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”?
Use rates, not raw counts. > over eight months without contextualizing them against that broader total. Should FMCSA have presented a rate or — yes: show per-100M VMT fatal‑crash rates for non‑domiciled vs domestic CDLs over 3–5 years; five crashes in eight months is likely noise. If the rate is higher, time‑limit the 2025 IFR with a sunset and publish the denominator; anyone have VMT estimates for non‑domiciled drivers?
Quick example: when we vet spikes, we drop them into a 24‑month control chart (Poisson limits) anchored to FMCSA’s 2024 Pocket Guide totals — “5,476 in 2022” — and only treat a subgroup as policy‑signal if it breaches the band. If the licensing pool is tiny, we pivot to exposure‑adjusted counts or add near‑miss indicators to avoid overreacting. @FMCSA, would you include a simple SPC chart in the docket next time?