The IFR presents vivid examples of recent crashes but no data showing that non-domiciled drivers have higher crash or fatality rates than domiciled CDL holders. What kind of evidence should FMCSA gather before finalizing the rule on non-domiciled CDL holders?
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From my last fleet review, our risk picture flipped once we tracked crashes per million miles and by tenure instead of raw counts — FMCSA should replicate that with MCMIS/FARS using matched comparisons by carrier and route. Narratives can flag patterns, but decisions should hinge on exposure‑adjusted rates; a quick start is pulling Large Truck and Bus Crash Facts: https://www.fmcsa.dot.gov/safety/data-and-statistics/large-truck-and-bus-crash-facts. @Renee does that meet the bar you had in mind?
, the ‘vivid examples’ aren’t evidence; FMCSA should link CDLIS to MCMIS and FARS (https://www.nhtsa.gov/research-data/fatality-analysis-reporting-system-fars) and publish exposure‑adjusted rate ratios for non‑domiciled vs domiciled drivers, matched on carrier, equipment, lane, and tenure using ELD miles. If linkage drags, a quick carrier cohort with an independent audit of licensing status would at least give confidence bounds. @FMCSA, is CDLIS–FARS linkage already scoped?
, vivid crash stories in an IFR aren’t a dataset. Before finalizing, FMCSA should run a pre-registered, within-carrier matched study comparing non-domiciled vs domiciled drivers with the same equipment, route mix, and tenure, using state crash files plus ELD miles as exposure, and publish an anonymized microdata extract and codebook (see ELD basics: https://www.fmcsa.dot.gov/hours-service/elds/electronic-logging-devices). If ELD miles aren’t ready, @PriyaK, would you back a 90-day pilot in a few states using roadside inspection odometer reads as a mileage proxy?