In last month’s issue we wrote about the US DOT’s National Roadway Safety Strategy and noted the six strategies assigned to FMCSA to improve road safety. DOT has initiated a Call-to-Action campaign to solicit feedback, and STC is happy to oblige.

Our first recommendation is for FMCSA to clearly define the most prevalent large truck and bus related crash scenarios and to conduct a robust root cause analysis. While crashes are unique events, there certainly are commonalities that can be documented and identified as contributory factors.

In STC’s view, the ultimate measure of safety is crashes. Therefore, FMCSA should undertake an effort to define these crashes, their root causes and contributory factors, and to build its organizational structure and activities around addressing these crash scenarios. This would entail its legislative strategy, regulatory and policy structure and priorities, research approach, educational and awareness programs, grant programs and enforcement initiatives.

While the Large Truck Crash Causation Study certainly was a tremendous research effort to help in this regard, that study is based on data collected from 2001 through 2003. And while we are aware the Agency is undertaking a significant new study as a follow up — anticipated to start data collection in 2023 — the results are years away, and we can’t afford to wait.

The DOT Inspector General agrees. In its FY 2023  Report on Top DOT Management Challenges, it mentions the “major surface safety challenge for DOT is reducing highway fatalities and injuries. In particular, DOT’s success will require identifying the root causes of the increased fatalities.”

Once these crash scenarios and contributory factors are defined, FMCSA should map all of its activities against these crash types and factors, in an effort to identify their strengths and weaknesses are and to develop a specific plan for addressing them. This plan would serve as the Agency’s North Star for Safety, should be published for all to see, and would provide metrics upon which the Agency is measured by Congress and the public. Agency activities that can’t clearly be correlated with these crash scenarios should be sun-setted.

This is a foundational exercise that would serve FMCSA’s Mission well and clearly communicate to all stakeholders that safety is the Agency’s highest priority. Indeed, as Congress indicated when passing the 1999 Motor Carrier Safety Improvement Act that established FMCSA, “In carrying out its duties, the Administration shall consider the assignment and maintenance of safety as the highest priority, recognizing the clear intent, encouragement, and dedication of Congress to the furtherance of the highest degree of safety in motor carrier transportation.” This starts and ends with understanding the root cause of crashes.