Note: "This (in my humble opinion) is an important paper. We must be serious about reducing commercial vehicle crashes; otherwise we are playing gotcha. The men and women in safety enforcement deserve to know if they are working to reduce crashes. Frankly, I do not believe Congress has any interest in funding "games" by regulators.

"The hope of CSA was that it would move towards risk mitigation of crashes instead of playing Smokey and the Bandit.

"While we continue to support the tenets of CSA, its evolution into a refined tool with open review must not only continue, it must continue quickly. Business, future careers, and jobs are at stake." -- Ken Presley, vice president and chief operating officer, United Motorcoach Association.

By Rob Abbott

When I was growing up, a friend and I frequently passed the time listening to an old Bill Cosby album.

This fine 33 1/3 record included an amusing and memorable bit about Cosbys experiences in shop class. Whenever a project didnt turn out as planned, Cosby would simply carve two grooves in it and, when asked what it was, would declare: "Its an ashtray!"

Even if he set out to build a shoe-shine box, upon failing he would carve two grooves in it. "What is it?" his teacher would ask. "Its an ashtray!" Bill would reply. "But it has shoe polish in it," replied the teacher. "Well, there are all types, you know."

Of course, the point of the story was that if something didnt turn out as planned, you could simply tweak it a bit and point to its new purpose, as though you had intended it from the outset.

Regrettably, we run that risk with CSA, the federal governments 18-month old safety scoring system.

According to the first paragraph of the CSA methodology, the goal of CSA is to implement more effective and efficient ways for the Federal Motor Carrier Safety Administration, its state partners, and the (commercial vehicle) industry to reduce commercial vehicle crashes, fatalities, and injuries.

Logically, scores in each of the measurement categories should reliably identify carriers most likely to cause crashes. However, in some instances, they do not.

For example, according to the FMCSA Evaluation of the CSA Operational Model Test, there appears to be no difference in crash rates for carriers with scores exceeding the intervention threshold in the Driver Fitness BASIC compared to carriers whose scores do not.

The evaluation report displays this relationship with a graph showing an inverse relationship between scores and crash rates. Despite this finding, FMCSA does not acknowledge that the methodology for this measurement category is flawed and continues to make these flawed scores public.

Instead, agency officials point to the merits of identifying carriers with patterns of violations in this category, even though these violations dont bear a relationship to future crash risk.

Naturally, we have to ask: Did FMCSA deliberately set out with this in mind when it developed the Driver Fitness BASIC? Its doubtful. According to the CSA methodology, each roadside inspection violation is assigned a severity weight that reflects its association with crash occurrence and crash consequences.

The sum of these weighted violations is then used to ultimately develop a quantifiable measure of safety for each scored carrier. So by design, the system should identify carriers that have more crash occurrences or, at very least, worse crash outcomes.

FMCSA runs the risk of going down this same path with its planned Hazardous Materials (HM) BASIC. The agency candidly acknowledges that "the goal of the HM BASIC is not to predict future crash risk."

Instead, FMCSA says the BASIC better identifies carriers that are more likely to commit future hazardous materials violations. The agency points to the importance of identifying such carriers since HM can increase the consequences of a crash, but presents no data to show that HM carriers have crashes with worse outcomes as a result of HM violations.

Of course, one has to wonder how often some of the most common HM violations (e.g., damaged or deteriorated placards), really lead to more severe crash outcomes.

Naturally, it may be tempting for FMCSA to simply change the goal and methodology of CSA to match the output. Also, the agency might modify how it characterizes the meaning of carriers CSA scores. Placing an emphasis on compliance is certainly important, though we could argue the merits of emphasizing compliance with regulations that have no statistical relationship to crash risk.

We also could discuss the merits of ashtrays. They prevent accidental fires and make the world a cleaner place. Ashtrays are important, too.

But in the end we should remember that CSA is about prioritizing carriers for intervention.

Accordingly, most people would probably agree that the highest priority should be placed on identifying motor carriers and drivers that are causing crashes and changing their behavior.

If the system doesnt do that, FMCSA should acknowledge the limitation and fix it rather than carving two grooves in it and calling it an ashtray.

Rob Abbott is vice president of safety policy at the American Trucking Associations.