Regular readers will recall the “Stoking the Log Fires” story about the uptake of ELDs among larger for-hire carriers and the partly resulting disproportionate burden of hours violations incurred at non-ELD carriers. The story, from our current July issue and published here online a few weeks back, generated a lot of discussion, but one particular comment caught my eye, from reader eharris5128:
How did we arrive at this juncture in the trucking industry? How did “compliance” with hours of service become the main focus of [truck] inspectors and the FMCSA? How did we go from a “wink and nod” on the old “comic book” of the ’70s and ’80s to the present day clampdown on strict enforcement of [an hours of service] rule that was originally designed to protect union drivers from being overworked?
One thing I see lacking in your report is the correlation between ELDs and at fault crashes. If the use of ELDs reduce the at fault crash risk, then well and good. But I bet that those small motor carriers that have the most log book violations also have the fewest at-fault crashes. I say this because most of the large truck crashes I see on the highways are from the mega fleets, not the smaller carriers.
Unfortunately, and as anybody who’s been following the CSA program at all the last five years knows, we don’t have a good comprehensive source for at-fault crashes, as the data collection that happens around crashes at the federal and state levels does not account for it. (Fault is often shared in any accident, in any case, and many argue that the “preventability” standard is a better though perhaps even more difficult one to meet when it comes to justifying the association of a crash with any carrier’s safety scores.) But in terms of crash incidence, regardless of fault, a look into crash data from the last two years among for-hire carriers shows that, in one sense, the commenter’s correct — the largest 500-plus-truck carriers are involved in the largest share of crashes on the whole among fleet size groupings.
Distribution of truck-involved crashes among for-hire fleets, past two years
A full fourth of crashes involving a large truck were associated with the largest carriers over the prior 24-month time period, according to this RigDig Business Intelligence analysis of the most recent 24 months of available data among the for-hire population. At once, however, that high number might be misleading. RigDig estimates power-unit counts in an attempt to refine federal data on power-unit numbers — given that data’s carrier-reported nature and the existence of fairly suspicious numbers in some instances — by utilizing a variety of sources showing actual business/truck activity. In their estimation, among this population, 500-plus-truck fleets control close to 30 percent of all the trucks on the road. Their crash percentage, by comparison, is a few percentage points better than their power-units presence on the road, according to these numbers. (And, keep in mind, for those among you who run leased to fleets of this size, your performance will be reflected within those large-carrier numbers, associated with the carrier’s DOT number.)
And who’s right behind the largest carriers for the second highest share of truck involved crashes? The smallest, 1-4-truck fleets also control the second largest share of trucks in this population, by RigDig’s best estimation — it’s right around 15 percent, slightly less than their share of overall crashes.
When you look at the crashes that matter most from a safety perspective (but again regardless of fault), those that involve injuries and fatalities, the total crash shares change very little. The largest carriers actually do a percentage point better in that view, the smallest near exactly the same. View the fatality/injury crash shares and total hours violations shares side by side, though, and the data seem to suggest a misplaced focus in hours enforcement (if not any real safety conclusions), if we accept FMCSA’s notion that simple involvement in a crash is a good predictor of future crashes and thus the need for enforcement.
Distribution of injury/fatality crashes (orange) and hours of service violations (blue)
Caveat to all of it: All things being equal, which, as my colleague Wendy Parker among others is fond of noting, they never are.
The use of ELDs at those larger-carrier levels virtually eliminates the most common hours of service violation, the non-safety-related (many argue) form and manner infraction. And then there’s utilization of power units, which varies quite a bit among these groups, though it’s likely greatest at the smallest-carrier level, considered across the entire population as a general rule. Greater utilization generates more opportunity for run-ins with four-wheelers, whoever’s at fault, to drive up the numbers. Also: more opportunity for inspection, more opportunity for violations. Widespread scale-bypass-system use among larger fleets nowithstanding, a decent measure suggesting utilization among different fleet size groups could be total inspections per power unit over the same period.
Inspections per power unit (red) and hours violations (blue) per power unit over most recent 24 months
Several things could be at play in the dramatic 100 percent difference between the largest-carrier inspections-per-power-unit rate of 1 and the 2-plus rate from 99-truck and smaller fleets:
- Bypass system have that dramatic of an effect on inspection reduction, though I know many sizable smaller fleets, and independent owner-operators, employ those as well.
- A sizable undercounting of power units exists in the federal system at the smaller-carrier levels — or overcounting at the largest-fleet levels.
- Utilization is just that much higher, per truck, at the smaller-carrier levels, given few idle or occasionally-idle units. High turnover at larger for-hire fleets suggests some effect for sure.
Or maybe Harris is correct in his further suggestions following the portion of his comment I featured above. Maybe the selection bias toward smaller carriers not running ELDs is having that big of an effect in the inspection numbers and contributes to the “nickel-and-diming” phenomenon of a greater incidence of inspection and what respondents to a recent Overdrive survey dubbed a top safety/regulatory concern: A perceived “nitpicking” in inspectors’ roadside-violation-writing practices in the CSA era was named by 50 percent of readers as one of the top three safety/regulatory issues. That’s getting more pronounced in the area of the logbook, as the numbers suggest, now that larger entities are running ELDs and, some contend, getting passed over during inspection selection (though law enforcement reps have denied it repeatedly over the years).
Here’s most of the rest of eharris5128‘s comment, which takes “nitpicking” further indeed:
What is the end goal of the ELDs (soon coming), speed limiters, driver-facing cameras and other such technology? Safety is just a ruse. One guest on the Road Dog Trucking News show believes the regulatory avalanche is really to decrease the total number of motor carriers down to a more manageable level. Currently there are over 350,000 registered motor carriers. If this number were reduced to, say, 100,000, FMCSA would have a much easier time conducting safety reviews and collecting [money] to keep a motor carrier on the road. Couple this with forcing older trucks off the road permanently using environmental reasons, and you will basically kill the independent owner-operators while increasing the indentured servitude of lease-purchase drivers and low-paid company drivers.
Though I know I haven’t answered the at-fault crash question with the data in this post, the rest should engender plenty of food for thought. What’s your take? Is the owner-operator/small fleet being “nitpicked” or “nickel-and-dimed” into oblivion?