I read the GAO Report to congress this morning and I can report that my expectations were met. The image that popped into my head as I was perusing the report was that of the toothless abominable snowman in the animated Christmas classic, Rudolph the Red-Nosed Reindeer. While extensive, I just don’t see any real energy in the Report that’s going to result in significant changes. While my expectations were relatively low, and thus met, there were a couple of things in the Report that provide food for thought.
In the section of the Report titled Agency Comments (page 32) the following appears: We provided a draft of this report to the USDOT for review and comment. USDOT agreed to consider our recommendations, but expressed what it described as significant and substantive disagreements with some aspects of our analysis and conclusions. USDOT’s concerns were discussed during a meeting on January 8, 2014, with senior USDOT officials, including the FMCSA Administrator. Following this meeting, we made several clarifications in our report. In particular, FMCSA understood our draft recommendation to be calling for specific changes to its SMS methodology. It was not our intent to be prescriptive, so we revised our first recommendation to state that FMCSA should conduct a formal analysis to inform potential changes to the SMS methodology.
Read the above excerpt again. What it states is that after the January 8th meeting with the FMCSA and USDOT, the Report was
softened revised to recommend a formal analysis of SMS. The GAO was apparently swayed by concerns that the Report was overly “prescriptive” and acted accordingly. I would have liked to be in that meeting. FMCSA: “We really don’t want to make specific changes to SMS right now. Can we just study things for a while (again) instead?” GAO: “Sure, why not. Sounds like a win-win.” This is our government at work. This is why, this morning, I do not suffer from unmet expectations.
Another area of the Report that caught my eye is reason for the title of this blog post. The FMCSA missed a huge opportunity on January 8th. Since the inception of CSA & SMS the FMCSA has clearly stated that SMS is not, and should not be used for, determining a carrier’s overall safety. Carriers have been arguing that SMS is being used for exactly that, much to the protestations of the FMCSA. The FMCSA continues to state that SMS is a prioritization tool. The SMS site disclaims: Readers should not draw conclusions about a carrier’s overall safety condition simply based on the data displayed in this system.
We’ve all been hearing that same position three years now. However, reading the GAO Report, we find this: The SMS uses administrative data on inspections of commercial motor carriers, violations of regulations, and crashes to measure carrier safety…………We find that FCMSA’s SMS makes a number of strong assumptions about motor carrier safety that empirical data cannot easily validate. (Appendix III)
Oops. All this time spent over the last three years defending SMS as a prioritization tool, and NOT a measure of carrier safety – down the drain. The GAO calls SMS the same thing carriers have been calling it – a measure of carrier safety. The FMCSA might have picked up on this and used the January 8th meeting to suggest modifications to the language, but did not. Let’s just call this an opportunity missed.