Remove Non-Fault Crashes from the CSA Data Already

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The American Transport Research Institute released a report Assessing the Impact of Non-Preventable Crashes on CSA Scores. Many in the industry have concerns about CSA’s accuracy in predicting crash risk. Under CSA, both carriers and drivers receive safety scores across seven BASICs. The research indicated that rating carrier safety performance by the cumulative number of alerts across BASICs could better identify high risk carriers better than the metrics currently used. CSA is plagued with data integrity errors according to a study by the University of Michigan Transportation Research Institute (UMTRI) and the Government Accountability Office (GAO). The GAO says "validating the relationship between crash risk and violations is difficult". The GAO also found that most carriers do not have sufficient safety performance information to make reliable comparisons between carriers. The Crash Indicator BASIC calculation includes all crashes regardless if a carrier or passenger vehicle was at fault. Modifying the Compliance, Safety, Accountability Program Would Improve the Ability to Identify High Risk Carriers.

The Crash Indicator BASIC calculation affects the livelihood of motor carriers. Carriers with a bad Crash BASIC can lose business, have higher insurance costs and litigating attorneys can cite the Crash BASIC during a trial as an indication of a careless carrier. The ATRI study says "The influence that BASIC scores have on the productivity and viability of a carrier make it paramount for the measures to accurately reflect a carrier’s safety performance. In addition to the economic viability of carriers, the absence of preventability determinations in crash reporting procedures creates impacts across a number of industry stakeholders."

The trucking industry understands that poor decisions based on bad data affects their ability to operate. But, FMCSA is concerned with the additional cost of collecting better data. FMCSA estimated that identifying and incorporating at-fault determinations to the Crash BASIC would cost between $3.9 and $11.2 million annually, with an initial startup cost of $1.1 million dollars. FMCSA's cost of better data collection should not be an issue. Especially, when they make decisions from that data and it affects our costs.

The American Transport Research Institute and the Government Accountability Office should look at one more dataset to remove or adjust-the aggregated numbers of all crashes. FMCSA's definition of a Commercial Motor Vehicle skews the aggregated data and makes the trucking industry look bad.

§ 390.5: Definitions
Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle

(1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or

(2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or

(3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or

(4) Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C. In turn, their definition skews the public's perception of the trucking industry, litigation and insurance premiums. FMCSA includes every crash involving a pick-up truck above 10,001 pounds (GVWR). A 15 passenger van is included in our data. Sunday's van fire in Maryland is included in the heavy truck crash data. An oil field worker that rolls his pick-up on a country road effects the trucking industry.

A 15 passenger van accident is included in our data. Sunday's van fire in Maryland is included in the heavy truck crash data. An oil field worker that rolls his pick-up on a country road effects the trucking industry. FMCSA's data affects all aspects of our business. They have a duty to protect the public AND they have a duty to the trucking industry. They can't forget about their duty to us.