Happy February everybody, and Happy Anniversary!
Its been exactly 6 months (August 1 – Feb 1) since FMCSA launched their 24 month Crash Preventability Demonstration Program to see what impact it would have if FMCSA reviewed DOT Record-able crashes and made Preventable/Non-Preventable determinations for purposes of CSA crash scores. So happy 6-month (26 week) anniversary!
According to Match.com findings a 6-month relationship is important because this is when three key relationship milestones take place:
- Revealing of one’s imperfections (24 weeks)
- First argument (23 weeks)
- Parental introductions take place (24 weeks)
So I ran some numbers FMCSA, its time to meet Momma.
Imperfection #1 – Permitted time period out of sync with CSA Scores
Lets start at the highest level. Motor Carrier (CSMS) CSA scoring is based on the most immediate past 2 years of data including crashes. In the two years prior to January 1, 2018, FMCSA recorded 307,732 crashes. (MCMIS as of December snapshot).
All Crashes – Two Years
But FMCSA only allows crashes after June 1, 2017 to be submitted for reviews under its new program that started August 1, 2017. So less than 25% of CSA crashes can be submitted at this time, it will only catch up with the 2 year CSA window, as the Demonstration Program comes to a close at the end of 24 months.
Crashes Qualifying for Review – 76,122 (24.7% of all Crashes)
Crash Locations – States (Oh look, Texas wins again!)
So as we sit here at the 6-month milestone, we can only judge the preventability project on the 1,149 submitted crashes out of 76,122 crashes that could possibly be submitted under the limitations put in place for this program, or 24.7% of all possible crashes. I never understood the reasoning behind limiting crash submissions to those since June, when FMCSA uses crashes back two years for scoring purposes. Seems fair to align those dates, but hey, we were early in the relationship and we didn’t want to have that first argument.
Imperfection #2 – Transparency could be better
On August 1, as soon as the Demonstration Program launched, Vigillo started capturing all crashes submitted through DataQ’s. FMCSA publishes the outcomes of crash reviews publicly, but cycles them through every 30 days, removing the previous month from public view. There is no running total, so we created one. We set up a daily capture and can now report that 1,149 crashes have been submitted for review by 588 different motor carriers since August 1. That’s just 1.5% of the possible 76,122 that have been recorded in that same time period. This is starting to look an awful lot like the DataQ’s system we already dated and broke up with. Lets get some reporting in there team, this is a demonstration program, lets see the results without having to do backflips. Motor Carriers, lets get busy, submit those crashes.
Imperfection #3 – Only certain predetermined categories can be submitted
FMCSA predetermined that only crashes in the following categories can be submitted for review:
- When the commercial motor vehicle (CMV) was struck by a motorist driving under the influence (or related offense)
- When the CMV was struck by a motorist driving the wrong direction
- When the CMV was struck in the rear
- When the CMV was struck while it was legally stopped or parked, including when the vehicle is unattended
- When the CMV struck an individual committing, or attempting to commit, suicide by stepping or driving in front of the CMV
- When the CMV sustained disabling damage after striking an animal in the roadway
- When the crash was the result of an infrastructure failure, or falling trees, rocks, or debris
- When the CMV was struck by cargo or equipment from another vehicle
And this is the breakdown now 6 months into the Program:
Actual Submissions by Crash category – 1,149 submitted
Actual Review Outcomes by Crash category – 596 Non-Preventable (52%)
Our first argument – Many clearly Non-Preventable Crashes are not being reviewed.
So to recap, Crashes going back two years should be permitted for submission, we need better and more transparent reporting from FMCSA, and with the huge investment in technology, including camera’s, there should not be predetermined categories of acceptable crashes. It is impossible for anyone outside FMCSA to know how many crashes are being submitted and rejected out of hand because they are not in one of the pre-determined categories, and even less knowable, how many carriers don’t even try.
The link below is from a motor carrier who will remain anonymous, and it shows a crash that is clearly not preventable by the driver or motor carrier. But it is a side collision, and FMCSA has predetermined that no side collision can be reviewed. It is a Demonstration Program, lets demonstrate what is possible today with technology and video. Until you do, I’m not sure how I feel about continuing our relationship, or having you meet my parents.