CSA 2011 UPDATECSA 2011 UPDATE

FMCSA UPDATE

COMMITTEE UPDATE

INDUSTRY/FINANCIAL IMPACT

MAIN TAKE AWAY

UNDERSTANDING CSAUNDERSTANDING CSA

BEFORE WE DISCUSS CSA, WE MUST FIRST UNDERSTAND THE SCOPE OF WHERE THE AGENCY IS GOING AND WHAT MIND SET THEIR OPERATING IN.

CSA “ 3 PRONG CSA “ 3 PRONG APPROACH”APPROACH”

SYSTEM: MANAGEMENT CONTROL FEATURES (CAN’T MANAGE WHAT YOU CAN’T MEASURE)

PROCESSES: TAKEN ACTIONRULES: ASSIGNING RATING

FACTORS AT ROADSIDE

SYSTEM: PROJECT “SCORESYSTEM: PROJECT “SCORE””

FMCSA Believes that SYSTEMS ARE ONLY EFFECTIVE IF “MANAGEMENT CONTROL FEATURES” ARE PUT INTO ACTION AND FOLLOWED THRU OUT THE ORGANIZATION. MANGEMENT CONTROL FEATURES, SET THE MATRIX BY WHICH PERFORMANCE IS MEASURED. BEFORE YOU MEASURE, YOU MUST SET A GOALACHIEVING YOUR GOAL, YOU NEED A BENCHMARKSETTING A BENCHMARK, REQUIRES A “NUMBER”NUMBERS REQUIRE “CALCULATIONS “CALCULATIONS NEED THRESHOLDS, THRESHOLDS NEED A SCORE. ADJUSTING YOUR SCORE, WILL REQUIRE A CHANGE IN YOUR “PROCESS”

PROCESSES: TAKEN ACTIONPROCESSES: TAKEN ACTION

FMCSA is grading your Processes based on your Roadside Violations which are defining what kind of Management Control Features have been set in place .

Poor Maintenance Practices, Lack of Driver Discipline resulting in Roadside Violations make it hard to defend that your Processes are working if the Management Control Features are really in place and being followed.

RULES: ASSIGNING A RULES: ASSIGNING A RATINGRATING

“RATING A FILE HAS THAT HAS NEVER DRIVEN ITSELF DOWN THE HIGHWAY, IS BORDERLINE INSANE”

“FMCSA WILL BEGIN ASSIGNING FUTURE RATINGS BASED ON ROADSIDE VIOLATIONS”

“FIX THE TRUCK, YOU FIX THE SCORE”

FMCSA UPDATEFMCSA UPDATE::

Phase I: Launched the CSA scoring system Dec 13th, 2010.

Phase II: Warning Letters begin going out mid February of this year and continue….28,000 plus letters had gone out by June of this yr.

Phase III: New rating system and rule making due out by 1st quarter of 2012

FMCSA UPDATE CONTFMCSA UPDATE CONT::

Remedial Directives: CARRIERS THAT ARE ISSUED A NOTICE OF VIOLATION THAT IS PLACED INTO A “REMEDIAL DIRECTIVE” AND THE CARRIER DOESN’T COMPLY WILL FIND THEMSELVES AT ROADSIDE PLACED OOS UNDER 395.13 (B)(4) OR 385.811 (D)

FMCSA UPDATE CONT:FMCSA UPDATE CONT:

Cargo securement will merge with Maintenance, Mid 2012 or sooner.

Medical card provisions go into effect Jan 30th, 2012

Trailer wind deflectors will add to an inspection item at Roadside, 396.1

Drivers will view a Carriers score before applying

Drivers will begin refusing dispatch or continuing if Equipment is not maintained.

CSA WORKING COMMITTEECSA WORKING COMMITTEE::

In the spring of 2009, Dave Osieki of ATA established a CSA task force committee that would be given the task of reviewing every section code in the CSA tables regarding the Severity Weight factor assigned to each violation.

13 Committee members reviewed the CSA tables and proposed changes to the “wieght rating” by the type of violation, mainly due to the Safety via Non-Safety related items they were grading, (form & manner, mud flaps, etc).

PAST COMMITTEE ACCOMPLISHMENTSPAST COMMITTEE ACCOMPLISHMENTS

Able to convince FMCSA to NOT post the Cargo Securement Violations

Able to convince FMCSA to continue to NOT post the Crash Data

Able to convince FMCSA to adjust their Severity Weight ratings at that time for specific violations

CURRENT WORKING COMMITTEE AGENDACURRENT WORKING COMMITTEE AGENDA::

Petitioning FMCSA to allow for Carriers to obtain the Drivers Safety Management Score

Petitioning FMCSA to remove a Rating Score OR Lesson the weight assigned to 392.2S for Dismissed citations by the court, instead of remaining on the Carrier and Drivers record.

