I spoke at the Warehouse Education and Research Council (WERC) meeting in Dallas yesterday on regulatory issues. In advance of that, we decided to update our analysis of the relationship between Compliance Safety Accountability (CSA) scores and carrier accident frequency and found there is no relationship between a carrier’s percentile scores on Unsafe Driving and Hours of Service and their accidents per million miles. These two charts show data for 28,000 carriers for Unsafe Driving and 48,000 carriers for Hours of Service from the March 2013 FMCSA data available on their website.
There have been numerous changes to the CSA program including a redefinition of BASICs, but the outcome remains the same. A carrier’s CSA scores are not a valid predictor of the likelihood of that carrier having an accident and should not be used by shippers and brokers in the carrier selection process.
We also reran the numbers removing all carriers with less than 25 trucks since those carriers have very few inspections and their scores are particularly unreliable. Even excluding the smallest carriers, it is still clear that there is no relationship between CSA scores and accident frequency. There are 9,905 carriers represented on the Unsafe Driving graph and 8,470 carriers on the Hours of Service graph.

The CSA data remains incomplete as well. As of March 2013, there are still only 89,134 carriers with a score on at least one of the five published BASICS out of a universe of at least 500,000 carriers, so less than 20% of carriers are measured. Of those carriers that are measured 55% have at least one BASIC over the intervention threshold. Given the phenomenal track record of the trucking industry in reducing highway accidents and fatalities, it is incredulous to think that 55% of carriers could have some deficiency in their safety programs.
Inspector General and General Accounting Office studies of the CSA program are underway and we are hopeful that these efforts will convince (or force) the FMCSA to use the CSA program as it was originally intended – that is as a mechanism to help the agency allocate its scarce enforcement resources. Many carriers also benefit from the feedback they receive from the inspection process. A federal lawsuit by ASECTT challenging the publication of scores is also heading towards oral arguments early this summer. The fundamental problem with this program is that the data is not valid for credentialing carriers, is not a suitable substitute for the Safety Fitness Determination that the FMCSA is federally obligated to provide, and should not be made available to the shipping public. Small businesses (carriers) are being harmed because they are denied freight that they should rightfully be allowed to haul. Shippers and brokers are needlessly being exposed to meritless liability claims.