While the American Trucking Assns. said it supports the Federal Motor Carrier Safety Administration’s (FMCSA) new process for improving its Compliance, Safety, Accountability (CSA) program, the system still has serious deficiencies that must be corrected, ATA said in comments filed with the agency on July 30.
But while the agency’s new approach to making methodology changes is better, it can be further improved, wrote Rob Abbott, ATA’s vice president of safety policy. “Specifically, greater visibility to the analysis and data upon which FMCSA develops changes would be useful. Not only would it help generate more informed comments, but it would help stave off skepticism of the program’s effectiveness and impact.
“For instance,” Abbott pointed out, “in the subject notice the agency made several references to effectiveness testing and analysis FMCSA performed to arrive at the planned changes, but did not initially make such analysis publicly available. Only after subsequent requests for these analyses did FMCSA eventually create and release a new document outlining the agency’s data supporting the proposed changes.”
And despite the more open process, Abbott said ATA still had significant concerns about the methodology — specifically the agency’s treatment of non-preventable crashes and the creation of a new category to exclusively measure hazardous materials safety.
ATA reiterated its support for FMCSA’s plan to create a separate category to measure hazardous materials carriers. However, ATA urged the agency to implement the change only after modifying and testing the methodology to ensure that carriers’ scores relate to future crash risk. Currently, the BASIC assigns high scores to many reputable, safe motor carriers with laudable crash rates and low scores in all other categories.
“While compelling fleets to improve compliance with HM regulations is important, the more pressing need — and the goal of CSA — is to identify fleets with a greater risk of crash involvement and to change their behavior,” said Abbott. “Doing so would undoubtedly be a more appropriate and efficient use of the system.
“There can be no better predictor of future crash risk than past at-fault crash involvement,” Abbott added.
Speaking to FMCSA’s recent announcement that it intends to spend a year conducting research before developing a process for determining crash accountability, ATA urged FMCSA to establish an interim process to remove from consideration those crashes in which it is “plainly evident” that the truck driver was not responsible for the crash.
ATA believes that FMCSA’s intent to identify carriers with the “greatest risk of future crashes” is a fundamentally flawed objective.
“Instead, the agency should seek out motor carriers with the greatest risk of causing crashes,” Abbott said. “Carriers at the greatest risk of being involved in future crashes are often those with greater exposure (e.g., urban carriers), not necessarily those with fundamental safety problems that could be impacted by an FMCSA intervention.”
Rather than devoting attention to carriers that endure greater exposure due to their operating environment, FMCSA should direct its limited resources where they would be most effective in preventing future crashes — “by focusing on carriers that are causing them. After all, doing so would help better meet the objective of CSA, to reduce crashes injuries and fatalities,” Abbott wrote.
ATA said it also supports moving load securement violations into the vehicle maintenance BASIC. The association also supports the revised criteria for applicability of lower thresholds to HM carriers in the other BASICs.
“However, the methodology for the HM BASIC must be modified substantially so that carriers’ scores reflect future crash risk. Only then will the HM BASIC help meet the program’s objective of reducing crashes, injuries and fatalities,” Abbott concluded.