Crash Risks by CMV Driver Schedules: What FMCSA's New Study Means for Your CSA Score
FMCSA is launching a new data collection on how CMV driver schedules affect crash risk and fatigue. Comments close May 20. What safety managers should know — and do — while the study is underway.
Crash Risks by CMV Driver Schedules: What FMCSA's New Study Means for Your CSA Score
On April 20, 2026, FMCSA published a notice seeking approval for a new Information Collection Request titled "Crash Risks by Commercial Motor Vehicle (CMV) Driver Schedules." The comment window is open until May 20, 2026. The notice is not a rule change and is not an enforcement action. It announces FMCSA's plan to collect data on how driver schedules and related factors may affect driver performance, fatigue, crash risk, and inspection violations. For safety managers, this is worth watching closely — but as a research step, not as proof that a Compliance, Safety, Accountabiliy (CSA) methodology change or Hours-of-Service rule update is imminent.
What FMCSA just announced
The ICR describes a data collection effort focused on the relationship between CMV driver schedules and measurable safety outcomes. According to FMCSA, the information collected will be used to examine the relative risk of crashes and inspection violations based on various factors related to the driver's work schedule and demographics. The notice says the research will require data from HOS duty logs, accident and incident data, inspection violation records, and driver demographic data. FMCSA also says HOS duty logs, along with incident and crash data, will be obtained through integration with telematics system providers, while demographic data will be provided directly by participating carriers.
FMCSA has not announced a rulemaking tied to this ICR. At this stage, the agency is seeking approval to collect data and inviting public comment on that request. That still makes the notice important, because research like this can influence future policy discussions — but the immediate significance is the scope of the study itself, not a change in the law.
FMCSA is required under the Paperwork Reduction Act of 1995 to publish an ICR notice and invite public comment before collecting information from the public. The comment window is the public's structured opportunity to push back on scope, methodology, burden estimate, or data protection — or to offer data the agency should consider including. Comments close May 20, 2026, and FMCSA directs commenters to submit them through reginfo.gov under the 30-day review process.
Why FMCSA studies precede rulemaking
FMCSA research initiatives often shape future policy discussions, enforcement priorities, guidance, or rulemaking over time. That is one reason safety and compliance teams pay attention to ICR notices early: they can reveal what the agency wants to study before any operational change is proposed.
Still, this notice should be read carefully for what it is. FMCSA is announcing a plan to collect information about how driver schedules may relate to fatigue, crashes, and inspection violations. It is not proposing a new Hours-of-Service restriction, and it is not announcing a CSA methodology change. The practical takeaway is not that a rule change is coming tomorrow, but that FMCSA is studying an area that could matter more in future safety oversight.
What the study will measure
The clearest specifics available now are in FMCSA's notice itself. The agency says the research will require HOS duty logs, accident and incident data, inspection violation records, and driver demographic data. It also says HOS duty logs, along with incident and crash data, will be obtained through telematics-system-provider integration, while participating carriers will provide demographic data.
The methodology will also likely account for carrier-level effects: two drivers operating the same schedule at different carriers may have different crash risk profiles because of training, equipment, dispatch culture, and safety climate. A well-designed study isolates schedule-specific effects from these confounding factors, which is harder than it sounds and is the kind of thing public comments often help refine.
As the collection moves forward, additional detail may emerge about methodology, data structure, and safeguards. For now, the key point is that FMCSA is looking beyond simple hours totals and studying how schedule-related factors may relate to safety outcomes in a broader way.
Where current HOS rules stop and crash-risk-by-schedule research begins
Today's Hours-of-Service regime is built on bright-line rules: 11 hours of driving within a 14-hour on-duty window, 30-minute break after eight consecutive driving hours, 10 hours off-duty before starting a new cycle, 60/70 hour limits over 7 or 8 consecutive days, and specific split-sleeper berth provisions. These rules are defensible because they are measurable and auditable: an ELD either shows compliance or it does not, and a roadside inspector can verify within minutes.
