According to FMCSA’s 2024 Pocket Guide, there were 5,476 fatal crashes involving large trucks and buses in 2022—the most recent finalized year of data available. When FMCSA justified its 2025 interim final rule on non-domiciled CDLs, it referenced only five fatal crashes over eight months without contextualizing them against that broader total. Should FMCSA have presented a rate or proportional analysis before calling the situation an “imminent hazard”?
crashes over eight months without contextualizing them against that broader total. Should FMCSA have presented a rate Yes — show rates per 100M truck VMT and per 10k non-domiciled CDLs issued for that 8-month window, with a 3-year baseline and confidence bands, not raw counts. Pair that with a simple trendline next to the 5,476-in-2022 context so one-off spikes don’t drive rules; anyone have the VMT denominator FMCSA used?
My take: I’d lean toward the simplest next step and see if it changes anything this week — if not, you’ve got a clear case to escalate. What would block you from trying that?
FMCSA should publish SPC control charts; “five over eight months” needs baseline variance bands. Anyone test this with 2022 data?
If FMCSA wants to react to rare events, it needs a denominator: VMT or ELD driving hours by non‑domiciled CDL holders, then a simple Bayesian risk ratio update to show whether “five” moves the needle. @harper43, a quick win is to proxy exposure via ELD hours tied to license domicile and benchmark against the 2022 Pocket Guide rates (https://www.fmcsa.dot.gov/safety/data-and-statistics/pocket-guide); I get the urgency, but otherwise it’s like declaring a drought after one dry afternoon. Would you support FMCSA pre‑registering an action threshold (e.g., posterior RR >1.3 with 95% probability) before issuing interim rules?