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Item Response Theory (IRT)

I want to address the Item-Response-Theory (IRT) as it relates to carrier safety scores but, first, I want to preface it with a few comments.

The Federal Motor Carrier Safety Administration (FMCSA) wants to make our highways safe – or safer, to be more precise. They have created regulations in the process and many of these regs are disconnected with actually promoting highway or carrier safety.

Take for example drivers’ hours-of-service (HOS) guidelines. The FMCSA and others feel that by regulating drivers’ drive time and rest time that it will decrease driver fatigue and this, in turn, will decrease the chance of crashes.

These HOS regulations may work if drivers have the same schedule day in and day out thus creating an imprint of sorts that allows drivers to be alert at the right times and then feel restful at the right times as well.

But, many if not most driver schedules, are not routine.

They may be picking up at six a.m. on one day but getting their mandated rest or sleep at six a.m. on another day.

There’s no chance for the human body to make that necessary imprint.

Any attempt to regulate driver’s biological clock and nocturnal instinct may, in fact, cause massive fatigue that runs counter to the initially planned outcome or purpose.

Can there be a strategy that allows the driver to determine his/her own rest/sleep/drive routine? Many are afraid of such a strategy for whatever reason.

Further, the FMCSA safety rating rule that wants to rely heavily on roadside inspections and violations for creating safety ratings may be in violation to Congress’ directive.

How so?

The FAST Act of 2015 directed the FMCSA to review and revamp the safety fitness determination program before embarking on any rule making.

The FMCSA has essentially ignored this directive.

Now, back to IRT – currently, there is a focus on “item-response-theory” for calculating carrier scores.

IRT takes into account variables such as violations and severity weights. Now, only 65% of all roadside inspections conducted by the FMCSA were full inspections in FY 2018.

This leaves 35% being less than full inspections and, yet, the FMCSA wants to use these roadside inspections as one of several metrics to determine overall driver safety fitness.

Also, consider this: when a truck is pulled over for an inspection, there is a 5.5 times more likelihood that the vehicle, not the driver, will not pass muster and will be placed out of service.

When arranging for transportation, freight brokers only rely on conversations with drivers, dispatchers and company personnel, leaving any determination about the readiness and reliability of the vehicle up to flawed or inadequate SMS data.

The use of roadside data has been highly criticized for being inadequate and for its bias towards larger carriers and against smaller ones.

More and more, it’s imperative that freight brokers become familiar with some of these regulations and issues. These regs and issues affect brokers and brokers need to do more than just talk a good talk on the phone.

Go here for more information on IRT: What Is the IRT?

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