An analysis of how the new Compliance, Safety, Accountability (CSA) system put in place by the Federal Motor Carrier Safety Administration (FMCSA) last year determined that there’s been a significant jump in trucking safety enforcement activities – with the system engendering three times more contact with carriers compared to the old system.
J.J. Keller & Associates and GE Capital Fleet Services shared their findings concerning CSA in a webinar this week, with Mark Catlin, J.J. Keller’s national account executive, noting that 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.”
“This is serious stuff,” he explained. “CSA has not changed any of the FMCSA’s 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.”
In an earlier interview with Fleet Owner, Jeff Kaley, product manager-TruckVantage compliance for GE Capital Fleet Services, noted that because CSA data is available online to the public for five of the seven Behavior Analysis and Safety Improvement Categories or “BASICs,” it’s 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 explained. “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 Dept. of Transportation (DOT) and FMCSA, they are subject to the CSA regulations.”
J.J. Keller’s Catlin, however, noted that several positive trends are developing as well – especially in terms of how carriers are responding to the “focused interventions” that occur under CSA versus the “compliance reviews” used under the old system.
“Some 20% of those carriers subjected to a focused intervention showed fewer safety problems 12 months after the intervention occurred,” he noted. “That means carriers are aggressively responding to safety issues.”
Caitlin added, however, that carriers also need to be more aggressive in terms of monitoring their CSA scores, especially in terms of combating incorrect information.
“A fundamental thing we’re finding that carriers must do is get copies of the roadside inspections from their drivers so they can track them,” he said.
“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,” Caitlin said. “Yet the state enforcement agencies don’t always provide updates every 30 days – sometimes there’s significant lag time. That’s why you need those roadside report copies, because by the time you discover an error – and 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.”
It’s also critical to bring drivers into the process as they will be in the best position to collect information at the roadside to back up any challenge a carrier may make under CSA.
“Open communication between fleet administrators and drivers is critical as they are both being scored under the CSA program,” noted GE Capital’s Kaley. “This is clearly a partnership between the fleet and the driver around what is acceptable and what is not acceptable when operating a commercial motor vehicle for the company. Additionally, the fleet needs to make certain that drivers understand the impact they have on the company.”
That’s because drivers are often in the best position to help carriers challenge inaccurate information, which, if left unchecked, could hurt its CSA scores.
“Incorrect data won’t change unless you challenge it – and you need to substantiate your challenge,” J.J. Keller’s Caitlin stressed. “You need back up data such as photos to prove your case if, for example, you’re dealing with transposed DOT numbers, for there’s no cross-checking process in place within CSA to ensure the accuracy of such information. That’s why you need to review the CSA data on a monthly, if not weekly, basis so can catch any such errors.”
