How fair is Compliance, Safety, Accountability (CSA)?
Not very fair at all, according to research done by Jack Lesshafft, a senior safety representative for Great West Casualty Company. He reviewed his research findings during the National Tank Truck Carriers Tank Truck Safety & Security Council Seminar held June 5-7 in New Orleans, Louisiana.
“Part of the problem with CSA is you have 48 different jurisdictions interpreted in these regulations,” he said, referring to the contiguous states listed in his study. “You have 48 people who all have a different opinion. They're all like little kids. They're not going to compromise on everything.”
The Federal Motor Carrier Safety Administration (FMCSA) would probably prefer more uniformity in the way CSA is interpreted and enforced.
For example, the US average for out-of-service (OOS) violations is 2.6 per one million miles. Arizona leads the nation with 11.6, followed by Minnesota (7.6), Maryland (6.4), Kentucky (6.3), Missouri (5.3), California (4.9), and Kansas (4.0). On the other hand, neither Colorado nor Nebraska had any OOS violations.
“I don't know what's going on in Nebraska,” he said. “They must not do any inspections. So if you're going to run any questionable equipment, do it in Nebraska or Colorado. Tennessee's a good one, Pennsylvania, Illinois. These are the states you want to put all your miles in, especially with bad drivers and equipment.”
Lesshafft took information from 15 carriers representing 500 million miles, downloaded CSA data off the website and then dropped it into an Excel spreadsheet so it could be measured.
There were a few disclaimers: there was no correction for ISS scores; states with less than one million miles were discounted; it's raw data with no analysis; there' no correction for different size carriers; the period in consideration was 2010 and 2011, which varies by carrier; and these were preliminary results.
“Whether these are representative of the national numbers, I don't know,” he said. “But it should be fairly close.
“Enforcement varies by states. Many states have extremely high rates of violations. Why? I don't know. But I think most importantly, what do we do with this information? I've suggested that some companies use it to educate their drivers. If you have a driver on a new route, say, 'Look, if you're driving through California, make sure you do good pre- and post-trip inspections. They do a whole lot of inspections for vehicle maintenance. If you're traveling through Indiana, make sure you obey speed limits, because they're going to get you.”
Indiana wants me
Lesshafft's interest was heightened because most of his customers are in Indiana, Illinois, and Kentucky. When CSA first came out, he started hearing from customers, “My numbers would be better if not for Indiana.”
He discovered that Indiana has about 350 inspectors, most of them state troopers, and about 42 commercial motor vehicle representatives.
“All state troopers coming into the Academy are certified Level 3 inspectors,” he said. “Most independent inspectors are Level 2, driver only. And the first 10 miles of I-65 in southern Indiana is the most heavily enforced speeding area of the country. Because most of the inspections are Level 3, they have to have a reason to stop you. So they'll stop you for doing one mile per hour over the speed limit. Then they'll start looking at your logs.”
As an example, he used one Indiana carrier that runs six million miles a year — three million in Indiana. He said one would expect that roughly 50% of the violations would be in Indiana, but this company was cited in Indiana for 76% of its unsafe violations, 70% of fatigued driving, and 100% of driver fitness. Vehicle maintenance was only 20%.
“Indiana is a typical example that's a little out of whack,” he said. “The unfortunate thing is that (FMCSA administrator) Anne Ferro, in a speech not too long ago, held up Indiana as a poster child. She thinks all states should be enforcing things like Indiana. If every state did everything the same, it'd be fair for everybody. But they're not.”
In unsafe driving (all violations), the US average was 2.4 violations per million miles. New Mexico led the way with 14.5, followed by Indiana (12.3), Michigan (6.6), Louisiana (6), West Virginia (4.9), Minnesota (3.8), and Arizona (3.2).
“I don't know what Minnesota is doing, but they have a rate of 3.8, and none of them are for speeding or seat belts. I guess a bunch of people don't know how to change lanes.”
Fatigued driving, with a US average of 15.2: California (51.9), Mississippi (45.9), New Mexico (44.2), Maryland (43.9), Kentucky (29.4), Minnesota (24.8), and Kansas 23.8.
Out of service violations for fatigued driving, with a US average of 0.6: California (1.9), Maryland (1.8), Arizona (1.8), Missouri (1.6), New Jersey (1.4), Mississippi (1.4), and Iowa (1.4).
HOS violations, with a US average of 0.8: Mississippi (2.9), Maryland (2.7), California (2.6), Iowa (2.4), New Jersey (2.2), Missouri (1.8), and Kentucky (1.4).
“Not everyone is enforcing this equally,” he said. “With numbers that high and the US average so low, you can imagine there are a bunch of states that don't have any violations.”
Vehicle maintenance inspections, with a US average of 7.7: California (42.2), Maryland (24.2), New Mexico (19.2), Mississippi (18.7), Kentucky (15.2), Kansas (14.2), and North Carolina (11.3).
For all BASICs rolled together, with a US average of 12.8: California (51.9), Mississippi (45.9), New Mexico (44.2), Maryland (43.9), Kentucky (29.4), Minnesota (24.7),
and Kansas (23.8). ♦
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