Okay, so much like everyone else who reads this column, I continue to be perplexed over the Federal Motor Carrier Safety Administration’s intent on issuing a proposed rule that determines the safety fitness of motor carriers that operate on our nation’s highways using the very same data that helps derive a carrier’s CSA BASIC scores.
Here is a rulemaking that has been long awaited, overdue in fact, since one of the main goals of CSA—when it first hit the streets in the original test states—was to eventually determine whether or not a carrier was unfit for operations. Heck, I was attending working group sessions for CSA back in 2008 when it was merely a concept surrounded by unicorns and leprechauns, and this rulemaking represents the first proposed rulemaking of its kind regarding CSA.
Before this column takes the inevitable turn towards the shortcomings of CSA and whether it is working or not, let’s marry CSA to the recently passed FAST Act (a.ka. Fixing America’s Surface Transportation Act), our industry’s newest long-term highway reauthorization bill. They said it could not get passed. They said we would be waiting until after the election, 2017 at the earliest, before we had meaningful long-term legislation.
Well, Congress beat the odds and we have the legislation, but in regard to CSA, the question remains as to whether it is meaningful.
The FAST Act recognized the flaws of the carrier safety measurement system and directed a study be done to remedy those flaws. In fact, the FAST Act even led to the removal of those flawed, inaccurate scores from the public eye until it was determined how those scores could be fixed to more accurately reflect the safety performance of the carrier.
Even more importantly, the FAST Act decided that any carrier safety fitness determination could not be derived from CSA-related data—and that very statement is where it gets a little murky.
CSA BASIC scores are derived from data and a carrier’s safety fitness will be determined by that
data, yet the FAST Act prohibits that. Huh?
Not sure if I read that right.
A carrier’s safety fitness will be determined by data from agency and roadside inspections and investigations, or both—you know, sort of like how FMCSA determines a carrier’s CSA BASIC scores.
Well, if it looks like a duck and quacks like a duck, then chances are that it is a duck.
Yes, Administrator Scott Darling said that determining a carrier’s safety fitness is entirely different than rating a carrier’s safety program using the same data. Really? I think he’s gone too far this time.
What the agency is refusing or even neglecting to acknowledge is that our carrier members don’t have a problem being judged, but they do have a problem being judged incorrectly.
When using the same poor data to develop an entirely new score, your new score will undoubtedly be poor as well. It’s that whole garbage in, garbage out philosophy. At some point, the agency must acknowledge that the problem is not the score but rather the data used to derive the score.
Fix the data and inevitably the score will take care of itself, and then the agency and the industry itself will recognize a carrier safety measurement system that does what it is designed to do—and that is to measure safety.
