As the Federal Motor Carrier Safety Administration prepares to conduct its latest study of large truck crashes, OOIDA asked the agency to learn from past mistakes.
“FMCSA should reflect on previous correspondence from the Transportation Research Board, pointing out flaws of the (2001-03) Large Truck Crash Causation Study and the improvements that need to be made in any future study,” the Owner-Operator Independent Drivers Association wrote in formal comments submitted on Feb. 27. “FMCSA must dramatically correct the failed structure and methodologies of the initial (study).”
The 2021 infrastructure law mandated the Department of Transportation Secretary to “carry out a comprehensive study to determine the causes of, and contributing factors to, crashes that involve a commercial motor vehicle.” In December, FMCSA published a notice and request for comments regarding plans for the study.
The Owner-Operator Independent Drivers Association used the opportunity to provide advice and remind the agency of the problems with the previous study.
Land Line’s Jami Jones reported in 2006 that rather than determining 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.
“Various industry stakeholders, such as OOIDA and the Transportation Research Board, repeatedly voiced concerns regarding significant shortcomings in the (previous study’s) approach, organization and presentation of results,” OOIDA wrote on Feb. 27.
The Association said researchers should design data collection methods aimed at answering the questions of interest.
“The Large Truck Crash Causal Factors Study should pursue a nationally representative sampling approach that accounts for the different types of roadways, weather conditions and other varying settings that drivers encounter on a daily basis across the country,” OOIDA wrote. “The study must present consistent data collection processes incorporating the Model Minimum Uniform Crash Criteria.”
As part of the process, OOIDA said FMCSA should rely on an expert panel of academics who can provide independent review and that the agency should conduct a pilot program “that is large enough to clearly indicate whether planned data collection and analysis methods could meet the declared objectives of the study.”
OOIDA also would like FMCSA to change the name to the “Large Truck Contributing Factors Study.”
“Unfortunately, the Large Truck Crash Causation Study implied that the study would show actual causes of large truck crashes,” the Association wrote. “However, it only showed categories of factors influencing crash risk, something quite different than the cause.”
OOIDA said the study “must be painstakingly thorough” and will be “essential to producing a statistically valid analysis that can evaluate crashes, identify contributing factors and help determine effective safety improvement policies and programs.” LL