CSA 2010 Effect On Driver Shortage Posted by DC Cargo Mall on January 24, 2011

CSA 2010 Effect On Driver Shortage - Not So Much In The Near Term...
January 23, 2011

Jay Thompson


Summary
Nascent freight predictions have many fleets and investors turning their focus toward the impact of CSA 2010, the aging driver pool and other issues on "an impending acute" driver shortage. Our requests around what CSA 2010 really means - are up from shippers, logistics providers, smaller truckers and others watching the industry. We agree that the driver pool is changing, but we don't see it as the crisis and happening as quickly as some think. Here are some thoughts.

Analysis
First of all, I must correct myself. CSA is no longer Comprehensive Safety Analysis 2010, but the acronym CSA was recently changed to mean Compliance Safety Accountability. For most, this creates some good comments (jokes) in the field around why Comprehensive and Analysis were changed. Needless to say the current name is more appropriate than the former.


Key to the program - or any analysis - is data. Just ask any statistician. One can run some controlled tests like we are doing with 2010-compliant engines - but that is a different animal. Another data argument surrounds the low percent of containers actually inspected that come into the country. Trucking / Logistics can be characterized as anything but a controlled test environment.

So when you ask statistics-folks how much data is needed to make decisions - they say lots. When you ask about the minimum amount needed - they say enough to make a decision. OK, I recently learned about enough and lots when we got trailer temperature data for loads for an Arizona State University USDA study. We got hundreds-of-thousands of data points from runs from Mexico and from across the US where I thought we had lots, but was told it was just enough. Even more would be better!

The same holds true when we look at macro fleet fuel mileage, average fuel costs, equipment utilization data, logbook data, maintenance data and all the other data truckers have to keep an eye on. That gets us into the old DOT SafeStat data, as well and the current "at least more comprehensive" approach. It was estimated by DOT that perhaps 2% of fleets were actually audited in the previous program, which came as a result of on-road inspections, log violations and tickets input. In other words, we needed more data to do it all better (we agree).

The data kicked out to date in CSA is interesting. Of the 400.000+ carriers that are estimated to be in the database, about 20% are rated. This percentage drops if the actual number of fleets are somewhere in-between the 400,000 and 700,000 shown in the DOT registration database (probably too much data here). Regardless if it's 400,000, this means that 80% aren't rated. Why? Not enough data. Why is this? Generally, smaller fleets don't get inspected as often as larger fleets (it's a numbers game) - so there's not "enough" data to rate them.

A good example of data needed comes from the previous Mexico Cross-Border Program. The 25 Mexican carriers and their 100 trucks in the pilot had driver out-of-service violations at one-half of 1% and vehicle violations were 9% - and NO fatalities. This compares to US-domiciled trucking fleets at 7% for drivers and 23% for vehicles. Of course, if you know you are going to be inspected - you do things the best you can - and is what we hope to see with CSA. The conclusion however was that there was not enough data to make comments as to whether these operations were safe.

Then there are the CSA data issues around equipment versus driver. An equipment issue affects both the fleet and driver's scores. What feeds the database? Data for the equipment comes from "certified" inspections entered in from the home-base - and those done on the roadside. Data for drivers comes from their driving record, logbooks, accidents - and those done on the roadside. Positive data can come from more "certified" equipment inspections and driver screening before trucks / drivers are put out on the road.

The key to staying out of trouble comes from data. Roughly a third of road-side inspections are triggered by speed - too fast / too close for conditions. Another third are triggered by visual defects seen in drive-bys such as brakes, lights and tires. The key here is to drive responsibly and do pre-inspections. Once pulled over, the big issues cited are driver logs and equipment maintenance.

As a reference, the 7 Behavioral Analysis & Safety Improvement Categories for Commercial Motor Vehicles are as follows:
1. Unsafe Driving - Dangerous or careless operation (e.g. speed / following too close).
2. Fatigued Driving - Driving when fatigued including Hours-of-Service violations
3. Driver Fitness - Operation by drivers who are unfit due to lack of training, experience, or medical qualification.
4. Controlled Substances and Alcohol - Operation impaired due to alcohol, illegal drugs, and misuse of prescription medications or over-the-counter medications.
5. Vehicle Maintenance - Issues due to improper or inadequate maintenance.
6. Improper Loading/Cargo Securement - Shifting loads, spilled or dropped cargo, and unsafe hazardous materials handling.
7. Crash/Incident Experience - Histories or patterns (frequency and severity of crashes.

So what does this mean? If only a small percentage of trucking companies and drivers are rated, then it doesn't seem there will be a massive squeeze on capacity and drivers that some are predicting - until we get a lot more data in for smaller carriers. For the major carriers producing lots of data like Swift, Schneider, Con-way, Fed-Ex, US Xpress, etc., who are the some of most productive, they will be affected more around drivers - since they already do a good job in keeping the equipment up to snuff. The vast majority of the trucking industry will be less affected - for years. Those who do things right, even less so.

Otherwise, the driver opportunities are being planned for with fleets hiring recruiters - and driver schools being cranked up. Additionally, a driver new to the industry has a much better driver score than does an experienced one. Therefore, we feel that the driver shortage may not be coming as quickly as some think - and some others feel the same!