The American Trucking Associations (ATA) fully supports CSA 2010’s objectives of targeting unsafe operators, changing their behavior, and removing the most egregious actors from the road. However, ATA has concerns with the current design of CSA 2010 and how these flaws will affect the industry and highway safety if not corrected, said Keith Klein, Transportation Corporation of America executive vice-president and chief executive officer, to the US House Transportation and Infrastructure Subcommittee on Highways and Transit.
In his testimony on behalf of ATA, Klein said ATA supports the CSA 2010 initiative because it is based on safety performance rather than compliance with paperwork requirements; it focuses limited enforcement resources on specific areas of deficiency, rather than on comprehensive on-site audits; and because it will eventually provide real-time, updated, safety performance measurements.
“All three of these attributes address long-standing problems with the Federal Motor Carrier Safety Administration’s (FMCSA) current monitoring and enforcement program,” Klein said.
“FMCSA deserves to be applauded for its development and implementation of CSA 2010 to date. The agency has gone to great lengths to test the program, develop and implement an extensive outreach and education program, and demonstrated a willingness to accept stakeholder input,” Klein said. “However, ATA has a number of serious concerns relating to how CSA 2010 will work that, if not addressed, will have a dramatic impact on motor carriers and on highway safety.”
ATA recommends that FMCSA:
•Make crash accountability or “causation” determinations on truck-involved crashes before entering them into a carrier’s record so drivers and carriers are held accountable only for crashes they cause.
•Use vehicle miles traveled (VMT), not number of trucks or power units, as a carrier’s exposure measure.
•Focus on using only actual citations for moving violations and not unadjudicated “warnings” issued by law enforcement.
The intent of raising these concerns is twofold, Klein said. “The first is a matter of safety, to ensure that unsafe carriers are selected for interventions; and the second is a matter of equity, to ensure that relatively safe carriers are not selected for interventions.”
Klein said ATA is also concerned about how the severity weights for violations are assigned; measuring carriers based on violations committed by drivers who have since been terminated; measuring carriers based on citations that have been dismissed in a court of law; inequitable measurement of open deck or flatbed carriers; overly broad peer groups; and inconsistent state enforcement practices.
To avoid these consequences, Klein recommended that FMCSA wait to implement the program after they have the opportunity to review an evaluation study of CSA 2010 underway by the University of Michigan Transportation Research Institute. FMCSA must also make corrections based on ATA’s three primary concerns before initial implementation of CSA 2010 and before making the information publicly available.
Klein’s entire testimony is available at www.truckline.com/Newsroom/Pages/Testimony.aspx.