CSA’s statistical bias is unfair, does nothing for public safety.
In 2010, the Federal Motor Carrier Safety Administration (FMCSA) introduced the Compliance, Safety, Accountability (CSA) program. According to ATRI, CSA was intended to be a more targeted, robust system for identifying high-risk carriers and prioritizing carriers for intervention. While many in the industry find CSA to be an improvement over SafeStat, the industry is becoming increasingly concerned about CSA’s accuracy in predicting crash risk for one, and the impact the rating system has on operating costs, especially insurance.
FMCSA has made a number of changes to CSA since its debut in 2010 and recently implemented a new citation adjudication policy, which allows for the results of judicial proceedings that end in dismissed charges, reduced charges or a ruling of not guilty to be positively reflected in the Safety Measurement System (SMS) and the Pre-Employment Screening Program (PSP).7 This change aligns compliance scores with judicial proceedings which is only fair, but the new ATRI study shows FMCSA needs to address this fundamental issue on how CSA crash data is crunched.
Under the current SMS methodology all DOT-reportable crashes count against a carrier regardless of preventability determinations. Despite the Crash BASIC measure being restricted from the public, all DOT-reportable crashes that are used to calculate a carrier’s Crash BASIC measure are available to the public. “Many industry stakeholders have noted that not including a preventability determination in the BASIC formula may mislead conclusions about a carrier’s actual safety performance,” say ATRI analysts.
For example, if a legally parked commercial motor vehicle (CMV) is struck by another vehicle it qualifies as a DOT-reportable crash. In this case it’s obvious, neither the driver nor the carrier could have prevented the crash, yet accounting for such a crash skews the data and can lead to a statistical scarlet letter that the carrier is less safe.
It’s fundamentally unfair. According to FMCSA’s Crash BASIC fact sheet, “carriers should be aware that crashes in the previous 24 months adversely affect carriers’ SMS results and only not having crashes will improve carriers’ percentile ranking. Last time The only way a motor carrier can absolutely reduce crashes to zero is by parking the fleet. But then a carrier would not be in the shipping industry; it would be the proprietor of a very expensive parking lot. In its academic fashion, ATRI put it this way: “In the previous crash scenario the aforementioned policy is both untenable and harmful, warranting further investigation into assigning crash responsibility and its impact on a carrier’s Crash BASIC measure.” Yes. We couldn’t agree more.
Some safety advocates support the inclusion of all crashes, regardless of preventability, due to the correlation between past crashes and future crash risk, but failing to account for the difference between involvement and causation says ATRI, may result in an inaccurate representation of driver and carrier safety because it fails to control for exposure to other, unsafe drivers. No kidding.
Despite Crash BASIC measures being restricted from the public, including the data can still impact carriers and drivers significantly. ATRI says potential areas of impact include:
- Economic harm. Shippers can, and often do, require the disclosure of Crash BASIC measures and percentiles to assess the safety of a carrier. All other things being equal, carriers with a “bad” Crash BASIC score may be less likely to receive freight contracts than a “safer” carrier.
- Higher insurance costs. It is well understood that carrier BASIC scores are used as actuarial inputs for insurance risk assessments and determinations of premium levels.
- Legal consequences. Plaintiff attorneys may cite BASIC scores in legal proceedings, as an indicator of negligence and culpability.
- Lost productivity from more frequent inspections. The Inspection Selection System (ISS), a tool for selecting CMVs to inspect, is influenced by BASIC scores.
ATRI’s study says removing non-preventable crashes from the Crash BASIC would serve as an exposure adjustment, by removing all instances where involvement in a crash was the result of exposure to an unsafe but non-preventable externality. Thus the change would then better align Crash BASIC calculations with FMCSA’s mandate to identify carriers and drivers that pose the greatest risk to public safety. Further, ATRI says the influence that these scores have on carrier productivity and viability make it extremely important for this particular measure to accurately reflect a carrier’s safety performance.
Federal regulators, says a recent Transportation Topics item (“FMCSA Issues Driver Coercion Final Rule,” 11/30) have issued a final rule that prohibits carriers, shippers and brokers from coercing truck drivers to violate hours-of-service and other safety regulations.
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