ATA continues to work with FMCSA toward improving CSA 2010

May 12, 2010
The American Trucking Associations told a subcommittee of the US Senate Committee on Commerce, Science and Transportation recently that the Federal Motor Carrier Safety Administration's (FMCSA) Comprehensive Safety Analysis 2010 (CSA 2010)

The American Trucking Associations told a subcommittee of the US Senate Committee on Commerce, Science and Transportation recently that the Federal Motor Carrier Safety Administration’s (FMCSA) Comprehensive Safety Analysis 2010 (CSA 2010) is conceptually a good program that ATA supports because it is based on safety performance and measures specific driver-related behaviors. However, ATA does have concerns about CSA 2010 that need be addressed if this system is to effectively identify unsafe carriers, as intended.

In his testimony at the Surface Transportation and Merchant Marine Infrastructure, Safety, and Security Subcommittee hearing on Oversight of Motor Carrier Safety Efforts, ATA Senior Vice-President Dave Osiecki said CSA 2010 needs to be improved, and ATA has made recommendations to FMCSA to help better target unsafe carriers and drivers.

As a part of its ongoing advocacy efforts, ATA met with Administrator Anne Ferro in February to voice concerns over the CSA 2010 scoring system and to offer solutions. ATA also subsequently submitted these concerns and proposed solutions in a February 26 letter recommending 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 actual citations for moving violations and not unadjudicated “warnings” issued by law enforcement.

Ferro responded April 16 and thanked ATA for its concerns. “The FMCSA appreciates that the [ATA] continues to fully support the safety and efficiency objectives of the CSA 2010 program and that ATA has offered recommended solutions to address those concerns,” Ferro wrote.

She said that FMCSA is committed to making crash accountability determinations before crashes are entered into the carriers’ records in the CSA 2010 Carrier Safety Management System (CSMS). ATA is pleased that FMCSA has made this policy decision and will continue to push the agency to make this critical change before CSA 2010 is implemented, if not very soon thereafter.

In response to ATA’s recommendation to use VMT instead of power units, Ferro said, “FMCSA acknowledges that the use of power units as the sole measure of exposure can potentially create a disadvantage for segments of the motor carrier industry that employ greater asset utilization.” FMCSA agrees that VMT is another valuable and widely recognized measure of exposure that could potentially improve the effectiveness of CSMS. However, the letter also stated that FMCSA believes that using mileage as the sole measure of exposure creates disadvantages for other segments of the industry.

While ATA is pleased by the acknowledgement that the use of power units, rather than VMT, creates a disadvantage for some segments of the industry, ATA is concerned that the agency does not appear willing to adopt the industry’s accepted standard measure of exposure—which is mileage.

ATA’s third concern is that CSA 2010 counts all alleged moving violations listed on roadside inspections, regardless of whether a citation or just a “warning” was issued to the driver. Ferro said FMCSA has determined that it is not currently feasible, based on a systems issue, to exclude recorded moving violations from consideration by CSMS when a citation is not issued. To address the issue, FMCSA will eventually consider adding the option for a field officer to indicate whether a citation was issued in conjunction with a recorded speed violation. FMCSA will also allow state partners to indicate the degree—miles-per-hour over posted limit—of the speeding offense. ATA believes the delineation of speeding violations based on the degree of the offense is a good first step, but will only be meaningful if FMCSA modifies the weightings so that less weight is assigned to the more minor speeding violations.

To view ATA’s February 26 letter to FMCSA, visit

FMCSA’s April 16 response to ATA can be found at