Since October or November of 2009, amid all of the various and sundry things I’ve written about here at the blog and elsewhere in Overdrive, one subject has been a veritable constant, assuming perhaps the most prominent spot in the day-to-day of what I do here. Its three letters mean something to me decidedly different from what they mean for the majority of my friends and family here in Nashville, who use the acronym routinely to refer to weekly (sometimes biweekly and monthly) fresh-vegetable pickups they pay various local farms for.
My source file on the three letters — the word document where I’ve keep all of my notes from interviews on it over the past three-and-some years — is now as long in terms of word count as every bit of finished fiction writing I’ve done in the past 10 years of that pursuit, I’d say, upward of 400+ single-spaced pages of notes.
One thing’s certain, there’s never a dull moment talking about the subject — or listening, as the case may be, which I got the opportunity to do at the Mid-America Trucking Show during one of two “CSA Update” sessions an FMCSA specialist delivered on Friday last week at the show. For me, there wasn’t a great deal new delivered in the session, but I did bear witness to a phenomenon oft-remarked-upon by anyone who’s had the opportunity to sit on a CSA outreach session.
The official line from FMCSA on the CSA enforcement regime is that, as a public affairs officer told me and others have continued to insist throughout my reporting of the CSA’s Data Trail series of stories and data analysis ongoing, CSA is a “workload prioritization tool” for the agency, i.e. a series of statistical metrics to help the agency decide what carriers need attention and don’t to make the roads safer. Here’s my favorite quote about public use of the system, whose statistical metrics are of course at least mostly available to anyone with a computer and internet connection: The CSA Safety Measurement System “quantifies the on-road safety performance of motor carriers so that FMCSA can prioritize them for intervention. Use of the [the CSA SMS] for purposes other than those identified may produce unintended results and inaccurate conclusions.”
That one’s in this piece of the Data Trail series, about how things are working in the real world, where those “unintended results and inaccurate conclusions” have become something of the rule of the day for any small carrier unlucky enough to show a negative score.
During the session at MATS, however, the FMCSA specialist seemed to encourage such of the drivers in the audience there, offering the public CSA SMS as a tool to weed out prospective employers when considering leasing on with or applying to a carrier. If you see a carrier with super-high numbers in the Hours of Service Compliance or Vehicle Maintenance BASICs, he said, you might say this: “I don’t know if I want to run for these guys. Maybe they’re pushing their drivers to run over hours, or maybe they’ve got junk equipment.”
I’m guilty of implying the same to one degree or another, but it’s my job to consider how these things are working in the real world, of course, where a carrier with a very high number in any SMS category is more and more likely to find itself losing freight. It’s FMCSA’s job to consider that as well when developing regulations, particularly as they pertain to small business. I figure if the agency is going to continue to insist that CSA is not for use in business decisions and is no more than a workload prioritization tool, they ought to have learned by now to keep well away from advising people on how to interpret the numbers. The impression they’re leaving is of a man talking opposite viewpoints from either side of his mouth.
“Community-supported agriculture” carries with it a nice and homey feel-good flavor for my friends and family when they say it.
I got my CSA! — fresh local vegetables warm the cockles and all that. Speaking those three letters makes most members of the general public feel nice and upright and good about themselves. Too bad we can’t feel the same.
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