About a month ago I attended a safety conference for the NPTC. It was a great conference, great speakers, and a great opportunity to see a lot of familiar faces. While attending, I had the opportunity to listen to a DOT representative state categorically that CSA 2010 will not, nor was it ever designed to, put drivers out of a job. WHEW!!! Everybody in the room was visibly relieved that all the scary stuff they'd been hearing was false and that the scoring and violations would NOT create the next big driver shortage.

Let's now leave that wonderful dream world of the FMCSA and, in the famous words of Paul Harvey, “now the rest of the story”. Immediately following that presentation another gentleman spoke. He was kind enough to agree with the previous enforcement official…before going on to point out that, “The ones putting drivers out of jobs will be you”, as he looked out at the audience of 100+ fleets representatives. Unfortunately, I happen to agree with his statement, and drilling deeper into violation history will support this.

As of August 27, the top 11 violations represented 87% of the total violations written. Of those, the driver is held accountable for 10. In other words, the driver will receive these points as part of their 3 year history of violations now feeding the Pre-employment Screening (PSP). The fact that on August 16 the FMCSA reduced SMS violations by 270 total violations (of which 139 were driver accountable) really doesn't cut the driver much slack because 87% of the time they ARE going to receive one of those top 11 violations.

So what DID the August 16 changes do for the driver? Absolutely nothing, accept place a bigger magnifying glass on their log book. I know you're dying to know why I picked the top 11 and not the top 10. Reason being, I found it very interesting that No record of duty status (or no log book at all) moved from number 20 on the list in 2009 to the number 11 spot. What does this all mean? Well, with 6 of the top 11 being Hours of Service related, the driver now has a 50% chance of being found in violation every time he is inspected. If drivers do not understand how these numbers affect them, they will as soon as they try getting another job but find out because they weren't any good at keeping their log book up to date and accurate, that they're now being shut out from gaining meaningful employment with another carrier. But hey, there's always hourly work within a 100 mile radius to fall back on. That will surely pay the bills of a driver that is used to making 65K a year…NOT!

Oh the doom and gloom of it all. Well, the fact of the matter is it's going to be tough on all drivers that choose not to take advantage of available technology. In my opinion, there is no better time than right now to move to electronic logs and, with full understanding of how CSA is going to work, the drivers shouldn't argue. Electronic logs give the carrier, and most importantly the driver, an opportunity to reduce their risk and exposure to a CSA 2010 beat down. Drivers need to understand their full exposure; even with the August 16^th changes, and subsequent reduction in violations, as you can see below, the drivers still became responsible for 5% more violations.

As they've made the menu of violations smaller in order to facilitate easier enforcement, it will become even more vital for drivers and carriers to manage those top 10 violations.

The time to take action is now. The intervention process will start in December, 2010 and carriers that have neglected to look at how they stand in the new process will quickly get a big dose of the “OH, CRAP. I had no idea”. All you can do is look them in the eye and say what my wife says to me, “Really?” That one word says it all. Its coming and you can't stop it. As big a pain as it is, it will make our roads safer and the subsequent reduction in accidents should make a carrier's P&L a little fatter.

I hope this information provides you with some valuable insight into a business that I dearly love. With only 2 months to go, the clock is ticking. I urge you to do the right things and believe that you're only changing the things that need to be changed. I'm headed to Canada to talk about CSA 2010; I guess they want to know how we do it south of the border. I'm out.

References:

• CSA 2010
• DataQ
• SMS Methodology [PDF]
• CSA 2010 FAQs