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scores public again. Transportation Secretary Anthony



Foxx recently commented, “Based on our preliminary assessment, it’s going to take a while to do the revised analy- sis,” referring to the changes in the CSA score methodology mandated in the FAST Act highway bill. “We expect it to take a year or two, probably more like two, before that information (CSA SMS rankings) will be posted back up,” Foxx continued. Some might have assumed that

cating how safe a carrier was; the fact that “administrative” types of violations in one category could carry the same severity weighting as a more egregious “unsafe behavior” violation in another; and, that all crashes – even those deemed non-preventable – were counted against a carrier. Despite the objections, the agency

continued to push the program forward, making periodic tweaks to the method- ology, but not addressing the underlying concerns. Eleven days after the CSA program

began, the Agency began socializing a new concept that would redefine the “safety rating” process, which ultimate- ly allows trucking companies to operate —or not. Under the existing process, safety

ratings fall into three categories: satis- factory, conditional, or unsatisfactory, and are largely if not solely derived from on-site Compliance Reviews (CRs). But with a ratio of almost 500 motor carri- ers for every one FMCSA employee, very few CRs are actually conducted. This has led to the majority of the industry being classified as “unrated”, and many carriers having had the same “satisfac- tory” rating for years with little or no interaction with FMCSA. Enter the Safety Fitness

Determination (SFD). In January, five full years after CSA

launched, a new SFD rulemaking was finally proposed by the FMCSA. The proposal introduced a single

rating of “unfit”, replacing the previous 34

three categories. So, carriers would be assumed to be operating in compliance, i.e. “satisfactorily”, but there would be no public indication as such, until or unless the carrier fell out of compliance, at which time the “unfit” label would be applied. Motor carriers could find them-

selves unfit through one of three differ- ent methods under the SFD proposal:

Unfit Method 1: Carrier with two or more failed BASICs from On-Road Safety Performance A reminder for readers that BASICs are the seven categories into which FMCSA grouped similar violations at the start of the CSA program. This method ties directly into and makes the most use of CSA data.

Unfit Method 2: Carrier with violations of the revised critical and acute regulations identified through an investigation Simply put, this method would make use of the most severe violations as determined by FMCSA.

Unfit Method 3: Combination of inspection data and investigation results

But a month before the Agency

announced the proposed rule, a lit- eral act of Congress, grounded in the long-standing concerns of the trucking industry, ended the public view of CSA scores (at least temporarily), and man- dated FMCSA address the significant defects in the system before making

FMCSA would hold off on issuing the proposed SFD rule until those defects were addressed. Those people would have been wrong. Comments to the SFD proposal

came quickly from the industry, with opposition centering on two primary concerns:

1. SFD is directly tied to CSA which has been pulled offline until reformed and should wait until such reforms are completed.

2. SFD is ineffective in using data to leverage the limited resources at the Agency’s disposal.

My company, Vigillo, has spent the

past seven years collecting and ana- lyzing CSA-related data and the CSA methodology on behalf of over 2,000 motor carriers, freight brokers and ship- pers who subscribe to our CSA reporting service(s). In our comments to FMCSA regarding the proposed SFD rule, we limited our input to Unfit Method 1 (data from roadside inspections). Since the inception of CSA, a critical justifi- cation of CSA itself was that the data would be an effective method of focus- ing enforcement effort on those motor carriers deemed to be riskier, so our analysis focuses on whether SFD in fact accomplishes that long stated goal. As the starting point for our

comments, we posed the question: Does the data driven component in this SFD (Unfit Method 1) give FMCSA and its enforcement partners insight into a meaningful number of high risk motor car-


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