BY CLIFFORD F. LYNCH
fastlane
2010 – A safety odyssey
WHEN IT COMES TO THE FEDERAL MOTOR
Carrier Safety Administration’s new Comprehensive
Safety Analysis 2010 initiative (CSA 2010), there’s no
such thing as a consensus opinion. Some have hailed
the program as a bold step toward making America’s
roads safer. Others have characterized it as potentially the most damaging regulation in the trucking
industry’s history—one that could result in a critical
shortage of drivers.
The lack of consensus hasn’t stopped the FMCSA
from pushing forward with plans for implementation. The regulations are scheduled to take effect this
year, although it appears they won’t be fully implemented until 2011. Questions of the timetable aside,
one thing is certain: They will be implemented, and
they will apply to all carriers and drivers over which
the FMCSA has jurisdiction.
The program at the heart of the controversy is a
government safety initiative aimed at reducing crash-es and associated injuries and fatalities by removing
the worst carrier and driver violators from the road.
It includes mechanisms for measuring driver and
carrier safety performance, determining the cause of
recurring safety problems, and developing recommendations for corrective action.
To identify safety risks, FMCSA has created a new
Safety Measurement System (SMS), which measures
drivers’ and carriers’ performance using the following seven criteria:
1. Unsafe driving. This is simply the careless operation of a commercial motor vehicle (CMV); it would
be measured by traffic violations and convictions for
such things as reckless driving, improper lane
changes, and speeding.
2. Fatigued driving. Basically, this is driving while
tired, as opposed to driving under the influence of
drugs, alcohol, or other controlled substances. This
would be tracked through hours of service compliance reviews, roadside inspections, and post-crash
inspections and reports.
3. Driver fitness. This category includes drivers who
are unfit to operate a CMV due to lack of experience,
lack of training, or some medical disqualification. Proof
would be derived from failure to have a CMV license or
from medical or training documentation, as well as
from crash reports citing any of these as a factor.
4. Use of controlled substances or alcohol. This is
self-explanatory, and can be discovered through
crash reports, drug tests, and roadside violations.
Carriers will be required to conduct testing as well.
5. Vehicle maintenance. Roadside violations for
brakes, lights, and other mechanical defects fall into
this category. Carriers will be required to keep pre-trip inspection, maintenance, and repair reports.
6. Improper loading or cargo securing. This refers to
the failure to secure loads to prevent shifting or
spilled cargo—a particular concern with hazardous
goods.
7. Crash experience. Crash
histories will be tracked, with
particular attention paid to
frequency and severity. This
information will come from
law enforcement and carrier
reports or through compliance reviews.
What critics object to are
not so much the measurement criteria themselves as
the point-based ranking system that will be used to evaluate truckers. Some have questioned the weightings
assigned to particular violations, while others have
raised concerns about fairness to drivers. For example, in testimony before Congress in June, the
American Trucking Associations argued that under
the current system, drivers could be held accountable
for accidents they didn’t cause, and urged the
FMCSA to revise the regulations.
This is a valid concern, and it is important that it
and other matters be dealt with as implementation
progresses. Carriers have a right to expect fair and
equitable treatment as well as consistent enforcement. The success of the program depends on it.
To learn more about the program, visit
http://csa2010.fmcsa.dot.gov. ;
Clifford F. Lynch is principal of C.F. Lynch & Associates, a provider of logistics management advisory services, and author of Logistics Outsourcing – A Management Guide and co-author of The
Role of Transportation in the Supply Chain. He can be reached at cliff@cflynch.com.
