CSA 2010 grief

“Denial — I think we're beyond that one,” said Claffey, who moderated the session. “Next is anger. I've been talking to you, and some are still angry. Then bargaining and depression: Some of you are already in depression. Finally, we'll get to acceptance.”

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.

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.

Next Page: Get proactive

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.

Get proactive

Usher Transport Inc's Mike Baker said communication with state troopers will be critical in the future.

“State troopers have been using the you-were-speeding excuse to pull trucks over and do inspections and give the driver a warning ticket,” he said. “I can assure you the next phone call a trooper gets is from me: ‘Why did you give this guy a warning ticket? Do you know that goes on our profile?’ I'm amazed that many troopers respond with, ‘What are you talking about?’ They don't understand. That's where we need to talk to their superiors to get this stopped.

“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.”

Baker added: “It's going to take a lot of work on our part to stay on top of things,” he said. “We were shocked when we saw some of the drivers highlighted in red in the initial CSA 2010 scoring. They were strictly in the wrong place at the wrong time. They're good drivers. Fact is, you'd better pay attention if you have bad players. To get ahead of this, we now generate a letter to our drivers when they get an inspection out on the road. We go in and assign the point value to it that under CSA 2010 they would receive. We have a running database. If a driver undergoes an inspection today, he gets 20 points. Three weeks down road, if he gets another inspection, he gets another 20 points. When he gets that letter, it shows, ‘You now have 40 points.’ They're very concerned they will be put out of work.”

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.

“They're going to look at your driving record,” he said. “If you're constantly getting dinged for something in roadside inspections, officials are going to take note. Once management looks at those scorecards and sees the information on there, they're all for it. They said, ‘Let's find out as much as we can and see where we're at.’ ”

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.

“You have four times more data that is now relevant to CSA 2010 than was relevant to SafeStat,” he said. “This is four times the work. This is a lot more data and applied methodology that is a lot more complicated than SafeStat.

“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.

“It's an inverse ratio,” he said. “If you can focus on the root cause — Why are we getting looked at? — it comes down to two big slices of the pie: speeding and observable defects. In fact, speeding is the cause of the vast majority of inspections, and that leads to an inordinate number of these CSA violations. For our customers, 70% of the points come from 30% of the inspections.“Seventy-six percent of Vigillo customers have at least one BASIC over the intervention threshold. The goal of FMCSA was to get more involved and do more interventions. It worked fabulously well. Seventy-nine percent of all your violations come from inspections that should have never happened but from the behavior of the driver. You can eliminate or reduce those inspections that should not happen.”