Opinion: CSA Data Too Flawed to Be Made Public
By P. Sean Garney
Manager, Safety Policy
American Trucking Associations
This Opinion piece appears in the Aug. 26 print edition of Transport Topics. Click here to subscribe today.
The Federal Motor Carrier Safety Administration enforcement mechanism dubbed Compliance, Safety, Accountability has been the topic of much discussion and controversy since its launch in 2010.
All agree that safety is a paramount concern for the industry, FMCSA and the motoring public.
All agree that regulatory compliance has a role to play.
All agree CSA has sharpened the industry’s focus on safety programs.
Still, it’s not all roses.
The trucking industry has long contended that, because not all CSA BASICs — i.e., Behavior Analysis and Safety Improvement Categories — correlate well to future crash risk, and many carriers with low crash rates have mistakenly high BASIC scores and vice-versa, it is inappropriate to provide these “scores” to the public.
The idea is intuitive. If these scores erroneously identify safe motor carriers as unsafe — or worse, identify unsafe motor carriers as safe — FMCSA should not be supplying this narrative to third parties to make business decisions until methodology and data flaws are corrected.
Detractors point to disclaimers on FMCSA’s CSA Web portal warning users that “readers should not draw conclusions about a carrier’s overall safety condition simply based on the data displayed.” It goes on to provide a Web link to their Safety and Fitness Electronic Records, or SAFER, website, where safety ratings, the only officially endorsed determination of a company’s safety culture, can be found.
So, that’s that? CSA is a compliance measurement tool that makes no assumptions regarding the safety posture of motor carriers. But here’s the rub: Third parties — e.g., shippers, brokers, insurers, banks — are making risk assessments based on FMCSA’s analysis. This is, in part, because the suggested alternative, carrier safety ratings, are often dated and sometimes obsolete.
This migration to CSA data usage can be partially attributed to shippers’ heightened vicarious liability concerns, as detailed in a recent American Transportation Research Institute report. ATRI’s survey found that nearly two-thirds of shipper respondents fear being held vicariously liable in the event of an accident. Shippers are so concerned that 41% of those surveyed request access to all BASIC scores, even those shielded from public view.
If BASIC scores were reliable indicators of the safety posture of a commercial motor carrier, shippers would be justified in using them as cover from liability claims. Trouble is, they’re not. ATA has been a powerful voice in highlighting the program’s deficiencies, focusing on three primary concerns: data accuracy, reliability and sufficiency; methodology problems; and the lack of crash accountability.
There’s no need to rehash each argument here. I’ll simply punctuate this statement by saying that 60% of the trucking industry does not have sufficient data to be assessed in any of the BASICs which, in almost half the categories, don’t correlate well with actual crash risk and include accidents the motor carrier could not have prevented. As a result, some experts have suggested that BASIC scores may not meet federal and jurisdictional rules of evidence requiring that data are trustworthy and rest on a reliable foundation.
The real problem, however, is that the complicated calculations informing CSA BASIC scores are lost on third parties searching in vain for a single indicator of a trucking company’s safety risk.
FMCSA has countered this by clarifying that these scores merely measure compliance with federal regulations while implying that adherence is tantamount to safety. Problem is, even some of the greatest statistical minds in our industry have had trouble replicating CSA’s complicated algorithm. As for compliance, there are 781 different violations that can earn “points” added to your CSA score, not all of which have safety consequences.
For many violations, there can be multiple reasons to be cited.
These incredibly intricate rules confound even the most seasoned veteran. How is a third party supposed to understand why a company has a high BASIC score relative to others in their “safety event groups?” The answer: They don’t.
Otherwise safe motor carriers are being penalized. The aforementioned ATRI survey found that 50% of surveyed shippers “asserted that poor CSA scores alone were sufficient reason to avoid contracting with a prospective carrier.”
A December 2011 Morgan Stanley survey of shippers found that 58% of shippers would not use a carrier with poor CSA scores at any price, and 60.7% of shippers are finding it somewhat or much more difficult to find qualified motor carriers to carry freight.
Nor is it just shippers using this data as a proxy for safety. At a recent meeting of the Motor Carrier Safety Advisory Committee’s CSA Subcommittee, financial giant J.P Morgan presented its “analysis” of CSA scores for 39 top publicly traded commercial motor carriers. The report contained no caveat emptor. Nowhere were the system’s identified shortcomings detailed. Scores were merely presented in a matter-of-fact manner as a representation of safety posture. For the nonpublic Crash Indicator BASIC, J.P. Morgan used the available crash data listed in the CSA portal to create its own crash metrics. There was no mention of the inclusion of unpreventable accidents and no effort to link BASIC scores with this new crash metric.
If the investment community, whose analysts are arguably some of the most talented, are not committing the time and resources necessary to understand the caveats and shortcomings of the CSA system, how are we to expect the shipping and brokerage communities — those whose business decisions more directly affect carrier profit margins — to embrace CSA as FMCSA’s new vision recommends, as an enforcement tool to measure compliance and enforcement only? This, combined with the lack of a reliable safety-fitness determination process, has left carriers and shippers in the lurch.
American Trucking Associations, the largest national trade federation for the trucking industry, has headquarters in Arlington, Va., and affiliated associations in every state. ATA owns Transport Topics Publishing Group.
