In an effort to “normalize” the data and judge the large carriers against large carriers, small against small, the agency created the concept of Peer Groups as an element of CSA 2010. Peer Groupings are determined in one of two ways; 1) Average Number of Power Units up to 18 months ago (APU)and 2) Number of relevant inspections in the past 24 months for carrier (CSMS) and 36 months for driver (DSMS)(RI). The seven BASIC’s break out as follows:
|BASIC||Peer Grouping By:|
|Improper Loading/Cargo Securement||RI|
So to begin with, the question: “Who is in my Peer Group ?” has 7 possible different answers, depending upon which BASIC we are discussing. Any given Motor Carrier may, on any given day, exist in any one of 35 possible Peer Groups (7 BASICS X 5 Peer Groups) “Who is in my Peer Group?” can only be followed by the next question… which BASIC, number of relevant inspections, and for what time period?
From here, the complexity gets positively diabolical. First, APU is the average number of power units reported on the Motor Carriers MCS-150 form as calculated up to 18 months ago. It is not what the MCS-150 states today. So if the goal were to get a count of everyone in Peer Group 5 in Unsafe Driving (APU based), you would need to know what the average PU count is for all Motor Carriers, not the current PU count. Further, even in those BASIC’s that are based on APU, Carriers may be removed from the Percentile Ranking if certain data sufficiency requirements are not met in terms of inspections and violations counts and age.
APU EXAMPLE: (straight out of the methodology) Determine the total number of inspections with at least one BASIC violation. For the Unsafe Driving BASIC, remove carriers with less than three such inspections. For the Controlled Substances/Alcohol BASIC, remove carriers with no violations in this BASIC. For the remaining carriers, place each carrier into one of five groups based on its average PU size… Within each group, rank all the carriers‘ BASIC measures in ascending order. Transform the ranked values into percentiles from 0 (representing the lowest BASIC measure) to 100 (representing the highest BASIC measure). Eliminate carriers whose violations in the BASIC are all older than twelve months. Then, assign the percentile values to the remaining carrier.
Second, if the question is who is in Peer Group 5 for Cargo Securement (RI based), you would need to know how many inspections (relevant inspections) exist for all Motor Carriers that meet the data sufficiency requirements of CSA 2010, not just how many inspections, and nothing at all to do with power units. Only then would it be possible to list those carriers who exist in that list, at that time.
RI EXAMPLE: Determine the total number of relevant inspections and number of inspections with at least one BASIC violation. For the Fatigued Driving (HOS) BASIC, remove carriers with (1) less than three relevant driver inspections or (2) no inspections resulting in at least one BASIC violation. For the Driver Fitness BASIC, remove carriers with (1) less than five relevant driver inspections or (2) no inspections resulting in at least one BASIC violation. For the remaining carriers, place each carrier into one of five groups based on the number of relevant inspections: