Over the past decade, the number of roadside inspection violations used in the Federal Motor Carrier Safety Administration (FMCSA) Safety Measurement System (SMS) has grown
from about 650 violations to 959 violations. As a result, there are often multiple ways to cite a carrier for the same underlying safety issue.
For example, as shown in the below table, an inspector could record an inoperative vehicle brake issue at a general level citing one violation or at a more specific level citing violations for each brake component that does not comply with federal regulations.
Example Citation Differences for Inoperative Vehicle Break Issue
Because all roadside violations affect a carrier’s measure, these differences can lead to carriers with the same underlying safety issue receiving different SMS results.
Proposal:
The proposed changes would organize the existing 959 roadside violations, along with an additional 14 violations currently not applied to SMS, into 116 violation groups. See
Reorganized Unsafe Driving Category to Include Operating While OOS Violations for more
details on the additional violations. While any of these violations can still be cited during an
inspection, for prioritization purposes, violations that identify the same or similar underlying
safety issue would be grouped together. If a motor carrier receives more than one of the
violations in a violation group during a single inspection, the proposed methodology would treat that set of violations as a single violation when calculating the carrier’s measure in that safety category.
For example, the HOS Compliance violations below are part of a violation group related to the safety issue of violating HOS regulations.
“HOS Requirements” Violation Group in HOS Compliance Safety Category
If a motor carrier is cited for two or more of the violations above in the same inspection, these violations would all appear in the inspection report. However, when FMCSA analyzes the carrier’s data to determine if the carrier should be prioritized, the proposed methodology would count this set of violations as one violation under the “HOS Requirements” violation group.
Grouping a motor carrier’s violations before analyzing their data would ensure that motor
carriers are treated fairly by holding carriers with similar safety issues to the same standards, regardless of how those issues were documented. This would prevent the inconsistencies in safety category measures that occur when multiple violations are cited for the same underlying safety issue during one inspection. As a result, it would reduce the total violation weights possible in a safety category during an inspection, eliminating the need for the violation weight cap of 30 currently used in SMS.
This reorganization would also make it easier for motor carriers and drivers to identify and
address their safety issues. Consolidation produces 116 violation groups, offering a greater
level of detail than the 67 groups in SMS. Table 6 shows a summary of the new roadside
violation groups by safety category, and Appendix A contains a complete list of all violation
groups.
Number of Roadside Violations in SMS Compared to
Roadside Violation Groups in Proposed Methodology
Analysis Method
FMCSA used the ET to compare SMS with and without reorganized violations using the
September 2017 Motor Carrier Management Information System (MCMIS) snapshot. For an
accurate comparison with the only difference being the reorganization, the Agency did not apply violation weights to either version of SMS.
Evaluation Results
Reorganizing violations would prioritize a very similar carrier population to SMS. As shown in Table 7 below, for any roadside safety category, 97% of the same carriers would be prioritized under both methodologies. FMCSA’s analysis indicates that, for prioritization purposes, determining whether a safety issue is identified is more influential than determining how many ways it was documented.
Same Carriers Prioritized With and Without Reorganized Roadside Violations
All information in this post was retrieved from the FMCSA New Prioritization Methodology: Foundational Document, Version 1.5, March 2022.
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