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MTO considers shifting inspection focus to audits

TORONTO, Ont. - The Ontario government's ongoing efforts to save money has Ministry of Transport enforcement officers concerned there are plans afoot to shift the focus of commercial vehicle inspectio...

TORONTO, Ont. – The Ontario government’s ongoing efforts to save money has Ministry of Transport enforcement officers concerned there are plans afoot to shift the focus of commercial vehicle inspection away from highways.

And one local enforcement officers’ union is even warning the plan, if carried out, will result in “another Walkerton.”

“There’s a program review underway in all the Ministries that’s what they’re calling ‘results-based,'” explained Joe Daniel, an MTO enforcement officer and the president of the Ontario Public Service Employee Union Local 506, which represents roughly 120 enforcement officers in the Greater Toronto area.

“All indication is that the Ministry wants to keep some form of enforcement program but only in a watered down version. It means there will be less Ministry of Transportation Ontario (MTO) enforcement officers on government payroll to perform roadside inspections.”

Daniel said the number of enforcement officers has already declined because of attrition, promotion and a number of other factors since 2000.

“In 2000 there were about 350 officers and now there are approximately 270,” he said. “And there has been no move on the part of the Ministry to replace them.”

And Daniel fears the reduction of roadside inspections will result in “another Walkerton.”

“The spin doctors have already made it known to the general public that this will not affect road safety at all since police officers are out in full force to augment CMV (Commercial Motor Vehicle) enforcement. But in reality, the police officers only carry out a fraction of roadside inspections. Furthermore, it was reported that on Civic holiday long weekend, OPP auxiliary officers were seen performing inspections on commercial motor vehicles. If you or your family members use Ontario highways, would you like to see untrained police officers and auxiliary police doing roadside inspections based on CVSA (Commercial Vehicle Safety Alliance) criteria? If this is a new trend, the industry should be concerned about the quality of inspections while road users should be mindful that their safety is being compromised.”

The move to audits as a more cost-effective means of enforcement for commercial vehicle safety is not a new idea. In fact, it has been a subject of debate since two Northwestern University professors, Ian Savage and Leon N. Moses, published a lengthy paper on the subject in the 1990s.

Their work, funded by the U.S. Department of Transportation, was based on data provided by The Federal Motor Carrier Safety Administration. The agency made available to the professors their entire database for both Safety Review and Compliance Review (SR/CR) audits and roadside inspections. The database contained information on the characteristics and safety performances of 75,000 U.S. motor carrier firms, and was considerably larger than any other that has been used in previous formal analyses of motor carrier crashes.

The first phase of the report, published in 1994,and titled “The effect of firm characteristics on truck accidents. Accident Analysis and Prevention” included an investigation of the relationship between trucking firm characteristics – such as size, ownership and cargo carried – and crashes. It also investigated the ability of the SR/CR program to identify the trucking firms with the poorest safety records. And it presented the following conclusions:

* Motor carrier crash rates decline as firm size rises. The largest firms have crash rates about half those of the smallest firms.

* Private carriers, have crash rates 20 per cent lower than for-hire carriers. Presumably, these firms have a strong incentive for safe operation because it is the company’s own cargo that would be damaged in a crash.

* Among the for-hire carriers, the General Commodity class of carriers have crash rates about 10 per cent higher than those firms who specialize in specific cargoes. Presumably specialist firms thrive by building up a good reputation with a relatively small number of shippers and those shippers become well acquainted with the transport business characteristics of the trucking firms they use.

* Carriers of hazardous materials have a rate of crashes involving fatalities and serious injuries some 20 per cent higher than that of other trucking firms. Firms that carry hazardous materials as part of a general freight business are worse than firms who specialize in particular hazardous commodities. Further analysis revealed that the transportation of packaged gases and liquids in tank-trailers is the most hazardous. Suggested explanations are poor packaging standards for gases, and the instability of partially filled tank-trailers.

* Certain management safety practices are effective in reducing crashes. The firms with the best safety records are those firms who keep records of crashes and investigate crashes to determine if disciplinary or educational action is necessary for the drivers involved. Firms who are conscientious in enforcing the maximum hours-of-service rules for drivers were found to have superior safety records.

The second phase of the paper, published in 1996, and titled “Identifying dangerous trucking firms. Risk Analysis” developed a statistical procedure for predicting the safety performance of motor carriers based on characteristics of firms and results of two government safety enforcement programs.

One program was an audit of management safety practices, and the other was a program to inspect drivers and vehicles at the roadside for compliance with safety regulations.

The results of the study suggested that both of the government’s safety programs helped identify the most dangerous firms. The 2.5 per cent of firms that did poorly in both programs had an average crash rate twice that of the mean for all other firms.

But it was the final phase of the report that is the most telling when it comes to what the MTO may be planning for the future.

Published in 1997, phase three of the report, titled “A cost-benefit analysis of United States motor carrier safety programs. Journal of Transport Economics and Policy” evaluated the economic and social costs and benefits of both the safety programs.

The report found that the audit program studied annually recommended approximately 2,000 motor carrier firms for enforcement and education actions. As a result of these remedial actions, targeted firms lowered their crash rates by 43 per cent. The benefits of reduced crashes from this program exceeded both government and carrier firm costs by a ratio of over 4:1.

But the study found the same was not true for the roadside inspection program. Here the benefits exceeded the costs under only the most favourable assumptions regarding the number of crashes avoided. Costs clearly exceeded benefits when more realistic assumptions were introduced, according to the report’s authors. And most of the costs of this program were borne by motor carriers whose trucks were delayed by inspections rather than government, the report found.

Included in the study of the costs and benefits of the two safety programs were estimates of a “deterrence effect” which assumed that firms improved their safety performance even though they have not been audited or had their vehicle(s) placed out-of-service. The deterrence effect had what the report’s authors called “a credible maximum value of 50 per cent of the direct effects of the programs, with a more plausible value of 25 per cent of the direct effects.”

In other words, stated the authors, “The net social benefits from the safety programs would be even greater if resources were diverted from the roadside inspection program to the audit program.

“Unfortunately, the FHWA (the FMCSA’s name at that time) is currently adopting the reverse policy.”

Daniel, who was not intimately acquainted with the contents of the papers, did not disagree that audits are in fact an
effective way of enforcing highway safety for commercial vehicles. But the union president did point out that roadside inspections play a important role in the auditing process, namely that out-of-service results, on highway violations and poor safety records are what cause a company to be audited.

“Without the roadside inspections, how else are we going to know who to audit?” he asked. “It’s because of roadside inspections and violations that a carrier gets inspected in the first place.”

Indeed the MTO has not yet revealed its plans for future enforcement strategies.

But if it does decide to reduce the number of enforcement officers on Ontario’s highways, it will have to come up with an answer to this question.

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