USDOT’S CSA program reviewed by Congress

Earlier this month, the Government Accountability Office released its findings on the U.S. Department of Transportation’s Compliance, Safety Accountability program, known as CSA.

I have written many times about this important enforcement program since it is the principal way DOT uses safety data to identify motor carriers that may be unsafe operators. Companies that ignore or that have minimal understanding of CSA risk being surprised by an enforcement intervention or when customers say that a carrier’s poor scores jeopardize ongoing customer orders.

The GAO performed this review at the request of Congressional members who received complaints that the CSA is flawed in identifying the truly at-risk companies and that small operators were largely getting a “pass” since the government’s databases have little or no performance data about them.

What the GAO concluded was that CSA has been able to improve carrier compliance by allowing enforcers to make earlier contact with companies needing improvement. This is done mainly by warning letters and governmental reviews that focus on the specific area of non-compliance. For example, if a carrier’s CSA scores show a pattern of non- compliance with keeping medical cards up-to-date, FMCSA or its state counterparts would focus its attention on that problem and not expand its review to include, say, hours of service issues (assuming those scores were satisfactory.)

The GAO concludes that CSA ‘s Safety Measurement System (SMS) could be much more effective if it were revised to satisfy the major complaints leveled against it, i.e., that the data collected on carriers does not  have a strong enough predictive ability to link non-compliance and the increased risk of crashes with several of the 7 CSA measures.

For example, in the medical card example I gave above, if a driver has an expired medical card it suggests there may be problems in a carrier’s internal safety monitoring systems that make it unable to flag when a driver has to be re-credentialed. But, does the violation suggest that driver is at increased risk of crashing? Probably not. But as someone who was directly involved in the design of the CSA program, the 7 measures that constitute CSA were intended to be both related to increased crash risk
(prior accidents and unsafe driving being the strongest links), but also the extent to which companies pay attention to their general regulatory obligations. A company that has a poor record manifested by violations received for  expired medical cards,  unsafe driving , or which has crashes disproportionate to their size and road exposure, etc., is probably a company with more deep-seated safety issues. The prior enforcement system DOT used did not have the ability to drill down and uncover these other behavioral traits. CSA does provide this increased ability to assess overall compliance.

Capturing data on small operators

The second area in which CSA needs to be improved, according to the GAO report, is finding a way to capture roadside and crash data on small companies and certain owner-operators since the likelihood of a roadside inspection or other event precipitating a data-generating entry into the SMS is very low with small or single vehicle fleets. This is a more difficult challenge given that using CSA to interdict and intervene with known problem carriers that have sufficient performance data commands priority attention by the enforcers. The government is in a conundrum since it risks criticism if it fails to intervene with a “known” high-risk carrier before that carrier has a crash, but lacks the resources needed to compile a complete profile on all of the carriers under its jurisdiction.

The truck and bus industries want CSA to be better at identifying companies likely to be involved in a crash sooner rather than later. The CSA system‘s design does give greater credence to the stronger predictive measures so it will be interesting to see where CSA goes from here.

I urge you to read the Feb. 3 GAO Report since I am only able to offer a brief glimpse here. As I have often stated, companies should work to understand CSA and should monitor their own carrier profile scores regularly.  In my work with motor carriers, I frequently encounter companies that know very little about CSA and how it impacts their operations.

As DOT moves to link the CSA scores with an overall safety rating scheme in a proposed rule coming later this year, carriers need to get their “house in order” now in order to establish an acceptable level of safety performance. Coming soon will be a proposed rule establishing a new safety rating scheme based, in large part, on the CSA data. While this report provides useful insights into this critical safety program, it will be up to DOT to consider whether the GAO’s findings will prompt changes in the CSA methodology.

For more information about CSA, contact Rose at info@fdrsafety.com or 615-370-1730.