FMCSA pushing forward with Safety Measurement System (SMS) changes in light of public comments
The Federal Motor Carrier Safety Administration (FMCSA) has released its latest plans to update the Safety Measurement System (SMS) as part of its ongoing efforts to refine how motor carriers are prioritized for safety interventions. Following its latest public comment period after releasing its original February 2023 proposal, the agency's updates reflect significant enhancements and stakeholder contributions. This article summarizes the changes and their implications for motor carriers going forward. Importantly, the FMCSA has not yet announced the implementation date for these planned changes.
Background on SMS
The SMS (colloquially known as "CSA scores"), introduced in 2010 under the Compliance, Safety, Accountability (CSA) program, identifies high-risk motor carriers for inspections and enforcement actions. The system analyzes safety data, including roadside inspections and crash records, to generate scores in specific safety categories (formerly called BASICs). These scores guide FMCSA’s enforcement priorities.
While FMCSA has periodically updated SMS, the planned overhaul of the system result from a comprehensive analysis and public feedback, aiming to improve accuracy, fairness, and transparency in carrier prioritization.
Key Proposed Changes and Public Feedback
The FMCSA's February 2023 proposal introduced seven major updates. Included below is a summary of each change, the public’s response, and the FMCSA's most recent refinements. Again, the FMCSA has not yet revealed the date for the planned rollout of these changes.
We broke these major changes down in the following video following the FMCSA's original announcement from February of 2023:
Renaming and Reorganizing BASICs
The BASICs (Behavior Analysis and Safety Improvement Categories) will now be rebranded as "Compliance Categories," reflecting a shift toward terminology emphasizing regulatory compliance rather than just safety.
Key structural changes include:
Combining Controlled Substances/Alcohol (CS/A) violations into the Unsafe Driving Compliance Category.
Splitting Vehicle Maintenance into two categories: Vehicle Maintenance and Vehicle Maintenance: Driver Observed.
Stakeholder Feedback:
The name change to "Compliance Categories" received mixed reactions, with organizations like the American Trucking Associations (ATA) supporting it for clarity. However, some stakeholders expressed concerns about diluting the safety focus.
FMCSA Response:
FMCSA chose to adopt "Compliance Categories," citing the term's broader appeal and its ability to simplify discussions around safety and compliance. It also emphasized the statistical connection between these categories and crash risks.
Violation Consolidation
The FMCSA reduced the number of individual violations analyzed in SMS from 959 to 116 by grouping similar violations. For example, 73 hours-of-service (HOS) violations were condensed into nine groups.
Stakeholder Feedback:
The majority supported this simplification, noting it reduces confusion and improves enforcement consistency. However, some worried it might mask the significance of severe violations.
FMCSA Response:
The agency maintained that grouping violations increases fairness by focusing on the presence of a safety issue rather than the number of ways it’s documented. Adjustments were made to avoid overlaps in groups like HOS and brakes.
Simplified Violation Severity Weights
Historically, violations in SMS have been assigned weights ranging from 1 to 10, based on severity. The planned system uses a simplified scale of 1 or 2, with higher weights assigned to out-of-service violations and severe infractions.
Stakeholder Feedback:
While stakeholders appreciated the simplicity, some expressed concerns that the reduced granularity might fail to reflect differences in violation severity adequately.
FMCSA Response:
FMCSA defended the 1-2 scale, highlighting its strong correlation with identifying carriers with higher crash rates.
Proportionate Percentiles
To address sudden percentile jumps caused by safety event group changes, FMCSA introduced a method where carriers’ percentiles are calculated using a weighted average of their individual events.
Stakeholder Feedback:
This change was widely supported, especially by smaller carriers, as it reduces erratic CSA score shifts.
FMCSA Response:
FMCSA emphasized that this method ensures stability and more accurately reflects carriers’ safety performance.
Improved Intervention Thresholds
Thresholds, which determine when carriers are prioritized for interventions, were adjusted in specific categories:
Driver Fitness thresholds increased (e.g., from 80% to 90% for general carriers).
Hazardous Materials (HM) Compliance thresholds also increased in the same manner.
Stakeholder Feedback:
Supporters viewed these changes as risk-focused, but others worried that higher thresholds could delay interventions for carriers with systemic safety issues.
FMCSA Response:
The agency justified the adjustments based on crash correlations, ensuring resources are focused on the highest-risk carriers.
Focus on Recent Violations
Carriers with no violations in the past 12 months will not receive percentiles in affected categories, even though violations from the past 24 months are still tracked.
Stakeholder Feedback:
Stakeholders broadly supported this change, emphasizing its alignment with current safety performance and the need for continuous improvement.
FMCSA Response:
FMCSA retained this approach, prioritizing carriers with active compliance issues.
Updated Utilization Factor
The Utilization Factor now accounts for carriers operating up to 250,000 vehicle miles traveled (VMT) per power unit (PU), an increase from the previous 200,000-mile cap.
Stakeholder Feedback:
While some praised this adjustment for recognizing high-utilization carriers, others worried about potential data manipulation through inflated VMT reporting.
FMCSA Response:
FMCSA affirmed the change, citing analysis that justified the new cap while committing to monitor for data accuracy.
Additional Changes Based on Feedback
FMCSA has implemented further refinements based on comments received:
Reorganization of Violations: Some violations were reclassified to better align with their root safety issues.
HOS and Brakes Adjustments: Overlapping violation groups were consolidated for consistency.
Frequency of Updates: FMCSA is exploring more frequent updates to the SMS website to reflect real-time safety data.
Next Steps for Carriers
FMCSA is finalizing its SMS methodology updates and will announce an implementation timeline through the Federal Register. In the interim, carriers can:
Review their data: The SMS Preview website remains available for carriers to analyze how the changes impact their scores.
Participate in webinars: FMCSA will hold educational sessions to help carriers understand the enhancements. Stay tuned for announcements of webinar dates.
Conclusion
FMCSA’s enhanced SMS methodology will be a significant shakeup in the way CSA scores are calculated. By addressing public feedback and leveraging data-driven insights, the updates aim to improve how motor carriers are prioritized for interventions.
Motor carriers should take this opportunity to familiarize themselves with the new methodology, engage in available training, and evaluate their safety practices in light of the planned changes.
For assistance with CSA scores or understanding how these changes may impact your operations, feel free to contact us. Also, be sure to subscribe to our newsletter to stay up to date with these types of regulatory changes and our analysis of them.
About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a livestream podcast on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who've assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube. Or subscribe to Trucksafe's newsletter for the latest highway transportation news & analysis. Also, be sure to check out eRegs, the first app-based digital version of the federal safety regulations aimed at helping carriers and drivers better understand and comply with the regulations.