Submitted to Federal Motor Carrier Safety Administration (FMCSA)
Vigillo is pleased to have the opportunity to comment on the Beyond Compliance Program. Vigillo is the leading provider of CSA Analytics in the industry and its Athena™ Big Data platform is the hub of all commercial transportation and logistics data from hundreds of public and private sources. Vigillo is uniquely positioned to act as a potential yardstick in measuring any and all data relevant to the Beyond Compliance Program as it evolves.
Our comments to each of the specific questions posed by FMCSA are as follows:
- What voluntary technologies or safety program best practices would be appropriate for a Beyond Compliance program?
- What safety performance metrics should be used to evaluate the success of voluntarily implemented technologies or safety program best practices?
Questions 1 and 2 need to be addressed together. If Beyond Compliance is going to work, it needs to foster innovation, imagine new disruptive technologies, and reward companies who bring new concepts, products and services to the industry that save lives. FMCSA should resist specificity in defining this Program. So, all manner of telematics, tracking, monitoring of everything from HOS to engine performance to lane departure and hard brake events would all be good candidates. Employee screening through PSP and Drug Testing, training programs, driver retention and pay systems, on board cameras, proximity alerts, environmental warnings and speed limiters all make sense intuitively. We need to stop being intuitive and look at the data.
Which is exactly why we need a standard measurement for safety. This one metric to rule them all should be preventable crashes per million miles. (period). Carriers with below national average preventable crash rates per million miles are eligible for Beyond Compliance. However they do it is no concern to anyone. They just do, making the best business decisions about services and technology that they can, and proving it all works by demonstrating lower than average crash rates.
Remember, CSA’s very premise was built on a “flattening” in the decreasing number of fatalities per million miles. FMCSA has gone off course and now uses power units as the basis for crash rates. We need to go back to 2004 and resurrect the concept of crashes per million miles, and it needs to focus on preventable crashes. It wastes resources and dilutes the usefulness of any program when carriers are held accountable for non-preventable crashes.
- What incentives would encourage motor carriers to invest in technologies and best practices programs?
- Credit on appropriate SMS scores (e.g., credit in Driver Fitness for use of an employer notification system)? Beyond Compliance should consider something Beyond Obvious. Reduction in SMS Scores feels circular to me. Its going to be carriers with lower CSA Scores who are likely to be the biggest adopters of Beyond Compliance, so a credit to their SMS Scores feels like a fizzle to me. “Great, I went from a 32 to a 27”
- Credit on ISS scores? Likewise ISS Scores are not even used in all States and I see very little “heat” around the non-public ISS Score. I doubt FMCSA will get a lot of carriers all excited about investing a lot to get lower ISS Scores
- Reduction in roadside inspection frequency? While this concept would have higher appeal to a carrier, fewer stops, fewer inspections, all good…however, I see a lot of problems in implementation. There is not one type of trucking company or mode of operation. If you cross borders, or operate in and out of ports, you are going to be subject to much higher inspection rates. If you operate in cities vs Midwest long haul, you simply exist as a very different business than the norm. Disparate Enforcement is one of the biggest issues that imbalance CSA today. I just don’t see this as a lever to pull.
- Other options?
First, normalize State Disparity: Vigillo has run the numbers. Many many carriers would benefit if their CSA Scores were normalized to an average to bring balance to those who operate in heavily inspected regions such as borders etc.
Second, set a threshold in Beyond Compliance that when met, re-scores a carrier using the normalized numbers. Maybe set this just a bit lower than the national average crash rate, say average less 10%.
Third, any carrier who is re-scored using normalized inspection/violation numbers AND has no CSA Alerts in any BASIC once re-scored should be designated as Beyond Compliant and make their CSA Scores Private, all of the.
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A Carrier must have lower than the national average preventable crash rate per million VMT.
Such carrier is re-scored using normalized inspection/violation data.
Carriers without CSA Alerts after re-scoring are designated Beyond Compliant: A carrier with National Average Crash rates (preventables per MVMT) and no CSA Alerts after normalized re-scoring would appear like this on SMS:
What events should cause the incentives to be removed? If safety goals for the carrier are not consistently achieved, what is the benefit to the motoring public?
Simply put, if Preventable Crash rate exceeds the national average, then the carrier does not qualify for Beyond Compliance.
Should this program be developed by the private sector like PrePass, ISO 9000, or Canada’s Partners in Compliance (PIC)?
FMCSA is going to have to figure out the preventable crash measurement—that needs to come with the blessing of the government. After that, it's just math. No particular expertise should be required to normalize and re-score eligible carriers, though Vigillo would be happy to accept the job.
How would FMCSA verify that the voluntary technologies or safety programs were being implemented?
The carrier stays below the national average of preventable crashes per million miles. The FMCSA does not need to measure what they are doing, just the clear, objectively measureable outcome…lower crash rates.
Who is to say whether one carrier finds great effectiveness in ELD’s or Speed Limiters, while a second carrier has great success by retaining good drivers with more comfortable mattresses in the sleeper and a third pays salaries and gets the driver home on weekends through better route planning? It does not matter, and the FMCSA does not have to try and select technologies or services or programs that they imagine might work. With JUST, we will stop imagining and just measure the objective results.
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