A New Corrective Action Plan For CSA Is Revealed

Have you heard? The FMCSA has released a mandated ‘corrective action plan’ for the much-maligned CSA program. But what does this mean?

The Details

On July 16 the FMCSA announced that they had delivered what they called a “Correlation Study Corrective Action Plan” for the CSA program. The report was delivered to Congress. The new corrective action plan will outline how the agency will address recommendations made in the National Academy of Sciences (NAS) report on improving the safety measurements the federal government uses to rank motor carriers.

The report examined how effective the percentile ranks given under SMS actually identifies high-risk carriers and what to do if the answer to that is not much. The report also takes a look at the accuracy of the data entered into the SMS database. Researchers were tasked with discovering other approaches to singling out high-risk fleets more effectively. Finally, they wanted to know how effective making the SMS information public has been on lessening the number of crashes recorded.

It is useful to note that the agency has already removed the SMS preview website from public view. This preview website contained changes that the agency was going to propose regarding SMS. Since the changes were released before the NAS report, they are moot.

There were six key elements in the NAS study that the agency addressed in their report to Congress. At the top of the list was the methodology the FMCSA uses to approach the data. NAS openly wondered if the methodology used by the FMCSA was not scientific enough in its modeling approach. They specifically mentioned an “Item Response Theory” approach to making the SMS system more fair and accurate.

What is IRT-Based?

With an IRT-based approach, the agency hopes that they can get an accurate measure of the ‘safety culture’ from fleet to fleet, rather than a zero-sum game of identification and intervention. This approach was further pushed late last year by the FMCSA’s Director of Compliance and Enforcement during a conference in Florida.

The agency states within their action plan that they would proceed with developing and testing an IRT model program. Of course, they would still receive public input on important measures, but they hope the IRT model will streamline and better inform the rule and regulations the agency does or does not decide to move forward with.

There is also a push to ensure that the quality of data within SMS is uncorrupted. A more frequent and much more detailed VMT data would provide much greater insight. Right now, the FMCSA only collects VMT data every couple of years. There is also no interoperability or communication between state and federal systems. More frequent collection of and collaboration with VMT data at the state and federal level stands to benefit everyone.

Finally, the agency wants to ensure it gives stakeholders proper consideration. Input must come not just from public comment, but from insurance companies, shippers, receivers, and just about anyone else making freight move within the transportation sector.

After the program is put together, FMCSA will create values based off of the IRT model to determine what information is relevant for the SMS system. Their goal is to have a small-scale model of the program ready to go by September of 2018.

How will all of this inform the next generation of CSA and SMS deployment? We will have to wait until the outcome of the FMCSA’s own internal studies before knowing which way the pendulum will swing on this issue.