On August 14, 2018, the Federal Motor Carrier Safety Administration (FMCSA) released its report to Congress outlining the corrective action plan for addressing the National Academy of Sciences (NAS) study on Compliance, Safety, Accountability (CSA).
By way of background, Section 5221 of the Fixing America’s Surface Transportation (FAST) Act required the National Research Council of the National Academy of Sciences (NAS) to conduct a correlation study of the Federal Motor Carrier Safety Administration’s (FMCSA) Compliance, Safety, Accountability (CSA) initiative and Safety Measurement System (SMS). The SMS is FMCSA’s algorithm for identifying patterns of non-compliance and prioritizing motor carriers for interventions. The FMCSA is prohibited from publishing percentiles and alerts on the SMS website for motor carriers transporting property until the Correlation Study is complete, and all reporting and certification requirements under section 5221 of the FAST Act are satisfied. FMCSA estimates it will need $2.5 million over two years for implementation of the action plan. This would include money for the creation of a standing committee, additional research, new labor costs for statistical modeling, and reallocation of contract resources from current work on SMS to work on implementation of the NAS recommendations.
FMCSA contracted with NAS to assist with its response to the report’s recommendations. NAS established a new Standing Committee that includes subject matter experts on organization safety, statistics, research and evaluation methods, motor carrier operations, enforcement, and IRT modeling.
The committee will provide expertise, guidance, and oversight to FMCSA in developing and testing IRT modeling, providing feedback and input on the other recommendations, and providing input on how to best measure motor carrier safety and system effectiveness. In addition, the Standing Committee will solicit input from stakeholders during the implementation process and will provide advice to FMCSA in the implementation of the recommendations. The Standing Committee will hold closed and open meetings to review FMCSA’s progress in implementing its action plan and to provide guidance and advice.
In addition, FMCSA is planning a public forum to discuss data issues and availability. Also, the Agency will establish a committee to provide feedback on the process of implementing the NAS recommendations under the Motor Carrier Safety Advisory Committee (MCSAC) to provide guidance and input as the process of implementing the NAS recommendations moves forward.
NAS Report Recommendations:
On June 27, 2017, the NAS released their comprehensive report on CSA and included six recommendations for FMCSA’s consideration. These included:
1. Investigate a new statistical model, within the existing structure of SMS, over the next two years. FMCSA should evaluate the model’s effectiveness at identifying motor carriers for intervention to inform the decision of whether to implement this new model.
2. Improve the quality of Motor Carrier Management Information System (MCMIS) data that feeds SMS by continuing to collaborate with States and other agencies. This effort should focus on data related to crash reports and carrier exposure (e.g., Vehicle Miles Traveled, Power Units, etc.).
3. Explore ways to collect additional data that could enhance the recommended methodology for safety assessment. This data could include carrier characteristics such as driver turnover rate, type of cargo, method and level of compensation, and better information on exposure.
4. Make user-friendly versions of the MCMIS data file, and computer code used to calculate SMS results, available to the public. The MCMIS file would not include any personally identifiable information and the computer code would comply with reproducibility and transparency guidelines.
5. Conduct a study to better understand if percentile ranks should be available to the public. This study should aim to determine whether percentiles are effective at identifying carriers for intervention. Findings from this study should inform the decision of whether to make percentiles public.
6. Use absolute measures, in addition to relative percentiles, to determine which carriers are prioritized for intervention. The percentiles should be calculated within carrier safety event groups and across all carriers.
FMCSA Corrective Plan Actions:
1. FMCSA is moving forward to develop and test an IRT model. That model will be used to inform the Agency’s work with opportunities for public input. As recommended by NAS, if the new IRT model performs well, it will replace the existing SMS. FMCSA will not substantively modify SMS while they are testing the IRT model to ensure they have a stable comparison to evaluate effectiveness.
2. The Agency agrees that more frequent and more detailed VMT data from motor carriers would reduce the need for FMCSA to use substitute values and would improve the quality of the data in SMS. The FMCSA currently only collects carrier VMT data every two years. Access to this data, by State, on a monthly basis is not currently feasible, but the Agency will continue to identify possible sources for this important data.
3. The Agency agrees that additional information about carrier operations might improve the Agency’s analysis and identification of non-compliant motor carriers. However, the collection of this data would come at a cost, and the benefits are unknown.
4. The FMCSA agrees that there could be benefits from making MCMIS data available to researchers and carriers. As a result, the Agency’s first effort will be to improve data availability. The FMCSA will develop a webpage where researchers, carriers, safety consultants, and the public can obtain simplified MCMIS data snapshots.
5. The FMCSA will be gathering public input from motor carriers, insurance companies and shippers regarding the ways in which the public uses SMS data. Using the data collected in these public listening sessions. FMCSA will scope and complete a study specific to the issue of percentile ranks and the usability of public scores.
6. Once IRT modeling is complete, FMCSA will evaluate the use of absolute measures for set intervention thresholds. Absolute measures and percentiles are products of the SMS system. At this time, it is not known how these would be affected once the Agency completes the modeling recommended by NAS. Therefore, FMCSA defers action on this recommendation until it is confirmed this would be relevant.
To view the full corrective action plan, click HERE.
TIA staff and the TIA CSA-Carrier Selection Framework Subcommittee will continue to review the corrective action plan and participate at all public listening sessions to ensure that the voice of the 3PL industry is heard. If you have any questions, contact Chris Burroughs at burroughs@tianet.org or 703-299-5700.