Amateurs and Explosives
Last Monday, March the 7th, the FMCSA posted the CSA BASIC Measures for 587,035 motor carriers on the public SMS website. There is specific language in the FAST Act (Highway Bill) that provides for this.
SEC. 5223. DATA CERTIFICATION
(c) CONTINUED PUBLIC AVAILABILITY OF DATA.—Notwithstanding any other provision of this section, inspection and violation information submitted to the Federal Motor Carrier Safety Administration by commercial motor vehicle inspectors and qualified law enforcement officials, out-of-service rates, and absolute measures shall remain available to the public.
There are also 39 States that permit almost any type of explosive fireworks without permits for July 4th festivities. Just because a law makes something possible, does not make it a good idea.
There is tremendous complexity behind BASIC Measures that require experience, training, and careful handling before attempting to put them to use. Unfortunately, a week in, and we’re hearing from our customers and partners in the industry that BASIC Measures are being adopted as the new way to benchmark motor carriers and make carrier selection decisions by shippers, brokers and insurance. This article is my attempt to point out some of the flaws in jumping in without understanding everything you need to know about BASIC Measures.
First, here are my cardinal rules for using BASIC Measures:
- Measures CANNOT be compared across BASICs
- Measures CANNOT be compared within BASICs
- Only those with deep knowledge and experience should play with dynamite
Now let’s review some of the numbers:
- BASIC Measures were posted on 587,035 Interstate and Intrastate Hazmat motor carriers.
- The Measures will be updated every month
- 306,333 (52%) had no Measure at all in any of the 5 BASICs where Measures were posted
- The remaining 280,702, who have a Measure >0 in at least one BASIC are the subjects of the remainder of this article.
SLIDE 1: Distribution of BASIC Measures of 280,702 Motor Carriers
Slide 1 Notes:
The large circles at the zero point on the Y-Axis illustrate the fact that the majority of carriers in each individual BASIC have a zero as their Measure. This is most obvious in the Controlled Substance BASIC where 98.3% of the motor carriers have a zero measure.
SLIDE 2: Range of Measures across BASICs
Slide 2 Notes:
The range of Measures across all 5 BASICs runs from zero to 172.2 as a high in the Unsafe Driving BASIC. Controlled Substance tops out at 20, while the remaining three BASICs top out at exactly 30.
Slide 3 Notes:
A direct quote I heard recently
“We’re going to set a threshold of 20 and not hire carriers over that.”
A Measure of 20 in Unsafe is utterly incomparable to a 20 in Substance, HOS, Fitness, or Maintenance. The insistence on referring to these as “absolute measures” is causing some to believe they can be compared…they cannot, it is meaningless.
Slide 4 – You cannot compare Measures within a BASIC
Slide 4 Notes:
Let’s look at the Unsafe Driving BASIC, the one that the FMCSA states is most correlated to Crash risk. On a scale of zero to 172, a person who did not understand the next level of complexity might choose something seemingly conservative as a BASIC Measure that they believe relates to good score. So I’ll play the part of such a person and select a seemingly conservative Measure of 10 of 172.
Slide 5 – Using Measures within a BASIC is explosive if you don’t factor in Safety Event Groups
Slide 6 Notes:
My decision to use a Measure of 10 results in hiring motor carriers who are at Alert status in the BASIC. I’m presenting this chart to show the relationship between Measures and CSA Percentile Scores. You won’t be able to see what Scores your selected Measure translates to, you will be blind.
Conclusion: Measures cannot be used between or within BASICs
Even if you understand Safety Event Groups, and have the experience and expertise to figure out who is in what group (these groupings are not public). You’ll still face the following challenges:
- Safety Event Groups are only provided one carrier at a time
- VMT provided in new public data is not always the VMT used in computing CSA
- No distinction in the public data for Combo or Straight segments (they are lumped together in one BASIC, this is invalid)
- No Measures are provided for Crash or Hazmat BASICs
- Many of the FAST Act CSA Defects are baked into the Measure (State differences, unscored carriers, SEG Math)
So before you jump on the BASIC Measure bandwagon as the new way to use CSA, make sure you fully understand what it all means.
Please don’t blow yourself up.