Large truck crash study must improve drastically, OOIDA says
March 17, 2020
As FMCSA undertakes a new Large Truck Cash Causation Study, the agency “must drastically improve upon the failed structure and methodologies” of its initial study, the Owner-Operator Independent Drivers Association said in formal comments.
In January, FMCSA announced it was working toward launching a study looking at the factors that contribute to large truck crashes. As part of the announcement, the agency issued a request for information notice on Jan. 15.
“FMCSA seeks information on how best to design and conduct a study to identify factors contributing to all FMCSA reportable large truck crashes (tow-away, injury and fatal),” the notice said. “Methodologically, the agency seeks information on how best to balance sample representativeness, comprehensive data sources, ranges of crash types, and cost efficiency.
“The study should be designed to yield information that will help FMCSA and the truck safety community to identify activities and other measures likely to lead to significant reductions in the frequency, severity, and crash rate involving commercial motor vehicles.”
OOIDA submitted its comments on Monday, March 16. The Association said the initial Large Truck Crash Causation Study conducted in 2001-03 had “significant shortcomings.”
“As a practical measure, FMCSA should change the name of this project to the Large Truck Crash Contributing Factors Study,” OOIDA wrote in comments signed by President and CEO Todd Spencer. “Further, if the (study) will be used to enact or repeal future or current regulations and rulemakings, then FMCSA must formulate precise statements of research objectives. The objectives should be stated in terms of critical policy issues and hypotheses about contributing factors and other risks that are common to crashes. Then researchers should design data collection methods to answer the questions of interest.”
OOIDA added that the study should pursue a nationally representative sampling approach that accounts for the different types of roadways, weather conditions, and other settings that drivers encounter daily.
“The study must present consistent data collection processes incorporating the Model Minimum Uniform Crash Criteria,” OOIDA wrote. “As part of the effort, FMCSA should also rely on an expert panel of academics that can provide independent review from the outset of the planning stages. Additionally, FMCSA should conduct a pilot program study that is large enough to clearly indicate whether the planned data collection and analysis methods could meet the declared objectives of the study.”
OOIDA said the name should be changed because the initial study implied that it would show actual “causes” of large truck crashes.
Land Line’s Jami Jones reported in 2006 that rather than reporting who was at fault and why, the study was actually a collision-avoidance or crash-prevention study focused on pre-collision events instead of the consequences.
One example in the study was a truck, which had the turn arrow, turning across the path of an oncoming car at an intersection. As part of the study’s methodology, the critical event was the truck’s turn across the path of the other vehicle even though the car was the one that ran the red light.
“Naming the task as a ‘contributing’ factors study, rather than a ‘causal’ factors study would be more practical, help achieve the study’s intended outcomes, and reduce the probability of regulators and others misusing the findings,” OOIDA wrote.
OOIDA said the process must be “painstakingly thorough.”
“That is essential to producing a statistically valid analysis that can fairly evaluate crashes, identify contributing factors and help determine effective safety improvement policies and programs.”
OOIDA’s complete comments can be found here.