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By now, all transportation executives and safety personnel have heard about the Federal Motor Carrier Safety Administration's (FMCSA) new safety initiative to improve commercial motor vehicle safety and ultimately reduce crashes, injuries and fatalities. Or at least you would think so, right?
According to an FMCSA report dated Sept. 22, only 2.6 percent of the 500,000 active carriers have gone online to view their safety scores under the new CSA2010 methodology.
On Dec. 5, all carrier CSA scores for six of the seven BASICs (excluding the Crash Indicator BASIC) will be made public. This system will replace the current SafeStat site used by customers, shippers, brokers and insurance underwriters to evaluate a carrier.
Many motor carriers will encounter a BIG surprise in December (and I am not talking about Santa Claus). Since the new initiative takes into account all violations instead of just the "Out of Service" (OOS) violations, several carriers who have maintained scores under 75 using the old methodology for SafeStat will find themselves "Deficient" under the new CSA methodology.
In fact, many carriers have reported that over 70 percent of their violations listed on their new CSA2010 safety profile are for non-out-of-service violations, which were never before reported or used in the SafeStat methodology. These violations have now placed many carriers into a Deficient category in one or more of the seven BASICs.
So what is the next step?
In late December, the FMCSA will begin sending out "Intervention Letters" to all carriers who are found to be Deficient in at least one of the seven BASICs. Carriers will be required to respond with a Corrective Action Plan describing how they plan to correct the Deficient BASIC or BASICs. The FMCSA will review the plan and make a determination if the plan is sufficient and acceptable. If the carrier's Deficient BASIC or BASICs do not improve within the time allotted, the FMCSA will then move to the second step of the Intervention process, the "Targeted Intervention," which will be conducted either on-site or off-site.
One of the most important things to keep in mind once notified of a Targeted Intervention is that the FMCSA already knows which drivers and/or equipment they are targeting. For instance, if you are targeted for fatigued driving (hours of service) violations, you can expect FMCSA to review your worst drivers (the drivers who have had roadside violations) rather than your best. If you are found to have more than a 10 percent violation rate, you may be required to have EOBR in all trucks within 45 days.
What can you do to prepare?
The most important things any carrier can do to be ready:
1. Check and update your records.
2. Be sure to log into the FMCSA website at http://csa2010.fmcsa.dot.gov/ and review your CSA safety scores.
3. Be sure to review your inspection and crash data and challenge anything that is incorrect.
4. Educate the drivers about their performance and how it impacts their safety record.
5. Educate your operations personnel and management about CSA2010.
6. Begin to develop a culture of safety within your organization. Safety is not just a department!
7. Be proactive in dealing with drivers and their violations.
8. Ensure compliance.
9. Document, document, document.
The Change in Practice
Knowledge gives rise to duties. A carrier has a duty to take appropriate action for those who violate regulations. Do you have the documentation for the action or training? More importantly, did you take the appropriate action based upon the severity of the violation? Can you provide documentation signed by the driver? Are you providing routine training and conducting safety meetings for all members of your fleet and staff?
If the carrier has taken appropriate action and can provide the documentation and the driver still continues to operate outside of compliance, then the intervention will turn toward the driver and the driver may be cited or fined. This is not to say that the carrier will not be held responsible or fined, but simply there is equal emphasis on the driver under CSA2010.
Some other changes carriers should expect: (1) Shippers will be modifying their contracts to reflect the changes from SafeStat to CSA; (2) The shipping and brokerage communities have become more aware of their potential liability for negligent hiring of carriers, so they may modify their qualification process accordingly; (3) Shippers will have to evaluate their tolerance for risk versus what they are willing to pay for safe carriers; (4) If a shipper or broker is going to use a carrier with a Deficient BASIC (which they inevitably will if they want to move their freight) they should, at minimum, verify that the carrier has at least 1 million dollars of liability insurance.
Finally, carriers need to take a serious look at their safety professionals. Do you have a certified safety professional with a solid understanding of the FMCSA regulations who can interact with government officials and carrier management to develop an action plan which ensures success? Do you truly have a culture of safety within your entire organization, as opposed to just a "safety department?"
CSA is a game changer. It is the biggest change within the trucking industry since deregulation. Some believe that resistance to change is part of human nature, which may explain why so few carriers have researched and prepared for CSA2010. Don't let the coming changes be a detriment to your business. Protect yourself by protecting your employees, your fleet and everyone who shares the road with your drivers.
Are you ready for the next step?
Source: Inside Trucking Newsletter
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