If you shoved the new federal Compliance, Safety, Accountability (CSA) program onto the back burner with your fleet, its time to move it to the front. Because the heat is on.
Everyone in your fleet organization especially your maintenance personnel needs to give whats cooking in the CSA pot a stir and examine what impact this new safety enforcement framework, activated late last year by the Federal Motor Carrier Safety Administration (FMCSA), will have on your operation.
The most important thing to note with CSA is that if your business is using trucks, you are subject to it, stresses Stephen Keppler, executive director of the Greenbelt, Md.-based Commercial Vehicle Safety Alliance (CVSA), an international not-for-profit organization composed of local, state, provincial, territorial and federal motor carrier safety officials and industry representatives from the United States, Canada and Mexico.
Historically, he says, a lot of refuse businesses did not really think of themselves as trucking companies; trucks were just one of many tools to collect trash and recyclables. Under CSA, they no longer have that luxury. Any business operating commercial trucks is going to be captured within this new safety net.
On top of that, CSA uses real-time data generated from roadside inspections to put together its fleet safety ratings, says Keppler. That means things like maintenance defects and out-of-adjustment brakes will find their way into in the public eye a lot faster than most fleets realize.
Thats perhaps the biggest CSA kicker of them all: Safety ratings will be made public via the Internet (though with certain limitations) for all to see. That, of course, includes your customers and the companies that provide insurance coverage to the refuse industry folks that will certainly raise an eyebrow if your safety rating starts to plummet.
At the end of the day, CSA takes safety enforcement to a whole new level, says Keppler. And to his mind, the way companies need to deal with CSA is the same way they deal with their finances: make it a frequent priority.
For example, many companies have auditing teams providing weekly, if not daily, reports on the fiscal performance of your business, he says. The same approach is needed in terms of fleet safety. You need to be proactive, monitoring your safety performance on a daily basis, because your customers are seeing this data the same way your investors are tracking your companys performance via your financial statements.
Breaking It Down
CSA is not a new set of safety regulations promulgated by the FMCSA; rather, its a re-engineering of the agencys enforcement and compliance process to provide a better view into how well large commercial motor vehicles and drivers comply with safety rules, and to intervene earlier with those that dont.
Officially rolled out in December 2010, the program establishes a new enforcement and compliance operational model that focuses on three major areas:
- Measurement: Using inspection and crash results to identify carriers whose behaviors could reasonably lead to crashes.
- Evaluation: Giving enforcement entities at the federal and state level the ability to correct high-risk behavior by contacting more carriers and drivers with interventions tailored to their specific safety problem, as well as a new safety fitness determination methodology.
- Intervention: Changing how safety data is collected, evaluated and shared, along with improved methods for enforcement officials to step in more effectively and efficiently.
Data for assessing those areas will come from three key areas: vehicle accidents, traffic citations and roadside inspections, says Roger Murphy, assistant vice president for hazmat transportation with Philadelphia-based consulting firm ACE Westchester Environmental. Any driver who experiences events captured in these three data sources will be assigned points that impact both the driver and motor carrier score on a monthly basis, he says. And its not just moving violations but maintenance issues that will raise the overall score.
Here are some examples of points determined under the new system; the more serious the perceived violation or issue, the greater the point assessment:
- Reckless driving: 10 points
- Tires with flat spots: 8 points
- Following too closely: 5 points
- Kink in a brake hose: 4 points
Violations, inspection results and crash data are then categorized into Behavioral Analysis Safety Improvement Categories, or BASICs, Murphy says. Those include:
- Unsafe driving: Includes speeding, reckless driving and lane change violations.
- Fatigued driving (hours of service): Includes violations dealing with logs.
- Driver fitness: Includes lack of experience, insufficient training and medical disqualifications.
- Controlled substances: Includes violations related to alcohol, drug possession, driving under the influence (DUI) and refusal to submit to a chemical test.
- Vehicle maintenance: Signifies failure to properly maintain brakes and other vehicle components.
- Cargo related: Pertains to securement, hazmat training/placarding.
- Crash indicator: Denotes a history of crash involvement.
These categories are weighted on perceived severity, which will be used in calculating the final rating, says Murphy. And while the CSA data feed will not be in real time, it will be very close to it. The uploading of information regarding roadside inspections, citations and accidents to the main system will enable a motor carriers rating to be updated on a monthly basis.
He points out that as a fleet accumulates BASIC data, and that data becomes more credible, one of three ratings will be assigned: Continued Operation, Marginal or Unfit. After the rating is assigned, the government will choose enforcement actions, if applicable, Murphy concludes.
The upshot for refuse fleets is that, if one of its garbage trucks gets pulled over for a roadside inspection and if, say, its brakes are found to be out of adjustment, that violation not only affects the companys safety rating within 30 days but also counts against the drivers safety record.
