You've heard of the five stages of grief, right? Usually, that theory is associated with the death of a loved one or the death of a marriage.
But Scott Claffey, Great West Casualty Co, has witnessed a strong correlation with the arrival of Comprehensive Safety Analysis 2010 (CSA 2010), a Federal Motor Carrier Safety Administration (FMCSA) initiative designed to improve large-truck and bus safety and ultimately reduce commercial motor vehicle-related crashes, injuries, and fatalities.
The grief cycle has struck many in the industry, he joked at the beginning of “Preparing for CSA 2010,” a panel discussion conducted during the National Tank Truck Carriers annual Tank Truck Safety & Security Council Seminar in Nashville, Tennessee.
Then there are those who still have only a vague idea of what CSA 2010 even is.
“I've been talking to a lot of folks for a year and a half about the issues surrounding CSA 2010,” he said. “Unfortunately, we're still coming across people who are saying, ‘CSA what?’ We've seen a sudden increase in the number of phone calls saying, ‘This thing's been pushed back.’ So they're just hearing of it, because some elements have been pushed back. There's a lot of misunderstanding about the issue.”
The initiative introduces a new enforcement and compliance model that allows FMCSA and its state partners to contact a larger number of carriers earlier in order to address safety problems before crashes occur. When the program is fully rolled out over the next year or so, FMCSA believes it will have a new nationwide system for making the roads safer for motor carriers and the public.
CSA 2010 has three major components: measurement, evaluation, and implementation. The program measures safety performance in new ways, using inspection and crash results to identify carriers whose behaviors could reasonably lead to crashes. When FMCSA rolls out CSA 2010, the Safety Measurement System (SMS) will replace SafeStat. Every month, SMS will measure the previous two years of roadside violation and crash data and calculate a score in seven safety behavior areas, called BASICs (Behavioral Analysis and Safety Improvement Categories).
Unsafe Driving. Dangerous or careless operation of commercial motor vehicles (CMVs). Data includes driver traffic violations and convictions for speeding, reckless driving, improper lane change, inattention, and other unsafe driving behavior. (FMCSR Parts 392 and 397.)
Fatigued Driving (Hours-of-Service). Driving a CMV when fatigued, which is distinguished from incidents where unconsciousness or an inability to react is brought about by the use of alcohol, drugs, or other controlled substances. Data includes hours-of-service (HOS) violations discovered during an off-site investigation, on-site investigation, roadside inspection, or post-crash inspection; and crash reports with driver fatigue as a contributing factor. (FMCSR Parts 392 and 395.)
Driver Fitness. Operation of a CMV by drivers who are unfit for that activity due to lack of training, experience, or medical qualification. Data includes inspection violations for failure to have a valid and appropriate commercial driver's license or medical or training documentation; crash reports citing a lack of experience or medical reason as a cause or contributory factor; and violations from an off-site or on-site investigation for failure to maintain proper driver qualification files, or use of unqualified drivers. (FMCSR Parts 383 and 391.)
Controlled Substances and Alcohol. Operation of a CMV while impaired due to alcohol, illegal drugs, and misuse of prescription medications or over-the-counter medications. Data includes roadside violations involving controlled substances or alcohol, crash reports citing driver impairment or intoxication as a cause, positive drug or alcohol test results on drivers, and lack of appropriate testing or other deficiencies in motor carrier controlled substances and alcohol testing programs. (FMCSR Part 392.)
Vehicle Maintenance. CMV failure due to improper or inadequate maintenance. Data includes roadside violations for brakes, lights, and other mechanical defects; crash reports citing a mechanical failure as a contributing factor; and violations from an off-site investigation or an on-site investigation associated with pre-trip inspections, maintenance records, and repair records. (FMCSR Parts 393 and 396.)
Cargo Related. Shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. Data includes roadside inspection violations pertaining to load securement, cargo retention, and hazardous material handling; and crash reports citing shifting loads, or spilled/dropped cargo as a cause or contributing factor. (FMCSR Parts 392, 393, 397, and HM Violations.)
Crash Indicator. Histories or patterns of high crash involvement, including frequency and severity. Data includes law enforcement crash reports and crashes reported by the carrier and discovered during on-site investigations.
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CSA 2010 grief continued...
Recent roadside violations and violations that correlate most with crashes will be weighted more heavily than other violations. The SMS will then rank carrier scores relative to their peers to determine which entities have specific safety problems.
Usher Transport Inc's Mike Baker said communication with state troopers will be critical in the future.
“The same goes for violations related to following too close. Some troopers in the Indianapolis (Indiana) area are famous for pulling guys over on that charge. Under this law, an Indiana truck is supposed to be 300 feet behind the vehicle in front of it. We're trying to get out to law-enforcement people and explain what's going on. Some of them don't even know what CSA 2010 is.”
Said Claffey, “It'll be a couple of interesting years until all the bugs are worked out. If you're still standing after a couple of years, you'll be alright. We'll have to go with the flow to see what happens.
“The lesson for motor carriers is, you have to manage the data. You're going to be measured off of your performance on the road. It's up to you to manage your data and determine what to do with it and how you interact with the law-enforcement and shipping communities. We have to internalize it and understand, ‘What is it going to do to us as motor carriers?’ We also need outreach programs where we're talking to business partners, like insurance companies. Ask the question, ‘How is this going to be used?’ Most of the underwriters I've talked to said, ‘For us, it's a tool to look at.’ Is it the tool? For some, yes. For others, it's just one. The key is to manage the data and know what it will do over the long term.”
Just like the IRS
Commercial Transport Inc's Dan Athmer said carriers need to look at this like they're being audited every month by the Internal Revenue Service.
Steven Bryan of Vigillo LLC — creator of data-mining software products designed to aggregate, organize, and deliver fleet-safety information — said his company tries to take the “firehose” stream of data collected and help clients understand the scorecard format. Currently there are over 1,200 carriers and 450,000 drivers using Vigillo scorecards.
“You extract wisdom from the data,” he said.
What can carriers do to prepare now? Understand the seven BASICs. He said clients can look at the scorecard by BASICs category, violation, or driver.
“Under SafeStat, most things that counted against you were OOS (out of service) violations. Everything counts under CSA 2010. You have 3,583 possible violations that can be written up on a truck and driver, and they all count. This is the reason we're seeing those good drivers showing up at the top of list. It's not unusual to see some of the best drivers, for reasons they could not have possibly foreseen, at the top. Scores are now new and different, and it's a game-changer.
“It is very clear that FMCSA is not going to turn on the driver safety-management system immediately. There are two systems that make up 2010: carrier safety and the driver safety-management system. There are slightly different formulas in there. You will not be able to get from FMCSA, in the short term, access to those driver scores. However, you have all the raw data. You get it. It is your data. You can download it. If you understand the method, you can process all the data and you can create driver scores.”
He said the basic concept is this: The minority of your actual inspections lead to the majority of your CSA 2010 points.