Editor’s note: This is the second installment of a multi-part series on CSA 2010 comparing successful compliance to catching and riding a wave without being dashed to pieces.
Pick the direction you want to go.
I have spoken with numerous carriers who are wrestling with the question of what they will do when CSA 2010 goes live and how it will impact their company. To paint with a broad brush, the most common answer to this question is that CSA 2010 will have a negative impact on many carriers. In fact, I have spoken with carriers who have seen their ISD score of 35 double to an SMS score of 70 under CSA 2010. Of course, this is cause for concern and many carriers are scrambling to address problems that may arise. While this is both prudent and necessary to address immediate concerns it may not provide the direction necessary to stay at the front of the wave.
If you are a carrier or an owner-operator let me ask you a question: where do you see your company one year after CSA 2010 goes live? Will you still be in business? Will you have reached your target SMS score? Have you thought about these questions? If not, I would suggest that you consider where you want to be one year, three years and five years after CSA 2010 goes live. The answer to this question is the direction you want to go. While everyone would love to have an SMS score of zero this is simply not realistic. No amount of training, retraining and luck will ever make that happen. With that in mind, what is an SMS range within which you feel comfortable operating? Now, what are you going to do to get there?
Paddle before the wave reaches you
As I mentioned earlier, the secret in getting where you want to go is to paddle like hell in the direction you want to go before the wave overtakes you. Of course, to get the most out of your effort you must use all the tools at your disposal. One of those tools is the very thing that makes CSA 2010 possible — technology. The ability to compile information from all 50 states on matters such as accidents (regardless of fault), roadside inspections and other basic categories and to use this information to create SMS scores for both drivers and carriers that are updated on a daily basis and available to enforcement officers in a real time basis is a formidable task. Ten years ago this could not be done. Only through this growth in technology can CSA 2010 operate. As a result, the only way to surf the CSA 2010 wave is to use technology to help you paddle before the wave reaches you.
Over the years I have had numerous conversations with carriers who claim they are informed of only 30 percent or so of all such violations in a timely manner. They eventually learn of the citations but often only after the court has entered a guilty verdict. Of course, statistics show that it is impossible to be proactive with citations of which you are unaware. This lack of notice has — and will have — a negative impact on a carrier’s SMS score. The best way to address this issue is to eliminate the “I thought I told you about that ticket/bad inspection scenario.” Technology now makes this possible. One way to use technology in your favor is to work with a third-party compliance system.
Using such a system, a carrier should be able to log onto the company’s Web site, set up a secure account and upload a list of their drivers and carrier information. The company can then gather information from a variety of sources — on a daily basis — and pull out all incidents related to the carrier and its drivers. The carrier will be able to log in any time of the day or night and see their current compliance information and view information about any roadside inspection or driver contact with any enforcement agent. In fact, the carrier will be able to view a copy of the actual inspection report or citation.
If it’s the right sort of company it will also prepare a list of “actions items needed’ and will include this information and will also be able to gather all of the required documents from various departments, either electronically or from an outside supplier, and attach those corrections or backup documents electronically to the roadside report and display the completed report on a screen where any agency, auditor or carrier can view for compliance.
Next: the CSA 2010 Scorecard
Jim C. Klepper is president of Interstate Trucker Ltd., a law firm dedicated to legal defense of the nation's commercial drivers. He is also president of Drivers Legal Plan, which allows member drivers access to his firm’s services at discounted rates. He works to answer your legal questions about trucking and life over-the-road and has his CDL.