The Federal Motor Carrier Safety Administration uses the Compliance, Safety Accountability (CSA) program to evaluate motor carrier safety and, seemingly, generate a never-ending list of abbreviations and acronyms. Take, for instance, the BASICs, Behavior Analysis, and Safety Improvement Categories, which represent the seven areas of safety compliance driven by data in the SMS, Safety Management System. We have learned through experience that the SMS algorithm closely mirrors the calculation that produces a motor carrier’s ISS, Inspection Selection System, score. A motor carrier’s ISS score influences which trucks law enforcement selects for inspection by law enforcement.

All that, and much, much more from three simple letters — CSA.

So, it may come as a surprise that when the U.S. Department of Transportation released its Significant Rulemakings Report last September, when FMCSA announced…

“FMCSA is seeking information on how the Agency might use data and resources more effectively to identify unfit motor carriers and to remove them from the Nation’s roadways. FMCSA would seek public comment about the use of available safety data, including inspection data, in determining carrier fitness to operate. The Agency would also seek public input on possible changes to the current three-tier safety fitness rating structure. The action would also include a review of the list of Federal Motor Carrier Safety Regulations (FMCSRs) that the Agency uses in its safety fitness rating methodology.”

The word “CSA” does not appear. However, what FMCSA describes here is the heart and soul of the Compliance, Safety, Accountability program.

Perhaps another three-letter abbreviation is to blame: IRT. IRT stands for Item Response Theory, and was added to this letter salad seven years ago as a possible enhancement for CSA.

While CSA was an improvement over its predecessor safety evaluation program, trucking industry reviewers noted its weaknesses. Not every BASIC, for example, was a good predictor of future crashes, and the assignment of violation severity could be arbitrary.

Congress directed the National Academy of Sciences to offer a more statistically sound approach to motor carrier safety evaluation for FMCSA. The NAS suggestion was IRT. Some scientific circles successfully use IRT in situations that can provide the intense amount of data required by the evaluation system. But in government regulatory circles, public data collection requires stakeholder input through a Federal Register notice. The trucking industry expressed concern that some of the data gathered by IRT would include items such as driver turnover rate, type of cargo, and method and level of driver compensation. Motor carriers consider that information to be proprietary data.

Without the range and type of data required by IRT, FMCSA’s attempts at “CSA Reform” have been stymied. Nonetheless, the DOT Significant Rulemakings Report revealed that FMCSA would publish an Advanced Notice of Proposed Rulemaking early this year, as described above.

It is always good for a regulatory agency to look for ways to improve its programs. But one has to wonder: if CSA itself is not mentioned, will IRT?

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