CSA 2010 – Hang On for the Ride
The NATC Perspective
By: J.P. Gibbons, NATC
This year the FMCSA will roll out CSA 2010 which will replace many
of the systems and databases used to rate the performance of motor
carriers and their drivers. This has been a very intense internal effort
by FMCSA Chief Safety Officer Rose A. McMurray and her team. Since
2004 there have been public meetings and attempts to get input from
the regulated industry. Most of these efforts have had less then a
resounding response. I know I have been involved from the start as
one of the few non-association or lobbying attendees. We should all
thank FMCSA and CSO Rose A. McMurray for the openness shown in
the past and hope that it continues throughout the process. I find CSA
2010 to be very impressive and insightful in its attempt to more effectively
utilize limited federal resources and get the bigger bang for the buck we
all talk about. I find CSA 2010 to be very disheartening in that it appears
the federal government will replace experienced field agents with computer
models which do not take into consideration some of the realities of the
highway transportation industry. (Since this is our website, I get to tell it
like I think and if I am wrong I am sure someone will be pleased to let
me know in a positive way.)
I am very concerned that the CSA 2010 system does not distinguish
between a driver who is 15 minutes over the 11 or 14-hour rules and
one who is two (2) or more hours over. Experience shows us that the
driver who shows 15 minutes over is logging accurately and not a fatigued
driver. However, the data used to create the seven (7) basics which make
up the core of CSA 2010 never distinguished at that level. Over hours is
over hours and considered a fatigued driver issue. I am also concerned
that the database driving this program originates from state impute which
historically has had many quality and timeliness issues. The amount of
DataQs expected once CSA 2010 becomes operational nationally will not
only test the system but will crash the system. I have heard no specifics
concerning time lines for states to respond or resolve DataQ challenges
that effect their performance. NATC has discovered and reported to
FMCSA several serious uniformity issues with roadsides performed by
different states and the restrictions placed on the states by their laws
and procedures. How will such issues be resolved and will negative data
be removed until validated like required under the Fair Credit Reporting
standards? I for one hope and pray so.
Since I am in favor of maximum utilization of limited resources, I would
like to propose that carriers who agree to specific performance standards
should be given access to tools and data which will assist the industry in
removing unsafe drivers and equipment. Let us start with publishing the
names of all drivers who have tested positive for controlled substances or
found under the influence of alcohol while driving a CMV. Let us just
disqualify these people for life. We disqualify drivers for other offenses,
but why not for these serious violations? Make all carrier subject to FMCSR
report all positive results under Part 382 or subsection 392.5. Such a
requirement would improve the Drug and Alcohol basic under CSA 2010.
Also let carriers and drivers have direct access to the CDLIS like the states
do at roadside inspections. Carriers who pull abstracts are not finding
disqualifications, revocations and suspensions on their driver’s records
because they do not have the same access. Usually a carrier does not
know a driver has a problem until the inspector tells their driver he/she
is Out of Service due to a suspension in some state for a parking ticket
or other violation they may not have known. Stop letting states use the
CDL program to collect old tickets that have little if anything to do with
safe driving. Set up a national standard for disqualifying a driver’s CDL
and make that the Out of Service standard for the Unfit Driver Basic.
We recently came across a 19 year old ticket in NY which was not on the
driver’s record two years ago but is now and resulted in the driver being
placed Out of Service.
For those who have not had the chance to review the data and materials
put out by FMCSA on CSA 2010 be warned. There are lots of companies
holding webair meetings and training sessions on CSA 2010 who are
putting out incorrect information. The driver and equipment violations
from roadsides will be on your record for a 24 month period not 36
months as some are saying. Misinformation is a big problem when
major programs are about to take effect. My strong recommendation
is to visit the FMCSA website and go to their CSA 2010 section for
accurate information. I also strongly encourage everyone to pay
close attention to public meetings and information sessions being
offered by FMCSA throughout the country and attend one for the
sake of your company and its future. Shippers should also attend
so they understand what the data is that they will be relying on when
SafeStat is replaced this summer with CSA 2010 and its SMS data.
As they say buckle up and hang on for the ride. If you are not prepared
for this one you may not survive the trip.