ATA again asks FMCSA to shed light on CSA methodology

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The American Trucking Associations on Tuesday, June 12, continued to call out the Federal Motor Carrier Safety Administration on its Compliance, Safety, Accountability monitoring and measurement system, asking the agency to release a study of the links between violations and crash risk used to develop its methodology for assigning carriers’ scores.

“As a regulated industry, trucking has a right and a need to know how the system we operate under was crafted,” said Bill Graves, ATA president and chief executive officer. “FMCSA has an obligation to release this study so that the industry, and other stakeholders, may evaluate CSA and offer substantive proposals to improve it.”

FMCSA cited the study, titled “2007 Violation Severity Assessment Study Final Report,” as a component in the development of the severity weights in CSA, which are assigned to all violations on a scale of 1-10 based on their relationship to crash occurrence and consequences.

ATA said it has requested the study in writing three times since May 2010 and that the agency has refused not only these requests, but a request from its own Motor Carrier Safety Advisory Committee for the document. MCSAC has concluded there is a “… continuing need for further data collection to accurately establish crash causation relationships to justify ultimate weighting scores.”

Because MCSAC was not provided with such data, its recommendations with respect to appropriate violation severity weights largely reflected “guesswork” on the relationship between particular violations and crashes, according to its final report.

An evaluation of CSA conducted by the University of Michigan Transportation Research Institute, released by FMCSA in 2011, described the assignment of severity weights as “arbitrary” and went on to point out that “Whether the weights used in the calculation of the BASICs scores are appropriate is not known.”

“FMCSA’s reluctance to release this document, as well as other important CSA-related documents, sends the wrong message,” said Graves, referring to ATA’s recent request for the agency to release its study of crash accountability. “This pattern of failing to disclose critical background information, despite numerous requests, contradicts the agency’s claims of openness and transparency.”

ATA also has asked Ferro to release the full results of the agency’s study on using police reports to determine crash accountability. “FMCSA continues to use crashes that motor carriers did not cause nor could have prevented in measuring motor carrier safety performance,” Graves said.

Graves said that in an August 2010 letter to ATA, FMCSA acknowledged it was in the process of reviewing the findings of the feasibility study and offered to make them public upon completion of the review, but has yet to do so. “To better understand FMCSA’s reluctance to act, the public should see the results of the study the agency promised almost two years ago,” Graves said.

FMCSA Administrator Anne Ferro – updating attendees of the CCJ Spring Symposium in Birmingham, Ala., on the agency’s latest rulemakings – said the industry can be on the lookout for a Safety Fitness Determination proposal and perhaps a rulemaking in 2013.

The agency’s Safety Measurement System – the workload prioritization tool that helps FMCSA identify motor carriers for safety intervention – replaced SafeStat to determine which fleets should be eyeballed for roadside inspections and to provide fleets with better visibility. Under the Safety Fitness Determination, FMCSA could use that data to replace the onsite inspection process.

Ferro said fleet feedback from the CSA preview is critical. “Some in the industry are very concerned, and we need to know what those concerns are so that we can address them,” she told Symposium attendees.

Ferro estimated a current population of about 500,000 freight carriers and said that about 490,000 of those have no fatality numbers. “We have 200,000 carriers with sufficient data to analyze for all carriers, and 92 percent of all crashes are attributed to those carriers,” she said. “They represent 80 percent of the power units.”

Crash history is one of the stronger predictors of future crashes, said Ferro, discussing how FMCSA is addressing crash accountability in CSA’s Behavior Analysis Safety Improvement Categories. Ferro said the agency calls this process “crash weighting” – preventable vs. nonpreventable.

“We started to answer that question through police reports, but those vary from state to state,” she said. “Over the course of the 90-day filing period, the content may change. So our challenge is if we have the final final report?”

FMCSA on May 25 announced a 60-day extension of the time that motor carriers have to comment on proposed improvements to SMS. During the extended comment period that runs through July 30, FMCSA is conducting further outreach to carriers to encourage them to review how proposed enhancements will affect their SMS score and take action to correct potential safety problems before the changes are implemented.

Carriers can access the SMS Preview through either the CSA Website or the FMCSA Portal using the “CSA Outreach” link. For more information about CSA, visit