I’m in Louisville, Ky., today at a Commercial Vehicle Safety Alliance workshop on the life cycle of a roadside inspection violation (follow my Twitter feed for updates throughout the day, and stay tuned for news from tomorrow’s sessions, set to feature FMCSA Administrator Anne Ferro, her Mexican counterpart and other highlights besides). What better time to share some perspective on the Compliance, Safety, Accountability regime from CVSA Executive Director Stephen Keppler, which came well after all of my March reporting in the CSA’s Data Trail series was over and done with.
One question I put to Keppler probed top law enforcement concerns with the program. Based on conversations I’ve had with officers around the country as well as drivers, I expected some disconnect between enforcement views on CSA’s problems and those of drivers (see our Top Ten from the March issue at right — note drivers’ No. 1 named problem: the deterioration of truckers’ relationship with law enforcement).
In one sense, I got that in spades: “Enforcement generally believes CSA is moving in the right direction,” Keppler began his response to the question. These days it’s not impossible to find a trucker who agrees with that notion, but I’d say if you walked into a crowded driver’s lounge and shouted it out you might have an interesting situation on your hands.
Keppler went on to speak of a lack of resources in state truck enforcement departments. “This is for all aspects of delivering the program, from training to technology to people,” he said.
Following that, however, there was more of broad concurrence: “We also believe the issue of crash accountability needs to be resolved in a way that properly reflects the carrier/driver/vehicle’s contribution to the crash,” Keppler said, hitting on No. 3 on drivers’ list. “Another important concern we have is with respect to how the data is portrayed to the public and accessibility. CVSA would support a review of the public display of CSA data in an effort to identify the most effective method of accurately targeting those carriers and drivers who continue to operate unsafely.”
Nos. 4 and 6 on drivers’ list both have to do with the fact that CSA scores are public, thus accessible to brokers, shippers, insurance companies and other carrier customers who can get an unrealistic picture from scores, given the now-well-documented pecularities of the ranking system.
All in all, as suggested a commenter on the “CSA v. the Independent” piece of the March installment of CSA’s Data Trail, officers and law enforcement departments around the nation may share more with drivers in terms of concerns about CSA than the opposite. “I think CSA is so complicated that even FMCSA can’t begin to understand it themselves,” the commenter wrote. “They can’t understand the disaster they created. I have been told more than once by inspectors that they don’t even understand half of it. One even told me, ‘There’s so much crap in there, you could never learn it all.’ This stuff in the name of ‘safety’ is way out of control. When the day comes and we are all out of business, what will they do then?”
Find more from CVSA’s Keppler on a few topics below:
Other CSA concerns
Enforcement officials must have the ability to view all performance and compliance-related information in order to make informed decisions on resource allocation. Another challenge with the program is its continual evolution. While FMCSA has been relatively receptive to people’s suggestions for changes/modifications to the program, being able to keep up with these changes and have an effective means with which relay this information to people in the enforcement community who need to know has been challenging. A critical component of uniformity and consistency in enforcement is the ability to have structure and clarity in law, regulations, operating procedures, policy and training.
On the use of CSA BASIC (Behavioral Analysis and Safety Improvement Category) percentile rankings in roadside inspection screening
There are a number of factors that go into the carrier/driver/vehicle roadside inspection selection decision, such as a routine traffic stop, an imminent hazard, whether the vehicle has a current CVSA decal, where the inspection is occurring or if there is a special enforcement detail. In addition, inspectors at roadside have access to the Inspection Selection System (ISS), which is a software tool that provides assistance in selecting vehicles for inspection. A recent American Transportation Research Institute study of enforcement personnel regarding CSA concluded that 70 percent of the respondents believe ISS has become increasingly effective as a result of including the expanded CSA information.
There also are several electronic screening programs that use the CSA BASICs as an input to making their red- or green-light screening decisions. There are also other types of technology-based solutions that are assisting enforcement in resource management such as GIS [Geographic Information System]-based mapping tools. With each passing day enforcement personnel are becoming more advanced and data-driven in managing their limited resources more effectively and efficiently to target their activities where they are most needed.
On department quotas
All state and federal CMV safety programs are performance-based, with a focus on reducing commercial motor vehicle crashes. Each jurisdiction’s programs are based on safety data that is used to identify and proactively mitigate potential crash problems. For example, if we identify a geographic problem area that is seeing an increase in commercial motor vehicle crashes we will target that area with proactive crash reduction strategies in an effort to drive the crash rate down in that area.
In addition, each state has to submit (annually) its Commercial Vehicle Safety Plan (CVSP) to FMCSA in return for the Motor Carrier Safety Assistance Program (MCSAP) funding authorized by Congress. As a part of the CVSP process each year, FMCSA provides guidance to the states on emphasis areas they believe are items states should consider addressing as part of their plan for the year. This guidance does not include any quantitative numbers. In their CVSPs the states set goals and targets with respect to “outputs” on items such as Roadside Inspections, Compliance Reviews, Safety Audits, Outreach activities and other projects. It is the state’s job to use its resources to the best of its ability and to be as productive as possible to meet these goals.
"Until a formal regulation is established with clear guidelines and borders ...