NTTC Responds to FMCSA Request for Comments on the Carrier Safety Measurement System
On May 12, NTTC submitted a letter to the Federal Motor Carrier Safety Administration (FMCSA) regarding proposed changes to the Safety Management System (SMS). The proposed changes are in response to a 2017 recommendation from the National Academy of Sciences that a new statistical model be implemented.
FMCSA has proposed changes as seven groups: (1) reorganized and updated safety categories, including new segmentation; (2) consolidated violations; (3) simplified violation severity weights; (4) proportionate percentiles instead of safety event groups; (5) improved Intervention Thresholds; (6) greater focus on recent violations; and (7) an updated Utilization Factor. In its letter, NTTC not only expressed support for the existing FMCSA Safety Management System (SMS) utilizing quantitative metrics to identify high risk motor carriers, it also overall agreed with the agency’s initiative to modernize and improve SMS as described in Docket Number FMCSA-2022-0066.
One item of particular interest to NTTC is FMCSA’s proposal to extend segmentation of carriers by operation and vehicle type to additional safety categories to improve carrier-to-carrier comparisons. This change would likely mean that cargo tank industry companies would be measured only against peers, recognizing that a cargo tank truck is inherently different and is subject to more roadside inspections.
Further, FMCSA proposed reorganizing 973 roadside violations into 116 violation groups of similar safety behaviors to prevent inconsistencies that occur when multiple violations are cited for a single or very similar underlying issue. NTTC expressed support for this modification as well, which will permit companies to facilitate training topics easier for their personnel. Also, consolidating violations would likely reduce stacking practices in which a driver could be cited multiple times for the same malfunctioning part.
NTTC staff will be monitoring the proposed SMS changes, and will share developments with NTTC membership accordingly. Questions can be directed towards staff, via [email protected]