The Federal Motor Carrier Safety Administration (FMCSA) published a request for comments in the February 15th issue of the Federal Register. They are seeking comments on proposed revisions to the Safety Measurement System (SMS). Data contained in the SMS is used to generate CSA percentile scores which are then used to prioritized motor carriers for intervention. The comment period ends May 16, 2023.
Some of the changes are minor, others represent a major revision. FMCSA maintains that these changes will enhance the ability of SMS to predict at risk motor carriers. Ever since SMS was established in 2010, the motor carrier industry, and some outside the industry, have questioned the validity of this claim. Regardless, SMS and the resultant CSA scores have a wide impact since they are available to the public. This data is used not only by enforcement officials but also shippers, insurance companies and even plaintiff’s attorneys.
FMCSA is calling the new structure Prioritization Methodology and is reorganizing the BASICs into Safety Categories as follows:
Revised Unsafe Driving. Controlled Substances / Alcohol and Operating while Out-of-Service violations are incorporated into this category.
New Vehicle Maintenance: Driver Observed. These are violations that should be observed by a driver during a pre-trip inspection.
Revised Vehicle Maintenance. All other vehicle maintenance violations.
No changes in the following categories:
- Crash Indicator
- HOS Compliance
- HM Compliance
- Driver Fitness
Under this new methodology the existing 959 roadside violations, along with an additional 14 violations, will be organized into 116 violation groups of similar behaviors. Under the current methodology, multiple violations can be cited for the same underlying safety issue during a roadside inspection. Under the new methodology, multiple violations in the same group will be treated as one violation for scoring purposes.
If a motor carrier is cited for two or more of the violations above in the same inspection, these violations would all appear in the inspection report. However, when FMCSA analyzes the carrier’s data to determine if the carrier should be prioritized, the proposed methodology would count this set of violations as one violation under the “HOS Requirements” violation group.
The 1 – 10 scale for severity will be changed to either 1 or 2. All violations will have a severity weight of 1 except out-of-service violations and driver disqualifying violations as defined in 49 CFR §383.51 which would have a severity of 2.
The new Vehicle Maintenance: Driver Observed and Vehicle Maintenance safety categories will both have the same thresholds as the current Vehicle Maintenance BASIC:
- 80% for general carriers.
- 65% for passenger carrier carriers.
- 75% for HM carriers.
The HM Compliance thresholds will increase:
- From 80% to 90% for all carrier types.
The Driver Fitness thresholds will increase:
- From 80% to 90% for general carriers.
- From 65% to 75% for passenger carriers.
- From 75% to 85% for HM carriers.
Safety Event Groups
Under Prioritization Methodology, safety event groups will no longer be used. Many carriers have experienced a large swing in their scores after being assigned to a different safety event group, and this has been an industry complaint for years.
Instead, “proportionate percentiles” will be used to eliminate the large fluctuations in percentile results that occur for non-safety related reasons under the safety event group approach. Proportionate percentiles would use the exact number of safety events to assign a percentile for a motor carrier.
Greater Focus on Recent Violations
Prioritization Methodology retains the SMS data sufficiency standard for Unsafe Driving and extends this same standard to the HOS Compliance, Vehicle Maintenance, Vehicle Maintenance: Driver Observed, HM Compliance, and Driver Fitness safety categories. This means that a carrier with violations in any of the above safety categories that are all 12 months or older would not be assigned a percentile and not be prioritized in that category based on roadside inspection data alone.
Updated Utilization Factor
The Utilization Factor helps ensure that measures for Unsafe Driving and Crash Indicator account for carriers’ different levels of exposure to inspections and crashes. The Utilization Factor has been increased to 250,000 VMT per average PU to account more accurately for the increased levels of on-road exposure to crashes and on-road enforcement of motor carriers with the most VMT per vehicle.
Segmentation accounts for differences in carrier operations by segmenting carriers by whether their company operates primarily Straight vehicles or Combination vehicles in the Unsafe Driving and Crash Indicator categories. Under Prioritization Methodology this is extended to Driver Fitness as well. Also, HM Compliance will be segmented by Cargo Tank and Non-Cargo Tank carriers.
A new website, see link below, is now live. Motor carriers can visit the website to preview how their data would appear under the proposed changes. Companies are encouraged to preview these results and submit feedback on the proposed changes.
Vehicle Maintenance Comments
Dividing Vehicle Maintenance into two categories is an interesting concept. There’s no doubt that a quality pre-trip followed up by prompt follow up to repair defective items is critical to avoiding roadside inspection violations. However, a deeper dive into the violations that would be part of the Vehicle Maintenance: Driver Observed category reveals the following:
- Insufficient brake lining thickness
- Insufficient braking force as a percentage of gross combination weight
- Bolts securing cab broken, loose, or missing
- Mismatched brake chambers on the same axle
- Front axle and any other steering component cracked or repair welded.
- Upper coupler assembly cracked greater than 20% across in the direction of the crack
These are just a sampling of the violations. Many of the violations listed under this new category are certainly easily detected and include the usual lighting and tire problems. However, drivers are not examining brake lining thickness or brake chambers for a mismatch. They certainly do not have the training or technology to determine braking force as a percentage of gross combination weight.
CSA is not going away, and some of the proposed changes will be helpful, such as getting rid of safety event groups. However, comments from the industry will be crucial to steering FMCSA away from creating new problems.