Anne Ferro, administrator of the Federal Motor Carrier Safety Administration, has written a letter to the American Trucking Associations outlining the agency's plans to address some the group's concerns over the upcoming Comprehensive Safety Analysis 2010.

Rob Abbott, the ATA's vice president of safety policy, called Ferro's letter "a good sign."

"She listened and appears to be taking some positive steps to addressing these" concerns, he said.

The ATA is pleased and encouraged that the FMCSA is having an open dialogue about the safety program, but they'll have to wait and see what changes are made before CSA 2010 is implemented in November, Abbott said.

Ferro's letter was a response to a Feb. 26 letter by Dave Osiecki, ATA's senior vice president for policy and regulatory affairs, highlighting three of the group's main concerns over the program.

Crash Accountability

The biggest problem, according to the ATA's letter, is the system's inability to assign fault for crash data that gets put into the system. Crashes will show up in a carrier's record, whether or not the carrier is at fault.

"This is a huge problem since the majority of serious truck-involved crashes are multi-vehicle crashes involving cars, many of which are caused by the driver of the other vehicle," Osiecki wrote in the letter.

The ATA recommended the use of a "crash evaluation team," which would include 13-15 people who would follow FMCSA standards for crash evaluation.

The FMCSA said it would consider several short- and long-term approaches to address this issue. In the meantime, it will exclude crash assessment from any public web sites that may be viewed by shippers and insurers, and it will consider accountability of crashes before issuing any final fitness ratings.

Over the long term, FMCSA said it will evaluate ATA's recommendation, and has already done some analysis in this area. Ferro also pointed out that the initial results of its feasibility study have shown the use of police accident reports (PARs) to be a viable option for determining accountability. The challenge, however, is getting those reports from the different state agencies involved, Ferro said. One option would be to require fleets to submit PARs for those accidents in which they seek accountability determination.

Abbott believes the FMCSA is headed in the right direction with its evaluation.

Mileage Data

ATA's second concern is FMCSA's use of a carrier's number of power units, rather than vehicle miles traveled as a measure of exposure.

"Motor carriers who employ greater asset utilization will have more actual exposure to crashes and other safety-related events, but will be compared to carriers who have less exposure-though the same or similar number of trucks," said Osiecki in his letter.

The ATA recommended making the mileage field mandatory on the MCS-150 form, and that FMCSA consider using an "average annual miles per truck" estimate for those carriers for which FMCSA does not have up-to-date mileage information.

The FMCSA letter agreed in part, but the agency does not believe mileage data should be the sole determining factor. The letter points out that VMT would put certain segments at a similar disadvantage, such as those fleets that operate limited mileage. However, the FMCSA has agreed to make the mileage field mandatory.

Warnings

The last concern ATA expressed is that CSA 2010 counts all alleged moving violations on roadside inspection reports, whether a citation was issued or not. The issue here is that warnings and notices are counted and scored the same as a citation. The association said warning and warning tickets should not be used under CSA 2010 initially. ATA suggested this information be maintained by FMCSA and evaluated to see if further action needs to be taken.

Abbott said the FMCSA did not address what severity weighting warnings will be given, but it will designate the severity of speeding offenses recorded on road inspections. For example, the roadside inspection report will say whether the violation was 1-5 mph over the speed limit, 6-10 mph over, etc. In addition, the FMCSA will consider adding a simple Yes/No field to inspection reports to determine whether a citation was issued.

Abbott said the move to address the warnings issue was a good first step, and adjusting the weighting of warnings is the next step.

While the ATA is supportive of the CSA 2010, they will "continue to advocate means to improve the program," so that it targets unsafe carriers, a shared goal of the two organizations, Abbott said.

To access Ferro's letter, go to http://csa2010.fmcsa.dot.gov/documents/ATAletter-4-16-10.pdf.