The research FMCSA is about to undertake starts where bright lines stop. Two drivers can be equally HOS-compliant today but have very different fatigue risk profiles because of when they drove within the legally available window, how consistent their schedules were, and whether they operated on their circadian peak or trough. If FMCSA's data collection shows that scheduling variables inside the current HOS envelope produce meaningful variation in crash risk, the Agency has three possible regulatory paths: tighten the existing HOS rules, add new scheduling constraints layered on top of HOS, or incorporate schedule variables into SMS BASIC scoring so that fleets with riskier schedule patterns see their CSA scores reflect it.
How your scheduling practices might look under this lens
Fleets that operate predictable, consistent schedules with drivers on stable shift rotations are likely to screen well under the analytical framework the ICR implies. Fleets that run irregular schedules — drivers on different start times from day to day, frequent split-sleeper use, back-to-back maximum-hour cycles — are more likely to surface as higher-risk profiles. None of this is predictive today; the study has not happened yet. But safety managers who can already describe their scheduling patterns with data are better positioned than those who rely on dispatcher intuition.
Fleets that use telematics and fatigue-management platforms already track many of the variables the ICR will study. If your telematics provider reports on driver schedule regularity, circadian timing of driving, or fatigue indexes, you have a head start on self-assessment. If you do not, the current ICR is a useful prompt to ask your provider what data elements they capture and whether those elements could be surfaced in fleet-level reports.
What to do now
- Before May 20, 2026. If your fleet has operational data, telematics capability, or safety outcome records relevant to the ICR's scope, consider filing a comment through reginfo.gov under FMCSA's 30-day review process. Comments that engage with methodology — what data should be included, how to account for carrier-level differences, and how driver privacy should be protected — are the most useful at this stage.
- Within the next 30 days. Review the schedule-related data you already have access to — especially HOS logs, crash or incident records, inspection history, and any telematics reports that show timing or consistency patterns. The goal is to establish a baseline view of how your drivers are currently scheduled before FMCSA publishes additional analysis.
- Within the next 90 days. Review dispatcher guidance on scheduling flexibility. Dispatchers often have latitude to assign within HOS constraints but may not have a framework for choosing schedules that minimize fatigue risk. Adding a light-touch "prefer consistent start times" guideline costs little and positions the fleet well if schedule-based risk factors enter regulatory or SMS consideration.
- Ongoing. Track the ICR. When the Supporting Statement is published and the data collection begins, follow FMCSA's annual research summary releases. The interval between ICR and consequential rule change typically runs 18–36 months; plan accordingly.
How Foley helps
Foley helps carriers stay organized around the compliance and safety records that influence FMCSA visibility, including driver qualification management, MVR monitoring, drug and alcohol program administration, and CSA-related monitoring workflows. While Dash is not a schedule-analysis or ELD optimization tool, Foley can help fleets strengthen the documentation and compliance processes that become more important when FMCSA research or methodology changes raise the bar on safety oversight. Review driver file management resources at foley.io/compliance or contact the compliance team.
Frequently asked questions
Does this ICR change Hours-of-Service rules?
No. An ICR authorizes data collection. It does not change any operational rule. HOS compliance continues exactly as it does today.
Could this ICR change CSA scoring?
Not directly. The ICR authorizes data collection, not methodology change. However, the data collected is the kind of data FMCSA has historically used to justify changes to SMS BASIC methodology. A future methodology change is plausible; a near-term change is not.
When will FMCSA publish the analysis?
FMCSA typically publishes analysis 18–36 months after the data collection begins. The comment window closes May 20, 2026; the collection itself would begin after OMB approves the ICR, likely in the second half of 2026. Analysis could be available in late 2027 or 2028.
Will drivers' identities be protected in the data?
This is exactly the kind of question public comments should address. ICR Supporting Statements typically describe data protection protocols; if your fleet has specific concerns about driver identification in the collected data, a well-framed comment is the most direct way to influence the protocol before it is finalized.
Should I change my scheduling practices now?
No — there is no rule or methodology change to comply with. But reviewing your scheduling patterns against the variables the ICR implies is low-cost and useful independent of any regulatory outcome. Drivers on consistent schedules tend to be safer and easier to retain; the ICR is a reason to look at something you should be looking at anyway.