virsight hearing - Motor Vehicle Hazard Archive Project

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At the same time, there are eeveral factors which often
make NTSB recommendations less usable and effective
than they otherwise might be. NTSB makes no effort to
aseesg the costs of its recommendations, or gauge their cost
benefrt. This can put the Board in a position of offering
recommendations which provide the public with a negative
cost benefit, or which ari simply not feasible for technical
or economic reasons. The Boiri could increase the functional
value of its recommendations by exploring implementation
issues, making a preliminary cosi benefrt estimate,
and providing this-info'rmation ai part of their recommendation
package.
Moreover, the Board issues a large numtrer of reconmendations-106
in the railroad areia over the last elht
years-without making any effort to prioritize among
them. Each recommendation .is treated in isolation, both
from a cost and an implementing perspective. All are accorded
equal priority. The problem with this approach is
that, as much as we might like it to be otherwise, resources
are finite, tre they in the public or private sector.
Rezulatory agencies have enorrrous inlluence on how privaie
parties;llocate those safety dollars. The key challenge-before
any safety regulatory agency is the challenge
to Drioritize. to pursue the option that will steer available
doliars to their irost effectivri use from a public safety perspective.
To the extent that regulatory agencies utilize
tireir authority to steer limited iesourc& td ttre 8th, gth,
or 10th most productive area, they have a less than oPtimum
impact on safety because of opportunities lbregone.
Determining which safety initiatives have the greatest
impact on public safety, and can offer the public the greatest
cost beirefrt, is a cirallenge that lies at the heart of effective
regulation. And NTSB's recommendations, ir' their
current format, offer little guidance in rnaking this type of
judgment.
The modal administrations. on the other hand, must
make safety policy decisions tliat are in fact resource alle
cation decisions, and must make them in a real world environment.
They must consider not only the merit of a
safety-enhancing measure, but also its t6chnical, financial,
and operational feasibility.
The Board responds that it has "very limited resources and i8
unable to make a cost/benefrt analysis with respect to the recommendations
we issue." The Board. howene., con-tends that it does
analyze "the expected impact" of its recommendations and ''only
issue those which pass a test of 'reasonableness'." The Board says
that the "cost of implementing a recommendation is a factor fre
quently considered iir this test'' and the "highet priority is given
to rec6mmendations which are 'reasonable' and which will yield
the highest safety benefits." The Board adds:
Also, after we issde recommendations to the modal agencies
we are freque;itly drawn into cost benefit discussions.
If the modal agency presenk a convincing case that imple-
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