Planning for Accountability

Comprehensive Safety Accountability 2010 (CSA 2010), previously known as Comprehensive Safety Analysis, is designed to reduce large truck and bus crashes, injuries and fatalities. The Federal Motor Carrier Safety Administration (FMCSA) introduced the initiative to improve the effectiveness of the agency’s compliance and enforcement program.

The program has had encouraging results. According to the Institute of Scrap Recycling Industries (ISRI), Washington, D.C., the rate of commercial motor vehicle fatalities has begun to level off since the initiative began. Figures from the Motor Carrier Management Information System (MCMIS) point to a modest reduction in fatalities from 2009 to 2010. According to (MCMIS), 3,359 large trucks were involved in fatal crashes in 2009. In 2010, that number had declined slightly to 3,285.

Making certain a fleet is prepared to comply with the FMCSA’s CSA 2010 requirements can be an undertaking. Recyclers who also oversee transportation operations can take several steps to ensure their drivers are in compliance.
 

Where to Start
Commodor Hall, ISRI transportation safety manager, suggests the best place to start is to “learn all you can about the Federal Motor Carrier Safety Administration’s safety rules and regulations.”

Additionally, fleet managers should know what the CSA 2010 Behavior Analysis and Safety Improvement Categories (BASICs) are and fully understand what they mean. BASICs are the categories the FMCSA uses to assess safety.

“It’s a good idea to brush up if you are unsure about the program. You’ll find this information at the CSA 2010 website (http://csa.fmcsa.dot.gov/default.aspx) along with the new Safety Measurement System (SMS),” Hall says.

CSA 2010 has been modified since its inception, and carriers can expect updates to continue in the future. For example, the FMCSA eliminated size and weight violations from the cargo related BASICs when the initiative was updated in August 2010. This means such violations will not be included in carrier and driver CSA scores.

The time to think about safety is before the trip even begins, Hall suggests. He says companies should perform annual inspections to ensure all vehicles are in working order and should instruct drivers to complete comprehensive inspections prior to each trip. Safety training should be a top priority for everyone at the company. By involving drivers in as much safety training as possible, Hall says, proper procedures will stay fresh in their minds. Also, it is important to enforce that employees only drive within the company’s hours of service. Companies should monitor their drivers’ hours of service for violations, Hall suggests.

A number of resources are available to transportation managers and drivers, and he suggests becoming familiar with them. Organizations like ISRI and the FMCSA offer regularly updated information through their respective websites.

Hall adds, “The FMCSA updates regularly on the CSA 2010 website, so be sure to visit the site often. You will find a plethora of resources to help answer any questions you might have. The CSA website has many documents, including fact sheets, explanations and rules.”

Companies should understand what a CSA 2010 violation can mean for them. For instance, violations that occur while a driver works for a company remain on the company’s record for 24 months, but violations the driver incurs after he or she has gained employment elsewhere do not affect the previous employer.
 

Have a Plan
The most common violations include requiring a driver to drive after 14 hours on duty, failing to keep a driver’s log current, operating outside service hours and speeding—which is cause for being stopped for inspection. Other violations Hall says he sees frequently include brake connections with leaks or constrictions, tire tread depth of less than two-thirty-seconds of an inch and defective or no lighting devices.

Hall says violations like speeding and reckless driving can be avoided with proper defensive driver training. He recommends a video series called the “Smith System” (www.smithsystem.com). Training of this nature needs to occur regularly, and managers should to communicate to their drives that these violations can affect their CSA drivers’ scores and eligibility, he adds.

Hall says there are seven basic inspection points a company should comply with. This checklist includes:

• Driver Fitness – Drivers’ licenses and medical cards should be checked on periodically.
   
• Unsafe Driving – Company-wide im- plementation of reoccurring defensive driver training can deter unsafe driving behavior. Hall suggests making employees aware that corrective action will be taken for unsafe driving behavior.
   
• Fatigue Driving – Drivers should be provided training in Hours-of-Service regulations. Companies should monitor drivers’ Hours of Service and restrict drivers from driving after 14 hours, Hall advises. More information on Hours of Service guidelines can be found at www.fmcsa.dot.gov.
   
• Controlled Substances/Alcohol – Companies should make sure they comply with all drug and alcohol requirements, such as pre-employment testing, random testing and post-accident testing. Managers should be trained to recognize alcohol and substance abuse, he suggests.
   
• Crash Indicator – Companies should implement an accident prevention program to deter serious Department of Transportation (DOT) recordable crashes, Hall advises.
   
• Vehicle Maintenance – Companies should require drivers to perform proper pre- and post-trip inspections, make sure annual inspections have been performed on their equipment and comply with all roadside inspections pertaining to correcting vehicle defects.
   
• Improper Loading/Cargo Securement – Management should instruct drivers on how to properly secure cargo. For example, Hall says, drivers should know how to properly secure and chain containers. Companies also should provide automatic tarping devices for roll-off container vehicles. Also, drivers should be instructed on how to properly block, brace and strap cargo. Management also should educate drivers on how to use netting and netting equipment to secure loose cargo, he suggests.

CSA 2010 is here to stay, and carriers who are well-informed and willing to comply with its regulations can save themselves a lot of headaches. Developing and implementing a safety plan is the first step.

The author is assistant editor of Recycling Today and can be contacted at kstoklosa@gie.net.