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Todd Dills

CSA: The difference (or lack thereof) a year makes

| May 01, 2014

It wasn’t so long ago that a majority of the MCSAC’s CSA Subcommittee “members urged the agency to withhold percentile rankings in the BASICs from public view until other underlying issues could be resolved.” I wrote that in February of 2013 after the last full two-day subcommittee meeting I attended had concluded. Even back then, those members had some sense of how fully invested FMCSA was in the SMS BASIC scores’ public nature. I continued:

Realizing withholding the rankings in total was unlikely to be something the FMCSA would act upon, compromise recommendations were as follows:

**Remove rankings from public view in BASICs where the numbers don’t correlate directly to crash risk (Driver Fitness, Controlled Substances/Alcohol).
**Keep the new Hazardous Materials Compliance BASIC measures hidden from public view, given similar lack of crash-risk correlation.
**Abstain from provide guidance or otherwise encouragement to third parties on how to use SMS data for carrier selection.

At yesterday’s meeting, the notion of removing the rankings was more or less off the table — and looking back on the preceding 2013 recommendations, FMCSA has at least done one of them, if they’ve more or less ignored the others. They’ve kept the hazmat BASIC shielded from public view. 

Subcommittee recommendations yesterday in some ways ran counter to the third item above — as you can read in this report, more (not less or no) advisement on how to use or how not to use the scores was urged. Part of the difference can be chalked up to changes on the committee itself. At least six members were not part of the early-2013 iteration. I think you can probably chalk more of it up to recognitions of realities of the road today when it comes to the CSA program and what program critics are up against. FMCSA isn’t going to just back away from what it’s invested so much in to date. CSA is their baby, and the fact that the percentile rankings are public they seem to view as primary in compliance achievements in the industry that have been made in recent years as carriers compete more with each other on CSA numbers.

I had a brief conversation about the notion of removing the scores from public view with OOIDA’s Todd Spencer on Tuesday. Spencer noted there’s a sort of “cat’s out of the bag” dynamic going on as well. Now that the brokerage and shipping communities know the scores exist, hiding them would only lead to some such entities writing carrier disclosure of the scores into contracts, which for small entities would be just another administrative burden to deal with month to month as numbers change. 

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Not that I mean to say Spencer is fond of the program, by any means. He was virtually alone among subcommittee members yesterday questioning the program on the statistical grounds that the Government Accountability Office noted — the small number of inspections/violations at the small-carrier level and the need for a greater data pool to truly be able to confidently rely on such data to make valid judgments. “The magic number, according to” numerous analysts, he said, including GAO’s: “if there’s not 20 inspections, there’s not reliability.” 

FMCSA seems to write off the GAO report as merely suggesting an alternative model — one that would only rank and measure larger carriers, noting that CSA’s effectiveness is in bringing the entire carrier population into its metric. FMCSA’s Bill Quade put it this way: “There has to be a model that’s effective for the small groups and effective for the big groups…. If 20 [inspections, where the GAO drew the bottom line for the statistically effective number of observations,] is what we want, there’s no point to CSA – none.” 

All that said, given the criticism the agency has gotten from Congress and other quarters on the underlying issues in the program, it’s certainly interested in improving it — I’ll report tomorrow on presentations given by the agency that could at least smooth out the month-to-month changes in small-carrier scores that have so plagued many carriers, among other potential changes. 

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At a certain point in the meeting Wednesday, Bruce Hamilton of the Amalgamated Transit Union, joined by Truck Safety Coalition’s John Lannen, a public safety advocate, urged a statement from the committee that would respond to some of the Congressional grandstanding around the GAO report and tell them, in Hamilton’s words, to “please leave the agency alone and let it do its work.” Such, he added, “could be very helpful” in stressing that the committee stands behind the program. 

But Spencer was quick to note that Congress does of course have a role to play — “This committee exists because Congress said, ‘create it.’ It may not get extended [with the highway bill this year].”

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Though a lot of political grandstanding does go on in Congress and elsewhere at the highest levels of government, Spencer added, oversight exists for a reason. “I’m not comfortable signing on to something on behalf of this committee admonishing lawmakers over what happens here,” he said, “because this committee is their business. They direct it. They oversee it.”

If there is a sizable change in the CSA program in the near term, I suspect it would come from them, too.