The Federal Motor Carrier Safety Administration (FMCSA) is in the process of overhauling its Compliance, Safety Accountability (CSA) safety program. Under congressional direction, FMCSA is adopting the recommendation of the National Academy of Sciences to adopt the “item response theory” (IRT) methodology for evaluating fleet safety.
Properly used, IRT brings mathematical validity to what have been controversial assessments under FMCSA’s Safety Measurement System (SMS), such as severity weights for violations. IRT will likely end safety categories, called Behavior Analysis and Safety Improvement Category (BASICs), and will move away from the “peer group” comparisons among fleets.
This IRT shift is intended to abandon CSA’s “crash risk” approach for a general, though statistically sound, sense of how well fleets value and implement safety across all aspects of their business. The end result may be a singular safety score for motor carriers instead of today’s percentile rankings.
Under IRT, weaknesses across a carrier’s operations may result in a low safety evaluation. Experts have described the IRT approach as an emphasis on the “safety culture” of a motor carrier. Other, however, believe this may simply be just another version of determining “crash risk.”
So, how does a fleet achieve a good safety culture? Here are four steps in building a strong safety culture in the new world of IRT:
- You will still be measured: Traditional definitions of “safety culture” emphasize the sharing of beliefs, perceptions and values among employees in an organization. But remember that IRT is a mathematical model built on hard data. Data comes from measurements and demonstrable results. The IRT “safety culture” is not some “touchy-feely” concept, rather it is the product of number-crunching. The difference, compared to FMCSA’s old SMS approach, is that IRT will look across the breadth of a motor carrier’s operations and not just at an “alert” status in one or more BASICs.
- Change starts at the top: Moving to a safety culture starts with company leadership. Many motor carriers have a safety manager and perhaps an equivalent position in vehicle maintenance. That’s good because those tasks demand constant attention. Employees, though, notice whether “the boss” truly places a premium on safety. Does company leadership get out of the office and visit the shop floor, the loading dock, the drivers’ lounge and see what they are asking of employees? Is safety the top item on every meeting agenda? Do employees feel comfortable raising safety issues up the ladder? Do line managers and supervisors preach safety before looking at production numbers? When tough business decisions are made, including meeting a particular customer’s demands, is the first question, “Can we do so safely?” Safety culture depends on the consistency of message and values, from the top down.
- Consistency is the most important attribute of a safe fleet: IRT looks across all aspects of a motor carrier’s operations. That means a consistent approach to safety will produce the best IRT results. That consistency goes beyond the messaging and shared values just discussed. It requires analysis and action – each and every time there is a citation, a roadside inspection issue, an audit result, a crash.
Analysis means asking questions: 1) is this an accurate report? 2) what is the scope of the problem – one vehicle, one driver, one location or fleet-wide? 3) is this a repeat offense? part of a pattern? Answers to those questions will drive actions: is the appropriate remedy a) reminders, b) training, c) incentives, or d) discipline? Perhaps equipment/technology upgrades are called for, or the introduction of safety analytical tools. If citations and inspection violations are inaccurate, the correct action may be challenging them through DataQs. Crashes that are non-preventable should similarly be challenged through the FMCSA Crash Preventability Demonstration Program. The key is consistently addressing each issue as it arises and taking the steps, especially the difficult steps of discipline and termination of personnel, as the situation requires.
Remember: IRT is driven by data. By consistently reviewing and acting on each safety problem, you will improve your data in all areas of your operation. Employees will understand and accept actions which are consistent with the values management espouses. We all respect people who “walk the talk.” Both actions are required: walking and talking.
- Celebrate: A fleet’s safety culture does not end with identifying and correcting problems. An often-overlooked component is the need to celebrate success. IRT may not capture your fleet’s driver safety awards or the technician who finished high in the national skills competition, but employees who see their work appreciated will produce the measurable results that impact IRT. A true “safety culture” is something to celebrate!