If you’ve been reading my column or if you know me, then you know that I am a baseball fan.
In knowing baseball, you know that the term “Mendoza line” is used to basically define an incompetent hitter or one whose batting average drops below .200. That being said, think about the difference, in 500 at-bats, of being a .250 hitter vs. a .300 hitter. Batting .300 has often been a determination of success. Think about that difference though. Twenty-five hits out of 500 at bats—a minute sample to say the least—is the determining factor of being successful or basically average.
Without turning this into a column about baseball, my point is that the Federal Motor Carrier Safety Administration (FMCSA) is trying to better define a successful carrier and possibly an incompetent one by including the theory of preventability into a carrier’s CSA score or more specifically, the Crash Indicator BASIC.
In a notice of request for public comment issued in mid-July, the agency appears to be traversing down the road of addressing the preventability of crashes for motor carriers into its carrier safety measurement system, an action in which we, as the trucking industry, have been advocating for years and one that has even appeared in this very column (which I have been writing since 2009). In other words, FMCSA is taking the advice of an industry that has been touting this very action since CSA’s inception. It is also following the direction set by Congress in the FAST Act by possibly eliminating crashes that have been determined to be non-preventable from the carrier’s list of crashes posted on the SMS website. That is, if this rule ever makes it to fruition.
“It is now up to us to continue to comment on this notice so that we ... can accurately define safe and not-so-safe carriers.”
At one point, this industry had argued the premise that accidents that inherently were not the fault of the driver were being held against us. Regardless of crash accountability, the agency had stood its ground, providing that past performance, when it comes to crashes and unsafe driving, almost always was indicative of future results. We, as an industry, clearly did not succumb to that theory and constantly advocated that CSA was inaccurately portraying motor carriers because it didn’t take these accidents into account when determining crash scores.
Even last year, a study conducted by the agency stated that the difficulty and cost of including crash accountability in CSA outweighs the benefits of doing so and that incorporating fault does not consistently improve CSA’s ability to predict crash risk.
The reality is that we are dealing with crashes that would go under a review panel of sorts, and those crashes that consist of an opposing driver driving under the influence, driving in the wrong direction, striking the CMV in the rear, or striking the CMV while it was legally stopped would only be considered for the not preventable title, so to speak.
While these scenarios are not the be-all and end-all of determinations, they represent a start and a positive step for an industry that constantly hammered home the point that our carriers and the accidents they are involved in need to be more accurately portrayed.
We all know that there are times when drivers are placed in situations where there are no immediate solutions. The publication of this and the measures that the agency is taking represent a positive step that demonstrates that the agency is listening to us. It is now up to us to continue to comment on this notice so that we, as an industry, can accurately define safe and not-so-safe carriers by creating a Mendoza line of sorts for ourselves.
