Let’s consider what the genius who imagined the math behind the workings of the universe might think about the Compliance, Safety, Accountability program.
Einstein preached simplicity. His E=mc2 was, on the face of it, magnificently simple. But Einstein knew it didn’t tell the whole story. And, more to the point, he wasn’t that great at math (for a theoretical physicist, anyway), so for him simple was always better. What’s this got to do with trucking? Let’s find out.
Even Einstein could do this math. Can you? One formula is very old, one is very new. Let’s call these Formula A and Formula B. Go to the next page when you’ve figured them out, or when you haven’t.
Over the several hundred years before another revolutionary scientist, Galileo, pointed his telescope at Jupiter, astronomers had developed a very complex method to calculate the way the planets rotated around Earth. There was a problem, of course: The Earth wasn’t the center of the universe. But by golly, some very bright people had made the wrong math, featuring epicycles (orbital loop-de-loops), work better and better as a way to calculate the motion of the planets. Above is a graphical representation of this geocentric model, and Formula B is a key element to figuring it out.
This is the FMCSA flow chart of the CSMS methodology, the heart of the CSA model. Not nearly so messy as epicycles, at first glance. Formula A is the calculation for a motor carrier’s score in a BASIC, and it’s not really that complicated either – except for all the moving parts. BASICally, if one variable in the formula has a problem, the whole system has problem. Even Einstein knew that. But what could go wrong here? Let’s see …
For starters, everything in CSA depends on the quality of data. And getting uniform regulatory inspection results from 50 state trucking enforcement agencies on hundreds of thousands of DOT-authorized motor carriers is a monumental task. While FMCSA has made good progress in improving state reporting systems, states continue to assert their right to pick and choose which trucking regs are important to them. See the award-winning CCJ series examining the CSA Data Trail for more details. Then there’s the whole crash accountability problem. Moving on …
FMCSA deserves credit for continually working to improve the CSA scoring system. Critics, however, might call this “tinkering” or even “moving the target.” Going back to the first rule of data processing, “garbage in, garbage out, ” the problems with inspection data inconsistency show up here in the measurement phase. “It’s not how you run, it’s where you run” is a common carrier complaint.
The math really hits the fan in the safety evaluation phase, or it would if the system worked as intended. A Government Accountability Office review of CSA recently determined that only 13 of the 750 regulations it examined consistently had an association with crashes, and only two violations had sufficient data to establish a “substantial and statistically reliable” relationship with crash risk. So, many agency interventions could be called into question – to say nothing of FMCSA’s refusal to remove carrier scores, despite these issues, from the public website.
But as the latest audit by the DOT’s Office of the Inspector General concluded, FMCSA’s intervention efforts are sorely lacking: Only 10 states have fully implemented CSA enforcement interventions. The good news for carriers is that the proposed rule using the CSA math as grounds for carrier safety fitness determinations has been slow in coming; the bad news is that, even with the CSA engine missing on several cylinders, FMCSA is still pushing for the rule.
Prof. Einstein has the answer, theoretically. FMCSA and the trucking industry must work together to improve safety, and these 3 Rules of Work most certainly apply to CSA. Of course, that’s simpler said than done – but the framework is a good place to start. Let’s work on that next time. Until then, all suggestions welcomed.