The Impact of CSA on Shippers and Freight Management Companies

CSA 2010 was created by the U.S. Department of Transportation's Federal Motor Carrier Safety Administration (FMCSA) to remove unsafe commercial drivers from the America's roads.  CSA, short for "Compliance, Safety and Accountability," uses a complex methodology to rate motor carriers on safety. It incorporates a "Safety Measurement System," or SMS, that assesses a trucker's on-road performance over the most recent two-year period and indicates whether the assessment should prompt the agency to dig deeper into the carrier's operational fitness. 

The SMS includes seven "Behavior Analysis and Safety Improvement Categories" known as "BASICs." Embedded in the seven categories are more than 640 infractions that a driver and vehicle can be cited for. The SMS database is populated by data generated from roadside inspections triggered by infractions such as speeding on an interstate or state highway. A speeding violation gives law enforcement "probable cause" to pull a truck over and conduct what is known as a walk-around inspection of the vehicle and driver. Any infractions that are then found will accumulate as points on a company's safety "scorecard," which is updated monthly. 

Fatigue Driving (hours of service), Vehicle Maintenance and Unsafe Driving are the three areas of most concern.  Should the point total exceed the FMCSA's threshold for safety compliance, government inspectors will conduct an in-house audit or intervention of the company's operations. From there, a determination will be made if the driver is fit to continue behind the wheel.  American, Canadian and Mexican carriers are all subject to inspection.  An estimated ratio of 1 in 5 carriers is at risk of an intervention.

The CSA program is expected to have multiple impacts on the freight industry.  While the system is imperfect and controversial, it is projected to move 10 percent of America’s 3.5 to 4.0 million drivers out of the industry, exacerbating the driver shortage that already exists.  It will likely have an impact on insurance costs and driver training costs.  Cost increases coupled with fewer drivers will serve to drive up freight rates that are already on the upswing due to the improving economy and carriers’ reluctance to make fleet additions.

The question for shippers and freight management companies is where do CSA scores fit in the selection and procurement of freight transportation services?   Concerns over legal liability seem to be playing a role in carrier choice.  A late 2011 shipper survey conducted by Morgan Stanley & Co. found that 55 percent of those polled were afraid to use a carrier if even one of its seven BASIC scores came in above the CSA threshold. If those shipper attitudes become more entrenched, carriers with a positive safety history but a poor CSA record may be “blackballed” and pushed out of business, according to the program's critics. 

Shippers and freight management companies can expose themselves to enormous legal risks in the event of a fatal or serious accident involving a carrier they've selected and if a jury finds that they failed to give CSA scores sufficient weight when evaluating the driver and carrier.  A jury could find them "vicariously liable" for damages resulting from an accident involving a carrier that they thought was a good safety performer.

This leads to the first conclusion that CSA scores should not be ignored.  On the other hand, a carrier’s safety performance is still only one albeit important variable in the carrier selection process.  An FMCSA spokesperson has stated that those looking to investigate a carrier's safety record should also rely on the agency's "Safety and Fitness Electronic Records System," or SAFER, which officially rates a carrier based on its most recent on-site compliance review, as well as the agency's "License & Insurance Website," which confirms that a carrier has active operating authority and adequate insurance.  The agency said that by combining all three resources, users can get an "informed, current, and comprehensive picture of a motor carrier's safety and compliance standing with FMCSA.

C. Thomas Barnes, president of Con-way Multimodal, the brokerage arm of Con-way Inc., takes a “hybrid” approach toward CSA. His company monitors carriers' performance under the CSA BASICs to ensure vendors remain within the acceptable thresholds. However, the CSA scorecard is just one part of a "weighted average" calculation in determining if a carrier is fit for service. This leads to the second conclusion that other factors such as historical service performance, meeting contractual commitments, financial viability, IT capabilities, strategic importance and how a carrier addresses failures should be part of the carrier assessment.

Like Barnes, Joshua Dolan, director of global logistics and customs compliance for Philadelphia-based auto parts and service giant The Pep Boys, considers CSA scores to be a "component" of the carrier selection process.  Pep Boys also uses other criteria and will drop a carrier that doesn't measure up and doesn’t take corrective action.  Dolan advises companies to use outside services like Carrier411, a Norcross, Ga.-based provider that monitors CSA scores and creates quarterly alerts for customers to keep track of carrier performance.

Dolan said CSA will force shippers and freight management companies to care more about carrier choice than they have in the past, adding that "there is an expense associated with that." Safe and experienced drivers will be able to command higher salaries and benefits, and driver wages in general are likely to rise from current levels, he said. "It will become a strategic goal on the part of companies to keep drivers," he said. "Drivers will be picking and choosing companies, not the other way around."

This leads to a third conclusion.  Whether you love or hate CSA, it is here to stay.  Shippers and freight management companies must closely monitor the evolution of CSA and the multiple impacts it is having on the freight industry. CSA will result in improved safety which is a good thing.  Unsafe drivers are a drain on a trucking company’s bottom line.  But CSA will drive up costs for driver recruiting, training and compensation (to secure and retain the better drivers) and trucking company insurance.  It will certainly drive up freight rates.