Everyone involved with interstate trucking has a vested interest in the federal Comprehensive Safety Analysis 2010 (CSA 2010 2010) safety behavior program that should be implemented nationwide by the end of 2010. The new program builds upon the success of the SafeStat system that tracked out-of-service violations. CSA 2010 analyzes the actions of motor carriers and their drivers, looking for those who display unsafe behavior.
Areas of concern are spelled out in the Behavior Analysis and Safety Improvement Categories or BASICs. Carriers’ BASICs scores reflect their safety behavior. Information for BASICs scores comes from the roadside, so whether the result is a clean inspection, a citation or a warning for a violation, all information gathered during the inspection affects the score.
The BASICs include:
1. Unsafe driving such as careless or dangerous operation.
2. Fatigued driving such as Hours of Service violations.
3. Driver fitness such as training, experience or medical qualification.
4. Controlled substances and alcohol such as DUI, illegal drugs and misuse of prescription drugs.
5. Vehicle maintenance such as improper or inadequate maintenance.
6. Loading/cargo securement such as shifting or spilled cargo, unsafe handling of hazmat, or oversize/overweight violations, and
7. Crash/Incident Experience such as patterns of crash involvement.
Recently, I spent an hour with Jan Skouby and Charles Gohring of the Missouri Department of Transportation. Jan is the director of the Motor Carrier Services Division and Charles is Motor Carrier investigations administrator in the same division. We discussed changes coming about as a result of the Comprehensive Safety Analysis and Missouri’s experience as a CSA 2010 2010 test state.
I had heard Jan speak at the national Truckload Carrier Association meeting in Kansas City and later the same week, listened to a presentation by Anne Ferro, administrator of Federal Motor Carrier Safety Administration (FMCSA 2010) at the Arkansas Trucking Association Business Conference in Little Rock. It was quite an education on CSA 2010 2010.
FMCSA 2010’s enforcement approach is evolving as government agencies, carriers and drivers gain experience in the tests. This teamwork approach reflects the intent of CSA 2010: that all agencies, carriers and drivers work together to encourage safe behavior and reduce the number of CMV crashes.
Two things were made perfectly clear by Ferro and Missouri officials: CSA 2010 aims to identify and correct unsafe driver and carrier behavior, and once CSA 2010 is in effect, all roadside inspections and violations will impact driver and carrier safety behavior scores.
I asked Jan and Charles to describe the difference between the CSA 2010 safety measurement system and the current SafeStat rules in one thought so everyone could understand. Jan Skouby replied, “Our current investigative processes are reactive, by that I mean a problem must occur before steps can be taken to solve that problem. CSA 2010 is pro-active; we take the vast amounts of current data available to the federal government and the states and use that data to try to prevent problems with drivers and carriers before they result in a crash.”
Charles Gohring added, “The main difference between the current Safestat system and the CSA 2010 Safety Measurement System is the current system uses serious Out of Service violations to determine the both the drivers’ and carriers’ safety performance and determine which trucks to inspect as well as which carriers to investigate. This process has worked well and has greatly reduced the crashes/VMT for many years. But the positive trend has flat-lined. For the past five to eight years the reduction of crashes involving commercial motor vehicles (CMV) has leveled off. The CSA 2010 initiative is the next effort to continue lowering CMV crashes/VMT with pro-active methods.”
Missouri is one of the original four 50/50 test states. MoDOT applied CSA 2010 to half of the interstate carriers in Missouri, offering a glimpse of what the rest of the country may expect when the CSA 2010 safety measurement system is implemented nationwide. MoDOT plans to complete training of their compliance review investigators, those who go to a carrier’s place of business for an audit and examination of required safety records by mid-August. They expect to implement the CSA 2010 fully on Sept. 1, making Missouri a 100 percent CSA 2010 state.
CSA 2010 provides states better information on the safety behavior of each interstate carrier and every driver with a CDL. States will use the information to address unsafe behavior before it becomes a habit and causes crashes. For example, should a carrier’s BASICs score indicate Hours of Service issues; the state will bring the issue to the carrier’s attention. This may come in the form of a letter, a phone call or a site visit to inspect logbook records or more severe sanctions, depending on whether the carrier responds and shows improvement.
MoDOT is not the only agency involved in Missouri CSA 2010 activity. The Missouri state Highway Patrol and the Kansas City and St. Louis Police Departments’ efforts are crucial. They continue to conduct roadside inspections and stop CMVs for violations. What will change is that the information they gather will be used to track good and bad safety behavior. Good inspections will positively impact carriers’ BASIC percentile scores. The opposite is true for inspections that reveal violations.
Implications for drivers
It is important for every driver to realize that records of their safety behavior and inspection history are maintained for 36 months, updated every month. Whether a driver works for one or several carriers during this time, every clean roadside inspection, citation or violation warning is recorded and has a direct effect on information seen by a potential employer. Since safety records affect carriers’ bottom lines, it should surprise no one that employers will seek drivers with clean violation and inspection histories.
Job hopping could become a thing of the past. A new program, the driver Pre-Employment Screening Program (PSP), provides a driver’s last five years of crash data and three years of roadside inspections to carriers who subscribe to the private service. Because a driver’s inspection history is an indicator of their future performance, carriers are not likely to be interested in hiring a driver with an unsafe history.
Drivers have expressed some concern that their records might not be accurate. Claiming that paperwork is not always completed when they pass an inspection cleanly, they are concerned that PSP data might not show an accurate record of their experience. Clean inspections improve drivers’ data and carriers’ BASICs scores.
Jan addressed the issue by saying, “…we at MODOT and those at CVSA understand the concerns and want all roadside inspections to be fair and equitable to both driver and carrier. We are working and talking with our inspectors and officers to educate them on both the positive and negative effects of a roadside inspection while at the same time making their time as valuable and productive as possible to enforce CSA 2010. Of course, if a carrier suspects a particular officer of abusing their power and failing to be fair in their roadside inspections, then the carrier should send a letter to that officer’s supervisor outlining their concerns so the issue can be evaluated.”
Ride CSA 2010 to Success
My advice to drivers is to educate yourself as much as possible about the CSA 2010 BASICs with any safety training your company has. Pre-trip and Post-trip inspections have always been required, now you really must do them since one-third of all roadside inspections are due to vehicle defects an officer can see when he passes you; lights and tires come to mind here. One-third of all roadside inspections are caused by speeding. Slow down, be safe and keep your job. I say these things because if you the driver can keep your MVR and CMV inspection history clean, you will be able to make more money and keep your job.
If what many suspect — that unsafe drivers will need to find a new career when potential employers see their safety records — comes to pass, fewer drivers will soon be pulling more loads with higher pay. It might as well be you making the good money. So, watch your speed, keep all your paperwork current and keep an eye on the truck because law enforcement will certainly be watching. Remember, safe drivers are going to be the key to the carrier’s success with CSA 2010 and they will only want to hire good, clean drivers.
Jim C. Klepper is president of Interstate Trucker Ltd., a law firm dedicated to legal defense of the nation's commercial drivers. He is a lawyer who has focused on transportation law and the trucking industry in particular. He works to answer your legal questions about trucking and life over-the-road and has his CDL.
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