Research evaluates CSA’s operational impacts

The American Transportation Research Institute (ATRI) has released an analysis evaluating operational impacts on business and carrier supply chains that have occurred since the full rollout of the Federal Motor Carrier Safety Administration’s Compliance, Safety, Accountability (CSA) program in December 2010.

ATRI’s latest CSA report examines two year’s worth of data collection from fleets, drivers, shippers and motor carrier safety enforcement personnel, providing what ATRI called the first comprehensive look at industry impacts including changes in driver hiring, driver training, driver wages, freight pricing and safety improvements.  The data also evaluates industry perceptions and knowledge of critical CSA program components.

Previous research from ATRI released this past fall focused on the relationship between CSA scores and crash risk. The latest industry impact study provides further insight into the impact of CSA on industry operations.

“There has been extensive debate concerning the real-world effects of CSA on the trucking industry. This paper examines several of the program’s anticipated or experienced outcomes, and assesses the likely short- and long-term byproducts of CSA,” the ATRI report said. “Conclusions are based on the existing literature as well as stakeholder input collected through ATRI’s separate motor carrier, truck driver, shipper and enforcement data collection efforts. Together, these sources have provided insights into the nature of CSA’s impacts on the commercial driver labor pool, the operations of motor carriers, the shipper-carrier relationship, and the ability of FMCSA to more effectively regulate the industry.”

After two years of CSA being fully operational, industry perceptions have adapted considerably to acknowledge that many of CSA’s impacts will be more long-term than initially expected, the study found.

“The program did not immediately result in a mass exodus of drivers or dramatically exacerbate shipping and operational costs. Still, the program remains a work-in-progress and will continue to draw criticism until persistent flaws are addressed,” ATRI notes.  Of particular concern are BASIC scores that do not measure crash risk, the absence of a mechanism for incorporating crash accountability determinations and regional differences in enforcement.

 

Impact on truck drivers

Concerning the commercial driver pool, the availability of drivers has not tightened as broadly as expected (beyond existing demographic and economic trends), the study found.

“Specifically, only a small fraction of currently employed drivers have been put out of work explicitly due to CSA. This is a marked deviation from industry expectations; shortly after CSA was introduced, experts were predicting that 10% to 20% of drivers would be terminated as a result of the program,” according to the report.

“Nonetheless, CSA’s effect has primarily been felt by prospective truck drivers. Employers report less leeway when evaluating driver applicants’ driving records compared to current employees,” the report said. “This makes sense since employers have more extensive knowledge of current drivers than of applicants, including insights into personality traits, behavioral patterns and home lives; therefore, employment decisions can often factor in information beyond a driver’s MCMIS or MVR data (not to mention, employers may be privy to explanations behind safety infractions or FMCSR violations).”

On the other hand, the report noted, applicants are principally defined by their driving histories. And since 2010, PSP has been particularly impactful in screening out a high percentage of undesirable drivers. “While this is a laudable practice that will likely keep the safety bar elevated, a consequence is that most employers now find it somewhat or extremely difficult to find and hire new qualified drivers. This figure grew from 72% of carriers in ATRI’s 2011 survey to 83% in ATRI’s 2012 survey, alongside the trend of carriers increasingly incorporating PSP into hiring practices.”

Although ATRI’s surveys and literature review revealed little change to drivers’ levels of base pay, numerous drivers and carriers reported financial safety incentives that were tied to CSA, the report said. For instance, some carriers now offer bonuses for RIs that are free of violations while others issue rewards to drivers for extended periods of driving without any safety incidents. Drivers are therefore more incentivized than ever to comply with safety regulations, which will not only improve their chances of remaining employed in the industry, but will also keep their employer’s CSA scores low.

Since CSA has altered many facets of a truck driver’s daily life, it is critical that drivers be informed concerning what CSA is and is not. Unfortunately, ATRI found that most drivers are not actively seeking out information on CSA. Fewer than half of drivers responding to ATRI’s surveys reported checking their respective employer’s BASIC scores. Similarly, a relatively small number of respondents (31%) have taken steps to access their own MCMIS data available through PSP. Not surprisingly then, is ATRI’s finding that drivers score very poorly on a CSA knowledge test.

ATRI says a more targeted learning approach is necessary for drivers since CSA represents a marked shift in the way safety and compliance are measured, and requires a tremendous amount of information to be communicated to drivers from FMCSA, fleets and trucking associations.

 

Motor carrier impact

Nearly all fleets responding to ATRI’s survey said they have taken an active approach to CSA with 96% accessing their company’s CSA data at least monthly and attempting to use the information to advance practices and policies. ATRI found that most carriers report offering CSA-specific training to their drivers; incorporate PSP into hiring practices; invest in technologies that can improve CSA performance; and terminate drivers in accordance with how severe CSA consequences are (i.e. the number of BASICs a carrier had above threshold corresponded with the percentage of that carrier’s workforce that was terminated for reasons pertaining to CSA).

