Grading on a Curve is Not Acceptable for Safety Fitness Determinations

For over 75 years, safety fitness determinations have been based upon objective safety proficiency standards and compliance reviews of regulated carriers which afford due process prior to terminating a carrier’s operating authority. The Agency has successfully overseen the motor carrier industry, reducing crashes year after year by managing the industry on a risk assessment basis, auditing only those carriers which it determines in need of attention.


CSA / SMS methodology would drastically revamp this effective system, replacing it with an intricate peer group percentile ranking weighting system which amounts to “grading on a curve” in which a predetermined percentile of carriers will fail regardless of the state of their compliance. Safety under SMS methodology is to be made a competitive game, like “Dancing with the Stars” - no matter how good the industry as a whole becomes the judges have predetermined that a certain number will be eliminated.

It is submitted that this system is systemically flawed, impossible to administer, and unable to achieve the proclaimed results. The Agency does not have data sufficient to rank in all 7 peer groups, well over half of the 483,000 it regulates.

Hank Seaton