Some More Thoughts About CSA 2010
While I’m thinking of it, there are a few differences in the CSA 2010, and how DOT is going to do their business. For the uninitiated, DOT means the same as FMCSA, which is the Federal Motor Carrier Safety Administration. They’re the group that regulates anyone who has a truck. They are the government, and they’re not there to help you. In fairness to the FMCSA, I do not believe their agents say that anymore.
Anyway, DOT is planning to conduct many more “interventions” (their word) under CSA 2010. Seriously, where do they come up with these words? If I had to guess, they probably had a meeting, which may have taken multiple days, and decided they need a new, non-threatening word for “audit”. Boom, we have “intervention”! After all an intervention is where your friends (like the DOT!) sit around in a circle and force you change your behavior. So, maybe they still are thinking they’re here to help you.
These interventions are mostly going to take the form of them sending you threatening letters, and then you will have to send them many pages of documentation, showing you are in compliance with the rules. Then they may go away. They might not. They might come out and do an audit, they might send another threatening letter, or they might actually just send you a fine. I doubt they’ll start fining motor carriers without doing an audit immediately. It will probably take them a year or so, until they feel comfortable with their system, but that’s definitely where they’re going with this.
There are still many unanswered questions about CSA 2010, so I wouldn’t get too worked up over it. DOT wants to expand their footprint, expand their outreach by fining more motor carriers, but the problem is, they don’t have the auditors to do it. Even if they do issue more penalties, even by mail, they don’t have the people to process them. I doubt they’ll be able to hire more people, because in November the $$$ spigot is going to be shut off. Ok, it won’t be shut off, I’m not dumb enough to think the GOP will actually bring back any sort of fiscal sanity to government. The $$$ spigot will be partially shut off, how’s that?
