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 at https://csa.fmcsa.dot.gov.
Hazardous Materials (HM) Compliance BASIC
The SMC job aid for the Hazardous Materials (HM) Compliance BASIC indicates that the following Policies and Procedures should be in place:
- Management should develop a security plan according to regulations. This includes the requirement for appropriate security awareness and in-depth security training.
- Management should develop procedures addressing regulatory requirements for HAZMAT-transportation registration, recordkeeping, packaging, securement, marking, labeling, placarding, reporting, documentation, security, and emergency response.
- HAZMAT employees and other designated personnel should be provided with procedures to conduct effective verification, certification, and sequencing of documentation, packaging, marking, labeling, placarding, and inspection tasks.
- Management should develop procedures for testing and inspecting cargo tanks according to Federal and State requirements and for preparing the appropriate reports and marking requirements. Appropriate tests include external visual, leakage, internal visual, thickness, lining, and pressure.
- Management should develop procedures for accepting and assigning HAZMAT loads to drivers and for establishing delivery schedules to meet safety and security-risk-related objectives.
- Management should establish procedures for coordination of regulatory controls among commercial entities involved in HAZMAT shipments.