Annette Sandberg, former FMCSA admnistrator
A recent study showed that 70% of American drivers weren't familiar with Compliance, Safety, Accountability (CSA), which was rolled out in December 2010 as a major Federal Motor Carrier Safety Administration (FMCSA) initiative to improve the effectiveness of the agency's compliance and enforcement programs.
“To me, that's scary,” said Annette Sandberg, CEO of TransSafe Consulting and the FMCSA's administrator and deputy administrator at the time CSA started.
Want to know what's even scarier? She says that 50% to 60% of carriers didn't even know what CSA is, according to the study.
“If I had a public scorecard on my company that was available on the web and anybody could look it up, I would be checking that every single day,” she said. “Carriers can not only look at a snapshot, but can go in through the portal and see inspections loaded daily. It's important that they are proactive on this.”
In “The Impact of CSA: Helping Your Customers Comply While Growing Your Business,” Sandberg — a nationally recognized expert in the field of Department of Transportation (DOT) safety who advises motor carriers, logistics companies, and shippers in transportation regulatory compliance and motor carrier safety issues — analyzed and brought clarity to this misunderstood regulation.
She said FMCSA regulates a population featuring 514,000 active interstate motor carriers, nine million large trucks, 843,000 buses, and 6.8 million commercial vehicle drivers, including smaller CVs.
“One of the things Congress told us when I was administrator was that we had to more effectively identify unsafe carriers sooner before they're involved in a catastrophic crash,” she said. “CSA is what I'd call a targeting tool. It allows FMCSA and states to have more tools to intervene with ‘potentially unsafe’ carriers and uses all data from the roadside to identify potential problems. It will mean more potential enforcement against poor-performing carriers and new accountability for drivers.”
She said that in CSA's operational model, data collected from roadside inspections and state-reported crashes is processed through its Safety Measurement System (SMS), featuring: the Carrier Safety Measurement System (CSMS), using 24 months of data; and the Driver Safety Measurement System (DSMS), using 36 months of data.
FMCSA regulates all motor carriers (all vehicles with a GVCWR over 10,000 lbs in interstate commerce and all hazardous material carriers). Many states require intrastate carriers to register and get a DOT number. Some FMCSA regulations (CDL and drug testing) apply to all commercial motor vehicle drivers if the vehicle is over 26,000 lbs GCVWR. This applies to Canadian and Mexican carriers entering the United States.
Sandberg said an interstate motor carrier applies when:
The cargo originates in one state and the destination is in another state or country.
The cargo originates in one state, the destination is in the same state, and the vehicle passes through another state or country to get to the destination.
The cargo originates in one state, moves by motor carrier to another location in the same state, and then moves by another mode (air, rail, water) to a destination in another state or country.
The cargo originates in one state, moves by another mode (air, rail, water) to a destination in another state, and then moves by motor carrier to its final destination in the second state.
The cargo originates in another country, arrives in a state, and moves by motor carrier to its final destination in the same state.
Roadside inspections are the primary source of data. In 2011, there were 3,593,600 nationwide roadside inspections, with a 5% driver out-of-service rate and 20.28% vehicle out-of-service rate. She said the biggest reason trucks are placed out of service is vehicle maintenance. Carriers with one to six power units accounted for 1,014,729 inspections — 28% of the total, leading all categories.
“They are small operators — the people who need help the most because they don't necessarily have a big staff supporting their operation,” she said.
CSA is governed by BASICs (Behavioral Analysis and Safety Improvement Categories):
- Unsafe driving
Speeding, tailgating, lane change, seat belt. Includes warnings and tickets.
- Fatigued driving
Hours of service, log books, ill, or fatigued driving.
- Driver fitness
Driver's license (right class, restrictions, suspended), med card (valid, current).
Use or illegal possession of drugs or alcohol. It's only what's found at the inspection and has nothing to do with employment or random testing.
- Vehicle maintenance
Driver inspections, equipment defects.
- Cargo related
Hazardous material, load securement, cargo leaks. This category soon will be only hazmat and will be renamed.
- Crash indicator
DOT recordable accidents, including both preventable and non-preventable. All crashes, not just those where they were at fault.
“They're looking at the type of crash and trying to determine the severity,” she said. “Is that violation likely to lead to a crash if the behavior continues? Or is the crash severe enough to indicate that carrier is already operating unsafely?”
CSA is like golf: The higher your score, the worse you're playing. Reckless driving is at the top end of the scale (10 points), while unlawful parking and a damaged windshield are at the bottom (one point). Crashes in the past six months are weighed at three points, with six to 12 months at two points and 12-24 months at one point.
“All data stays with the carrier in two years,” she said. “If it's a driver violation, the carrier still owns the data for two years.
“They try to normalize the data. If a carrier has 100 trucks and two violations, that carrier shouldn't look as bad as a carrier with two trucks and two violations. What might be an average performance for one carrier might also be considered quite poor for another. So they normalize that and try to measure like carriers with like carriers.
“The risk of intervention is tied to the carrier's peer percentile ranking. FMCSA has set a safety threshold for each BASIC. A carrier is at risk for intervention if they are over threshold in one or more BASICs or in just one of the stand alone BASICs: unsafe driving or fatigued driving.
“One of the weaknesses of the system is that not every carrier gets measured. There are 3.5 million roadside inspections, 6.5 commercial vehicle drivers, and 14,000 carriers. Carriers have to have multiple inspections in order for a score to show up.”
Fatigue driving is the most prevalent over-the-threshold BASIC, with 26,921 violations, followed by vehicle maintenance (18,556), unsafe driving (11,809) and crash indicator (5744).
Sandberg said that the top maintenance violation is inoperative required lamps.
“It seems like a pretty straightforward thing,” she said. “What's your process? What's your routine maintenance? Do drivers do a walk-around inspection? We try to look for obvious defects — the things drivers should notice when they do the federally required walk-around. A tire tread problem doesn't happen overnight. It might be a training issue with that particular driver.
“Brakes are a big one. It's really important when it comes to maintenance violations. Almost all brake violations are worth 10 points.”
She said that in order to improve scores, new approaches are required.
“I recently had a carrier that had an audit, and the driver consistently showed he was an hour off-duty when he was fueling,” she said. “Those are considered false log violations. That carrier nearly lost its rating.
Find the Heavy Duty Aftermarket Week Report archive with articles from 2012 to present