Sunday, February 6, 2011

2011 - the year of regulation?

Four months later...  I started a new job about the time I last posted, and it's been consuming a lot of my energy and time.  I'm enjoying the work, especially the focus on data analysis and the bigger picture.  So, apologies for the nonexistent posts.

I'm now focused on domestic transportation, primarily truckload and small parcel.  That's had me thinking a lot about CSA 2010.

I hadn't heard of CSA 2010 before I started this job, which in retrospect surprises me a little.  It hasn't been covered much in the mainstream press, nor in the blogs I was following.  I've added some domestic transportation blogs and newsletters to my 60-odd list in google reader since then.

So what is CSA 2010?  On the surface, it's a change in the way the FMCSA measures companies that employ commercial drivers.  All interstate carriers (including limo and bus companies) are subject to CSA 2010 as part of their DOT compliance.  The fact that they're measured isn't new, but the categories are a major change.  Drivers' safety histories are now part of the score, regardless who the driver worked for when the violation occurred.  In the past it only counted if the driver was an employee of the company at the time.

What does this mean?  Drivers with poor safety records (accidents, hours of service, or vehicle maintenance violations) became unemployable in December.  Estimates vary, but a lot of experts think the driver pool is going to shrink by 5% in 2011.  Minnesota was one of the pilot states, so carriers here are mostly already compliant.  Some of them even won awards in 2010. 

As a driver, I'm happy that unsafe drivers are going to be off the road.  As a shipper, I worry about my costs going up.  There wasn't much slack in the market before CSA 2010 went into effect.  As a consumer, my costs at the store will also go up as transportation costs increase.  Carriers pass along costs directly to shippers and shippers usually pass them to the customer.

2011 is stacking up to be a year of significant US rulemaking on a lot of issues in transportation.  The FMSCSA has announced rules requiring Electronic On-Board Recorders in interstate commercial vehicles unless the driver is paid on a timecard.  Most reputable carriers are already using them, but added cost and improved hours of service compliance will push low-end carriers out of the industry.  A new hours of service rule is currently in the comments phase, potentially reducing driving time from 11 hours a day to 10. 

In ocean news, the Justice Department is reviewing the anti-trust immunity among Pacific carriers and the Coast Guard is going to release new ballast dumping rules in April.

It's going to be an interesting year.