Petitioning FMCSA/CVSA to evaluate and lesson the weight rating for Carriers that had no knowledge of a Drivers CDL suspension , basically Safety related CDL suspensions via Non-Safety related suspensions

Lesson severity weights if Carriers can prove that a State did not notify the Carrier of the drivers CDL suspension.

CSA FINANCIAL IMPACT AREAS:CSA FINANCIAL IMPACT AREAS:

Administrative training will be a of a key essence when paying attention to CSA inspections and taken action once a Roadside Inspection as occurred, which equates to cost/training.

Lack of Credit lines and loans will cause more stress on Carriers that are forced to run there Aging Equipment

Investments and Investors will begin to use the CSA scores for underwriting purposes when evaluating their risks and return on growth.

Insurance have begun using Carriers Scores for underwriting puposes.

Shipper demands for new equipment are being felt on Carriers. Legal escrow accounts will have to be increased.

CSA SIGNIFICANT IMPACTS:CSA SIGNIFICANT IMPACTS:

Maintenance “Intervals” will demand that “Major Components” be added to rotation schedules.

Type of parts used and supplier warranties will have to be paid closer attention to, life cycles of components a key factor here.

INDUSTRY IMPACTINDUSTRY IMPACT::

Attention will have to be spent protecting the Carriers “Image”

Higher Driver Pay Substantial Increase in Maintenance Costs Increased Insurance Premiums Enhanced Shipper Relations Exposed Legal Issues Stricter Lending Rules

INDUSTRY IMPACT CONTINDUSTRY IMPACT CONT::

Second hand equipment challenges for Owner Operators

ECM: Security IssuesEnhanced Public Relation programsRegulatory Trust and CreditTechnician Accountability, they need

to know their now going to be involved in Data Q’s and Audits

ADMINISTRATION COSTSADMINISTRATION COSTS::

CSA will demand that 86% of the carriers staffing time be paid attention to what is being said about that carriers drivers and operations derived from Roadside Inspections

Due Diligence will have to be addressed immediately once a Roadside violation has been recorded.

HIRING PRACTICESHIRING PRACTICES::

Don’t let the Roadside Officer tell you who is driving your truck…….know who you’ve hired. Your ability to remain in business and your very existence depends on it.

PSP ReportPSP Report

PROTECT YOUR DRIVERPROTECT YOUR DRIVER::

Enhance your HR toolsDon’t issue pin and portals log in’s to

customers that now have your drivers private information

Don’t hide your problemsCommunicate with honestyRemember their name, not their unit

number…….they are a person

MAINTENANCE MATTERSMAINTENANCE MATTERS::

Establish CSA safety lanes across the US. Tighten your Brake Component intervals Place your lighting components on

intervals Tire wear and inflation, tighten up the

intervals. Require “proof of repair” for record

retention of Data Q’s

KNOW YOUR STEPS, TRAINING:KNOW YOUR STEPS, TRAINING:

Level 1 inspections on Tractor/Trailer combinations have a 37 step procedure that Roadside Officers follow:

Of those 37 steps, 32 of those steps have 672 ratable sections in the CSA tables…….672 different ways to be scored in 1 Roadside Inspection.

EVALUATE YOUR BUSINESSEVALUATE YOUR BUSINESS::

Downsizing may not sound or look attractive, but trying to maintenance equipment 2,000 miles from your terminal with a 2 year roadside violation on your record isn’t attractive either.

Just know that downsizing will result in pricing lanes differently and driver pay.

ENHANCE EQUIP SPECSENHANCE EQUIP SPECS::

Work with manufactures for image displays of electrical screens for diagnostic checks before and during dispatch…..KNOW that your LIGHTS are still BURNING!

Dry sump pans……why oil leaks?Enhanced fault code alerts, brake

adjustments, air leaks, etc.

Warning LettersWarning Letters

CHOOSE YOUR BATTLES WISELYCHOOSE YOUR BATTLES WISELY::

Attacking the issues on your operations will reach far more in the Regulators eyes, then attacking the Regulators.

Let the Associations help pick your Battles since they are near the heartbeat of the lawmakers.

DON’T FIGHT THIS ALONEDON’T FIGHT THIS ALONE::

Third party help will help outweigh public and court opinion then trying to going alone.

Use the tools and resources available so your able to defend your companies image when an accident occurs or legal action is taken against you.

USE THE TOOLS YOU HAVE AVALIBLE!!!