National Tank Truck Carriers filed comments on December 5 regarding proposed changes to FMCSA’s Compliance, Safety, Accountability (CSA) Safety Management System (SMS). In October, FMCSA had proposed several changes to the program.
NTTC supported FMCSA’s other proposed changes, including changing minimum scores for law enforcement interventions, increasing the utilization factor used in the Unsafe Driving BASIC and the Crash Indicator, and changing the lookback period for several BASICs. Although most of the changes proposed would improve the program, FMCSA proposed two changes to the Hazardous Materials BASIC that would harm the tank truck industry without any improved safety benefits for the CSA program, according to Boyd Stephenson, NTTC senior vice-president of government affairs.
First, FMCSA proposed to change the categories for carriers in the HM BASIC. “In addition to dividing carriers based on their number of relevant inspections in the last 24 months, FMCSA also wanted to divide carriers into cargo tank and non-cargo tank operations,” he said. “Because cargo tank carriers generally have better HM BASIC scores than non-cargo tank carriers, this proposed change would increase the number of tank truck operations targeted for inspections at the expense of non-cargo tank operations that tend to have more violations and higher HM BASIC scores.”
FMCSA also proposed making scores in the HM BASIC available to the public at large. All CSA BASIC scores are currently hidden from public view until the agency completes congressionally-required actions linking carriers’ individual CSA scores to their safety performance. Once this is done, all BASICs will return to public view except the HM BASIC and the Crash Indicator. This change would make the HM BASIC publicly available at that time. Because there is no relationship between a carrier’s HM BASIC scores and its safety performance, NTTC opposed this change as well.