NTTC FILES CSA COMMENTS

NTTC called on the Federal Motor Carrier Safety Administration (FMCSA) to support our petition to PHMSA to require all applicants for a Hazardous Materials registration number to also supply a USDOT number in our recommendations for improving the Compliance, Safety, Accountability (CSA) program. That is the best way to ensure that the “peer comparison” aspects of CSA include information from intrastate HM carriers.

We stated our continued support for the goals of CSA – to enable the agency to better utilize data to apply its resources to carriers needing attention--and thanked the agency for revising the BASIC categories to provide a unique HM classification as we and ATA have advocated from the start.

NTTC reiterated its great disappointment at “the Agency’s reneging on its commitment to industry to fix the obvious ‘crash accountability’ problem and now relegating that critical component to a lengthy study process.”  We further requested “. . . that raw accident data numbers not be displayed on the public website until a process is in place for accident accountability. We have complete faith in the personnel at FMCSA to give different weight to a ‘death by truck suicide’ fatality and one where a driver falls asleep and rams his truck into another vehicle when it is determining the need for an intervention.  Regrettably, we know that this naked number is being misused, either through intent or ignorance, by the news media, plaintiff attorneys, insurance companies and competitors.”

We asked FMCSA to not liberalize the classification of what carriers should be included in the HM BASIC.  We support the current approach where a carrier who hauls one placarded load is an HM carrier and should be part of the HM peer group.  We pointed out that when it comes to being an HM transporter, “you either is or you ain’t.”  We also relayed concerns we have heard from carriers about “gotcha citations” such as for faded placards which appears to be nothing more than “we couldn’t find anything else to write up.”

Finally, we asked FMCSA to continue to constantly review the CSA program for its primary purpose which is to develop and utilize data that indicate a carrier is prone to have a crash, not just to drive up numbers with “hits” for violations which have no relationship to crashes.  In the long run, a focused CSA program should work in the best interests of tank truck carriers who are the safest segment of the trucking industry.  Please provide your NTTC staff with any positive or negative observations you have from the real world on CSA.