CSA 2010 POINT SYSTEM
Jason did a great job explaining and linking the point system which will be used to score drivers under CSA 2010. Many of you, including Milt in the blog, have asked how many points do you get under this system. I think that’s a pretty good question and one that we need to spend a little time with.
First, we have not yet received any guidance from the FMCSA on that part. The driver register which carriers were supposed to be able to access in December has not yet been released, so we don’t know whom they will consider unfit under the CSA 2010 scoring. Second, whatever they decide, it is important to note that those will be minimum standards and motor carriers, under the regulations, are allowed to set tougher standards.
For example, Mercer has tougher medical standards than are required under the regulations. Our policy of “ four strikes and you’re out” in regards to preventable accidents and moving violations won’t be found anywhere in the regulations, either. Nor will inspecting our trucks every six months. Likewise with a truck dress code and a 25 year old age requirement for drivers. Our standards are high, and each of our drivers and each of their trucks have met, and continue to meet, Mercer’s high standards. Or they truck someplace else.
How do these standards get determined? Basically, there are there are five things that are considered in every aspect of our Safety Policy: 1) What is required by and compliant with the Federal Motor Carrier Safety Regulations? 2) What is our insurance company comfortable with? 3) What are the industry standards and accepted practice of our peer group? 4) What do we feel can be successfully defended in accident litigation? 5) What is the collective value system of our owners and management? All of these play a part and are considered.
This is the process I am currently using to evaluate what will be Mercer- acceptable scores under CSA 2010. In addition to the current policy concerning moving violations and accidents, which will remain, there will need to be an additional part to address the CSA 2010 point thresholds for warning, probation and termination of lease. Several things are involved in doing this.
Obviously, I am looking at the CSA 2010 scores of our drivers, since I have our SafeStat data formatted into the new system. I am comparing drivers’ point scores with their current safety status under our existing system to get a handle on any patterns that emerge. Frankly, folks that have a problem under our current system with moving violations and accidents are probably going to have the same problem under CSA 2010. Folks who are required to come to Louisville as a result of OOS inspections or for log problems are also going to have a problem under CSA 2010. Probably a worse one. With the help of a bunch of great people in Safety, Claims and Truck Operations we are wading through the data to see what appears to be the norms for our fleet and what we can live with.
In addition, I am in touch with our insurance company and have meetings scheduled. We have an excellent relationship and stay in regular contact. Their feelings will have great weight in the process. In April, I will attend the annual CVSA/FMCSA leadership meeting in San Antonio. We expect the FMCSA to provide many more details on CVSA 2010 and other issues (ie hours of service and BMI) during that time. Likewise, I will attend the annual Truckload Carrier Association’s Safety and Security conference this May in Kansas City. The FMCSA will again have presentations and workshops. More importantly, three hundred or so safety directors will be together discussing how to apply CSA 2010 to their respective fleets. As a result, we will have a better idea as an industry what the acceptable practices will be. It is never a good idea to wait for the FMCSA to tell you what you can merely get away with.
Next month I am attending a legal seminar in Houston for safety directors and their attorneys concerning CSA 2010. We should get some insight into how the plaintiff bar is viewing this and what our appropriate defenses should be. This will be extremely important in determining an acceptable point standard.
This is the process involved and pretty much the timeframe. I am hesitant to jump into establishing a point system too quickly as I don’t want to eliminate folks now that may be in the process of improving their scores. We do have several more months and most of our drivers have time to get their house in order with clean inspections. I want that to happen. And I want to be fair.
In the meantime, my best advice is to get clean inspections. Today, tomorrow, as many as you can. In particular, don’t get written up for speeding, log violations or securement violations. Those are the ones that will hurt you the most. Remember, just the writeup alone does the damage. If these things are problems for you, now is the time to change your habits. I appreciate everyone’s thoughts and comments. Be safe.