CSA 2010 is sure getting a lot of publicity these days. And with good reason ... this is the year 2010! There have been a few test states in the past and recently Delaware was added to that list. A lot of hype has been ongoing for something that isn't supposed to start officially until at least mid-year of 2010.
I, along with my regulatory manager Rich Wilson, attended one of the first sessions years ago that the feds sponsored on this subject. Rich was all aglow about it, citing the need for this kind of action and the effects it will have on our customers. I must admit, I thought 'yeah, right' when I heard the master plan from the feds. I had been down this road before with something called 'zero base review'.
Two decades ago the feds touted a new wave of regulatory writings. Their plan was to take all of the regulations down to zero ... that’s right ... to nothing ... and start over using a question and answer format. The idea was to make the regulations read at something like a fourth grade reading level. As exciting as that was ... it never materialized. Oh new regulations began being written in a Q and A format, but they never became an easier read ... and I have never seen a total rewrite from 'zero'. So I was skeptical, cynical, and just downright unenthusiastic about this whole CSA 2010 thing.
Meanwhile, Rich attended every meeting he could regarding this subject. He acquired the official fed training material and power point presentations. He learned, offered opinions, and reported back to me about the feds progress. He figured how these new procedures were going to affect our customers. So now, here I am, eating my own words about the feds ideas and playing catch up on this now very important subject. I recently spoke to another regulatory professional who admitted to me that he too was entirely skeptical that this would ever get off the ground, citing his frustration over the zero base review of decades past.
So after a couple of months of feeling like a high school kid cramming for finals, I am finally ready to speak with some degree of confidence on this subject. Perhaps the biggest issue is actually not even a new issue. Your compliance requirements are not changing. There are still driver qualifications to be done, hour of service to be calculated, drug and alcohol tests to be administered, daily and periodic inspections to be done and CDLs to obtain. Everything in that regulation book you have bought from Trans Products STILL must be done!
The greatest impact of CSA 2010 lies in how the feds will assess your compliance. Your company and your drivers are in essence being graded on your regulatory abilities. This is way different than an audit (which is a look back into your compliance). CSA 2010 will be real time viewing of how well you and your drivers are complying. REAL TIME! I guess the Internet and email have finally caught up to us!
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