FMCSA Ask for Public Feedback on Next Round of SMS “Enhancements”

Federal Motor Carrier Safety Administration (FMCSA) seeks public comments, due by July 29, 2015, on proposed enhancements to the Agency’s Safety Measurement System (SMS) methodology. TIA’s CSA and Carrier Selection Framework Committee is reviewing the changes and developing comments for submission. TIA will file comments on behalf of our members.

The proposed measures being considered are:

1. Changing some of the SMS Intervention Thresholds to better reflect the BASICs’ correlation to crash risk.

2. Two changes to the Hazardous Materials (HM) Compliance BASIC: a. Segmenting the HM Compliance BASIC by cargo tank (CT) and non-CT carriers; and b. Releasing motor carrier percentile rankings under the HM Compliance BASIC to the public.

3. Reclassifying violations for operating while OOS under the Unsafe Driving BASIC, rather than the BASIC of the underlying OOS violation.

4. Increasing the maximum Vehicle Miles Travelled (VMT) used in the Utilization Factor (UF) to more accurately reflect operations of high-utilization carriers.

Proposed changes to SMS intervention thresholds:

FMCSA is proposing to make changes to more closely align intervention thresholds with each BASIC’s correlation to crash risk. FMCSA determined that lowering the Vehicle Maintenance BASIC intervention threshold to better reflect the seriousness of the crash risk associated with vehicle maintenance issues and raising the intervention thresholds for the Controlled Substances/Alcohol, HM Compliance, and Driver Fitness BASICs would more effectively prioritize motor carriers. As part of the SMS Effectiveness Test analysis, FMCSA analyzed the correlation of each BASIC with crash risk and introduced three levels of crash risk correlation:

  • High: Unsafe Driving, Crash Indicator, Hours-of-Service (HOS) Compliance
  • Medium: Vehicle Maintenance
  • Low: Controlled Substances/Alcohol, HM Compliance, and Driver Fitness

After thorough analysis of crash data and other available data, the Agency is proposing the following changes to the intervention levels:

  • Unsafe Driving, Crash Indicator, HOS Compliance = remain the same
  • Vehicle Maintenance = reduce to 80 (currently 75)
  • Controlled Substance/Alcohol, HM Compliance, Driver Fitness = increase to 90 (currently 80)

The Agency notes that lowering the Vehicle Maintenance BASIC intervention threshold will identify a new set of motor carriers to receive warning letters so that they may address noncompliance issues before crashes occur. The changes would maintain the current intervention thresholds of 65% for the BASICs with the strongest relationship to crash risk. While fewer carriers will be identified for interventions in those BASICs where FMCSA proposes to raise the threshold to 90%, a similar number of carriers will be identified across all BASICs as under the current intervention thresholds. In addition, under the proposed changes the carriers prioritized for interventions will have a higher crash rate than the carriers currently prioritized for interventions. We examined the interstate carriers that are identified as at or above intervention threshold in any of the six BASICs (HM is excluded as it is handled in a different analysis). The effectiveness testing, which uses historical data, showed under the current thresholds that 39,454 carriers at or above intervention thresholds had a crash rate of 5.12 crashes per 100 Power Units (PU) and under the proposed thresholds 41,012 carriers at or above intervention threshold had a crash rate of 5.49 crashes per 100 PUs. This is a 7% increase in crash rate. A recent snapshot of SMS data (Dec 2014) shows that 2,431 carriers are newly identified while 453 are no longer identified with any of the six BASICs at or above the intervention threshold.

Proposed HM Compliance BASIC Changes:

Due to industry enforcement concerns that large non-cargo tank HM carriers have difficulty improving their scores in the HM Compliance BASIC because they are being unfairly compared to cargo tank HM carriers. This is because of the drastically different operations and how they often receive different violations. Because of these concerns, the Agency is proposing to split these two different segments of the industry within SMS. Additionally, with these proposed changes to the HM Compliance BASIC, and confidence in the data FMCSA proposes to make the HM Compliance BASIC information available to the public.

Violating Out-of-Service Orders:

Currently, when a carrier is cited for violating an OOS Order, these violations are associated with the same BASIC as the initial OOS violation. However, the behavior of deciding to violate an OOS Order is more closely related to a motor carrier’s or driver’s safety judgment, regardless of the underlying OOS condition. FMCSA reviewed these violations and analyzed the potential impact of reclassifying violations of an OOS Order to the Unsafe Driving BASIC. The Agency found that the crash rate of carriers at or above the intervention threshold in the Unsafe Driving BASIC will remain the same under this proposed change. Moreover, consolidating these OOS violations in the Unsafe Driving BASIC will help enforcement and motor carriers better identify and correct driver-related safety issues. Therefore, FMCSA proposes to move all violations of operating while OOS to the Unsafe Driving BASIC.

Changing the Maximum Vehicle Miles Travelled (VMT):

The Utilization Factor (UF) is an analytical element determined by dividing a motor carrier’s vehicle miles traveled (VMT) by the number of power units (PU) in the carrier’s fleet. The UF provides a more accurate picture of a carrier’s safety and compliance. The UF is used in the Unsafe Driving BASIC and Crash Indicator BASIC when a carrier has a higher than normal utilization of its vehicles (VMT per PU). The UF is currently limited to 200,000 miles. Industry stakeholders noted that the current UF is not accurate for some companies with extremely high utilization. Data reviewed by FMCSA indicates that 200,000 miles may not be the appropriate cap. Therefore, FMCSA is examining allowing additional credit to high-utilization carriers to provide a more accurate picture of the carriers’ crash exposure and unsafe driving behaviors.

FMCSA believes that extending the UF to carriers with VMT per PU up to 250,000 miles, from the current level of 200,000, will allow for a better measure of exposure for carriers with very high utilization. During the preview, carriers will be able to see the individual impacts of this change.

FMCSA plans to release later in 2015 a preview of the upcoming enhancements for motor carriers to view their data and proposed design changes.

Comments must be submitted to FMCSA by July 29, 2015.