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 An interview with a trucking company in one of the CSA 2010 test states that has asked to remain anonymous, due to an ongoing intervention.
First, a little history on the company:
Under the current SafeStat rating system, the company had an excellent safety rating with few safety issues or fines. Now their ISS-D inspection score is deficient enough that they are on the DOT radar.
Since the new Safety Measurement System (CSA) has been activated this company is now enduring their second intervention since October 2008. The first intervention was the result of a reportable accident that resulted in the companies drivers/trucks being under "Targeted Roadside Inspections".
The "Targeted Roadside Inspections" intervention has resulted in the second intervention "On-Site Investigation" now in its second week. This has cost the company thousands of dollars in fines and extra hours in preparing for the "On Site Investigation"
Both interventions were the result BASIC violations by drivers. The company took actions and let the drivers go, however this did not have any effect on the intervention process. The company’s ISS-D inspection score remains deficient..
When a company is under an intervention, the DOT has pre-set steps they must follow and enter into the COMPASS collection data system. If your company is targeted for Roadside Inspections the pre programmed inspection must be followed and all data must be entered. It is a well-known fact that if someone looks hard enough, they are likely to find some small violation with any truck on the road.. This then, leads to continued Targeted Inspections resulting in more violations, more repairs, more driver down time, and more time working through the compliance steps
The same for On Site Investigation and from what this company said "This is NOT a Friendly Environment for Carriers".
I was also informed under CSA 2010 there are no distinctions between preventable and non-preventable accidents in the intervention process. An accident is an accident, which can lead to interventions, as it has for the company interviewed here.
Please keep in mind that the company’s "history" or last 36 months of Driver/Truck data has been entered into the COMPASS system. The company safety director feels this could be a factor in their first intervention, which has continued to snowball.
There also seems to be some confusion about formulas for how violations are weighted, even the inspectors were unable to fully explain exactly how the components actually work that triggers an intervention. FMCSA has published the formulas for how violations are weighted and calculated. The published information is that violations that occur in 12 months or less would have the points doubled. Violations in the 13 to 24 month range would points assigned to that violation. It was discovered during the "On Site Investigation" FMCSA was using a different weight formula. 0 to 6 months would be triple the point value, 7 to 12 months would be double and 13 to 24 months would be the assigned points. So, the actual formula being used is different from what has been posted to date and the new formula is much more aggressive and can trip the intervention process much easier than expected.
A few additional things I took from the conversation were:
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CSA 2010 initiative IS GOING TO HAPPEN and it will affect everyone.
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Although the drivers will be given a safety score under CSA 2010 and they will likely be the trigger for most interventions, the carrier still pays a heavy price.
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Carriers will be paying more in fines than ever before.
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Carriers MUST begin a measurable Driver Safety Training program TODAY as all DOT driver/truck data happening today will be entered in COMPASS for your Safety Rating Score in 2010.
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This process is comparable to an IRS Audit. It’s not something any Carrier wants. Once on the radar it is a tough process to get out of. As our interviewee stated, the New CSA 2010 "Is NOT a Friendly Environment for Carriers".
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