Load Securement and Unintended Consequences of CSA 2010
By Jim Park, Equipment Editor
What will happen to open-deck carriers when the CSA 2010 points for cargo securement violations start piling up? The Federal Motor Carrier Safety Administration has developed a weighted point system for determining the severity of various violations of the FMCSRs, listed in a document called the Safety Measurement System (SMS) methodology. The section dealing with cargo securement lists 95 violations. All but five carry a 10-point rating.
According to Al Koenig, the "retired" chairman of Midwest Specialized Transportation of Rochester, Minn., open-deck carriers are going to accumulate points at a great rate, and that could cause a few shippers and insurance companies to question the integrity of their carriers.
"Overall, the CSA 2010 concept is a good one, but there are some unintended consequences," he says. "More than 50 percent of the violations that end up in the load securement category are not load securement violations at all. They are primarily violations of certain state permit requirements."
For example, one of Koenig's trucks was cited at a scale for violating permit conditions prohibiting travel when temperatures exceeded 85 degrees. The thermometer at the scale facility showed 88 degrees. That kind of problem, Koenig says, is just part of the heavy-haul world - but under CSA 2010, it's also a 7-point violation in the cargo securement category. In other instances, he notes drivers and carriers are being cited for "shifting cargo" that resulted from non-preventable crashes, but not contributing to crashes.
"If you have hours of service problems, or driver or mechanical problems, you can fix those things," he says. "You cannot fix 'load securement' the way it is right now because there are other things going in there that will turbocharge the score."
He's referring to the degree to which the regulations are interpreted differently in various jurisdictions, and to the issue of warning tickets. In the past, warnings were just that. Under CSA 2010, warnings are recorded too - at 10 points a pop. That kind of thing is causing a lot of people to question the need to rate nearly every cargo securement violation a 10.
"What conclusions am I supposed to draw about a 4-point violation for brakes out of adjustment, and 10 points for failing to chain down the screed on a paving machine?" he asks. "We're not supposed to compare points accrued across other categories, but to a shipper, an insurance company, and to enforcement, an 80 is an 80. That's going to attract attention in a hurry."
Discussions are taking place with DOT already, and everyone at the table has an open mind at this point. In the meantime, Koenig urges carriers to bring this issue to the attention of their customers and insurers.
From the July 2010 issue of Heavy Duty Trucking.
By Jim Park, Equipment Editor
What will happen to open-deck carriers when the CSA 2010 points for cargo securement violations start piling up? The Federal Motor Carrier Safety Administration has developed a weighted point system for determining the severity of various violations of the FMCSRs, listed in a document called the Safety Measurement System (SMS) methodology. The section dealing with cargo securement lists 95 violations. All but five carry a 10-point rating.
According to Al Koenig, the "retired" chairman of Midwest Specialized Transportation of Rochester, Minn., open-deck carriers are going to accumulate points at a great rate, and that could cause a few shippers and insurance companies to question the integrity of their carriers.
"Overall, the CSA 2010 concept is a good one, but there are some unintended consequences," he says. "More than 50 percent of the violations that end up in the load securement category are not load securement violations at all. They are primarily violations of certain state permit requirements."
For example, one of Koenig's trucks was cited at a scale for violating permit conditions prohibiting travel when temperatures exceeded 85 degrees. The thermometer at the scale facility showed 88 degrees. That kind of problem, Koenig says, is just part of the heavy-haul world - but under CSA 2010, it's also a 7-point violation in the cargo securement category. In other instances, he notes drivers and carriers are being cited for "shifting cargo" that resulted from non-preventable crashes, but not contributing to crashes.
"If you have hours of service problems, or driver or mechanical problems, you can fix those things," he says. "You cannot fix 'load securement' the way it is right now because there are other things going in there that will turbocharge the score."
He's referring to the degree to which the regulations are interpreted differently in various jurisdictions, and to the issue of warning tickets. In the past, warnings were just that. Under CSA 2010, warnings are recorded too - at 10 points a pop. That kind of thing is causing a lot of people to question the need to rate nearly every cargo securement violation a 10.
"What conclusions am I supposed to draw about a 4-point violation for brakes out of adjustment, and 10 points for failing to chain down the screed on a paving machine?" he asks. "We're not supposed to compare points accrued across other categories, but to a shipper, an insurance company, and to enforcement, an 80 is an 80. That's going to attract attention in a hurry."
Discussions are taking place with DOT already, and everyone at the table has an open mind at this point. In the meantime, Koenig urges carriers to bring this issue to the attention of their customers and insurers.
From the July 2010 issue of Heavy Duty Trucking.
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