Despite the best of intentions, CSA has not moved the crash reduction needle. As shown in this table, large truck-involved fatal, injury and PDO crash rates rose substantially between the launch of CSA and 2017, which is the latest year for which finalized crash data is available. These rates account for exposure (i.e., the increase in mileage over time). Unfortunately, when looking at absolute crash numbers between 2010 through 2017, the percentage increases are even higher – +30%, +82% and +66% respectively. Is it time for FMCSA to consider a new and different approach to CSA, and perhaps more generally?