Who exactly is safe?
By Matthew A. Daecher
The year 2011 continues to challenge the passenger transportation industry. The series of crashes that seem perfectly timed to keep the story fresh are having a negative effect on the image of the industry; not to mention the related fallout and pressure from the public, politicians, regulators and enforcement.
Most of the high-profile crashes have involved curbside operators, that segment of the industry long suspected and criticized as being unsafe and non-compliant. These companies tout ultra-cheap fares and non-traditional point-to-point service coupled with vague domiciles, which many believe is a carefully designed tactic to elude the typical inspection processes.
In light of the recent accidents, maybe those doubting these operations are correct. Although a number of time-tested companies have emulated this successful business model, what makes one operator safer than the other? How does anyone know who is safe? These are not rhetorical questions.
Stereotyping is certainly not the proper way to judge any passenger carrying company. I have walked into operations I thought were going to WOW me, only to leave disappointed and scratching my head. I also have walked into operations expecting the worst and seeing the best. The fact is this: Great companies operate on one end of the spectrum and lousy companies at the other. Mediocre, or just plain lucky companies, operate somewhere in between.
Safe is not regulatory compliance. Instead, compliance should be incorporated into the design of a sound risk management program that produces safe as its byproduct. Safe does not mean a carrier has never had an accident; it is what a carrier does to prevent accidents and how they respond to them when they occur.
Safe is an intangible result of beliefs, practices and the making good choices. Nor does Safe mean a carrier does not have any regulatory violations. Rather, it is how they address their issues to prevent infractions from reoccurring.
The media has sensationalized the terrible bus accidents this year, using ammunition courtesy of the new FMCSA Safety Measurement System (SMS). Now implemented nationwide, this new system is receiving its own share of attention, particularly as operators begin to feel the effects of its more detailed measurements and evaluation criteria. The storyline is that unless you understand the regulations and violations, and choose to drill down deep enough into the data to fully understand violations cited against a company, the SMS can be misleading.
Proponents will say this system does well to capture and identify the issues, hence the reason the carriers involved in crashes had BASICs that exceeded the thresholds. It signified them as carriers with significant issues. Opponents claim the system is misleading and penalizes carriers unfairly for “nuisance” violations that have little correlation to crash risk.
Indeed, the correlation between exceeding thresholds and crash risk does not necessarily represent of an unsafe operation. It is only representative of a carrier that did not comply with a written regulation, regardless of the effect the violation had on actual safe operations. And this true representation is really the other side of the story. It provides a look behind the scenes of each transportation provider.
These failures point to a breakdown in the system management process that needs to be in place to limit these violations. It is apparent that many operators developed or executed their management processes only to the point that they consistently managed their major out-of-service violations — the only violations that counted under the old Safestat system.
Frankly, this was not much of a challenge. It only required knowing the most serious violations and focusing efforts in those areas to prevent them. They simply did not bother with violations they considered unimportant. Now the new SMS requires a more comprehensive management system to address all violations, a challenge and change in mindset many good operators now face.
If you find yourself with high BASIC percentile rankings due to these “nuisance” violations, it is time to review your system management processes. Don’t blame the new system; look at the regulations you have not complied with and figure out why your management process didn’t correct your non-compliance when it occurred. Fixing the processes to address these matters will make a better company. And, right or wrong, outsiders will perceive you as a safer company.
Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA.