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WHO’S UNFIT? UNFIT


CARRIERS


TOTAL UNIQUE DOT#’S TOTAL DRIVER COUNT TOTAL POWER UNITS TOTAL VMT*


DOT RECORDABLE CRASHES FATALITY CRASHES (FATALITY COUNT) 67


1,868 1,833


349,572,435 289 5


*The author considers VMT to be an unreliable data point.


riers beyond the roughly 15,000 compli- ance reviews conducted annually under the current Safety Rating System? To answer this question, Vigillo


decided to start with the data. Our meth- odology was to focus on Unfit Method 1, data collected at roadside inspections for the most recent 24-month period (April 2014–April 2016).


STEP 1: WHO IS ELIGIBLE? - We pulled 24 prior months of inspection activity to identify the eligible carriers (11 inspections with violations in the BASIC) and reviewed the inspection data of all 621,665 interstate motor carriers in the MCMIS Census file as of April 2016. The result was 50,585 motor carri-


ers deemed eligible for an unfit rating based on the 11 inspections threshold.


STEP 2: WHO IS UNFIT? - We looked at the CSA BASIC percentile scores for the five relevant BASICs for SFD including hazmat, vehicle maintenance, unsafe driving, driver fitness and hours of service. If a carrier exceeds 96 percent in hazmat, unsafe driving or hours of service, it fails the BASIC. If a carrier exceeds 99 percent in vehicle maintenance or driver fitness, it fails the BASIC. If a carrier fails two BASICs, it is labeled unfit. Note that we used


ARKANSAS TRUCKING REPORT | Issue 3 2016


the existing SMS methodology rather than the new SFD methodology to determine percentile scores. They have different safety event groups, so there could be some difference though it is unlikely to be significant. The result was exactly 178 inter-


state motor carriers who would fail two BASICs at those thresholds.


STEP 3: REMOVE VIOLATION CODE 391.11 (b) (2) – The SFD requires this violation, which deals with English-speaking drivers, be removed from the calculation of percentile scores for the driver fitness BASIC under SFD. The result of removing the viola-


tion code was a remaining total of 67 interstate motor carriers who would be labeled unfit after the three steps are completed and SFD is applied to the industry. Note that 100 percent of the carriers removed due to the non-English violation are domiciled in Mexico. Once we analyzed the data and


applied the SFD methodology to the DOT regulated trucking industry over the most recent two-year period, it is clear that Unfit Method 1 of the SFD brings no value in identifying a mean- ingful number of motor carriers as unfit. SFD identifies exactly 67 interstate


motor carriers as unfit if the SFD were applied to the industry as it existed


when our study was conducted. This is a .4 percent improvement above and beyond the 15,000 identified by the cur- rent rating system. Does the percentage improvement


justify the proposal?


1. If I weighed 250 pounds and lost .4 percent of my weight, I’d weigh 249 pounds.


2. If I ran a marathon in 260 minutes (average time globally in 2014) and improved by .4 percent, I’d run it in 258.9 minutes.


3. If I worked 40 hours a week and was asked to put in an extra .4 percent, I’d work 40 hours and 9 minutes.


4. If we reduced the headcount of Federal Government employees of 2.7M by .4 percent, we’d still have 2.7M.


Based on this data—and the lack


of benefit—our response to FMCSA’s request for comments was emphatically opposed to the proposed rule. FMCSA should focus its efforts on true CSA reform where the program would ful- fil its original goal of identifying and dealing with carriers who are actually unsafe—based on real science. ATR


35


TOTAL INDUSTRY (INTERSTATE)


621,665


6,119,257 9,912,402


306,525,676,172 187,555 6,421


INDUSTRY %


.01 .03 .02 .1


.15 .07


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