Apex Encourages Motor Carriers to be Attentive to CSA Scores While CSA Debate Continues
Apex Capital supports the Alliance for Safe, Efficient and Competitive Truck Transportation (ASECTT). ASECTT is a group of shippers, carriers, brokers and allied industry participants calling for a critical analysis of the FMCSA’s Compliance, Safety, Accountability (CSA) program, and a step back from its current use until that analysis is complete.
According to the ASECTT website, ASECTT’s members “are concerned that while CSA’s SMS methodology is a work in progress, portions of it have been released to the public without proper vetting, including but not limited to, the most basic scientific and statistical studies necessary to justify a nexus between the compliance violations measured in each of the so-called 7 BASICs and crash predictability.”
Apex shares ASECTT’s concerns. But while the CSA debate continues, obtaining and maintaining favorable CSA scores will remain important to motor carriers. For that reason, Apex launched a series of eight blogs on February 6, 2013 regarding the seven CSA Behavior Analysis and Safety Improvement Categories (BASICs) to encourage clients to be attentive to their CSA scores.
The FMCSA recently released new materials intended to assist motor carriers in identifying and addressing their safety and compliance issues. These materials include seven Safety Management Cycle (SMC) job aids originally created for agency enforcement personnel. There is one job aid for each of six of the BASICs and two for the Vehicle Maintenance BASIC: “Inspection-Repair-Maintenance” and “Cargo-Related.”
Establishing proper Policies and Procedures is the first step a motor carrier must take to utilize the SMC job aids to enhance CSA scores. This is one of a series of eight releases listing the Policies and Procedures a motor carrier should have in place as indicated by the SMC job aid for a specified BASIC. To learn more about the SMC job aids, and a full SMC analysis performed by FMCSA safety investigators, please visit the Resources page on the FMCSA’s CSA website.
Controlled Substances/Alcohol BASIC
The SMC job aid for the Controlled Substances/Alcohol BASIC indicates that the following Policies and Procedures should be in place:
- All regulations regarding controlled substances and alcohol use, testing, training, and records retention for all employees should be incorporated into a written policy.
- Drivers should submit copies of all citations for moving violations to carrier management within 24 hours.
- Drivers who are randomly tested should be immediately removed if they are found positive and they should not return to safety-sensitive duties until they have complied with a “return-to-duty” process.
- Management should promote, verify, and enforce adherence to all controlled substance and alcohol rules and regulations. Procedures should be tailored to company operations and should provide specific checks and guidelines to ensure adherence.
- Management should ensure that test results are properly safeguarded from unauthorized disclosure to prospective employers without specific written consent of the tested individual. Safeguards also apply to disclosure under any circumstances to insurance companies and other nonqualified parties in accordance with regulations.
- Management should ensure that all alcohol testing is conducted immediately before or after the period that employees are performing a safety-sensitive function. Drivers can be tested on their day off only for controlled substances. Once notified of their selection, drivers should be required to proceed immediately to the testing facility. If a driver refuses to go, this should be considered as equivalent to a positive result.
- Management should consider developing a driver selection protocol that uses valid random-number generator software on a monthly basis to select, by driver identification number, 5 to 8 percent of drivers for controlled substance testing and 2 to 5 percent for alcohol testing. This will ensure selection of 50 percent of drivers for controlled substances testing and 10 percent for alcohol testing per year given fluctuations in the driver workforce.