Wikipedia defines the 404 error as the most common error found on the web. You type a url into your browser and get back that obnoxious message that the page is gone, missing, moved or never existed.

We are closing in on 5 years since the implementation of CSA and there are still fundamental flaws in CSA that cripple it, rendering it far less useful than it could, or should be.  The solutions to these four critical defects are well known, well understood, and totally, 100% fix-able.  These defects are:

1. Crash Preventability – all DOT recordable crashes count including clearly non-preventable crashes such as a drunk car driver slamming into a parked truck at a rest stop. Clearly, only preventable crashes should be used to measure carrier safety. Fixable.

2. Disparate Enforcement – Law enforcement focuses on wildly different aspects of commercial vehicle enforcement across this wide and diverse country.  CSA treats every mile (city, country, mountains, winter, or border crossing as if every mile were exactly the same) Law enforcement knows better and adapts, CSA does not. Fixable.

3. Safety Event Groups  – are a LOL Joke. Carriers are not grouped and compared to similar carriers, they are not grouped geographically, or by truck type or line of business.  Safety Event Groups are not like grouping male teenage drivers together for comparison as FMCSA likes to say.  Safety Event Groups compare male teenagers with female retirees, 1957 Chevy’s and ferrets. Worse, you can jump Safety Event Groups from month to month, this month I’m a ferret, next month, I’m an ice cream sundae. Madness. Fixable.

4, Ghost Carriers – The FLMCSA (Federal Large Motor Carrier Safety Administration) ignores 89% of all Motor Carriers for purposes of CSA Scores.  This huge gap in scoring allows 678,147 regulated motor carriers (August 2015 number) averaging 3 drivers (over 2M drivers) to go un-scored in any CSA BASIC category.  The remaining 11% of all regulated motor carriers averaging 34 drivers, have CSA Scores and must compete for business with the Ghost Fleet.  On a driver count basis, FMCSA misses almost half the operators on the road. Fixable.

This past July, under tremendous pressure from the industry, Congress finally woke up.  A bill, passed by the Senate in the last days of July that would have addressed some of these defects failed to be taken up by the House, and so died without becoming law.  Congress passed a funding patch to get us through October.  NOTE: On that same day, the Senate did manage to unanimously pass a resolution declaring July 31, 2015 to be “National Whistleblower Appreciation Day”

I’m blowing the whistle on FMCSA.  Watch this blog over the next 60 days , we have some ideas.

If you are interested in reading the relevant portion of the 1034 page Senate bill, called the DRIVE Act, I’ve posted it here.  Now I don’t suspect many of you are going to read 1034 pages, so I’ll make it easier for you.  All of the CSA fixes are spelled out in 23 pages that begin on…you guessed it.

Page 404.