Page 34 - ATR 3 2016 web

scores public again.
Transportation Secretary Anthony
Foxx recently commented, “Based on
our preliminary assessment, it’s going
FMCSA SHOULD FOCUS ITS EFFORTS ON TRUE to take a while to do the revised analy-
sis,” referring to the changes in the CSA
CSA REFORM WHERE THE PROGRAM WOULD score methodology mandated in the
FULFIL ITS ORIGINAL GOAL OF IDENTIFYING AND FAST Act highway bill. “We expect it to
DEALING WITH CARRIERS WHO ARE ACTUALLY take a year or two, probably more like
UNSAFE — BASED ON REAL SCIENCE two, before that information (CSA SMS
rankings) will be posted back up,” Foxx
continued.
Some might have assumed that
FMCSA would hold off on issuing the
proposed SFD rule until those defects
cating how safe a carrier was; the fact three categories. So, carriers would be were addressed. Those people would
that “administrative” types of violations assumed to be operating in compliance, have been wrong.
in one category could carry the same i.e. “satisfactorily”, but there would be Comments to the SFD proposal
severity weighting as a more egregious no public indication as such, until or came quickly from the industry, with
“unsafe behavior” violation in another; unless the carrier fell out of compliance, opposition centering on two primary
and, that all crashes – even those at which time the “unfit” label would concerns:
deemed non-preventable – were counted be applied.
against a carrier. Motor carriers could find them- 1. SFD is directly tied to CSA which
Despite the objections, the agency selves unfit through one of three differ- has been pulled offline until
continued to push the program forward, ent methods under the SFD proposal: reformed and should wait until
making periodic tweaks to the method- such reforms are completed.
ology, but not addressing the underlying Unfit Method 1: Carrier with two or
concerns. more failed BASICs from On-Road Safety 2. SFD is ineffective in using data to
Eleven days after the CSA program Performance leverage the limited resources at
began, the Agency began socializing a A reminder for readers that BASICs are the Agency’s disposal.
new concept that would redefine the the seven categories into which FMCSA
“safety rating” process, which ultimate- grouped similar violations at the start My company, Vigillo, has spent the
ly allows trucking companies to operate of the CSA program. This method ties past seven years collecting and ana-
— or not. directly into and makes the most use of lyzing CSA-related data and the CSA
Under the existing process, safety CSA data. methodology on behalf of over 2,000
ratings fall into three categories: satis- motor carriers, freight brokers and ship-
factory, conditional, or unsatisfactory, Unfit Method 2: Carrier with violations pers who subscribe to our CSA reporting
and are largely if not solely derived from of the revised critical and acute regulations service(s). In our comments to FMCSA
on-site Compliance Reviews (CRs). But identified through an investigation regarding the proposed SFD rule, we
with a ratio of almost 500 motor carri- Simply put, this method would make use limited our input to Unfit Method 1
ers for every one FMCSA employee, very of the most severe violations as determined (data from roadside inspections). Since
few CRs are actually conducted. This by FMCSA. the inception of CSA, a critical justifi-
has led to the majority of the industry cation of CSA itself was that the data
being classified as “unrated”, and many Unfit Method 3: Combination of would be an effective method of focus-
carriers having had the same “satisfac- inspection data and investigation results ing enforcement effort on those motor
tory” rating for years with little or no carriers deemed to be riskier, so our
interaction with FMCSA. But a month before the Agency analysis focuses on whether SFD in fact
Enter the Safety Fitness announced the proposed rule, a lit- accomplishes that long stated goal.
Determination (SFD). eral act of Congress, grounded in the As the starting point for our
In January, five full years after CSA long-standing concerns of the trucking comments, we posed the question:
launched, a new SFD rulemaking was industry, ended the public view of CSA Does the data driven component in this
finally proposed by the FMCSA. scores (at least temporarily), and man- SFD (Unfit Method 1) give FMCSA and
The proposal introduced a single dated FMCSA address the significant its enforcement partners insight into a
rating of “unfit”, replacing the previous defects in the system before making meaningful number of high risk motor car-

34 Issue 3 2016 | ARKANSAS TRUCKING REPORT