Here’s how to fix flawed CSA scoring methodology

In a rare show of solidarity, various trucking interests are asking the Department of Transportation’s Federal Motor Carrier Safety Administration to remove online safety ratings of individual motor carriers until flaws in the CSA methodology are fixed.
 
Among the 10 groups asking FMCSA to take down the safety ratings are such divergent interests as the American Trucking Associations (representing mostly large trucking companies), the Owner-Operator Independent Driver Associations (representing owner-operators)—who rarely agree that Christmas falls on Dec. 25—and three groups representing the bus industry.
 
“The CSA system is a good system but it needs to be fixed,” Pitt Ohio President Chuck Hammel told LM. “Once it is fixed and becomes a fair system, then there needs to be enforcement at both the company and driver level for the system to work as designed.”
 
CSA (which stands for Compliance, Safety, Accountability) began three years ago as a way to crack down on unsafe fleets and drivers CSA was designed to weed out as many as 5 percent—or 150,000—of the nation’s 3 million or so long-haul truck drivers that the government believes are involved in a disproportionately high number of truck accidents and fatalities.
    
CSA uses seven “Behavior Analysis and Safety Improvement Categories,” known as “BASICs.” These seven “Basics” are designed to identify specific driver and carrier safety performance issues. The seven are: Unsafe Driving, Hours of Service, Driver Fitness, Controlled Substances and Alcohol Abuse, Vehicle Maintenance, Hazardous Materials Cargo, and Crash History.
    
All roadside violations are counted against driver and carrier safety performance ratings. Violations are ranked based on severity ratings, with higher point values assigned to safety violations deemed to increase the probability of highway accidents. Point values are rated from 0 to 100.
    
All carrier scores except Hazmat and Crash History are available to the public on the FMCSA web site, at https://csa.fmcsa.dot.gov. The lower the number, the safer the fleet. Any score above 65 warrants a “warning letter” from the government. A score above 65 means that 35 percent of carriers in their class have worse scores. For hazmat carriers, the cutoff score is 60.  The problem stems from the methodology

“As it stands today a high score might not be as high if the flaws in the system are straightened out,” says Hammel, whose Pitt Ohio company has won numerous national safety awards and is known nationally for its proactive safety programs.
  
It’s not just trucking companies and owner-operators complaining. In February, the Government Accountability Office (GAO) issued a scathing report on CSA, saying it found substantial flaws with its Safety Measurement System that rates carriers.

According to trucking industry sources, there are five major flaws with CSA, They are:
 
Validity of BASICs: There is no scientific validation to support that the SMS BASICs of unsafe driving and fatigued that correlate to the likelihood of crashes based on the current methodology of capturing and calculating these BASICS and thus they should be modified accordingly. One huge issue is the crash BASIC. Truckers say even though this is not released to the public they can see their our scores, and those scores do not take into account preventable accidents compared to non-preventable accidents. For example, 83 percent of our DOT reportable crashes are non-preventable.
 
Carrier Peer-grouping (Straight vs. Combination) relative to the Unsafe Driving and Crash BASICs:  Due to fleet composition, companies with straight trucks can have higher scores even though straight trucks are less risk than tractor trailers. Potential solutions to this issue could include raising the straight truck peer group percentage cutoff and/or revising the FMCSA Form 150 census reporting process to better reflect the true nature of carriers with straight trucks and their operations versus over the road operations.
 
Stacking of Violations: Truckers say enforcement needs to be uniform and fair. Putting the same violation down repeatedly on an inspection because there is more than a single observation of the very same violation is unfair, they say. If it is a violation, note it and move on. Noting multiple incidences of the same violation from the same cause—i.e. a loose wire, brakes out of adjustment etc—is unfair and leads to skewered scores.
 
Flawed enforcement and adjudication of CSA roadside violations at the state level/Lack of Due Process:  Due to the varying policies and procedures at the state level, CSA roadside violations are not uniformly issued or adjudicated throughout the country. Individual carrier exposure to the legal and operational idiosyncrasies of particular states results in disproportionate and disparate outcomes within the CSA scoring methodology. One well-documented example of this concerns the Unsafe Driving BASIC and the grouping/ranking of carriers that operate in and around so-called “probable cause states” with carriers from other jurisdictions that issue substantially fewer speeding and other warnings/citations.
  
DataQ process needs major overhaul:  Currently the DataQ disputes are handled by the very officers who wrote the violations to begin with. If a carrier disputes a violation and request a correction, the officer is basically admitting that he made a mistake. If the DataQ process is denied there is a limited recourse for the carrier. There should be an appeal process to FMCSA available for disputed violations, carriers say.
 
The trucking groups, in an Aug. 22 letter to Transportation Secretary Anthony Foxx, asked the DOT’s FMCSA unit to stop posting CSA scores of carriers online until these technical changes can be made.
 
“Our organizations understand and appreciate the merits of using safety measurements to publicly distinguish carriers that are involved in crashes or cited for violations that are related to crashes from those that are not,” the truckers’ letter says, adding that accurate CSA scores must be a “high priority” for the agency.
 
“We recognize that assignment of accurate and consistently reliable scores is a very difficult goal for FMCSA to achieve,” the truckers’ letter continued. “But it is nevertheless one that the agency must be committed to attaining.”
 
FMCSA, while not formally responding to the truckers’ request, has said in the past that adopting the GAO’s one-size-fits-all methodology of scoring fleets would break its budget because it would require tripling the number of roadside inspections it performs to more than 10 million a year.
 
FMCSA is also in a period of flux. Anne Ferro, FMCSA’s top administrator for the first five and a-half years of the Obama administration, suddenly resigned in late August. The agency has named its top attorney, Scott Darling, acting administrator. But it is unclear whether he will be named permanently, or that he even wants what is largely seen in Washington circles as a thankless job.