CSA2010 (Comprehensive Safety Analysis 2010) is here, like it or not. What this provision in the DOT (Department of Transportation) is does not bode well for the trucking industry. Let me explain what CSA2010 is, what its goal is, and how this will affect the basis of the trucking industry, which is the lifeblood of commerce in the United States. This program of the DOT will affect everyone in the country. As I have always said, the only thing not delivered by a truck is a baby.
In the world of trucking, safety is the key to minimize loss of life and property along our national road network, be it interstate highways, US highways and state and county roads, all the way down to city streets, dirt roads and driveways, wherever you may find them. Safety is a worthy goal in any endeavor to be sure, but the federal government is going about it the wrong way if you ask me.
The DOT, or more specifically the FMCSA (Federal Motor Carrier Safety Administration) has used a program known as Safestat to rank a company’s safety ratings into 4 Safety Evaluation Areas (SEA), Accident, Driver, Vehicle and Safety. All the data collected by the government at weigh stations and portable scales is fed into Safestat. This program has worked efficiently for many years.
When discussing CSA2010, the safety ratings are now known as Behavioral Analysis and Safety Improvement Categories, or BASIC, and are divided into 7 areas, Unsafe Driving, Fatigued Driving, Driver Fitness, Controlled Substances and Alcohol, Vehicle Maintenance, Cargo Related, and Crash Indicator. All of this data will be used to assign a rating to each individual carrier. But here is the catch. The actions of an individual driver will affect the rating of every driver that is employed by that carrier.
Let me give you one example of many things that can put a driver out of work due to the actions of another driver who may be 2500 miles away. Suppose a driver gets pulled into the Winchester VA inspection station and the inspection officer puts the driver out of service due to a faulty mudflap on a company owned trailer he is pulling, writes him a ticket and enters it into the Virginia state database. I can be driving in the state of California and get pulled into a state scale there and I can be put out of service and not allowed to drive all due to the actions of a driver I do not know in a place 2800 miles away. In addition, I find it detestable that I am betting my career on something that I have very little control over, that being maintenance issues that were under the control of someone I do not know or have no relationship to except for the fact that he and I work for the same firm.
This system is ripe for fraud and abuse all in the name of ‘safety’. There is also something else that has been going on behind the scenes I find very disturbing.
On October 27, 2009, the FMCSA briefed the U.S. Senate Committee on Appropriations, Transportation, Housing and Urban Development Subcommittee, the U.S. Senate Committee on Commerce, Science and Transportation and the U.S. House of Representatives, Committee on Transportation and Infrastructure about the implementation of CSA2010. You can find the Congressional Briefing at this page.
On November 3, 2009, there was a news item regarding Warren Buffett that appeared on MSNBC.com about his purchase of BNSF for 34 billion dollars.
IF the CSA2010 program is implemented without any modifications or changes, I foresee the following three things happen.
a. Most smaller companies today will be forced to stop business operations if too many of their drivers have their Commercial Drivers Licenses pulled. Owner-operators that are leased to smaller companies will also share in this situation. Why make the unemployment rate of one of the largest sectors of the US economy grow larger? We have enough unemployment as it is right now.
b. Most of the large companies today also have an intermodal division, such as JB Hunt, Schneider National, Swift Transportation and others. If the smaller outfits are put out of business due to CSA2010, logically, more freight will be picked up by these large firms and put on the railroad, increasing the profits of Warren Buffett.
c. Freight rates WILL go up across the board if there is lack of competitition. Free and fair competition has made America the envy of the planet when it comes to our way of life. With the implementation of CSA2010, the government is very close to putting in place defacto monopolization of the freight industry in the United States. The Feds should remember how John D. Rockefeller was running the oil industry and what happened to Standard Oil.
I question the timing of the implementation of CSA2010. Why is the Obama Administration very quietly putting CSA2010 into practice? Why haven’t there been press releases or news stories about CSA2010?
In my point of view (and I am one of many that share this), this is yet another heavy handed action of the Obama Administration to dismantle our way of life. Higher prices in virtually everything will occur and most people know it. If it costs more to bring things to market, who do you think will end up paying more? Not the freight outfits and not the railroads, they will factor that into their rates. Yes, you and I and everyone you know will get kicked in the teeth.
In my opinion, put the brakes on this anticapitalistic government program and leave each state to decide how to deal with safety.
Tags: Regulations, Transportation