Early on, carrier dissatisfaction with CSA was likely the result of greater carrier scrutiny compared to SafeStat, the report notes. For instance, ATRI found that the percentage of respondents with no SafeStat areas above threshold was higher than 70, but less than 45 for CSA. Since then, carriers have been steadily improving BASIC scores, on average, and are learning to adapt to the new standards associated with CSA. “As the program becomes the norm, dissatisfaction is now most likely to be the result of the industry’s perception that FMCSA is not incorporating the industry’s input (only 14% of carriers completing ATRI’s 2012 survey were satisfied with FMCSA’s responsiveness to their concerns),” the report says.

In addition to issues like a lack of crash accountability determinations and safety event group fluctuations influencing scores (apart from true changes in performance), ATRI found several indications that fleet size has a bearing on a carrier’s CSA standing. Small fleets tend to have less reliable BASIC scores (e.g. small carriers report significantly more safety event group fluctuations); more challenges to remaining in business; and fewer resources to invest in technology, training programs or PSP (each of which helps larger carriers improve CSA scores).

Overall, carrier concerns from ATRI’s 2011 survey were far more negative than carriers’ 2012 perspectives based on prolonged experience operating under CSA, the report says. In 2011, 87% of carriers expected CSA to adversely impact the number of motor carriers able to remain in the industry, whereas only 59% held this belief in 2012. “This suggests CSA has not presented as many obstacles as expected, however, the issue clearly remains a major concern,” the report notes.

“As carriers continue learning to adapt to CSA, they are aided by adequate general knowledge of the program, particularly when compared to drivers,” the report says A win-win scenario may involve carriers transferring this knowledge to their drivers, which would likely have a measurable impact on future CSA performance. Drivers who misunderstand CSA are unlikely to take the correct actions that can improve scores. For instance, many drivers do not understand that clean inspections can help improve most BASIC scores and therefore do not make habits of requesting documentation for violation-free inspections (or challenging inaccuracies through DataQs). Ensuring that all members of a carrier’s operations have accurate and up-to-date knowledge on the methodology behind CSA is therefore a prudent step toward remaining in good standing.”

 

Impact on shippers

Like the evolving relationship between drivers and carriers, CSA has also impacted shipper-carrier relationships. ATRI found that shippers were less discerning when evaluating the CSA scores for currently contracted carriers as opposed to carriers seeking a new role in the shipper’s business.

“This makes intuitive sense since shippers have more information at their disposal concerning established carriers. Shippers may in fact be quite comfortable with a company’s safety record despite high BASIC scores if they have utilized the carrier in the past. For this reason, shippers reported through ATRI’s survey that CSA scores are not typically sufficient reason for terminating an existing contract.”

Instead, ATRI said, most shippers utilize what is called a Corrective Action Plan, asking carriers to submit plans for improving problematic BASIC scores. On the other hand, prospective carriers are much less likely to be selected by shippers without having a strong CSA profile.

“Primarily, this is because shippers fear being held vicariously liable for selecting carriers without giving adequate consideration to available safety information,” the report said. “Still, only half of the shippers participating in ATRI’s survey claimed that poor CSA scores alone were sufficient reason to avoid contracting with a prospective carrier.”

A key consideration in the shipper community is whether CSA scores fairly and accurately measure carrier performance. According to ATRI’s analytic research, several BASICs should not be interpreted as identifying higher-risk carriers, although the Unsafe Driving, Fatigued Driving and Vehicle Maintenance BASICs do appear to measure carrier crash risk. “To the extent other BASICs are utilized, shippers may be identifying false positives (i.e. carriers that are safe in reality but unsafe according to CSA),” the survey report says.

 

Enforcement impact

Of all stakeholders surveyed by ATRI, enforcement personnel held the most favorable perceptions of CSA. Even this group, however, felt that training and educational opportunities have not kept pace with the new and complex safety measurement program. Nearly three-quarters of respondents indicated that more CSA training is needed to help standardize enforcement processes.

Respondents said they were most interested in receiving regular “refresher” courses on CSA; timely updates on general program or SMS methodology changes; additional information on how to properly document violations; and a fuller understanding of the implications that enforcement actions (such as “frivolous violations”) have on motor carriers. More than half of enforcement personnel said there are insufficient resources available to enact the desired training procedures.

Despite these limitations, CSA has exceeded the expectations of the enforcement community, and most believe the program has already been a factor in reducing the number of truck crashes, the report said. “Contributing to these beliefs, enforcement personnel contend that enforcement tools, such as the ISS and CSA’s four new types of interventions, represent significant improvements compared to the tools available under SafeStat. These improvements have allowed them to focus their limited resources on a more targeted group of at-risk carriers and drivers. Additionally, one apparent benefit of CSA is that drivers are now identified as part of the process for identifying unsafe practices and procedures.”

“Clearly, CSA presents a host of both challenges and opportunities for the trucking industry,” the report concluded. “Supply chain members that are benefiting are realizing advantages by closely tracking safety and operational data; investing in the right human capital based on an evidence-based evaluation of which drivers will likely improve rather than harm CSA performance in the future; and utilizing innovative technologies that are capable of improving otherwise difficult-to-change safety dimensions. For the foreseeable future, however, the economy will exert a much greater influence on the dynamics of the supply chain, with CSA and new regulations (e.g. changes to the HOS rules) playing a secondary role.”

A copy of this report is available from ATRI at www.atri-online.org.

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