The Federal Motor Carrier Safety Administration (FMCSA) is undertaking a new study of the causes behind commercial motor vehicle (CMV) crashes. The agency released the last such study in 2006, based on data from 2001-2003.
In the Infrastructure Bill signed into law in late 2021, Congress directed FMCSA to conduct this new, updated study. FMCSA began that effort in 2022, with an Information Collection Request (ICR) on the first phase of the study, referring to it as the “Large Truck Crash Causal Factors Study.” In this latest ICR, FMCSA lays out its overall approach to crash data collection, noting that while the first phase focuses on fatal crashes involving Class 7 & 8 trucks, future phases of the study will include other CMV classes and crash severities.
Why conduct a study? The FMCSA mission is to “reduce crashes, injuries, and fatalities involving large trucks and buses.” Understanding the contributing factors to those crashes helps guide effective rulemakings.
Why a new study? Much has changed in truck safety and highway safety over the last 20 years. Today, CMVs come equipped with advanced safety technologies, such as stability controls, electronic logging devices, and automatic emergency braking. On the other hand, today’s drivers hit the road with access to cell phones and operate at higher speeds in more congested situations.
What are the dangers of a new study? Congress directed this study to look only at crashes involving trucks, which aligns with the FMCSA mission. Every safety-conscious motor carrier and professional truck driver supports improvements in highway safety. If the study yields insights that can make America’s highways safer, everyone will benefit.
This study becomes a danger to the trucking industry if elected officials and the public at large view the results as an indictment of CMVs, rather than an examination of factors surrounding truck-involved crashes. After all, Congress did not require a companion study of factors in passenger car-involved crashes. The first phase focus on Class 7 & 8 trucks elevates that danger, which the public may regard as inherently less safe.
What can I do? The current ICR reads like the template for a graduate student’s research paper – “this is what I intend to study and how I will find the data.” Still, every ICR creates an opportunity to submit comments to FMCSA. Motor carriers should remind FMCSA that:
- “Causal factors” and “crash causation” can be misleading and incendiary terms. FMCSA should emphasize that the study is concerned with factors surrounding crashes for the betterment of highway safety, not finding fault.
- Similarly, FMCSA should take care to note that individual crashes differ in those factors. Without such a disclaimer, trial attorneys will generalize the study findings and use them against truckers.
- Finally, motor carriers should urge FMCSA to keep study results private until it completes all phases. The complete study may offer better perspective.
Meanwhile, motor carriers can take three easy steps to help make the study more accurate:
- Use the FMCSA DataQs to correct any errors in citations and police reports. Clean data makes for a better study.
- Similarly, use DataQs to submit a Request for Data Review under the FMCSA Crash Preventability Determination Program. FMCSA should acknowledge which crashes in the study are determined to be “non-preventable.”
- Finally, share videos with state and local safety officials that show the sequence of events leading to a crash. In the study, FMCSA will reach out to them for truck crash data. Help make sure the study gets the complete “picture.”
Comments on this ICR are due by June 26, 2023.
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