OOIDA says study of CSA flaws stops short of root causes

By Jami Jones, managing editor

A study of the CSA program by the National Academies of Sciences, which found the concept of the program defendable on paper but falling short on execution, missed the core problems, according to OOIDA.

The study by the National Academies of Sciences validates a number of concerns and criticisms of the program articulated by the Owner-Operator Independent Drivers Association. But the Association felt the overall study fell short.

“Now we understand that the panel was not going to attack the FMCSA for its attempt to discriminate between safe and unsafe motor carriers,” OOIDA Executive Vice President Todd Spencer said. “What we did not expect was for the panel to gloss over the unscientific methodology used in the system nor did we expect the panel to defend conclusions and a system based on bad methodology and data insufficiency.”

The study was prompted by Congress in the Fixing America’s Surface Transportation Act, or FAST Act. The highway bill, signed into law in 2015, recommended that the Federal Motor Carrier Safety Administration fund a study by the National Academies of Sciences, Engineering and Medicine. The purpose of the study was to evaluate the Safety Measurement System.

The SMS serves as the backbone of the Compliance, Safety Accountability, or CSA for short, safety measurement program. The FMCSA uses the CSA program in an attempt to predict what motor carriers are more likely to be involved in crashes. As part of the program motor carriers are ranked in six BASICs, which are categories of similar regulations. Motor carriers with high rankings are considered at risk and are subject to enforcement interventions by the agency.

Criticism has mounted since the agency began its soft rollout in 2010. Eventually, in 2015, Congress essentially mandated a study to get to the bottom of whether the program was flawed.

The National Academies of Sciences tasked a panel of researchers with the job.

“(The Safety Measurement System) is structured in a reasonable way, and its method of identifying motor carriers for alert status is defendable,” the panel states in the report’s summary.

“However, much of what is now done is ad hoc and based on subject-matter expertise that has not been sufficiently empirically validated. This argues for FMCSA adopting a more statistically principled approach that can include the expert opinion that is implicit in SMS in a natural way.”

The core objective of the SMS and CSA is to reduce crashes. It’s a simple concept with complex factors impeding execution, according to the National Academies study.

The report identified a number of data quality issues and recommended that FMCSA should continue to collaborate with states and other agencies to improve the collection of data. Types of data specifically identified include vehicle miles traveled and crashes, but the data are often missing and of unsatisfactory quality.

The study panel also acknowledged it is not just about how many miles a truck or company runs, but where it runs. Including the vehicle miles traveled data by state and month will enable SMS to account for varied environments where carriers travel – for example, the panel points out, in icy winter weather in the North.

In addition, the report says FMCSA should research ways of collecting data on carrier characteristics – including driver turnover rates, type of cargo, and method and level of compensation. For example, compensation levels are relevant because it is known that drivers who are better compensated, and those not compensated based on miles traveled, have fewer crashes. This additional data collection would require greater collaboration between FMCSA and the states to standardize the effort and to protect carrier-specific information.

The committee that conducted the study and wrote the report was unable to recommend whether SMS percentile ranks should be made public because it would require a formal evaluation to understand the consequences of public knowledge of the distributed information. LL