TransComply: Falling inspections weaken safety oversight, CSA
The Federal Motor Carrier Safety Administration announced Feb. 29 that commercial motor vehicle (CMV) roadside and traffic enforcement (TE) interventions in fiscal 2012 saved an estimated 472, according to the agency's Roadside Intervention Effectiveness Model (RIEM).
An anlysis by TransComply, however shows that using FMCSA’s own model those interventions could have saved 169 more lives that year had the number of TE inspections not dropped by more than 43% from their peak in fiscal 2006.
Although not covered in FMCSA’s latest report, applying the RIEM to roadside and TE interventions in fiscal 2015 indicates that 461 lives were saved due to inspections. But another 224 lives could have been saved had TE inspections remained at fiscal 2006 levels. To put that figure in perspective, FMCSA estimates that the new electronic logging device rule will save 26 lives a year and that the hours-of-service rule, as issued, saves 19 lives.
“If FMCSA’s model is accurate, the trend is alarming, and the agency has only limited tools to do anything about it,” says TransComply President Avery Vise. “On the other hand, it is possible that traffic enforcement activities actually have improved motor carrier safety even while reported TE inspections have plummeted. Unfortunately, we don’t know because FMCSA currently captures no usable data on traffic enforcement that occurs without a reported inspection.”
TE inspections are those conducted over the road following moving violations such as speeding or reckless while the more frequent roadside inspections (RIs) are typically conducted at fixed locations, such as weigh stations. According to the RIEM, TE inspections are about four times as effective as RIs in reducing crashes, injuries and deaths.
Despite the effectiveness of TE inspections, they peaked at just over 900,000 in fiscal 2006 and have plummeted 60% to just under 360,000 in fiscal 2015, according to FMCSA data. RIs generally have continued to grow, but they, too, have dipped slightly since fiscal 2012.
In addition to lower fatalities, FMCSA analysis using the RIEM indicates that inspection and enforcement prevented 8,833 injuries and 14,424 crashes involving large commercial trucks and buses in fiscal 2012. However, RIEM methodology indicates that had TE inspections remained at fiscal 2006 levels an additional 2,825 injuries and 3,718 crashes would have been prevented.
A foreseeable outcome Practically all TE inspections and RIs are conducted by state and local agencies. TE inspections have fallen probably due to a combination of factors, including tighter state budgets. Another possible contributor is slower highway speeds due to carrier concerns over safety, fuel economy and Compliance, Safety and Accountability (CSA) program scores.
“If truckers are drawing fewer inspections because they are committing fewer moving violations, then that would be a positive safety development, but it also would be difficult to establish without more data,” Vise says. “Also, CSA presumably would not have played a role in slower speeds until at least fiscal 2010 by which time TE inspections had already dropped by more than 20%.”
A significant factor in lower TE inspections over the past decade undoubtedly is legislation that Congress enacted in 2005 allowing states to use funds under the Motor Carrier Safety Assistance Program, or MCSAP, for motor carrier traffic enforcement activities that do not result in an inspection. The rationale was that because so few law enforcement officials are qualified to conduct CMV inspections, we should incentivize law enforcement agencies to devote more resources to policing truckers’ moving violations.
“If states can obtain FMCSA reimbursement for traffic stops without having to devote the time and resources to conducting CMV inspections, you would expect the number of inspections to drop, and that’s exactly what happened,” Vise says.
Presumably, encouraging more interaction with truckers even without reported inspections has produced safety benefits, and FMCSA is trying to maximize these benefits through free, easy-to-implement training programs for law enforcement officers. FMCSA cannot quantify the impact on safety, however, because it doesn’t collect data on these activities in any central database that could be analyzed.
“The bottom line is that either we are seeing crashes, injuries or deaths that could have been avoided or FMCSA’s Roadside Intervention Effectiveness Model is incomplete at best,” Vise says.
One clear impact Even though the safety impact of the reduced TE inspections is uncertain, the sharp drop has had at least one clear consequence. All of the data populating the Unsafe Driving Behavior Analysis Safety Improvement Category (BASIC) comes from TE inspections.
“TE inspections are down more than 35% since FMCSA launched CSA,” Vise notes. “This reduction surely has undermined the Unsafe Driving BASIC, which affects the quality of FMCSA’s targeting of motor carriers for intervention today and could have consequences for the agency’s proposal to assign safety ratings based on inspection data alone.”
For a copy of FMCSA's report, click here.
See related post: If FMCSA is right about inspections, there's a problem.