On February 15th, 2023, the Federal Motor Carrier Safety Administration (FMCSA) announced that they would be making changes to the Safety Measurement System (SMS). One of the biggest changes to come with this, is the way the Behavior Analysis and Safety Improvement Categories (BASICs) would be organized.
Through the Item Response Theory (IRT) study, the FMCSA learned that the Controlled Substances/Alcohol and Vehicle Maintenance BASICs could be reorganized making it easier to pinpoint and address specific safety issues. These BASICs were candidates for potential reorganization because they are the smallest and largest categories respectively.
Vehicle Maintenance is the largest BASIC with 406 violations, ranging from those easily identifiable during a pre-trip inspection, to those more commonly identified by an inspector, mechanic, or other expert during a more thorough inspection.
Controlled Substances/Alcohol is the smallest BASIC with 11 violations, and these violations are also cited relatively infrequently.
The table below demonstrates that only 0.1% of driver inspections contain Controlled Substances/Alcohol violations, whereas Hours-of-Service (HOS) Compliance and Unsafe Driving violations are each found in more than 10% of driver inspections. This data sparsity in the Controlled Substances/Alcohol BASIC leads to lower correlation with crash rate than most of the other BASICs.
Vehicle Maintenance will be divided into two categories:
Vehicle Maintenance: Driver Observed includes violations that could be observed by a driver as part of pre-trip inspection or detected by a law enforcement officer as part of a Walk-Around (Level 2) roadside inspection.
Vehicle Maintenance includes all other vehicle maintenance violations, more commonly identified by a mechanic doing routine maintenance or detected by a law enforcement officer as part of a Full (Level 1) roadside inspection.
Unsafe Driving would include the following violations:
Controlled Substances/Alcohol violations (no longer in their own standalone category). The BASIC’s data sparsity limited it's ability to identify high crash risk carriers. However, holding carriers accountable for their drivers’ drug and alcohol use remains important as a means of addressing safety issues.
An Exploratory Factor Analysis (EFA) demonstrated that Controlled Substances/Alcohol violations were strongly associated with the Unsafe Driving BASIC.
Example: “396.9(c)(2): Operating an OOS vehicle” is included in the Vehicle Maintenance BASIC in SMS but would be part of the Unsafe Driving safety category in the proposed methodology.
The FMCSA conducted an EFA during the IRT study to determine potential approaches for
reorganizing the Vehicle Maintenance and Controlled Substances/Alcohol safety categories. The EFA identified potential new groupings for these safety categories by highlighting statistical relationships between the violations within each safety category.
The EFA results suggested that the Vehicle Maintenance safety category could be divided into two categories: violations readily detectable by a driver during a pre-trip inspection, which inspired the idea for a new Vehicle Maintenance: Driver Observed safety category; and all other vehicle maintenance violations. This second new safety category aligns with Intermodal Equipment Provider (IEP) “Pre-Trip” designations where applicable.
The EFA was also used to determine whether the very small set of Controlled Substances/Alcohol violations could be grouped in one of the other driver-focused safety categories, Unsafe Driving and Driver Fitness. The analysis supported grouping the violations with Unsafe Driving because they were strongly associated with this safety category in general, and with the “reckless driving” violation.
Reorganizing the Vehicle Maintenance BASIC into two safety categories will provide more specific information to help motor carriers and enforcement pinpoint unsafe driver behavior and sources of vehicle maintenance issues.
The table below shows that although this leads to a slightly lower crash rate for prioritized carriers, the new safety categories would prioritize 18% more carriers than Vehicle Maintenance under SMS and these carriers are involved in 34% more crashes.
In addition, moving Controlled Substances/Alcohol violations to Unsafe Driving would help focus the FMCSA’s investigative resources on carriers with higher crash rates. The below table demonstrates that this change, in conjunction with the other proposed changes, would identify carriers with higher crash rates for investigation.
All information in this post was retrieved from the FMCSA New Prioritization Methodology: Foundational Document, Version 1.5, March 2022.
Stay tuned for more information on the FMCSA's proposed changes to SMS.
Until then, make sure to check out our online DOT Training platform, DOT University! We currently are offering Reasonable Suspicion for Supervisors, Cargo Securement, Defensive Driving, and Pre/Post Trip Inspection. In the coming months, we plan on releasing Designated Employer Representative and Appendix A.
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