In early August 2019, FMCSA published a request for comment on its plan to expand and make permanent its Crash Preventability Determination Pilot Program. This got us to thinking how FMCSA may be finding its way out of a tough pickle. For years, research has shown that all crashes, regardless of fault, have a strong correlation to future crash risk. It’s been statistically tested and validated by government and industry researchers. That’s why, on average, the Crash Indicator CSA BASIC is the best indicator of future crash risk.
This flies in the face of conventional wisdom, though, which tells us that it is inappropriate to use a crash that could not have been prevented to make assumptions about a driver’s or motor carrier’s safety posture. In fact, STC staff fondly remembers the days when, as advocates for the American Trucking Associations, this was our sharpest criticism of CSA.
FMCSA’s Crash Preventability Determination program is FMCSA’s attempt to ease that dissonance and the low rate of usage among motor carriers is allowing them to have it both ways. Sure, in the two years since the program began, they reviewed 5,619 crashes submitted by 3,558 carriers, 93% of which were deemed preventable. But, in context, this means that less than one percent of motor carriers submitted less than one percent of all crashes for review. As a result, those few carriers who are using the program are watching their Crash Indicator BASIC improve while their peers who have not used the program are watching their BASIC score worsen and may not know why.
Of course, not all crashes can be contested as not preventable, but this still constitutes an alarmingly low rate of submission and means that, for most carriers, CSA still judges future crash risk using all crashes, regardless of fault. Meanwhile, FMCSA has removed the sharpest arrow in CSA critics’ quiver. To be sure, FMCSA has done industry a favor by proposing to expand and make permanent their crash preventability program, but unless the industry uses it, it’ll be business as usual.