The American Trucking Associations (ATA) has urged the Federal Motor Carrier Safety Administration (FMCSA) to conduct a comprehensive review of the current safety rating system, citing geographic disparities and data quality issues that undermine its reliability.
ATA: Current Rating System Needs Reform
In formal comments submitted to FMCSA, the ATA called for reevaluating the Carrier Compliance Review (CR) process and how the agency determines when to conduct audits, including unrated and off-site interventions. The association had successfully requested a 30-day extension for public comments, which closed on November 30.
The FMCSA is seeking input on developing a new methodology to assess motor carriers' fitness for interstate operations, aiming to repair flaws in the Safety Measurement System (SMS). Industry critics argue SMS unfairly penalizes carriers for minor operational errors, damaging their market reputation.
"While ATA doesn't oppose modifying carrier fitness determinations, we believe the agency must first incorporate industry feedback before finalizing changes to the current rating system," the ATA stated.
FAST Act and NAS Report
Section 5221 of the Fixing America's Surface Transportation (FAST) Act mandated the National Academy of Sciences (NAS) to conduct an independent SMS study. In 2017, FMCSA withdrew its 2016 proposed rulemaking pending NAS's completion of a correlation study and corrective action analysis.
The NAS report, titled "Improving Motor Carrier Safety Measurement," concluded that SMS's structure was fundamentally sound for identifying at-risk carriers. It endorsed FMCSA's crash prevention approach over predictive modeling but recommended developing an Item Response Theory (IRT) statistical model as a potential SMS replacement.
Data Limitations and Geographic Bias
The ATA highlighted concerns raised by the Government Accountability Office (GAO) about data sufficiency in the Compliance, Safety, Accountability (CSA)/SMS framework. For carriers to be evaluated under CSA/SMS, they must have at least 11 inspections with violations.
ATA emphasized that enforcement disparities create geographic bias. For example, in 2022, Texas issued vehicle maintenance violations for 84% of all citations, compared to just 34% in Indiana. "A carrier operating primarily in Texas would face stricter scrutiny not because its vehicles are less safe, but due to jurisdictional enforcement priorities," ATA explained.
Industry Stakeholders Voice Concerns
The Owner-Operator Independent Drivers Association (OOIDA) stated that CSA/SMS has "completely failed" to reduce crashes and fatalities since its 2010 implementation. It criticized FMCSA's Safety Fitness Determination (SFD) process for covering only 2% of interstate carriers in FY2019.
The Commercial Vehicle Safety Alliance (CVSA) advocated replacing the three-tier rating system (satisfactory, conditional, unsatisfactory) with a single "unfit" designation. It argued current ratings often become outdated and misleading.
The National Association of Small Trucking Companies (NASTC) called the existing system "terribly broken," noting that carriers completing lengthy compliance reviews remain "unrated" rather than receiving a "satisfactory" designation. It suggested renaming "unrated" to "authorized to operate" as an interim solution.
NASTC also highlighted how plaintiff attorneys misuse CSA scores as litigation evidence, creating liability concerns even for objectively safe carriers.