A number of changes to the Federal Motor Carrier Safety Administration's Compliance, Safety, Accountability (CSA) program are coming in December. Topping the list for tank truck carriers is the official implementation of the Hazardous Materials Compliance BASIC.
While FMCSA has rightfully concluded that most hazmat violations are not predictive of crashes, failure to comply with hazmat regulations is viewed by the agency as an indicator that a carrier may have other compliance issues which could lead to crashes, according to National Tank Truck Carriers officials.
FMCSA has made minor changes to the definition of its hazmat carrier classification category, which does have lower intervention thresholds than for non-HM carriers. For a carrier to be subject to the HM threshold, that carrier must have had at least to two inspections on placarded vehicles within the past 24 months with one of those inspections occurring in the past 12 months. Those inspections of placarded vehicles also must make up at least 5% of the carrier's total inspections. Any carrier that has an HM Safety Permit or that has been identified as a carrier of placarded quantities of hazardous materials from an investigation in the past two years is considered a hazardous materials carrier.
NTTC officials say they have discussed CSA with a number of shipper and carrier groups over the past several months. NTTC's main message has been that CSA is a tool that can be used in carrier evaluation but that it should not be used as the sole reason to use or not use a carrier.
The tank truck association has encouraged shippers to designate someone within their companies as the key CSA expert. Here are two useful websites for carriers to employ to educate themselves and their customers on what CSA is and what it is not. (A copy of NTTC's most recent CSA PowerPoint presentation at SCMchem Phoenix 2012 can be found at www.tanktruck.org)