Barr-Nunn Transportation, Inc. - Comments

As a safety focused carrier, we are concerned about the proposed changes to CSA and the negative effect they will have on the motoring public’s safety. As a carrier that hauls approx 1% low risk hazmat freight and thus has very few hazmat inspections, any violation received would cause large spikes in our score and create an unfair bias against carriers that do very little hazmat. A vehicle with a hazmat load is no more likely to be involved in an accident than a non-hazmat vehicle.The risk associated with hazmat is already accounted for by implementing lower thresholds for hazmat carriers, additional regulations, and increased training for hazmat endorsed drivers. A vast majority of the violations involve paperwork and placarding issues that do not seem to support the goal of reducing crashes.We have yet to have an accident contributing factor of "improper placarding". Overall, the severity weights do not seem to correlate to crash risk. We don't believe one missing placard increases crash risk, whereas a cargo securement issue can and those violations have now been diluted to the point of nonexistence.Eliminating the Cargo BASIC will result in carriers with load securement issues not being properly tracked. Flatbeds are more open to safety issues because the cargo is not enclosed and has a greater risk of impacting the motoring public. Since there is more risk, the scrutiny of flatbeds is in line with the goals of CSA. A level 3 inspection should be included as a relevant inspection when hazmat freight is noted.The officer is reviewing our driver's logs/BOL’s and thus a carrier should get credit for a "clean" hazmat inspection especially when the converse is true.We ask that the proposed Hazmat BASIC not be implemented. We recommend that the Cargo BASIC remain intact and the weightings of the cargo/hazmat violations be adjusted accordingly and remain non-public until the results and scores can be monitored further in conjunction with crash risk contribution.