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.
Driver Fitness BASIC
The SMC job aid for the Driver Fitness BASIC indicates that the following Policies and Procedures should be in place:
- Management should perform a periodic review (at least twice per year) of driver qualification files. Reliance on third-party sources, such as insurance agencies, is not sufficient. Management should make certain: all documents requiring renewals are in place; drivers are reminded of the expiration dates on medical certificates, in order to schedule another physical examination in advance; and documents related to driver qualifications have not been falsified.
- Drivers should submit copies of all vehicle and roadside inspections and moving violations to management within 24 hours. Drivers should notify management of suspended or revoked Commercial Driver’s Licenses (CDLs) immediately following notification of suspension/revocation.
- All new (since 2003) CDL drivers should submit documentation of entry-level driver training, including driver qualification requirements, Hours-of-Service, driver wellness, and whistleblower protection. Alternatively, CDL drivers should take entry-level training provided by management.
- Management should assure that document retention and recordkeeping are appropriate for all circumstances, including documents that should be in the possession of drivers as proof of credentials.
- Management should assure that operations are always conducted with the proper amount of fit drivers and address issues such as sick leave, vacation, training, suspension, and termination.