2. FMCSA’s Compliance, Safety, Accountability (CSA) program

Dec. 17, 2013

After first appearing on the Top Ten list in 2010, CSA reached the number one position in 2012. However, concerns over new changes to HOS outweighed CSA worries, causing the issue to drop one position to second place in this year’s list. The gap in concern between HOS and CSA is quite large, as evidenced by the drop in the Industry Concern Index (ICI) to 69 for CSA (compared to 100 for HOS).

Nevertheless, CSA is still of significant concern to many in the industry and is ranked first, second, or third by 42% of respondents. CSA was first implemented nationally by the Federal Motor Carrier Safety Administration (FMCSA) in late 2010. Since that time, industry groups have identified a number of challenges within CSA.

Two of the most significant areas of concern surrounding CSA are the lack of crash accountability in CSA scoring and the inability of CSA scores to accurately predict carrier safety performance. Research by ATRI released in 2012 found that only three out of five publicly available Behavior Analysis Safety Improvement Category (BASIC) scores were positively correlated with crash rates.

Proposed Strategies:

a) Push for a crash accountability determination process that removes non-preventable crashes from carrier scores. Nearly half (49.4%) of respondents support this as their primary strategy for addressing concerns with CSA. According to research conducted in 2012, there generally is agreement among motor carriers and enforcement personnel that crash accountability should be taken into account as part of CSA. However disagreement remains over the use of police accident reports (PARs) for determining crash responsibility.

b) Utilize Inspector General (IG) and Government Accountability Office (GAO) findings to push FMCSA to correct flaws in the scoring system. In early 2013, the IG began an audit of CSA to determine whether FMCSA developed proper controls to ensure the quality of the data used for CSA enforcement actions. Approximately one-quarter (29.3%) of respondents believe that using the IG and GAO findings offers the best opportunity for convincing FMCSA to improve the program.

c) Quantify the impact of disparate state enforcement practices on carrier CSA scores and advocate for more uniform enforcement. There is concern among many in the industry that enforcement practices vary significantly from state to state. Given this concern, ATRI’s Research Advisory Committee (RAC) identified this topic as a top research priority and ATRI is currently conducting a study in this area. This strategy is the top choice of 21.4% of respondents.