FMCSA Report on Life-Saving Impact of Safety Enforcement Challenged

The Federal Motor Carrier Safety Administration estimates that commercial vehicle roadside safety inspection and traffic enforcement programs saved 472 lives in 2012. 

What’s more, the agency said that since 2001, these programs have saved more than 7,000 lives and have prevented nearly 9,000 injuries from more than 14,000 crashes involving large commercial trucks and buses. 

All those figures came out of FMCSA’s latest annual Roadside Intervention Effectiveness Model (RIEM) analysis. It took into account statistics for 2012, the most recent year for which data is available. 

But a supplier of safety and compliance services and, separately, the American Trucking Associations have taken issue with what the agency contends the report indicates.

“Our analysis demonstrates that inspectors at roadside and state troopers conducting traffic enforcement are making a vital difference to prevent crashes,” said FMCSA Acting Administrator Scott Darling. 

Noting that the vast majority of unannounced roadside CMV safety inspections are conducted by the states, which receive annual grant support from the agency for safety program activities, including roadside inspections and traffic enforcement, FMCSA said it developed RIEM as “a tool to annually analyze and measure the effectiveness of these roadside safety inspections and traffic enforcement programs and activities in terms of crashes avoided, injuries prevented, and lives saved.” 

The RIEM tool associates each violation of FMCSA’s safety regulations with a specific crash probability.  Using these probabilities, FMCSA said, analysts can estimate the number of crashes avoided as a result of correcting these violations.

Different Takes

As welcome as the FMCSA estimate of reduced fatalities appears to trucking, a supplier of safety and compliance services argues that 169 more lives would have been saved in 2012 had the number of traffic enforcement inspections not declined by more than 43% from their peak in fiscal year 2006.

And the American Trucking Associations contends that the number of lives saved by FMCSA’s CMV roadside safety inspection and traffic enforcement program fell has from 735 in 2002 to 472 in 2012.

"If FMCSA’s model is accurate, the trend is alarming, and the agency has only limited tools to do anything about it,” said Avery Vise, president of TransComply, which provides motor carriers with compliance and safety programs, in a news release. 

“On the other hand,” he continued, “it is possible that traffic enforcement activities actually have improved motor carrier safety even while reported TE inspections have plummeted. Unfortunately, we don’t know because FMCSA currently captures no usable data on traffic enforcement that occurs without a reported inspection.”

Vise also stated that although it is not covered in FMCSA’s latest report, applying the agency’s RIEM to roadside and TE interventions in fiscal 2015 indicates that 461 lives were saved due to inspections.

“But another 224 lives could have been saved had TE inspections remained at fiscal 2006 levels,” he argued. “To put that figure in perspective, FMCSA estimates that the new electronic logging device rule will save 26 lives a year and that the hours-of-service rule, as issued, saves 19 lives.”

In addition to lower fatality numbers, Vise said FMCSA analysis using the RIEM tool indicates that inspection and enforcement prevented 8,833 injuries and 14,424 crashes involving large commercial trucks and buses in fiscal 2012. “However, RIEM methodology indicates that had TE inspections remained at fiscal 2006 levels, an additional 2,825 injuries and 3,718 crashes would have been prevented.”

According to Vise, despite the effectiveness of TE inspections, which are conducted following moving violations, they peaked at just over 900,000 in fiscal 2006 and have fallen 60% to just under 360,000 in fiscal 2015, per FMCSA data. He added that while RIs generally have continued to grow, they have also dipped since fiscal 2012.

As Vise sees it, “fewer inspections may represent lost opportunity and weaker CSA data.” While conceding that “the safety impact of the reduced TE inspections is uncertain, the sharp drop has had at least one clear consequence. All of the data populating the Unsafe Driving Behavior Analysis Safety Improvement Category (BASIC) comes from TE inspections.

“TE inspections are down more than 35% since FMCSA launched CSA,” he continued. “This reduction surely has undermined the Unsafe Driving BASIC, which affects the quality of FMCSA’s targeting of motor carriers for intervention today and could have consequences for the agency’s proposal to assign safety ratings based on inspection data alone." 

It’s an either-or conundrum, according to Vise. “The bottom line is that either we are seeing crashes, injuries or deaths that could have been avoided or FMCSA’s Roadside Intervention Effectiveness Model is incomplete at best.”

The American Trucking Associations is also taking issue with the agency report. ATA spokesperson Sean McNally told HDT that the number of lives saved by FMCSA’s CMV roadside safety inspection and traffic enforcement program has dropped from 735 in 2002 to 472 in 2012, marking a 36% decrease.

“So,” said McNally, “despite consistent increases in funding, the program has become less and less effective. Yet they [FMCSA] took a victory lap [with this announcement].

“The decrease in crashes prevented and lives saved is largely driven by the decrease in traffic enforcements,” he continued, citing page 18 of the FMCSA report.

“Traffic enforcements are four times more effective at preventing crashes and saving lives [per page 22], yet the report reflects a consistent decline in traffic enforcement activity.”

McNally added that “this report only reflects data through 2012. FMCSA’s website reflects more recent years with a continuing trend. If anything, this report bolsters ATA’s position that FMCSA and the states should be in the business of doing traffic enforcement, vs. just roadside inspection after roadside inspection.”

It seems CMV inspections are much in the news right now. Just last week, the Commercial Vehicle Safety Alliance criticized the agency for unduly burdening roadside inspectors by issuing carriers and drivers too many safety-rule exemptions. 

“Recently, the Federal Motor Carrier Safety Administration has issued notices of final disposition that hinder the roadside inspector while conducting inspections,” stated Collin Mooney, CVSA executive director, in a Feb. 18 letter to FMCSA’s Scott Darling.

With additional reporting by Deborah Lockridge

Related: CVSA Cites FMCSA for Burdensome Exemptions