FMCSA hits back on CSA measurement system’s effectiveness with new report

Amid increasing calls from industry, law enforcement and some members of Congress for the Federal Motor Carrier Safety Administration to remove the Compliance, Safety, Accountability system’s rankings/scores from public view, a new analysis from FMCSA reiterates what the agency has said all along about the CSA Safety Measurement System, which ranks carriers according to their violations in seven “BASIC” categories of measurement. The agency uses those measurements to prioritize carriers for intervention in an effort to improve regulatory compliance and, the agency contends, highway safety writ large.

The CSA Safety Measurement System “ensures that there is oversight on the largest population possible—including both small and large carriers,” the report’s summary states. “Since introducing the use of the system, violation rates have dropped by 14 percent. Motor carriers are paying attention to their safety data more than ever before, which improves safety on the roadways.”

The analysis was requested attendant to a March House appropriations bill and follows concerns with data sufficiency identified by the Congressional Government Accountability Office in February of 2014. GAO took issue with the number of inspections FMCSA requires before assessing a carrier in any of the BASICs, as few in some instances as three inspections with an associated violation. In essence, GAO suggested a higher volume of data — whether number of inspections, past crashes or other metrics — would make the measurement system a much better mousetrap. In an alternative methodology, it utilized 20 inspections as a data-sufficiency standard.

In FMCSA’s new report, the agency once again takes issue with “GAO’s alternative approach” for its stated focus “on those carriers that have already had a crash,” it says. FMCSA “believes that motor carriers that commit patterns of violations that have been shown to have a strong correlation to crash risk should be identified and appropriately prioritized for intervention,” such as a warning letter about rising rankings/scores or an on-site investigation, “before a crash…. The assumption that a motor carrier that has no crashes during a limited observation period also has no crash risk, irrespective of demonstrated poor on-road performance and safety non-compliance across multiple inspections, is incorrect and irresponsible.”

As part of the data sufficiency analysis, FMCSA noted that the SMS “contains sufficient data,” or enough to produce a ranking in any BASIC category, “on approximately 200,000 of the 525,000 active motor carriers.” Those 200,000 carriers, the agency notes, account for more than 90 percent of all recordable crashes.

It offered the following table to show the crash rates of carriers with sufficient and insufficient data in the system to produce a score. Crash rates were measured, significantly, after the data snapshot was taken.

Carriers with the highest scores, those above intervention thresholds, had the highest average crash rates overall, the agency notes. Further, FMCSA looked at the crash rates of groups of carriers with scores above the intervention thresholds in BASICs other than the Crash Indicator, separating those populations by the number of inspections recorded by the system. The highest crash rates were shown not for those with the highest number of inspections but for those with 11-20 inspections in the system.

From that analysis, the report contends that increasing the data sufficiency standards as high as 20 inspections would make it more difficult for the agency to appropriately intervene with the group showing that highest average crash rate.

The report comes to light following Congress’s most recent attempt to include language in a long-term highway bill that would pull the CSA SMS BASIC rankings from public view. This most recent attempt fell apart with the highway bill itself and the short-term funding extension currently in place. The agency in part addresses public-view concerns with a small section on a goal of “transparency” in offering public inspection and violation data on a central website. “Open and transparent reporting of safety data encourages a culture of commercial motor vehicle safety and creates incentives for motor carriers to improve their safety performance,” the report notes. The agency appears to have fully embraced third-party use of the SMS with this report as well, adding that “transparency also allows members of the public to make informed business decisions based on all available sources of FMCSA data, including FMCSA safety ratings, licensing and insurance information, and SMS data.”

Such public, commercial third-party use of the system (such as by shippers, brokers and insurance companies), given volatility in the rankings at the small-carrier level, has been a principle concern of that population of carriers through much of the system’s history.

To download a full copy of the new FMCSA analysis, follow this link.

Also, FMCSA is currently at work on a rule designed to revamp the safety rating process to primarily utilize violation data procured at roadside and during carrier investigations. Known as the Carrier Safety Fitness Determination rulemaking, a DOT significant-rulemakings calendar projection of a September 30 date for release passed without incident. The October significant-rulemakings report has not yet been published.

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