Be ready for second year of CSA
You probably didn’t notice any fanfare on Dec. 13 when the Compliance, Safety, Accountability (CSA) enforcement program marked its first anniversary.
This was quite a contrast with the hand-wringing for more than a year that preceded it. The industry was concerned that it would be crippled with excessive penalties, out-of-service drivers and enough red tape to stripe the interstate highway system.
Nothing that dramatic came to pass in CSA’s first year. Nevertheless, carriers have noted structural problems, such as how violations are weighted. For example, requiring a driver to exceed the 11-hour driving limit or the 14-hour on-duty limit has a severity rating of 7, the same rating as not wearing a seatbelt.
Even as the industry wrestles with such problems, there are things to be gleaned for leased and independent owner-operators, based on data from the first 10 months in 2011. These stats were gathered by Overdrive’s sister magazine Commercial Carrier Journal from the Federal Motor Carrier Safety Administration:
[bullet]Lights are a glaring problem. Under the equipment violations, the two most common involve missing, broken or defective lights or reflective devices, for a combined 17 percent of all violations.
[bullet]Tread depth is a deeper problem. Following lights/reflectors, the most common equipment violation (5 percent) was having tread depth less than 2/32 of an inch. However, with a severity rating of 8, it’s much more critical than the light-related items, rated at 2 and 3.
[bullet]Logs are as important as ever. “Form and manner” log violations and “record-of-duty status not current” together account for 28 percent of driver violations.
The first two points can be easily controlled. Turn on your lights, see which ones are out. If you don’t have a tread depth gauge, get one (they’re cheap) and use it.
As for logs, buckle down and keep up with them. If you’re not already using an electronic onboard recorder, get ready to do so. Their use probably will become industrywide, whether through formal mandate or practical necessity. Compliance is expected to be quite the challenge under the new, more complicated hours rule, which was to have been announced by year-end.
Because CSA is so ambitious, many carriers have received little scrutiny. More than two-thirds of carriers had two or fewer inspections during a 24-month period ended in October, according to analysis by Randall-Reilly TruckIntel, owned by Overdrive’s publisher.
Most initial efforts have focused on larger carriers, so there are thousands of independent owner-operators who have yet to experience the long arm of CSA. Its first year might have seemed benign to you, but it’s still warming up. Be prepared for a closer acquaintance in 2012.