In comments submitted July 27 to the Federal Motor Carrier Safety Administration, the Intermodal Association of North America shared several concerns on the impacts of the Agency’s changes to the Safety Measurement System component of its Compliance, Safety, Accountability program.
IANA’s comments focused on ensuring the proper allocation of motor carrier and intermodal equipment provider violations by using identified attribution processes that were collaboratively developed last fall with the involvement of law enforcement, motor carriers and IEPs. With respect to FMCSA’s Intermodal Chassis Violation List that drives the enforcement roadside system algorithms and violation attribution determination, IANA suggested that standard processes should be developed to guide and manage IEP and motor carrier accountabilities for specific violations.
Another key concern was the assignment of a percentile ranking to each BASIC and crash indicator instead of using an absolute measurement. IANA observed that assigning a set deficiency threshold to a carrier’s relative performance within a safety event group assumes that a certain percentage of carriers in the group exhibit unacceptable safety behavior, regardless of actual performance. The Association also took issue with the weighting of crash data that implicates a motor carrier even though the trucker is reported to have no contributing factors to the incident.