of Service

The trucking industry has been met with dozens of new regulations under the current administration — more than I have seen in all the years of my career combined. Many of these regulations have been very costly for carriers, shippers and consumers.

The most recent of these are the revised hours-of-service rule changes announced in late December. More rule changes are absolutely the wrong solution for issues that involve improving safety on American highways.

In November 2008, our company made the decision to voluntarily implement electronic logging devices (ELDs) in our entire fleet of 450 units. Since that day, we continue to see dramatic improvement in both our accident frequency and severity. We also have an immediate and proactive status of all our vehicles and drivers, 24 hours a day, seven days a week.

With ELDs not mandatory and no secure method of recording and monitoring a paper hours-of-service system, falsification will occur, plain and simple.

Carriers that place safety first already have implemented ELDs or have started the process.

The revised rules proposed by the Federal Motor Carrier Safety Administration pose an astronomical economic burden on trucking, shippers, receivers and consumers. These rules will do more harm to public safety and the transportation infrastructure than good.

Primarily, the change to the restart provision seems to claim that it is safer for a driver not to drive two nights in their cycle between 1 a.m. and 5 a.m. (“Ferro Defends Restart Change, Vows to Pursue 10-Hour Limit,” 1-23, p. 1).

I guess we should ask physicians, emergency medical services, firefighters, police, government, manufacturing and others to refrain from working during these times as well, because this now is deemed a risk.

Make no mistake — this change will add billions (yes, with an “s”) of dollars in cost to the entire economy at a time when we can least afford it. And it will place more trucks on the road during the daylight hours, creating the risk for more accidents, not fewer.

With less truck utilization, more costs — and those costs being passed to the consumer — the price of goods delivered to market will skyrocket.

Bottom line — why revise rules that are not securely and equitably enforced and monitored?

The real solution would be to have logs electronically recorded and monitored. Keeping all carriers in compliance is the real and only true solution for major improvement in highway safety, and absolutely not more regulation.

John Pope

Chairman

Cargo Transporters Inc.

Claremont, N.C.