Wells Fargo Senior Analyst Anthony Gallo published an excellent document on March 28 highlighting critical problems with CSA 2010. You can contact me or contact Anthony directly at firstname.lastname@example.org for the full document, but I want to highlight a couple of key points. The analysis shows little or no correlation between the CSA BASIC scores for unsafe driving and fatigued driving and accidents per million miles. Everyone wants to see continued reductions in truck-related accidents. It appears, however, that the key CSA measures that would indicate a carrier should be a candidate for further scrutiny bear no relationship to the actual safety ratings of those carriers. This is one of numerous reasons why shippers should not use CSA data to create their own carrier credentialing methodologies. Here is an excerpt from the Wells Fargo publication.
FMCSA assigns a composite score in seven Behavior Analysis and Safety Improvement Categories (BASICs) along with a corresponding “limit” threshold. When a carrier breaches the threshold, corrective actions must be taken to remedy the violations. Serious or persistent violations can result in enforcement actions against either the driver or carrier. Motor carriers initially receive a “warning letter” informing them of their violations. According to several reports as many as 50,000 letters were expected to be sent in H1 2011.
When we dissected the underlying data in relation to the composite scores, we were somewhat surprised to see that there was little correlation between the scores and the actual number of accidents and injuries/fatalities. Specifically, we observed little correlation between poor scores in the Unsafe Drivers and Fatigued Drivers categories and the actual number of accidents or injuries/fatalities. Further, we could not find and are not aware of FMCSA data that statistically demonstrates a correlation behind these factors and accidents. Certainly, it is intuitive that “unsafe drivers” and “fatigued drivers” should be more prone to accidents. However, this does not appear to be the case. We feel this may be due, in part, to the methodology by which the categories are scored. For example, unfavorable Fatigued Drivers scores typically result from Hours of Service violations, but also include Logbook violations and errors. So while a fatigued/tired driver (assumed to be tired if outside of HOS criteria) may indeed be more likely to be involved in an accident, one with Logbook errors would perhaps not be. Thus, if an unfavorable Fatigued Driver score is in fact being driven by Logbook errors, the composite score would be less likely to correlate with accidents, in our view.
We understand the Unsafe Drivers/Driving category is meant to capture speeding, reckless driving, improper lane changes, etc. Certainly we think these behaviors should be captured and likely have some correlation with accidents. However, there are literally dozens of subcategories within the Unsafe Driving category, and a severity weight is given to each violation subcategory. This may help explain some of the disconnect between the scores and the actual number of accidents. For example, “reckless driving” and “texting while driving” both carry 10 point weights. Conversely, “failure to use a seatbelt” has a 7 weight whereas “improper lane change” and “following too close” each carry a 5 weight, although intuitively the latter two appear to be less safe activities, in our view.
The bottom line is that CSA is too new and unproven for shippers and brokers to be using the posted data to make carrier selection decisions. Shippers should avoid creating their own carrier credentialing methodologies that will open them up to challenges by trial lawyers when accidents do occur. It is the duty of the FMCSA to determine whether a carrier is fit for service. Shippers and brokers should be choosing carriers that provide good service at a competitive price and who maintain adequate insurance coverage.
Tom Sanderson is chairman, president & CEO of Transplace, a leading provider of logistics technology and transportation management services. Sanderson’s nearly 30 years of experience includes senior executive roles at Clicklogistics and PTCG, Inc. He also spent several years in the trucking industry, holding management positions at J.B. Hunt Special Commodities, Inc., J. B. Hunt Transport, J. B. Hunt Logistics (now Transplace) and Schneider National. Sanderson also has consulting experience with Mercer Management Consulting and Andersen Consulting (now Accenture). Sanderson has a master’s in business from Indiana University, has been married for 28 years and has three children.