Scene Opens: A dark cave. In the middle, a Caldron boiling. Thunder.
Fillet of a fenny snake, In the caldron boil and bake; Eye of newt, and toe of frog, Wool of bat, and tongue of dog, Adder’s fork, and blind-worm’s sting, Lizard’s leg, and owlet’s wing,— For a charm of powerful trouble, Like a hell-broth boil and bubble. Double, double toil and trouble; Fire burn, and caldron bubble…from Macbeth, circa 1613
The FMCSA has described the soon-to-be-released “improvements” to CSA’s methodology including the creation of a new HAZMAT BASIC. In short, the intention is to:
Our friends at FMCSA have been very receptive to suggestions for change since CSA launched in 2010. I’ve heard a lot of clamoring for a lot of changes, many of which have been made, many others appear to be in the works. But I’ve never heard anyone pleading for a HAZMAT BASIC, so I thought I’d dig into this a bit. Found some interesting data. Thought I’d share, thats what we do…
First, one assumes that a major change to something like CSA would be driven by its underlying goal which is to reduce the number of crashes involving commercial motor vehicles. I began my analysis with the assumption that this new HAZMAT BASIC, along with the inclusion of Cargo violations into the Maintenance BASIC, would reveal some new information, perhaps bring laser focus to issues previously unknown in order to give carriers, law enforcement and the public the information they all need to continue the efforts to make our roads safer. The reformulation of the BASICs as currently described will, in my opinion have exactly the opposite effect.
The most common Cargo BASIC violation today is 393.104(b) Damaged or Insecure tie-downs. In fact, seven of the top ten Cargo violations are directly associated with insecure loads or vehicle equipment (see slide 4). Real safety stuff. A person could imagine real accidents, real injuries, real bad things if cargo or equipment decide to leave the vehicle without permission. Today’s Cargo BASIC, while not visible to the public, does clearly communicate to carriers where they stand with their Cargo related violations. They matter.
The new categorization moves those Cargo violations to the Vehicle Maintenance BASIC where they disappear into a vast ocean of maintenance related violations that occur with far more frequency. The number one Cargo violation mentioned above is now the 42nd most frequent violation in the new Maintenance BASIC (I think I hear the flatbed segment cheering).
So what do we get in trade for the disappearance of real, serious Cargo related violations (drum roll)… a new HAZMAT BASIC that is populated almost exclusively with placarding and paperwork violations (see slide 7). It is logical to imagine a faulty tie-down leading to a crash, it is less clear how a placard “displayed other than horizontally”(frequency #7), or “obscured from the direction it faces” (frequency #12) logically leads to a crash. Yet, that is exactly what this new HAZMAT BASIC spotlights; placarding, paperwork, and compliance.
Finally, the new HAZMAT BASIC is very sparsely populated with data. I studied 895,480 violations in Maintenance and Cargo for this analysis. 849,097 were in Maintenance, 46,383 from Cargo as it exists today, and only 14,960 (1.6%) end up in the HAZMAT BASIC if it is organized as the Agency has described. Divide that into 5 Safety Event Groups (Peers) and the result will be a highly volatile environment where a small number of new violations will result in skyrocketing HAZMAT scores. Scores that will now be open to the public.
A couple other observations:
1. Last year, the Agency changed how HAZMAT carriers are designated. No longer is it determined by Carrier Safety Permit alone, but also now includes any carrier with an inspection or investigation with placardable quantities of HAZMAT.
2. Many Carriers believe that if they are NOT HAZMAT permitted, they don’t need to worry about this new BASIC. Au contrair, mon ami. The larger issue here is what happened to Cargo? Carriers all need to know and understand their own violation status and the relationship between their Maintenance and Cargo violations.
3. The FMCSA has always been consistent in advising against adding CSA Points across BASICs. A CSA point in Unsafe is not equal to a CSA point in Fitness. Yet that is exactly what is being done here. There are 350 violations that currently make up the Cargo BASIC (New 2.2 methodology) and 115 of them are packing their little bags and heading for their new home in Maintenance. What happened to not adding across BASICs? I know, I hear you all now, well Steve (you are thinking…or yelling), they’ll adjust the severity weights to welcome all these newcomers. Note: The Tie-Down violation I’ve mentioned here has a severity weight of 7 already. So make it a 10, it moves into 24th place. It would require a massive down-weighting of far beefier tire, brake and lamp violations in order to bolster our wimpy little Cargo friends onto the comfy couch at their new Maintenance home (OK, pushed that too far).