In our 2010 White Paper, The Perversion of Safety in the Transportation Industry, we shared a model for how government intervention causes negative effects to transportation firms (below):
Does this model reflect reality or is it cynically off base as it relates to CSA? Could there possibly be focus on the wrong things as the model suggests?
Judge for yourself as you read this incisive study, Statistical Issues in the Safety Measurement and Inspection of Motor Carriers, written by Dr. James Gimpel, PH.D of the University of Maryland.
Dr. Gimpel makes a lot of points in a few pages. Within a larger array of evidence, he asserts and justifies the following:
• Where you’re running freight means a lot. There’s a lot of variability in local enforcement. Some states are strict, others not so much. “Just five states: Michigan, Indiana, Tennessee, Texas and Pennsylvania, are responsible for 45 percent of the violations which form the statistical analysis for unsafe driving”. You get thumped for being in the right place at the right time. Or is it the wrong place at the wrong time?
• There’s also a lot of variation in what state officials are investigating. Some focus on certain violations more than others. Again states’ biases may mean bad scores for some carriers depending on where they are inspected. It’s not supposed to work that way.
• Small carriers aren’t inspected as often as larger carriers. A few bad inspections and they’re in the soup. One or two bad inspections subject their scores to wild fluctuations. On the other hand the majority of small carriers don’t have any or enough inspections to land on the radar screen at all. That just contributes to the arbitrary nature of the process.
• Frequently, clean inspections, where there are no violations, don’t get reported and therefore don’t get into the system. Just like in school, if your bad grades count and the teacher loses your “A” papers, your grade point average won’t look very good.
• And maybe worst of all, there isn’t a strong relationship between some of the BASICS and accident risk. “The relationship between unsafe driving scores and crash rate is almost non-existent for the carriers with fewest inspections and is weakly positive for carriers in the higher inspection categories…” The Driver Fatigue basic has similar results. If CSA was credible, these relationships would be much stronger.
The U. S. Congress became involved with a July 11 hearing entitled, “Is the Federal Motor Carrier Safety Administration’s Compliance, Safety, Accountability Program Driving Small Business Off the Road?” The primary conclusion was that the issues (including those brought by Dr. Gimpel) suggested “the agency and the public would benefit from more stakeholder input into the design of the SMS methodologies.”
Eventually, after enough complaints (aka “market response”) and studies, the Feds may fix some of these issues…and as the model above suggests, the cycle will start again.
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