And brake defects happen to be one of the most common vehicle maintenance issues detected by roadside inspections. For example, CVSA noted in that during its annual 72-hour roadcheck safety inspection blitz in 2010 (the most recent data available at the time of this writing), out-of-adjustment brakes comprised 23.7 percent of all out-of-service (OOS) violations recorded by inspectors. Overall brake system violations climbed to 27.1 percent of total vehicle OOS designations last year, up from 26.9 percent in 2009.
Another factor: According to an analysis of CSA to date conducted by research firm J.J. Keller & Associates and leasing company GE Capital Fleet Services, CSA engenders three times more safety enforcement contact with carriers compared to the old system.
The odds have increased substantially under CSA that carriers will be targeted for some sort of enforcement activity, either in terms of receiving warning letters or being subjected to focused interventions, notes Mark Catlin, J.J. Kellers national account executive. Thus, if a waste firm has its safety rating downgraded, it may be put on a watch list of sorts, alerting inspectors nationwide that its vehicles and drivers should be flagged for more frequent investigations.
This is serious stuff, Catlin warns. CSA has not changed any of the FMCSAs regulations; rather, CSA is designed to get enforcement personnel involved earlier in the process. And though CSA will continue to change and evolve, it is here to stay. So you need to do everything you can to drive your CSA scores down lower than your peers.
And remember that a far wider range of situations can generate data for FMCSA to use in calculating safety ratings going forward. For example, the agency notes on its web site some roadside inspections are performed following traffic enforcement stop for a moving violation. Yet while violations reported during such stops do not always result in a driver citation, they will be used in the agencys Safety Measurement System (SMS) regardless.
Jeff Kaley, product manager for TruckVantage compliance for GE Capital Fleet Services, says that because CSA data for five of the seven BASICs is available online, its creating a ripple effect not only with shippers, but with insurance companies and financial institutions as well.
It basically means doing nothing is not an option, he says. Often companies do not fully understand the impact bad drivers may have on their CSA scoring. In fact, many of our customers do not see themselves as trucking companies. But as they use commercial motor vehicles to perform [certain] functions, in the eyes of the Department of Transportation and FMCSA, they are subject to the CSA regulations.
Catlin notes that, as a result of all of this, any business using trucks needs to be more aggressive in terms of monitoring their CSA scores, especially in terms of combating incorrect information.
A fundamental thing were finding that carriers must do is get copies of the roadside inspections from their drivers so they can track them, he says.
CSA is designed to focus intently on roadside inspection data accrued every 30 days so you as a carrier are only as good as your last 30 days, says Caitlin. Yet the state enforcement agencies dont always provide updates every 30 days. Sometimes theres significant lag time. Thats why you need those roadside report copies, because by the time you discover an error an improper DOT number, for example you might be three months behind the data upload.
Thus, keeping current with the roadside reports is critical for spotting trends.
Incorrect data wont change unless you challenge it, he adds, and fleets will need to substantiate any challenge they make.
You need back up data such as photos to prove your case if, for example, youre dealing with transposed DOT numbers, for theres no cross-checking process in place within CSA to ensure the accuracy of such information, Caitlin says. Thats why you need to review the CSA data on a monthly, if not weekly, basis so can catch any such errors.
What To Do
For those refuse fleets unsure about how to deal with CSA, ACEs Murphy has some advice: As with any new federal regulation, its best to become as familiar with it as possible, he says. CSA is indeed here to stay.
That being the case, Murphy recommends that fleets do the following:
- Understand and respect this initiative and its meaningful enforcement power.
- Obtain a personal identification number [PIN] so fleets can access their specific account to view BASIC data, when available.
- Use the database information to monitor drivers monthly.
- Educate drivers, especially in terms of vehicle needs, as strong pre-trip inspections are key to heading off maintenance-related CSA issues.
- Educate customers so they understand the fleets daily challenges.
In particular, CSA and BASIC scores have been generating significant attention from the insurance underwriting community, he adds. In some cases, favorable BASIC scores may have a significant impact on pricing and underwriting decisions from an insurance perspective but also may concern customers and other interested parties who are keeping a close watch on potential liability issues.
Thats why fleets must proactively monitor, identify and address any areas of vulnerability when it comes to CSA vehicle maintenance included as it will be part of the overall effort to protect their companys bottom line, according to Murphy.
CSA is a collective new reality, and it will only become stronger as the data is collected, aggregated and translated into specific motor carrier and driver ratings, Murphy says. CSA needs to govern every aspect of [fleet] operations and permeate their everyday thinking and actions. While the regulations may force some of us to rethink protocols, the end will hopefully justify the means: to have every driver and vehicle return home safely, every day.
Sean Kilcarr is a senior editor for Fleet Owner, a sister publication of Waste Age.