November 4, 2011
CSA: Good Intentions, Unclear Outcomes
As we approach the one-year anniversary of CSA 2010, an initiative developed to improve bus and motor carrier safety, we continue to find various aspects of the program problematic. And, while we applaud the original intent—to reduce crashes, injuries and fatalities--it is still not clear to us whether the carrier safety performance measures accurately portray either the risk profile of individual carriers or the likelihood of an accident. As such, our confidence is not high that improving scores actually predict reduced crashes, injuries, or fatalities. In fact, according to our analysis of the 200 largest carriers in the CSA database, we find no meaningful statistical relationship between actual accident frequency and BASIC scores for Unsafe Driving, Fatigued Driving or Driver Fitness. Regardless, carriers must still bear both direct and indirect costs of compliance. For example, one indirect cost that we find particularly troubling is the undeniably wide range of inspection frequency. Above-average inspection rates could disproportionally reduce carrier productivity and potentially create a negative feedback loop. In this note, we examine the various performance measures and explain why we feel BASIC scores should not be used exclusively in assessing carrier risk and that they may, in fact, provide misleading information.
• IN COMPLIANCE:
The FMCSA established 5 primary BASIC (Behavior Analysis and Safety Improvement Categories) categories in order to assess carrier safety. According to current data, the carriers in our research universe are all within the maximum threshold for each of the five categories, although various carriers have occasionally exceeded a BASIC threshold for a short period. Several have commented that once they breach a threshold, it can be quite challenging to return to compliance because additional scrutiny (i.e., inspections) appears to align with increased violations. Our findings appear to support this observation.
• WHAT COULD BE WRONG:
First, CSA is a federally implemented program enforced at the State and local level with overarching jurisdictions and greatly varying enforcement policies. Second, composite score severity weights are not entirely intuitive and may not accurately capture carier/driver crash risk. Finally, there does not appear to be a mechanism in place to account for these and other inspection variances (i.e. inspection frequency, mode of haul, etc.).
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