Qualified Carriers Blog
Wednesday, July 5, 2017
Update on the CSA Program, June 30, 2017
One of the tools QualifiedCarriers.com
provides clients, is the ability to set your own thresholds for a variety of
motor carrier safety and/or compliance data, with FMCSA’s Compliance, Safety
and Accountability (“CSA”). Congress commissioned The National
Academy of Sciences (“NAS”) to conduct a comprehensive review of the CSA
program to test the validity of the system and the impact of its scores on the
public who might consider using them. The NAS has completed its review. We’ll
highlight some of the findings.
The program was found to be “structured
in a reasonable way,” that it has sound reason behind the method of identifying
motor carriers with a certain alert status, but that it should be done by a
more statistical, measurable, principled approach. NAS took issue with FMCSA’s
use of experts instead of relying on data.
The NAS did not make a recommendation
as to whether SMS results and scores should be available to the public.
However, the NAS recommends that the Agency conduct a detailed review and
analysis of the potential impacts that those scores will have on the industry
and the public if they are made readily available. With this said, CSA’s
percentile scores may be hidden while that impact study is performed.
NAS recommended multiple quality and
transparency improvements be made by FMCSA. Specifically, CSA should be a
system that relies more upon data than selected expert opinion; FMCSA should
embrace transparency so data quality can be tested and improved; NAS supports
the direct estimation of variability in scores and rankings; all of which should
allow FMCSA to better adapt to changes in the future. Additionally, NAS
encouraged FMCSA to collaborate closely with state law enforcement to improve
data quality and to implement a National Minimum Uniform Crash
Criteria—something some in FMCSA and safety advocates have been loath to
accept.
NAS provided additional advice to
FMCSA, suggesting it consider evaluating both percentile ranks and absolute
measures, when making decisions regarding whether to issue a carrier an SMS
alert. Presumably, NAS recognized that forcing a percentile number, is akin to
grading on a curve. Considering both absolute and percentile scores allows law
enforcement to have a bigger, better picture.
Finally, NAS’ review contained one
already new and controversial suggestion. NAS, wrote of its desire to see FMCSA
collect more operational and financial information on carriers, including
compensation style and data, driver turnover and other data that might provide
more complexion. The controversy lies in the compensation piece. Ironically,
while NAS suggests FMCSA rely more upon data than expert, it ran afoul of its
own advice when it referenced an expert opinion that salary drivers are “known
to be” safer than drivers paid on a mileage basis. No comprehensive or
definitive study on this exists.
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