As part of its ongoing effort to improve CSA 2010, ATA submitted a comprehensive letter to FMCSA, Nov. 29, suggesting additional changes to the Agency's evolving program.


In the letter sent to the Federal Motor Carrier Safety Administration, ATA's manager of safety and security operations, Boyd Stephenson, urged the agency to hold off on full implementation of CSA 2010 until certain deficiencies in the rating system are ironed out.

Among the difficulties ATA has with the current plan is that many violations are inappropriately high in relation to their crash causation likelihood. By extension, carriers saddled with certain violations might be branded unsafe in the public's eyes.

"Until FMCSA can confirm that the system accurately identifies unsafe carriers in a category, it is inappropriate to make carriers' scores in that category publicly available, as they may erroneously label safe, responsible carriers as unsafe," Stephenson notes in the letter.

ATA did commend the Agency for redacting the Cargo-Related BASIC from public view in the CSA 2010 web tool until that BASIC score can be more effectively calibrated to crash risk.

ATA is also urging FMCSA to add industry representation to the panel that determines the severity of given violations.

"We believe that if the CSA 2010 methodology incorporates subjective input, it should be from as broad and experienced a sample of individuals as possible," the letter states. "The agency can certainly benefit from the experience and perspectives of industry professionals."

ATA says it's quite concerned about the subjective nature of some of the severity ratings, and has made suggestions for possible modifications to the SMS rating that would, in ATA's opinion, reflect actual crash risk, not anecdotal experience and subjective viewpoints.

Among ATA's proposed changes are several HAZMAT-related violations that don't seem to bear any direct relationship to crash propensity. ATA is suggesting these be down-rated from five points to one or two points.

Others from the Cargo Related BASIC carry a score of 10, but the association points out the infractions are vague and the severity does not account for minor problems that don't necessarily make the carrier unsafe. For example, 392.9(a)(2); failure to secure vehicle equipment. ATA says this violation is too broad to hold the highest severity weighting. It could be taken to include oil or windshield washer jugs sitting atop fuel tanks and held in place with bungee straps.

ATA says its letter is a good faith effort to improve the CSA 2010 program in lieu of including industry in the actual discussions. Enforcement officials were given an opportunity to recommend higher and lower suggested violation severity weights in a final review stage of the CSA 2010 methodology - an opportunity that was denied to motor carriers.

"ATA seeks to remedy that lack of equity and represent a good faith effort to improve the CSA 2010 program. Members of ATA's CSA 2010 Working Group recommend both lowering and raising some violation severity values," the letter states in a closing paragraph. "We urge the Agency to consider these recommendations with the same weight as was given to our enforcement partners. After all, safety is a shared goal between industry and government."

Click here to read a copy of ATA's letter to FMCSA.