The American Trucking Associations supports Comprehensive Safety Analysis 2010 but has concerns with its current design and how these flaws will affect the industry and highway safety if not corrected, an ATA representative testified Wednesday, June 23, before a U.S. House subcommittee.
In testimony before the House Transportation and Infrastructure Subcommittee on Highways and Transit, Keith Klein said ATA fully supports CSA 2010’s objectives of targeting unsafe operators, changing their behavior and removing the most egregious actors from the road. Klein said ATA also supports the CSA 2010 initiative because it is based on safety performance rather than compliance with paperwork requirements; it focuses limited enforcement resources on specific areas of deficiency, rather than on comprehensive onsite audits; and it eventually will provide real-time updated safety performance measurements.
“All three of these attributes address longstanding problems with the Federal Motor Carrier Safety Administration’s current monitoring and enforcement program,” said Klein, executive vice president and chief executive officer of Transportation Corporation of America. “FMCSA deserves to be applauded for its development and implementation of CSA 2010 to date. The agency has gone to great lengths to test the program, develop and implement an extensive outreach and education program, and demonstrated a willingness to accept stakeholder input.”
However, Klein said ATA has a number of serious concerns relating to how CSA 2010 will work that, if not addressed, will have a dramatic impact on motor carriers and on highway safety. To address the primary concerns with CSA 2010, ATA recommends that FMCSA:
• Make crash accountability or “causation” determinations on truck-involved crashes before entering them into a carrier’s record so drivers and carriers are held accountable only for crashes they cause;
• Use vehicle miles traveled (VMT), not number of trucks or power units, as a carrier’s exposure measure; and
• Focus on using only actual citations for moving violations and not unadjudicated “warnings” issued by law enforcement.
The intent of raising these concerns is twofold, Klein said. “The first is a matter of safety, to ensure that unsafe carriers are selected for interventions, and the second is a matter of equity, to ensure that relatively safe carriers are not selected for interventions,” he said.
Klein said that in addition to the primary concerns, ATA also is concerned about how the severity weights for violations are assigned; measuring carriers based on violations committed by drivers who since have been terminated; measuring carriers based on citations that have been dismissed in a court of law; inequitable measurement of open deck or flatbed carriers; overly broad peer groups; and inconsistent state enforcement practices.
