OTA Dispatch Issue1, 2021

9 www.ortrucking.org Issue 1 | 2021 take on the responsibility for utilizing state employees to perform the work associated with the NCE and PRISM programs. Such duties of course reduce the amount of time state employees have available to devote to their otherwise assigned workload, so it is reasonable to take a look and see what the motor carrier industry stands to gain in return for this change in direction. I obtained from academia copies of recent research looking at FMCSA New Carrier Entrant Audit data and found them an interesting read. I have long been skeptical of worthwhileness of the NCE program. After reading these research documents I have moderated my opposition but still express a twofold concern. I’ll give you my two cents. I reviewed the following research abstracts: 1. “The Impact of New Entrants and the New Entrant Program on Motor Carrier Safety Performance” – David E. Cantor, Thomas M. Corsi, and Curtis M. Grimm 2. “An Exploratory Investigation of New Entrant Motor Carrier’s Longitudinal Safety Performance” – Jason Miller and John P. Saldanha One of these research papers suggests small fleets benefit more than larger fleets from the NCE program. Similarly, there were variations noted between specific industry segments. Yet, FMCSA does not allow for discretion by States in choosing motor carriers most likely to benefit from participation and instead requires a one size fits all approach. I suggest jurisdictions receiving MCSAP grant should have latitude to deploy their limited safety resources where they determine the positive return to be greatest. How does any state know whether NCE delivers the best bang for the buck in reaching the safety goal of reducing truck at fault accidents? In my experience, that determination most likely occurs when the state safety professional staff tests their best inclinations derived from their cumulative years of experience on the ground by subjecting their assumptions to data driven statistical regression analysis and determining where the greatest correlation is between the two data sets of work activities performed and the desired outcome of reduction of truck at fault accidents. In other words, if management required all safety inspectors to wear pink coveralls and then observed truck accidents went down in a reporting period is it reasonable to conclude pink coveralls causes safer trucks? Of course not! This relationship is obviously random. In Oregon, it was once thought if more and more mechanical inspections of trucks were performed all over the state that it only made sense that truck at fault accidents would decrease. That seems to make sense, right? When statistical regression analysis was done to examine the relationship between increased numbers of truck mechanical inspections and resulting numbers of truck at fault accidents, it was determined that one had nothing to do with the other. The result was just as random as the pink coverall example. How could that be? Upon further study, it became clear that over 95% of truck at fault accidents were not the result of a truck mechanical defect. Over 95% of truck at fault accidents resulted from driver behaviors including speeding, following too closely, unsafe lane changes, or driver over HOS. Therefore, investing all your resources in what was causing less than 5% of truck at fault accidents (mechanical inspections) was likely not going to move the needle. However, by changing course and following the empirical statistical analysis and redirecting resources to focus on the driver by increasing police patrols on the interstate and focusing roadside inspectors on driver qualifications the number of truck at fault accidents declined. Regression analysis demonstrated a strong correlation between these two variables in Oregon. I’d also venture to say the result of this kind of outcome-based performance measurement approach might not be consistent from state to state. Yet, FMCSA does not allow for discretion by states in choosing motor carriers most likely to benefit from participation in NCE and instead requires a one size fits all approach. Secondly, in the other research abstract, the relatively low adjusted r-squared values in the regression analysis suggests that lurking out there are yet to be discovered other factors that impact motor carrier safety among new entrants. Nevertheless, FMCSA takes an all-in singularly focused approach. This is referred to as “unobserved heterogeneity” and implies the existence of unmeasured (unobserved) differences between study sample participant carriers that are associated with the observed variables of interest. FMCSA’s conclusions are therefore shallow if not self-serving. More research is necessary to fully evaluate whether universally required new entrant carrier audits are the silver bullet some claim them to be. I’m not alone in these observations. I queried a senior individual in a safety regulatory program in a western state on his/her views about the value of their mandatory participation in NCE and heard this in reply: “What keeps me from grabbing my Super-Big-Gulp cup and running to the NCE Kool-Aid party is what my investigators have told me for years. During CR’s, they consistently find that carrier officials have little to When statistical regression analysis was done to examine the relationship between increased numbers of truck mechanical inspections and resulting numbers of truck at fault accidents, it was determined that one had nothing to do with the other.