Sam Tucker is the founder and CEO of Carrier Risk Solutions, Inc., an Atlanta, Georgia based transportation risk management startup. Prior to this venture, Sam spent 13 years underwriting trucking and logistics accounts at some of the most well known insurance companies. He holds degrees in Business Economics and Finance/Risk Management as well as multiple professional insurance designations. Carrier Risk Solutions' innovative safety management platform can be found online at MySafetyManager.com. Reach Sam by email at STucker@CarrierRiskSolutions.com.
CSA BASIC scores are back in public view after a little facelift courtesy of the recently passed FAST Act. In my opinion, they are better than ever!
In case you missed the small announcement by the FMCSA this morning, the FMCSA recently re-tooled their public facing website to show all motor carrier’s absolute BASIC scores. Now, John Q. Public, every interested attorney, freight broker, insurance underwriter and reporter can breathe a collective sigh of relief!
We can all have a nice discussion at length about how the FMCSA’s Safety Measurement System is flawed. Everyone knows that the SMS is far from perfect. Disparate enforcement of laws, no accident causation analysis, weak correlation between some violations and actual crash risk...the list is lengthy. But, the current system is an improvement and it is getting better.
Let’s put aside that point for a while and deal with what we have now been given.
Per the FAST Act, Relative Percentages are history...at least for now. Previously, all motor carriers who belonged to the same “Safety Event Group” were pitted against one another in a dog eat dog DOT compliance battle.
Even if a motor carrier did nothing to improve or worsen their DOT compliance, their BASIC score for a given category could rise or fall based on the performance of their SEG “Peers”. Fair or not, that is gone for the time being. Personally, I think that is wonderful! It is certainly one of the best changes that resulted from this new set of laws.
In place of the Relative Percentages, we now have The Performance Measure and Performance Percentiles! I know, sexy names right?!?! This is the FMCSA and the DOT, so let’s not get carried away. The names say what they mean and mean what they say...but they could be a little cooler..
The Performance Measure, as defined by the FMCSA is:
Carrier violations or crashes are weighted by time and severity to produce a measure for that carrier in each BASIC. The measure only considers individual performance, with a measure of 0 indicating best performance.
In non-government speak, this means that when a motor carrier receives a violation, that violation is assigned a number based on which law the driver broke and how long ago it happened. While the severity part of the equation is fixed, the time weight changes at each anniversary of the violation.
The PM considers these numbers and scores the motor carrier for how well it did in each of the BASIC categories. These are carrier specific numbers and the lowest scores are the winners (in the FMCSA’s compliance game).
The Performance Percentile is defined as:
The SMS calculates a percentile (based on the measure) for each carrier with sufficient information to be compared against carriers with similar safety events (inspections, inspections with violations, crashes). Percentiles are calculated on a 0−100 scale, with 100 indicating worst performance and 0 indicating best performance.
With the Performance Percentile, things get a little bit more interesting. A motor carrier has to have enough inspections in a particular BASIC category in order to trigger a PP rating. As with the Performance Measure, ) wins the day and it gets worse from there.
Here is an example of what the new public site looks like for outsiders:
As you can see in the photo below, this motor carrier had a PM of 1.82 in September of 2015. As of February 26, 2016, that score increased to 2.00.
The FMCSA also now offers a little more meat on the bone by showing which Safety Event Group the Motor Carrier belongs to for that BASIC category and if they had any acute or critical violations that resulted from their most recent DOT compliance inspection.
Is 1.82 a “good number”? Is 2.00 a “good number”? I don’t know….but the reasonable conclusion to draw from the numbers face value is that 0 is the best that a motor carrier could aspire to and a 2.00 out of 100 seems pretty darn good to me!
Now, is the fact that the number has increased from 1.82 to 2.00 over the last 5 months alarming? Is it a normal and expected fluctuation? Should an insurance underwriter or fleet safety director view that change a decent, okay, horrible, etc.. I think that each situation is relative and should be looked at on a case by case basis….but most won’t. As humans, we try to draw inferences from the information available in order to make sense out of what we are seeing. Most folks will see this change from 1.82 to 2.00 (a 9% increase in the PM) as a negative development and will search for an explanation of the variation. (Nevermind that it was actually 2.02 just the month before).
Taking the motor carrier’s scores into account and saying that even a 2.00 measure, when pitted against the other SMS Safety Event Group brethren, is excellent. After all, it is a 2.00 rather than a 92!
But wait! I thought that the FAST Act actually prohibits a motor carrier’s BASIC scores from being shown to the public?!?!?
According to the FMCSA’s press release from 3/7/2016, here is the scoop:
Section 5223 (c) of the Fixing America’s Surface Transportation Act(FAST Act) of 2015 requires the Federal Motor Carrier Safety Administration (FMCSA) to keep property carriers’ absolute measures available to the public.
These measures are generated directly from safety data and not based on relative comparison to other motor carriers.
The FAST Act prohibits the display of a property carrier’s relative percentile, so on December 4, 2015, FMCSA removed the information prohibited from display, and also removed the absolute measures to allow time to modify the SMS Website to be compliant.
At this time, those modifications are complete and the SMS Website is fully compliant with the FAST Act.
So, this could easily turn into a letter of the law versus spirit of the law debate, but I’m not going there. Y’all can save that discussion for the water cooler. One thing is for certain:
Scott Darling and the rest of the folks at the FMCSA have some moxie and they are taking their mandate seriously.
To really consider the full effect of this, you have to look at this move in the context of the recently proposed changes to the FMCSA’s Safety Fitness Determination regulations.
Under these proposed changes (which still has about a week left in the public comment period for those who are interested), roadside inspection data will be used to determine if a motor carrier is unfit to operate. Additionally, the FMCSA is very specific about abandoning the relative percentage scores that were previously used in lieu of using a motor carrier's….wait for it…..absolute percentage measurement!
It is no coincidence that the BASICs are laid out this way, that you can now easily see which Safety Event Group a motor carrier belongs to and the presence or absence of any acute or critical inspection violations.
With these changes to how the public views a motor carrier’s BASIC scores, the FMCSA has now started to lay the groundwork for the implementation of their new Safety Fitness Determination regulations!
Want to learn more? Give us a call at 855-211-5550! We can help you navigate the increasingly complex world of DOT compliance and fleet safety!