CSA, as the regulation is called, started to take effect last year and already is beginning to reshape the trucking landscape. Some in the aftermarket believe it will have a similar impact on their businesses.
"If you don't know CSA, you can't help your customers," says Gordon Botts, president of Botts Welding and Truck Service, Chicago. "CSA services are more than a way of differentiating yourself from the competition. They are about survival."
Botts and others are gearing up an effort to raise the awareness of CSA among aftermarket service providers. That's in part because CSA will dramatically affect the way trucking companies conduct their business - especially the way they maintain their equipment - and in part because CSA creates an opportunity for service providers to strengthen their ties to their customers.
CSA, which stands for Compliance, Safety, Accountability, is an information-based regulatory system devised by the Federal Motor Carrier Safety Administration, the branch of the U.S. Department of Transportation in charge of truck and bus safety.
Its purpose is to reduce the number of fatal crashes by measuring key performance characteristics and grading trucking operations on how well they do compared to their peers. A carrier that is not up to snuff will get a warning letter to start, but if its performance does not improve, the pressure increases through varying degrees of inspections to costly fines and possibly being placed out of service.
The performance characteristics targeted by the system cover all aspects of trucking operations that are related to safety. They are divided into seven categories, called BASICs (Behavior Analysis and Safety Improvement Categories):
- Unsafe Driving keeps track of behaviors such as speeding, not using a seat belt, not obeying traffic signals, following too closely or improper lane changes.
- Fatigued Driving tracks violations of the driver hours of service rules. These range from false reporting on a driver log and failure to keep logs current, to exceeding driving limits or a company requiring or allowing a driver to break the rules.
- Driver Fitness tracks a wide range of requirements such as having a proper medical certificate or driving without a commercial license, to not being qualified to drive or not being able to speak English.
- Controlled Substances/Alcohol tracks violations such as driving under the influence and possessing drugs.
- Cargo Related tracks things such as cargo tie-down and placarding.
- Crash Indicator tracks a carrier's history or patterns of crash involvement, including frequency and severity.
- Vehicle Maintenance tracks the full range of equipment issues, from whether or not the lamps are working to the tread depth on the tires.
Each of the dozens of individual elements within these BASICs are ranked according to their significance in relation to safety - speeding is ranked higher than the driver not having a copy of his medical certificate, for example - and recent violations are given more weight than older violations. The data is gathered from roadside inspections and state police reports, as well as information the carriers are required to keep.
What emerges from this complex assessment is a series of percentage rankings in each of the BASICs for each carrier. Some of these rankings are posted on the CSA page of the FMCSA's website for anyone to review. If a carrier's ranking exceeds a standard set by the FMCSA, the agency starts enforcement actions.
The CSA program is unfolding in stages. The initial stage started late last year, and already the safety agency has sent out 23,000 warning letters. This year the state departments of transportation and highway patrols will work through the changes they need to make in order to implement the new system. And later this year the agency will propose a new rule designed to implement the last phase of the program, a process that is likely to take a year or more to complete.
So what does all this mean for aftermarket service providers? Start by looking at the impact on the industry's customer base - the trucking companies. For them, CSA is a game-changer.
CSA digs more deeply into a carrier's performance than the old system, and it requires better performance at every level. And it's not just the risk of enforcement action that is getting carriers' attention. The carrier's performance information is available to the public, which means shippers and insurance providers are paying close attention.
Steve Williams, chairman and CEO of Maverick Transportation, Little Rock, Ark. recently told FMCSA Administrator Anne Ferro how CSA is affecting his company.
"I have many shippers who always said I'm too expensive ... that are walking in the front door saying all the jack-leg (carriers) we've been using for the last 20 years we know are not going to make it, so we'd like to align ourselves with you," he told Ferro.
Williams was referring to the way CSA forces trucking companies to take their safety compliance efforts to a whole new level.
Under the old safety system, FMCSA limited its analysis of roadside inspection data to violations that result in out-of-service orders. But under CSA, all safety violations are included. This means violations that used to be statistically insignificant will now carry significant weight - a point of considerable importance to truck maintenance professionals.
Another carrier, Frank Molodecki, president of Diversified Transportation and Storage in Billings, Mont., put it in down-to-earth terms.
"In the past we may have said, 'OK, it's just a missing mud flap. We're still legal to run, it's not an offense that will shut us down,'" he said. "But now it's something that gets taken care of immediately because it's going to count against us."
Formerly, it was more of a don't-get-caught type of thing because you were focused only on the big, out-of-service defects, Molodecki said. "Now that they are looking at everything, you have to anticipate what can really happen in an inspection, and target training, education and communication with drivers, to see that you are focusing on those things. I think that's a positive development for our industry."
Trucking companies also are learning that one of the most important elements of a successful CSA compliance program is a careful pre-trip and post-trip inspection by the driver, and then following up by paying close attention to the Driver Vehicle Inspection Report (DVIR).
Richard Jenkins, vice president of safety and loss prevention for James Brown Contracting, Lithonia, Ga., recalled having an FMCSA auditor going through a handful of DVIRs that showed no deficiencies. "His comment was, 'Well, I guess your trucks don't have any maintenance issues.'"
But then the auditor compared the DVIRs to reports from roadside inspections and found inconsistencies that could lead to citations.
"You need a way for drivers to report deficiencies in vehicle safety to you immediately," Jenkins said. "The rules require you to fix the safety defects on the DVIR. If you don't, the roadside inspector becomes the enforcer, and you run the risk of fines that exceed the cost of repair and being placed out of service, not to mention getting higher CSA scores."
What it means to you
These issues have major implications for independent aftermarket servic