Monday, November 7, 2011

BREAKING NEWS: Important Study Challenges SMS Methodology

The predicate for use of SMS methodology as a new safety fitness determination is the unproven assumption that percentile rankings of carriers by peer groups based upon roadside inspections is an adequate predictor of carrier safety. The Agency’s methodology was constructed and modified without the benefit of completed statistical and scientific research and has been supported only after the fact by release of the ambiguous University of Michigan study which was based upon stale and unchallenged data.

This week Wells Fargo released an independent study comparing the percentile rankings of the 200 largest carriers with crash ratios in two of the critical BASICs – unsafe driving and fatigued driving.

Unlike the University of Michigan study, the Wells Fargo study is based upon contemporary data, a straight line analysis, and the performance of carriers with enough performance data to draw proper statistical conclusions.

Release of the Wells Fargo study is particularly timely since the FMCSA has not yet sent its SMS methodology to OMB for approval for submission in the formal APA mandated rulemaking process. In view of anticipated stout opposition to approval of SMS methodology, this report strongly suggests that the Agency should immediately remove percentile rankings of carriers from carrier profiles on the FMCSA website and re-think how best to achieve its goal of more efficiently making safety fitness determinations for the 797,000 carriers it is charged with regulating.
To review the Wells Fargo study, see attached.

For additional information about flaws in the SMS methodology and its adverse effect on competition, efficiency, and the 600,000 small privately owned motor carriers the Agency regulates, visit

Wells Fargo-CSA Good Intentions 11-11

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