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.


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 literal act of Congress, grounded in the long-standing concerns of the trucking industry, ended the public view of CSA scores (at least tem- porarily), and mandated FMCSA address the significant defects in the system before making 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 analysis,” referring to the changes in the CSA score methodol- ogy mandated in the FAST Act highway bill. “We expect it to take a year or two, probably more like two, before that infor- mation (CSA SMS rankings) will be posted back up,” Foxx continued. Some might have assumed that


FMCSA would hold off on issuing the pro- posed 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 analyzing CSA-related data and the CSA methodolo- gy on behalf of over 2,000 motor carriers, freight brokers and shippers who subscribe to our CSA reporting service(s). In our comments to FMCSA regarding the pro- posed SFD rule, we limited our input to Unfit Method 1 (data from roadside inspections). Since the inception of CSA, a critical justification of CSA itself was that the data would be an effective method of focusing enforcement effort on those motor carriers deemed to be riskier, so our analy- sis focuses on whether SFD in fact accom- plishes that long stated goal. As the starting point for our com-


ments, 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 carriers beyond the


roughly 15,000 compliance reviews conduct- ed annually under the current Safety Rating System? To answer this question, Vigillo decided to start with the data. Our methodolo- gy was to focus on Unfit Method 1, data col- lected 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 carriers


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 rel- evant BASICs for SFD including hazmat, vehicle maintenance, unsafe driving, driver fitness and hours of service. If a carrier exceeds 96 percent in hazmat, unsafe driv- ing or hours of service, it fails the BASIC. If a carrier exceeds 99 percent in vehicle main- tenance or driver fitness, it fails the BASIC. If a carrier fails two BASICs, it is labeled unfit. Note that we used the existing SMS methodology rather than the new SFD


Continues Issue 3, Fall 2016 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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