CSA - Crash Indicator Basic

Crash SMS Basic Points Calculation, the Crash Indicator BASIC percentiles have never been publicly available, however the use of all crashes in SMS, may give an inaccurate impression about the risk posed by the company. As a motor carrier we have customers and insurance companies that request our crash basic and base their business decisions on these facts. Now that we’ve had several years of researching Crash Preventability DataQ’s, by providing accident records into FMCSA via the DataQ’s website, we’ve proven that motor carriers and drivers are not entirely responsible for every accident they are involved in or included on the police accident report.

FMCSA uses all reportable crashes, regardless of preventability, to find carriers that pose a safety risk. As it stands, only crashes that are plainly non-preventable are eligible for review under the Crash Preventability Determination Program. This process was for motor carriers and/or driver to challenge a Not Preventable accident, and it was supposed to streamline the process of Request for Data Review on DataQ’s website. I I’ve participated in the Crash Preventability Demonstration Program from the very start as well as Crash Preventability Determination Program and find the process to be difficult and time consuming to receive a response back from FMCSA on my requests. This is affecting our Crash Indicator BASIC as well as drivers on their PSP, negatively due to the delay in the FMCSA response to our RDR requests. Recently, the delays to get a response from FMCSA have been well over 100 days after the request has been entered. It is clear, that everyone is submitting RDR (request data review) on non-preventable accidents and now there is a large backlog of challenges not being responded to or answered in a timely manner. Most police accident reports show whom the officer (responding agency) feels is at fault for the accident as an example California Highway Patrol includes the cause of the crash at the bottom of the officer’s narrative. By FMCSA’s own figures (Federal Register Notice dated April 13, 2023), it states that 96% of the eligible crashes that submitted RDR’s were in fact found to be not preventable. The crashes that were found to be Preventable were for a driver and/or equipment violations that was operating with a pre-crash (OOS) violation.

It is my request that FMCSA and CVSA exclude not preventable and undecided crashes when calculating a motor carrier's Crash Indicator Behavior Analysis Safety Improvement Category measure. This will reduce all the backlog that is currently affecting the FMCSA on the RDR’s submitted DataQ’s that have not been responded to yet. If an accident is determined by the investigating officer to be as a not at fault or the other involved driver is issued a traffic citation for the accident-causing violation, the accident shall be considered a non-preventable for the other drivers-vehicles involved and no CSA points shall be issued. If no fault can’t be determined due to the lack of evidence, or conflicting witness information-driver’s account, the accident shall be deemed neither preventable nor non-preventable and no CSA points assigned. If both vehicles committed actions that contributed to the accident causation and/or both drivers are cited for accident-causing violations, CSA points shall be applied to all CMV involved. If the motor carrier and/or driver would like to challenge this determination, they may submit a RDR with DataQ’s for review. Can we have an open forum question/comments at the CVSA Conference on September 20th in the Committee Meeting – Crash Data and Investigation Standards in in Grapevine, TX? Thank you, Sharon Wheeler CSA Safety Compliance Knight Swift Transportation