Letter to the Editor, Transport Topics 2/22/10

CSA 2010

As implementation day for CSA 2010 — the Comprehensive Safety Analysis program — gets closer, there is bound to be a flurry of concerns emerging. One of the major concerns should be with enforcement: How exactly is this going to be conducted?

Is the Federal Motor Carrier Safety Administration going to go on a national hiring blitz for auditors? What are the expectations of FMCSA’s ability to conduct all the targeted areas of safety/compliance audits as they present themselves?

As it now stands, there simply are not enough enforcement personnel available to conduct current audits, let alone what will be necessary once CSA 2010 is in place. There will be too many audits to perform and not enough auditors to perform them.

Because the audit criteria will change to target only — even just one deficient area of concern — there automatically will be more audits to perform.

We all know how flawed the SafeStat system has been in gathering accurate information from the states — and especially so with regard to accidents. Yet FMCSA still uses this flawed information, in part, upon which to base a safety/compliance audit, even though the information was removed from SafeStat years ago because it was not accurate.

This same information source will be what generates an audit going forward. The carrier involved should not have to be the one to clear up inaccurate information for FMCSA, especially after they show up at your door.

How easy is it to get bad data removed with FMCSA’s DataQ system for filing concerns about federal and state data made public by agency, and what is the success rate in doing so?

To begin with, we should demand accurate state reporting. We are held accountable for compliance assurance, so why aren’t the states?

As for not holding the driver accountable for his or her inaccuracies and/or violations with the onset of 2010, that is not acceptable. The drivers are the propelling force behind an audit. Without holding them accountable while doing their job, the company is still at their mercy.

Companies simply cannot continue to attempt compliance assurance after the fact; the time to address violations and accountability is at the time the violations are observed.

Lawrence Hartung
Director of Safety
deBoer Transportation Inc.
Blenker, Wis.