FMCSA’s proposed changes to its CSA Safety Measurement System fall short of the comprehensive overhaul that is needed, the Owner-Operator Independent Drivers Association says.
In comments filed to the Federal Motor Carrier Safety Administration on Tuesday, May 16, OOIDA told the agency that its proposal doesn’t take the steps needed “to accurately identify at-risk carriers and reduce truck crashes.”
“The overwhelming majority of data the agency collects and analyzes has absolutely no connection to crashes,” OOIDA wrote in comments signed by President Todd Spencer. “Thus, further relying on this data is a misguided approach that will not fix the inherent problems with the Compliance, Safety, Accountability and Safety Measurement System programs.”
In February, FMCSA published a notice with a proposal for changes to its CSA Safety Measurement System aimed at making it easier to identify companies that need intervention.
- Reorganized BASICS. Now called safety categories, the focus would be on motor carriers with higher crash rates with the goal of more accurately determining unsafe behaviors.
- Reorganized roadside violations. More than 950 violations would be condensed into 116 violation groups.
- Simplified severity weights. A 1-10 scale would be replaced by a 1-2 scale.
- Improved intervention thresholds. The thresholds would be adjusted for three safety categories to focus on carriers with the highest crash rates.
- Proportionate percentiles. The proposal would eliminate large percentile changes that occur for reasons unrelated to safety to more precisely indicate how a motor carrier’s performance is trending from month to month.
- Greater focus on recent violations. Percentiles would only be calculated for safety categories in which a carrier has received a violation within the past 12 months.
- Updated utilization factor. The goal would be to receive a more accurate account of on-road exposure of motor carriers with the most vehicle-miles-traveled per vehicle.
- New segmentation. Carriers would be segmented by operation and vehicle type in an attempt to improve carrier-to-carrier comparisons.
- Accounting for not preventable crashes. Results from the Crash Preventability Determination Program would be incorporated into the prioritization methodology.
“Safety is FMCSA’s core mission,” FMCSA Administrator Robin Hutcheson said in February. “The proposed changes are part of the agency’s continued commitment to enhancing fairness, accuracy and clarity of our prioritization system.”
Background
FMCSA implemented SMS in 2010 as part of an effort to identify high-risk motor carriers for investigation.
In 2017, the National Research Council of the National Academy of Sciences recommended that FMCSA develop and test a new statistical model. As part of its recommendations, the council said FMCSA should develop an item response theory model, which is a more statistically principled approach.
FMCSA tested the model and determined that it doesn’t perform well for the agency’s use in identifying motor carriers for safety interventions.
“Because (item response theory) is overly complex and adopting the IRT model would reduce transparency without improving safety, FMCSA will not replace SMS with an IRT model,” the agency wrote in the notice. “Instead, FMCSA continues its commitment to continuously improving SMS to identify motor carriers that present the highest crash risk through a transparent and effective system.”
OOIDA’s recommendations
OOIDA said that the system needs a comprehensive overhaul that will incorporate better data, encourage states to implement the National Highway Traffic Safety Administration’s Model Minimum Uniform Crash Criteria and support standardized enforcement programs across different states and geographic regions.
“OOIDA acknowledges the difficulties associated with applying an IRT model for the trucking industry,” the Association wrote. “However, we are concerned that outright rejecting the IRT model will mean that FMCSA does not give proper consideration to the panel’s other findings, given IRT was the NAS’ top recommendation.
“We adamantly disagree that the current and proposed system can be considered transparent or effective given the performance of these safety measurement programs since their implementation.”
FMCSA’s current proposal will not accurately identify at-risk carriers or help reduce crashes, OOIDA said.
“These programs will not achieve these objectives until they incentivize actual safety performance instead of regulatory compliance,” OOIDA wrote. “The majority of data the agency collects and analyzes has no connection to crashes. As such, further relying on this data is a misguided approach that will not fix the inherent problems within CSA/SMS.” LL
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