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William Quade, Federal Motor Carrier Safety Administration (FMCSA) associate administrator for program delivery and enforcement, said the agency delayed the national launch date for Comprehensive Safety Analysis (CSA) 2010 to address some concerns expressed by the industry.

NTTC William Quade FMCSA has pushed back the start date of CSA 2010 to November, a full five months past its original June kick-off date. Enforcement still should begin in 2011.

“Through the process of doing the test and trying to actively engage the industry, we were hearing a lot of concerns,” he said during the National Tank Truck Carries annual Tank Truck Safety & Security Council Seminar April 6-8 in Nashville, Tennessee. “We think they have legitimacy and we need to take time to address them before we roll out the system.”

The concerns:

  • Crash data reported to FMCSA by state partners — and linked to motor carrier records — does not identify whether the motor carrier was accountable for the crash, and the Carrier Safety Measurement System (CSMS) methodology uses the recordable crash data to identify motor carriers for intervention without an accountable determination.

    In a letter to the American Trucking Associations (ATA) eight days after the NTTC seminar, FMCSA administrator Anne Ferro said that while the agency works to address the issue, it will exclude the crash assessment of the CSA 2010 CSMS from any public Web Sites that may be viewed by shippers or insurers and will continue to consider accountability of crashes before issuing any formal and final adverse safety fitness ratings that follow compliance reviews. FMCSA also is evaluating the feasibility of having staff assess state-reported crashes for accountability before they are considered by the CSA 2010 CSMS methodology. Initial results of a feasibility study indicate “that the use of police accident reports (PARs) is a viable option for determining large truck and bus crash accountability.”

  • The CSA 2010 CSMS currently uses a motor carrier's number of power units rather than vehicle miles traveled (VMT) as a measure of exposure. Ferro said FMCSA acknowledges that the use of power units as the sole measure of exposure “can potentially create a disadvantage for segments of the motor carrier industry that employ greater asset utilization,” and the agency will make the vehicle mileage field of the MCS-150 a mandatory field for updates. As part of the recently released CSA 2010 Data Review Web site, FMCSA is encouraging motor carriers to provide their annualized data.

  • Violations are not weighed equitably.

“Right now, a tire violation is a tire violation is a tire violation,” Quade said. “It's been pointed out to us that a tire violation on a steering axle is a lot more significant than a tire violation on a trailer.”

Warning letters

Beginning in July, SafeStat will be replaced with SMS (CSA 2010), a warning letter PDF sample will be sent to all motor carriers nationwide, FMCSA will begin inspecting carriers with deficient BASICs from collected data and finalize the intervention process.

NTTC Safety image A Motor carriers that exceed the intervention threshold in any of seven BASICs (Behavioral Analysis and Safety Improvement Categories) segments will receive a CSA 2010 warning letter. Warning letters are automatically generated on a monthly basis, and the Comprehensive Safety Information System (CSI) system tracks whether or not carriers check their results. In Phase I of the test states, 50% of carriers receiving warning letters checked their results in CSI.

Roadside inspectors in all states using Inspection Selection System (ISS)/Query Central will be able to see which carriers exceed BASIC thresholds. CSMS and BASICs values will replace SafeStat and SEA values in roadside inspection systems such as ISS, Query Central and State CVIEWs (Commercial Vehicle Information Exchange Window). Carriers whose BASIC scores exceed the threshold will be “Targeted Roadside Inspect” (red light) in ISS.

Next Page: Old safety ratings

Refining CSA 2010 continued...
Starting in July, states will be incorporated into the new intervention process on a rolling basis. FMCSA will train states on how to conduct CSA 2010 interventions in classroom training with case studies. Once trained, a state will operate under the new system, with all states operating in the new environment by January 2011.

Quade said FMCSA believes SafeStat works, and even though it is not a perfect system, carriers that are identified as high-risk have a higher crash risk than carriers that are not. But he believes it tends to generalize the violations.

NTTC Safety image F “Under SafeStat, we don't start intervening until a carrier has a problem in two or three areas,” he said. “So we created the Safety Management System, and instead of breaking violations into three broad categories, we're breaking them up into six behavioral areas and one for crashes. Four behaviors are focused on drivers.

“All preliminary data says we are able to touch more carriers and we are successfully intervening. The data is saying we're heading in the right direction with this.

“In the current system, it's one-size-fits-all. Under CSA 2010, we have a variety of interventions. We start off with a warning letter for carriers on the cusp, bringing it to their attention, asking them to investigate and look at the data and spend some time thinking about why crashes are happening. We want to get the attention of management before we actually go out and do the intervention.

“We're also doing more targeted interventions. If we see a carrier having one problem in one area — driver qualifications — instead of going out spending time looking at their logs and maintenance systems, we're going to go and look at driver qualifications. We'll look at driver files, CDLs, the records, and hiring process. Some of the interventions will be off-site. We will say, ‘Please send us these files, instead of us coming out and disrupting your business.’ ”

Old safety ratings

He said the safety fitness determination will come later.

“We still have to do the rulemaking,” he said. “Right now, we only issue a safety rating after we've done a complete compliance review, and that safety review sticks with the company until we issue a new one. There are fleets in our database that have safety ratings that go back to reviews conducted in the 1980s. A review conducted in the 1980s is probably not an accurate picture of the safety of a company in 2010. We're going to propose a safety rating methodology that builds on the BASICs and says that we will assess safety ratings based on the on the road performance of carriers without necessarily coming in and doing a review.

“On November 30, we propose going live with the SMS system. Between August and November, that gives the industry another three months to look at the data and how they compare, and make whatever adjustments are necessary. This will be a key point, something we emphasize with state partners — data quality. Part of this system is incumbent on you, the carriers, to make sure this data is accurate.

“CSA 2010 official interventions probably will not kick off until next spring. We have an IT system that we're bringing along slower than originally planned. Safety fitness will come through the rulemaking process. We will probably propose in December (2010) or January (2011), after everybody has had a chance to look at SMS.”

“The current intervention program is very much based on what is happening and what violations occur. We kind of stop there. At the end, we tell a carrier, ‘You have 14 hours of service violations.’ Under CSA 2010, we're going to be focusing on why. Why do violations exist? And we encourage carriers and give suggestions and ideas regarding underlying reasons violations are existing. Can we identify any disconnect between the dispatch and the safety department? Maybe for larger companies with robust safety departments, these are things that get dealt with through the fleet's own processes. But 90% of the companies we deal with have 10 trucks or fewer. Many don't have formalized safety processes, and we really believe this is something we can do that will make a larger impact on safety.” End of feature

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